South Red Bird Wildlife Enhancement Project
Official documents for the South Red Bird Wildlife Enhancement Project can be found on the Daniel Boone National Forest website here.
Keep scrolling down this page for more information, updates, documents and maps.
You can read comments that have been submitted by the public, here.
Keep scrolling down this page for more information, updates, documents and maps.
You can read comments that have been submitted by the public, here.
Kentucky Heartwood files formal objection to South Red Bird project
This area along the Redbird Crest Trail is approved for logging by the Forest Service. Most of the trees in this photo will be cut under the Forest Service's plan.
Posted October 13, 2020
On Monday, October 5th, Kentucky Heartwood and the Kentucky Resources Council jointly filed an administrative objection (“predecisional objection”) to the South Red Bird Wildlife Enhancement Project on the Daniel Boone National Forest. The project would approve 3,600 acres of logging in the Redbird District of the Daniel Boone in Clay and Leslie Counties. The project also approves the construction of nearly 100 miles of full-bench skid roads across extremely steep and highly erodible mountain slopes for hauling out the timber. Extensive field work by Kentucky Heartwood has demonstrated massive and ongoing landslides resulting from the same types of management in the adjacent Group One project. The Forest Service’s South Red Bird project could degrade or destroy up to 16% of designated critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum), and degrade habitat for the federally-endangered snuffbox mussel (Epioblasma triquetra).
The South Red Bird project could also have major impacts to federally-threatened northern long-eared bats (Myotis septenrionalis) through large-scale habitat fragmentation (some logging units are 200 acres to nearly 400 acres in size) and logging the closed-canopy flight corridors they use to travel in the forest.
Throughout the Forest Service’s analysis, misleading and arbitrary characterizations of the landscape and potential adverse environmental effects – especially to aquatic and interior forest species – were used to excuse the aggressive and inexcusably destructive logging practices in the project. Despite the Forest Service’s lip-service to “collaboration,” the only public that they listened to were organizations like the Rocky Mountain Elk Foundation, which has lobbied the Forest Service to clear more of our native forests to make it easier to hunt introduced Rocky Mountain elk.
Kentucky Heartwood’s advocacy helped to identify and protect the 40 acres of old-growth on Little Flat Creek that the Forest Service had planned to log. However, this isn’t nearly enough. The Forest Service still has an opportunity to drop or make major, substantive changes to the South Red Bird project. But if they aren’t willing to do what’s right, and to fulfill their legal obligations under the Endangered Species Act (ESA), National Environmental Policy Act (NEPA), and other laws and regulations, then we’ll be ready to take them to court.
The critical work that allowed us to develop such a strong, substantive objection, and to demonstrate that the Forest Service was misleading the public (and themselves), included nearly 300 hours in the field. That’s in addition to the hundreds of hours spent on research, analysis, and the drafting of comments and other materials needed to respond to the South Red Bird proposal.
We can’t do this level of work without support. To our members and volunteers who have helped us in this effort: Thank you. You have made a difference. But this isn’t over. We will need your continued support to take this project to court if the Forest Service remains unwavering in their willingness to bury our mountain streams in mud and rock, and destroy that habitat of at-risk species, to sell timber from our public lands.
You can join or donate to Kentucky Heartwood here.
On Monday, October 5th, Kentucky Heartwood and the Kentucky Resources Council jointly filed an administrative objection (“predecisional objection”) to the South Red Bird Wildlife Enhancement Project on the Daniel Boone National Forest. The project would approve 3,600 acres of logging in the Redbird District of the Daniel Boone in Clay and Leslie Counties. The project also approves the construction of nearly 100 miles of full-bench skid roads across extremely steep and highly erodible mountain slopes for hauling out the timber. Extensive field work by Kentucky Heartwood has demonstrated massive and ongoing landslides resulting from the same types of management in the adjacent Group One project. The Forest Service’s South Red Bird project could degrade or destroy up to 16% of designated critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum), and degrade habitat for the federally-endangered snuffbox mussel (Epioblasma triquetra).
The South Red Bird project could also have major impacts to federally-threatened northern long-eared bats (Myotis septenrionalis) through large-scale habitat fragmentation (some logging units are 200 acres to nearly 400 acres in size) and logging the closed-canopy flight corridors they use to travel in the forest.
Throughout the Forest Service’s analysis, misleading and arbitrary characterizations of the landscape and potential adverse environmental effects – especially to aquatic and interior forest species – were used to excuse the aggressive and inexcusably destructive logging practices in the project. Despite the Forest Service’s lip-service to “collaboration,” the only public that they listened to were organizations like the Rocky Mountain Elk Foundation, which has lobbied the Forest Service to clear more of our native forests to make it easier to hunt introduced Rocky Mountain elk.
Kentucky Heartwood’s advocacy helped to identify and protect the 40 acres of old-growth on Little Flat Creek that the Forest Service had planned to log. However, this isn’t nearly enough. The Forest Service still has an opportunity to drop or make major, substantive changes to the South Red Bird project. But if they aren’t willing to do what’s right, and to fulfill their legal obligations under the Endangered Species Act (ESA), National Environmental Policy Act (NEPA), and other laws and regulations, then we’ll be ready to take them to court.
The critical work that allowed us to develop such a strong, substantive objection, and to demonstrate that the Forest Service was misleading the public (and themselves), included nearly 300 hours in the field. That’s in addition to the hundreds of hours spent on research, analysis, and the drafting of comments and other materials needed to respond to the South Red Bird proposal.
We can’t do this level of work without support. To our members and volunteers who have helped us in this effort: Thank you. You have made a difference. But this isn’t over. We will need your continued support to take this project to court if the Forest Service remains unwavering in their willingness to bury our mountain streams in mud and rock, and destroy that habitat of at-risk species, to sell timber from our public lands.
You can join or donate to Kentucky Heartwood here.
Click the file below to download and read our administrative objection.
| south_redbird_objection_khw.pdf |
Kentucky Heartwood, Kentucky Resources Council and Center for Biological Diversity join in comments on Redbird Project
Posted December 8, 2019
Click here to read the comments submitted by Kentucky Heartwood (pdf download); we were joined by of the Center for Biological Diversity, and the Kentucky Resources Council in these comments.
Click here to read the comments submitted by Kentucky Heartwood (pdf download); we were joined by of the Center for Biological Diversity, and the Kentucky Resources Council in these comments.
Action Alert: Comments needed to stop 3,650 acres of logging in the Redbird District of the Daniel Boone National Forest!
A steep shelterwood logging unit on Lower Jack's Branch. The skid roads and log landings occupy about 30% of the area - three times what's allowed in the Forest Plan. Logging units in South Redbird will be as much as six times the size of this one.
Posted December 3, 2019
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.
Comments from the public are 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 by midnight, this Friday, December 6th by midnight.
Comments can be sent directly on the Forest Service’s project page here or by emailing SM.FS.r8dbredcom@usda.gov
You can read comments that have been submitted by the public, here.
Be sure to include “South Red Bird Wildlife Enhancement Project” in the subject line.
Comments can also be postal mailed to:
Robert Claybrook, Redbird District Ranger
91 Peabody Road
Big Creek, Kentucky 40914
For more information, read our recent post in our Forest Blog here.
Posted December 3, 2019
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.
Comments from the public are 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 by midnight, this Friday, December 6th by midnight.
Comments can be sent directly on the Forest Service’s project page here or by emailing SM.FS.r8dbredcom@usda.gov
You can read comments that have been submitted by the public, here.
Be sure to include “South Red Bird Wildlife Enhancement Project” in the subject line.
Comments can also be postal mailed to:
Robert Claybrook, Redbird District Ranger
91 Peabody Road
Big Creek, Kentucky 40914
For more information, read our recent post in our Forest Blog here.
Forest proposed for logging along the Redbird Crest Trail.
Forest Service says old-growth forest is only 65 years-old, should be logged
Originally published June 2019, in our Spring 2019 newsletter
Last year the Forest Service released a proposal to log over 3,000 acres of the Redbird District as part of the South Redbird Wildlife Enhancement Project. Most of the proposed logging would be even-aged “shelterwood” harvests that cut most of the trees on areas up to 350 acres on steep slopes above streams designated as Critical Habitat for the federally-threatened Kentucky arrow darter. Only 15% of the forest in the project area is over 100 years old. The Forest Service thinks that’s too much, and plans to cut nearly a quarter of those older forests.
Only 2% of the project area has been inventoried as being over 130 years old, including a 50-acre stand on Little Flat Creek that the Forest Service has proposed for a shelterwood cut. Previous Forest Service inventories stated that the stand is 135 years-old, which would qualify it for a more rigorous examination as potential old-growth. This more detailed look is required by the Forest Plan, which incorporates the Region 8 Guidance for Conserving and Restoring Old-Growth Forest Communities. Old-growth determination in the R8 Guidance is based on four criteria: stand age, disturbance history, basal area, and density of large trees.
Last year the Forest Service released a proposal to log over 3,000 acres of the Redbird District as part of the South Redbird Wildlife Enhancement Project. Most of the proposed logging would be even-aged “shelterwood” harvests that cut most of the trees on areas up to 350 acres on steep slopes above streams designated as Critical Habitat for the federally-threatened Kentucky arrow darter. Only 15% of the forest in the project area is over 100 years old. The Forest Service thinks that’s too much, and plans to cut nearly a quarter of those older forests.
Only 2% of the project area has been inventoried as being over 130 years old, including a 50-acre stand on Little Flat Creek that the Forest Service has proposed for a shelterwood cut. Previous Forest Service inventories stated that the stand is 135 years-old, which would qualify it for a more rigorous examination as potential old-growth. This more detailed look is required by the Forest Plan, which incorporates the Region 8 Guidance for Conserving and Restoring Old-Growth Forest Communities. Old-growth determination in the R8 Guidance is based on four criteria: stand age, disturbance history, basal area, and density of large trees.
Mapping of trees over 20” dbh in the Little Flat Creek old-growth site. Dots are scaled for size and color denotes species.
Last fall, we examined the stand and found that it exhibits good old-growth characteristics for the Dry-Mesic Oak Forest community type as described in the R8 Guidance, and appears to meet all of the necessary operational criteria for designation as old-growth. We wrote to the District Ranger describing our observations, informing him that the stand needed closer examination, and that it should be conserved for it’s old-growth character and not logged.
The response that we received from the Forest Service refuted our observations, as well as the earlier inventory data. The District Ranger informed us that in 2016 “a black oak, representative of the stand was chosen to be cored, and the age was approximately 65 years old,” and that, therefore, the stand is not old-growth and does not require any closer examination. He stated that the stand age of 135 years was “reported in error and will soon be updated within the (Forest Service) database.” From our observations and experience, we knew that the Forest Service’s assessment of the stand was grossly incorrect – both in methodology and determination. So we opted to perform our own detailed investigation and uncovered a considerably more rich and complicated forest than that described by the Forest Service.
Using an increment borer to extract small core samples from 16 trees (including 8 species) distributed throughout the stand, we found that fourteen of these trees were between 150 and 370 years old. Based on our observations, the trees that we sampled were not atypical of the forest more broadly. In addition to the age criterion, to be considered as old-growth the forest needs to have at least 6 to 10 trees per acre that are 20” or greater in diameter at breast height (dbh). To assess large tree density, we were assisted by 6 volunteers over two weekends as we measured and mapped over 500 trees by diameter and species. We determined that the stand has an overall density of 11 trees per acre that are at least 20” dbh. Along with the large tree density, the stand easily meets the basal area criterion of 40 ft2/ac.
Tree ring samples from (L to R) old-growth white ash, white oak, and mockernut hickory. The lines on the left are each 1 mm.
The final criterion for determining old-growth status is an assessment of human disturbance. The R8 Guidance states that “For a stand to be considered as existing old growth, no obvious evidence of past human disturbance which conflicts with the old-growth characteristics of the area should be present.” It’s important to note that the Guidance does not disqualify stands with “any” human disturbance. During our assessment, we found several uncut American chestnut remnants as well as some cut chestnut stumps near the top of the ridge. Chestnut blight killed American chestnuts in southeastern Kentucky mostly in the mid-1930’s, though extending into the 1940’s is some locations. Most of the tree core samples that we gathered show an increase in growth rate (a “release” event) around 1946, suggesting that some type of disturbance took place at that time. Given the lack of logging roads or other infrastructure, we suspect that chestnut decline was followed by limited salvage harvesting of dead American chestnuts along with the possible selective removal of a small number of other trees at that time. The timing also appears to correspond to the Forest Service’s 65 year-old black oak. We suspect that a pulse of young trees followed the 1946 event, and that the Forest Service undercounted their core sample (typical of field counting instead of proper core preparation and examination with a microscope).
Based on our surveys, the Little Flat Creek stand clearly meets the operational thresholds for old-growth designation under the Forest Plan and R8 Guidance. The stand exhibits classic old-growth characteristics for Appalachian forests, including a multi-aged structure dominated by very old trees, large down woody debris and snags, and a history of moderate- to low-severity disturbance events. It is upsetting that the Forest Service, in all their expertise, classified this old-growth forest as a 65 year-old stand, and so readily dismissed information contradicting their assessment. It brings in to question their assessments across the forest, and makes us wonder how much of our limited remaining old-growth forests are on the chopping block. Right now there are about 8,000 acres on the Daniel Boone NF proposed for new logging projects. Surveying all of these areas is very time consuming, and more detailed assessments even more so. Through the support of our members, we’ve been able to look at about 3,000 acres so far, but there’s much more to be done.
The Forest Service’s quarterly Schedule of Proposed Actions (SOPA) states that the comment period on the Environmental Assessment for the South Redbird project is expected now (May 2019), but all indications are that they are considerably behind schedule.
Kentucky Heartwood comments on proposed
South Redbird Wildlife Habitat Enhancement Project
Posted April 2, 2018
Kentucky Heartwood has submitted comments to the Daniel Boone National Forest concerning the proposed "South Redbird Wildlife Habitat Enhancement Project". (Scroll down for text or click here for a downloadable PDF of our comment letter).
It is very important that the Forest Service receive comments from the public. 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. But, keep in mind that comments have the most influence if they are written in your own words.
Official documents for the project can be found on the Daniel Boone National Forest website. Or, keep scrolling down this page for more information, updates, documents and maps.
Comments are due by Monday, April 2, 2018, and should be emailed to:
comments-southern-daniel-boone-redbird@fs.fed.us
Please note in the subject line that the comments are for South Red Bird Project.
Comments can also be mailed by U.S. Postal Service to:
Robert Claybrook
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914
Kentucky Heartwood has submitted comments to the Daniel Boone National Forest concerning the proposed "South Redbird Wildlife Habitat Enhancement Project". (Scroll down for text or click here for a downloadable PDF of our comment letter).
It is very important that the Forest Service receive comments from the public. 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. But, keep in mind that comments have the most influence if they are written in your own words.
Official documents for the project can be found on the Daniel Boone National Forest website. Or, keep scrolling down this page for more information, updates, documents and maps.
Comments are due by Monday, April 2, 2018, and should be emailed to:
comments-southern-daniel-boone-redbird@fs.fed.us
Please note in the subject line that the comments are for South Red Bird Project.
Comments can also be mailed by U.S. Postal Service to:
Robert Claybrook
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914
| south_redbird_project_scoping_comments_final.pdf |
Robert Claybrook
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914
April 1, 2018
RE: South Redbird Wildlife Habitat Enhancement Project
Dear Ranger Claybrook,
Thank you for the opportunity to submit comments on the South Redbird Wildlife Habitat Enhancement Project. These comments are submitted on behalf of Kentucky Heartwood and the Center for Biological Diversity. This project presents a number of significant concerns with regards to federally-listed species, forest composition, and other issues that need to be thoroughly addressed in any future analysis.
1. Not collaborative, so please stop using that term
Kentucky Heartwood actively participated in the early public input opportunities held by the Forest Service for the South Redbird project, including the public meetings on February 22 and August 24, 2017, February 20, 2018, and the field trip on May 2, 2017. The Forest Service loosely referred to these meetings as “collaborations.” As a result, the Forest Service listed Kentucky Heartwood as a “collaborator” in the scoping document. However, few (if any) of the comments, concerns, and constructive input provided by Kentucky Heartwood during those opportunities and by email are reflected in the scoping document. In fact, we see little in the proposed action that reflects any of the concerns we observed being raised during the pre-scoping opportunities outside of the clearly pre-determined, agency-driven emphasis on grouse management through large-scale, even-aged timber harvests.
We will address several of the specific issues and suggestions that were previously raised (and ignored) in the following sections of this letter. But it needs to be stated clearly here, at the outset, that the process was not collaborative in any sense of the term. It is clear from the proposed action that the Forest Service knew what type of management would actually be proposed through the NEPA process, and that the time, effort, and sincere input by Kentucky Heartwood and others was simply a veneer to sell the project. Following our experience with the Greenwood project on the Stearns District, we were promised emphatically by Supervisor Olsen and other forest leadership that future projects would be put together in a more genuinely collaborative, open manner. Frankly, we feel misled and used by the Forest Service.
It should also be noted here that the Forest Service, on February 23, opted to release for scoping an amendment to the Forest Plan that loosens logging restrictions implemented to protect Indiana bats. Scoping for the South Redbird project was published on March 1, and scoping for the Pine Creek project on March 22. In total, these projects cover management on nearly 80,000 acres of national forest land, including over 7,000 acres of commercial logging, and a major change in forestwide management for an endangered species in critical decline. While the Forest Service has been making overtures about bringing the public into an open public lands process, this coordinated avalanche of significant proposals and comment deadlines belies the statements made to us and the public at large.
2. Kentucky arrow darter and Snuffbox mussel
As the Forest Service notes in the scoping document, the project area includes a substantial portion of the designated critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum). We expect a robust, transparent analysis of potential impacts to the Kentucky arrow darter, including consultation with the U.S. Fish and Wildlife Service. During the analysis for the Spring Creek project (which is encompassed by the South Redbird project), the Forest Service stated that there was no Kentucky arrow darter habitat in the project area, despite agency staff knowing this to be untrue. At this time, the Forest Service has little credibility on this issue. The Forest Service has a duty to take proactive measures to support the Kentucky arrow darter. We do not see that represented in the scoping document.
With regards to the Snuffbox mussel (Epioblasma triquetra), the scoping document states:
“Known populations of the snuffbox mussel occur in Elisha Creek less than a half-mile upstream of the project area boundary.”
However, the entirety of the Elisha Creek watershed is within the project area, so it is difficult to understand how this is the case.
While efforts to clean up the mainstem of the Redbird River are laudable, the fact is that the Redbird River itself is not habitable by these species on account of pollution from mining and oil and gas operations, and the tributaries on national forest land must be protected from any form of additional degradation.
The Forest Service has a proactive duty to work toward the recovery of these species. Addressing sewage in the Redbird River and adding culverts to a couple of logging roads is not sufficient toward this end.
3. Ruffed grouse emphasis
It is clear that timber management for Ruffed grouse (Bonasa umbellus) populations is an emphasis in this project. While grouse are only briefly mentioned in the scoping document, the “need” to establish more young forest habitat for grouse was a predominant theme among state and federal agency personnel during pre-scoping meetings. While we recognize that Appalachian populations of grouse are declining, grouse are neither federally nor state-listed as threatened or endangered. Furthermore, in 2008 the Daniel Boone National Forest approved over 1,200 acres of timber harvest immediately north of the South Redbird project area. The “Group One” project also included a Forest Plan amendment to establish a 12,000 acre Ruffed Grouse Emphasis Area to be co-managed by the U.S. Forest Service and Kentucky Division of Fish and Wildlife Resources (KDFWR). Per the Goals and Objectives for Forest Plan Prescription Area 3.H.1 Ruffed Grouse Emphasis, the 12,000 acre area (minus riparian restrictions), is intended to be managed under 60-year even-aged timber rotations. In our conversations during the pre-NEPA “collaboration” meetings, we asked both district forester Jared Calvert and Zak Danks (Grouse coordinator for KDFWR) about the progress of management in the Group One project and Ruffed Grouse Emphasis area and no answers were forthcoming.
It is also notable that the Daniel Boone National Forest experienced a massive outbreak of the southern pine beetle between 1999 and 2002 that induced regeneration events on tens of thousands of acres across the forest. We are nearly 20 years out from that event, and therefore, based on conventional habitat assumptions, many sections of the DBNF should be experiencing significant increases in grouse numbers. Are there data to respond to this? If grouse have not responded to these widespread natural regeneration events, then what else is going on? Are there issues that need to be addressed with hunting pressure? If populations are crashing, then a 4 month grouse season, with a 4 bird/day limit may be inappropriate. Has West Nile virus been considered with regard to site-specific habitat modeling?
Furthermore, hemlocks are now dying in the Redbird district. The published scientific literature for the Appalachian region shows preferential use by grouse of mixed mesophytic forests on account of preferred and reliable forage (catkins, buds, etc.). How many acres of hemlock-mixed mesophytic forests are in the South Redbird project area? How many acres of openings in these mixed mesophytic landscape positions should we expect? It is plausible that the death of the hemlocks will reflect in a positive response in grouse populations due to increases in understory forage.
In terms of habitat, the relationship between young poletimber (forests ~15-20 years old) and grouse is well established. However, it has also been shown that reproductive female grouse in the central Appalachians preferentially use mature, closed canopy forests with little understory vegetation along with the presence of larger diameter trees and coarse woody debris for nesting.
It has also been shown that female grouse with young broods are as likely to utilize patches of early successional habitat created from mature forest canopy gaps as they are young forest created by large clearcuts. For example, Jones (2005)(1) states:
"With respect to forest types, broods used mixed oak stands in the 0–5, 6–20, and >80-year age classes. Site conditions were submesic to subxeric with northern red oak and red maple dominant in the overstory and flame azalea, American chestnut sprouts, red maple, serviceberry, and northern red oak, in the midstory (Tables 3.9, 3.10). The 0– 5-year class was represented by use of 3–4-year-old group selection cuts and edges of 2 recently harvested irregular shelterwood (i.e., 2-aged) stands. Broods also utilized edges of 6–20-year-old mixed oak clearcuts, but seldom ventured into their interior."
It’s notable that the forest ages between 20 and 80 years were largely useless to grouse – the range of ages that dominate the South Redbird project landscape. It’s also notable that canopy gaps in old-growth forests (>140 years) tend to be substantially larger and more frequent than those found in ~80 year-old forest which tend toward smaller gaps and an even, closed codominant canopy structure. Furthermore, it needs to be noted that broods “seldom ventured into (the) interior” of clearcuts, suggesting that large group selection harvests (or large gaps in old-growth forest) could meet the habitat needs of this species without sacrificing so many other values and the habitat needs of other species.
We’ll also add here that home ranges for grouse in the central Appalachians tend to be much smaller than many of the areas proposed for harvest in the South Redbird project, some of which range from 210 to 360 acres. Grouse success in the central Appalachians appears to be associated with home ranges in the tens of acres that include mixed-mesophytic and riparian habitat, areas of closed canopy forest with open understories and coarse woody debris, and patches of poletimber. The massive zones of regeneration harvests and thinning proposed may very well degrade grouse habitat by reducing the complexity of habitat components.
In order to address the habitat needs of grouse in a manner more consistent with the historical ecology of the area, Kentucky Heartwood suggested at multiple junctures during the pre-NEPA “collaboration” period that the Forest Service consider alternative silvicultural methods. Specifically, we suggested that the Forest Service consider demonstrated approaches that combine selective thinning aimed at promoting the complex and locally underrepresented forest structure associated with old-growth conditions along with large group selection cuts in suitable locations to provide for forage and future poletimber cover in a matrix of developing forest. Despite proposing 3,200 acres for logging, our recommendations are not reflected in any way in the scoping proposal.
4. Forest ages
We submitted extensive and detailed comments regarding forest ages and old-growth form and function to the Redbird District on the Spring Creek project, which is within the South Redbird project area. Rather than repeat all of it here, we incorporate it by reference and ask that you review those comments.
Our analysis of the project area using DBNF data shows that the forests in the project area are, on the whole, very young. We note a few statistics here:
• 15% of the forest in the project area (4,965 acres) is over 100 years old
• 2% of the forest in the project area (700 acres) is over 130 years old
• 9% of the forest in the project area (2,924 acres) has been cut since 1990
• 18% of the forest in the project area (5,837 acres) has been cut since 1980
• 23% (1,157 acres) of all forests over 100 years old are proposed for regeneration harvests
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914
April 1, 2018
RE: South Redbird Wildlife Habitat Enhancement Project
Dear Ranger Claybrook,
Thank you for the opportunity to submit comments on the South Redbird Wildlife Habitat Enhancement Project. These comments are submitted on behalf of Kentucky Heartwood and the Center for Biological Diversity. This project presents a number of significant concerns with regards to federally-listed species, forest composition, and other issues that need to be thoroughly addressed in any future analysis.
1. Not collaborative, so please stop using that term
Kentucky Heartwood actively participated in the early public input opportunities held by the Forest Service for the South Redbird project, including the public meetings on February 22 and August 24, 2017, February 20, 2018, and the field trip on May 2, 2017. The Forest Service loosely referred to these meetings as “collaborations.” As a result, the Forest Service listed Kentucky Heartwood as a “collaborator” in the scoping document. However, few (if any) of the comments, concerns, and constructive input provided by Kentucky Heartwood during those opportunities and by email are reflected in the scoping document. In fact, we see little in the proposed action that reflects any of the concerns we observed being raised during the pre-scoping opportunities outside of the clearly pre-determined, agency-driven emphasis on grouse management through large-scale, even-aged timber harvests.
We will address several of the specific issues and suggestions that were previously raised (and ignored) in the following sections of this letter. But it needs to be stated clearly here, at the outset, that the process was not collaborative in any sense of the term. It is clear from the proposed action that the Forest Service knew what type of management would actually be proposed through the NEPA process, and that the time, effort, and sincere input by Kentucky Heartwood and others was simply a veneer to sell the project. Following our experience with the Greenwood project on the Stearns District, we were promised emphatically by Supervisor Olsen and other forest leadership that future projects would be put together in a more genuinely collaborative, open manner. Frankly, we feel misled and used by the Forest Service.
It should also be noted here that the Forest Service, on February 23, opted to release for scoping an amendment to the Forest Plan that loosens logging restrictions implemented to protect Indiana bats. Scoping for the South Redbird project was published on March 1, and scoping for the Pine Creek project on March 22. In total, these projects cover management on nearly 80,000 acres of national forest land, including over 7,000 acres of commercial logging, and a major change in forestwide management for an endangered species in critical decline. While the Forest Service has been making overtures about bringing the public into an open public lands process, this coordinated avalanche of significant proposals and comment deadlines belies the statements made to us and the public at large.
2. Kentucky arrow darter and Snuffbox mussel
As the Forest Service notes in the scoping document, the project area includes a substantial portion of the designated critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum). We expect a robust, transparent analysis of potential impacts to the Kentucky arrow darter, including consultation with the U.S. Fish and Wildlife Service. During the analysis for the Spring Creek project (which is encompassed by the South Redbird project), the Forest Service stated that there was no Kentucky arrow darter habitat in the project area, despite agency staff knowing this to be untrue. At this time, the Forest Service has little credibility on this issue. The Forest Service has a duty to take proactive measures to support the Kentucky arrow darter. We do not see that represented in the scoping document.
With regards to the Snuffbox mussel (Epioblasma triquetra), the scoping document states:
“Known populations of the snuffbox mussel occur in Elisha Creek less than a half-mile upstream of the project area boundary.”
However, the entirety of the Elisha Creek watershed is within the project area, so it is difficult to understand how this is the case.
While efforts to clean up the mainstem of the Redbird River are laudable, the fact is that the Redbird River itself is not habitable by these species on account of pollution from mining and oil and gas operations, and the tributaries on national forest land must be protected from any form of additional degradation.
The Forest Service has a proactive duty to work toward the recovery of these species. Addressing sewage in the Redbird River and adding culverts to a couple of logging roads is not sufficient toward this end.
3. Ruffed grouse emphasis
It is clear that timber management for Ruffed grouse (Bonasa umbellus) populations is an emphasis in this project. While grouse are only briefly mentioned in the scoping document, the “need” to establish more young forest habitat for grouse was a predominant theme among state and federal agency personnel during pre-scoping meetings. While we recognize that Appalachian populations of grouse are declining, grouse are neither federally nor state-listed as threatened or endangered. Furthermore, in 2008 the Daniel Boone National Forest approved over 1,200 acres of timber harvest immediately north of the South Redbird project area. The “Group One” project also included a Forest Plan amendment to establish a 12,000 acre Ruffed Grouse Emphasis Area to be co-managed by the U.S. Forest Service and Kentucky Division of Fish and Wildlife Resources (KDFWR). Per the Goals and Objectives for Forest Plan Prescription Area 3.H.1 Ruffed Grouse Emphasis, the 12,000 acre area (minus riparian restrictions), is intended to be managed under 60-year even-aged timber rotations. In our conversations during the pre-NEPA “collaboration” meetings, we asked both district forester Jared Calvert and Zak Danks (Grouse coordinator for KDFWR) about the progress of management in the Group One project and Ruffed Grouse Emphasis area and no answers were forthcoming.
It is also notable that the Daniel Boone National Forest experienced a massive outbreak of the southern pine beetle between 1999 and 2002 that induced regeneration events on tens of thousands of acres across the forest. We are nearly 20 years out from that event, and therefore, based on conventional habitat assumptions, many sections of the DBNF should be experiencing significant increases in grouse numbers. Are there data to respond to this? If grouse have not responded to these widespread natural regeneration events, then what else is going on? Are there issues that need to be addressed with hunting pressure? If populations are crashing, then a 4 month grouse season, with a 4 bird/day limit may be inappropriate. Has West Nile virus been considered with regard to site-specific habitat modeling?
Furthermore, hemlocks are now dying in the Redbird district. The published scientific literature for the Appalachian region shows preferential use by grouse of mixed mesophytic forests on account of preferred and reliable forage (catkins, buds, etc.). How many acres of hemlock-mixed mesophytic forests are in the South Redbird project area? How many acres of openings in these mixed mesophytic landscape positions should we expect? It is plausible that the death of the hemlocks will reflect in a positive response in grouse populations due to increases in understory forage.
In terms of habitat, the relationship between young poletimber (forests ~15-20 years old) and grouse is well established. However, it has also been shown that reproductive female grouse in the central Appalachians preferentially use mature, closed canopy forests with little understory vegetation along with the presence of larger diameter trees and coarse woody debris for nesting.
It has also been shown that female grouse with young broods are as likely to utilize patches of early successional habitat created from mature forest canopy gaps as they are young forest created by large clearcuts. For example, Jones (2005)(1) states:
"With respect to forest types, broods used mixed oak stands in the 0–5, 6–20, and >80-year age classes. Site conditions were submesic to subxeric with northern red oak and red maple dominant in the overstory and flame azalea, American chestnut sprouts, red maple, serviceberry, and northern red oak, in the midstory (Tables 3.9, 3.10). The 0– 5-year class was represented by use of 3–4-year-old group selection cuts and edges of 2 recently harvested irregular shelterwood (i.e., 2-aged) stands. Broods also utilized edges of 6–20-year-old mixed oak clearcuts, but seldom ventured into their interior."
It’s notable that the forest ages between 20 and 80 years were largely useless to grouse – the range of ages that dominate the South Redbird project landscape. It’s also notable that canopy gaps in old-growth forests (>140 years) tend to be substantially larger and more frequent than those found in ~80 year-old forest which tend toward smaller gaps and an even, closed codominant canopy structure. Furthermore, it needs to be noted that broods “seldom ventured into (the) interior” of clearcuts, suggesting that large group selection harvests (or large gaps in old-growth forest) could meet the habitat needs of this species without sacrificing so many other values and the habitat needs of other species.
We’ll also add here that home ranges for grouse in the central Appalachians tend to be much smaller than many of the areas proposed for harvest in the South Redbird project, some of which range from 210 to 360 acres. Grouse success in the central Appalachians appears to be associated with home ranges in the tens of acres that include mixed-mesophytic and riparian habitat, areas of closed canopy forest with open understories and coarse woody debris, and patches of poletimber. The massive zones of regeneration harvests and thinning proposed may very well degrade grouse habitat by reducing the complexity of habitat components.
In order to address the habitat needs of grouse in a manner more consistent with the historical ecology of the area, Kentucky Heartwood suggested at multiple junctures during the pre-NEPA “collaboration” period that the Forest Service consider alternative silvicultural methods. Specifically, we suggested that the Forest Service consider demonstrated approaches that combine selective thinning aimed at promoting the complex and locally underrepresented forest structure associated with old-growth conditions along with large group selection cuts in suitable locations to provide for forage and future poletimber cover in a matrix of developing forest. Despite proposing 3,200 acres for logging, our recommendations are not reflected in any way in the scoping proposal.
4. Forest ages
We submitted extensive and detailed comments regarding forest ages and old-growth form and function to the Redbird District on the Spring Creek project, which is within the South Redbird project area. Rather than repeat all of it here, we incorporate it by reference and ask that you review those comments.
Our analysis of the project area using DBNF data shows that the forests in the project area are, on the whole, very young. We note a few statistics here:
• 15% of the forest in the project area (4,965 acres) is over 100 years old
• 2% of the forest in the project area (700 acres) is over 130 years old
• 9% of the forest in the project area (2,924 acres) has been cut since 1990
• 18% of the forest in the project area (5,837 acres) has been cut since 1980
• 23% (1,157 acres) of all forests over 100 years old are proposed for regeneration harvests
Comparing the rather unnatural, even-aged condition of the forests on national forest system lands with multi-aged old-growth forests is a little “apples and oranges,” but we point below to data from a 2014 study from the nearby Lilley Cornett Woods Appalachian Ecological Research Station(2). We cited data from Lilley Cornett Woods – one of the most extensively studied old-growth forest in eastern North America – in our comments on the Spring Creek project. Data from Lilley Cornett Woods are extremely relevant to understanding the natural ecology of the Redbird District and the forests in the South Redbird analysis area. Both forests are within the Dissected Appalachian Plateau Level IV Ecoregion, consist of similar slopes, elevations, and aspects, and are less than 25 miles apart.
As is apparent from the data, tree ages in Lilley Cornett Woods date to the mid-1600’s. Notably, the age data from the project area shows stand or canopy ages being less than 1/3 that of the oldest lived individuals in Lilley Cornett Woods. In other words, the data show that stand ages in Lilley Cornett Woods are up to or exceed 350 years, in contrast to the oldest stands in the South Redbird Project being only around 130 years old - and only a tiny acreage. The structural characteristics and processes associated with old-growth in the region do not emerge until around 130 years or more(3,4). As such, old-growth structural associations are effectively non-existent in the South Redbird project area. These included large trees (including cavity trees), large snags and coarse woody debris, complex canopy structure, and, importantly, large gap formation (5). Such associations need to be both conserved and enhanced in a deliberate, science-based manner. Reliance on landscape-scale regeneration cuts in the forests of the South Redbird project area represents a regressive, agronomic, and economically driven vision of forest ecology in the region.
As is apparent from the data, tree ages in Lilley Cornett Woods date to the mid-1600’s. Notably, the age data from the project area shows stand or canopy ages being less than 1/3 that of the oldest lived individuals in Lilley Cornett Woods. In other words, the data show that stand ages in Lilley Cornett Woods are up to or exceed 350 years, in contrast to the oldest stands in the South Redbird Project being only around 130 years old - and only a tiny acreage. The structural characteristics and processes associated with old-growth in the region do not emerge until around 130 years or more(3,4). As such, old-growth structural associations are effectively non-existent in the South Redbird project area. These included large trees (including cavity trees), large snags and coarse woody debris, complex canopy structure, and, importantly, large gap formation (5). Such associations need to be both conserved and enhanced in a deliberate, science-based manner. Reliance on landscape-scale regeneration cuts in the forests of the South Redbird project area represents a regressive, agronomic, and economically driven vision of forest ecology in the region.
5. Alternative silvicultural methods
Early in the process, we discussed with Jared Calvert the possibility of utilizing demonstrated, alternative silvicultural approaches to promote or enhance the within-stand structural diversity of forest stands in the South Redbird project area. While Kentucky Heartwood does not endorse the commercial sale of timber from our national forests, we believed that these methods would be worth considering as a more ecologically appropriate means for the Forest Service to meet multiple use objectives for harvesting timber.
In April, 2017, we emailed the following studies and reports to Mr. Calvert:
• Accelerating the Development of Old-growth Characteristics in Second-growth Northern Hardwoods, USDA Forest Service, Northern Research Station, General Technical Report NRS-144. Authors: Karin S. Fassnacht, Dustin R. Bronson, Brian J. Palik, Anthony W. D’Amato, Craig G. Lorimer, Karl J. Martin (February 2015).
• Managing for late-successional/old-growth characteristics in northern hardwood-conifer forests, Forest Ecology and Management 235 (2006) 129–142. Author: William Keeton (2006).
• Restoring Old-Growth Characteristics, University of Massachusetts-Amherst Extension. Authors: Anthony D’Amato and Paul Catanzaro
• Pioneer Forest - A Half Century of Sustainable Uneven-aged Forest Management in the Missouri Ozarks, USDA Forest Service, Southern Research Station, General Technical Report SRS-108. 2008.
• The Vermont Forest Ecosystem Management Demonstration Project, University of Vermont, Rubenstein School of Environment and Natural Resources. Presentation and summary of findings. Austin R. Troy, Allan M. Strong, Donald R. Tobi, Margaret Skinnerfrom William Keeton. 2008.
Combining these methods with group selection cuts, as discussed above in section 3. Ruffed grouse emphasis, could help meet the purpose and need of the project while supporting the development of old multi-age forest structure on the landscape, and further limiting the risk of erosion and stream sedimentation on these steep slopes. Or you could just let things be. But we assert that the above represents an extremely reasonable approach, and we are mystified as to why it was wholly rejected by the Forest Service in the development of the scoping document.
6. Oil and gas infrastructure
Before any decision is made, the Forest Service needs to conduct a thorough analysis and mapping of oil and gas infrastructure, including access roads, wells, collection lines, pumps stations, and holding tanks. This infrastructure is found throughout the project area, and may be contributing substantially to water quality issues, invasive species infestations, and habitat fragmentation. In the Spring Creek project, which is within the South Redbird project area, the Forest Service refused to acknowledge the presence of an oil and gas road running straight up a steep slope, through a proposed shelterwood harvest unit, and terminating in Spring Creek. The Forest Service improperly relied on gaps in split estate authority to avoid consideration of on-the-ground facts. This is unacceptable. The Forest Service needs to do better in the South Redbird analysis.
Among other obligations, the Candidate Conservation Agreement for the Kentucky Arrow Darter (Etheostoma spilotum), signed by former Regional Forester Tony Tooke in August, 2015, states:
“The DBNF agrees to:
“3.Work with the USFWS to inventory and map natural gas lines, oil wells, roads, other facilities, land ownership, and mineral ownership within Kentucky arrow darter watersheds on the DBNF.”
If the Forest Service has not done so, complying with the above language in the CCA should be a prerequisite to approving thousands of acres of logging in the project area.
7. Prescribed fire
The proposed action includes 7,400 acres of prescribed fire. We question why, when the Daniel Boone National Forest is already spread beyond capacity on approved prescribed burn areas, the Forest Service has chosen to add more burn units to the inventory (6). We don’t argue that fire is necessarily bad for all forest communities in the project area (it clearly is for some, e.g. beech-sugar maple forests), but fire is certainly less important here than in other portions of the Daniel Boone.
The Cooperative Inventory of Endangered, Threatened, Sensitive, and Rare Species, Daniel Boone National Forest, Redbird Ranger District (7) states that the available historical information on forest composition in the district suggests a relatively low influence of fire in the Redbird forests.
“Also, the lesser amount of Pinus in the RRD, and perhaps some of the Q. velutina group, may also be attributed to a lower fire frequency in previous centuries (see also Campbell et al. 1991). Two other successional species in the modern landscape -- Juniperus and Robinia -- were not listed by Barton (1919) at all in the RRD, in contrast to other DBNF counties.” (Report at 7)
McEwan et al. (2014)(2) state:
“Across all dates, the mean number of years between a detected fire was 9.3 (SD of the mean: 10.9). The composite fire record suggests that the study site experienced relatively infrequent fires in the pre-settlement period followed by an increase in burn frequency ca. 1870–1950 (Fig. 3). Only four fires were detected in the ca. 100 yrs from the beginning of the chronology to 1775 (Fig. 3).”
And:
“We detected many fewer fires in the 1700s and early 1800s than in the period from 1875 to 1950. Studies conducted in deciduous forests that have access to fire scars from prior to 1850 largely support these findings.”
Prior to Euro-American settlement, based on fire scar histories and historical accounts of vegetation, it appears that fire was an infrequent disturbance event on the landscape, and not a major driver of natural community composition at the landscape scale. This is quite different from some areas in the Stearns and London Ranger Districts (i.e., areas covered by the Cumberland River Fire Learning Network). It is entirely possible that the local pastime of arson is inducing more frequent fire return intervals that those that shaped the landscape. The Forest Service needs to take a hard look at fire in the project area, and consider the relative historical importance of fire in the area, and how committing to burn this substantially increased acreage in the Redbird District would divert resources from areas in the Daniel Boone with much higher frequencies of conservative, fire-adapted species.
In general, we suggest (and request) that the Forest Service take a good look at the 1993 Cooperative Inventory both to see what rare species may be present, and what gaps in information have been previously identified and are in need of filling.
Sincerely,
Jim Scheff, Director
Kentucky Heartwood
P.O. Box 1486
Berea, KY 40403
(859) 334-0602
jim@kyheartwood.org
Notes:
1 Jones, Benjamin Colter, "Ruffed Grouse Habitat Use, Reproductive Ecology, and Survival in Western North Carolina. " PhD diss., University of Tennessee, 2005.
2 McEwan et al. (2014). Fire and gap dynamics over 300 years in an old-growth temperate forest. Applied Vegetation Science 17 (2014) 312–322.
3 Scheff, Robert (2012). The Development of Old-Growth Structural Characteristics in Second Growth Forests of the Cumberland Plateau, Kentucky, USA. Master’s Thesis, Eastern Kentucky University.
4 USDA FS. 1997. Guidance for conserving and restoring old-growth forest communities on national forests in the southern region. Report of the Region 8 old-Growth Team. United States Department of Agriculture Forestry Report R8-FR, 56.
5 It cannot be stressed enough that gap formation in well-developed older (>140 year) forests is functionally different than in younger forests. Large trees in older forests, upon falling, are more likely to take out larger patches of canopy trees, thereby creating functional patches of early successional habitat within the old/mature forest matrix. Smaller-canopied trees in codominant stands tend to create smaller gaps upon falling. These smaller gaps experience quick, lateral closure rather than the establishment of a new cohort at the patch scale.
6 As we have pointed out to the Forest Service on several occasions, more than 100,000 acres of land on the DBNF are approved for prescribed burning, but capacity has been limited to about 10,000 acres per year treated. The resulting average return intervals of one burn every 10 years is insufficient to maintain functional habitat for our more conservative fire-adapted species and natural communities, which often need fire ever 2 to 3 years.
7 Cooperative Inventory of Endangered, Threatened, Sensitive, and Rare Species, Daniel Boone National Forest, Redbird Ranger District. 1993. USDA Forest Service, The Nature Conservancy, Kentucky State Nature Preserves Commission, and Kentucky Department of Fish and Wildlife Services.
Early in the process, we discussed with Jared Calvert the possibility of utilizing demonstrated, alternative silvicultural approaches to promote or enhance the within-stand structural diversity of forest stands in the South Redbird project area. While Kentucky Heartwood does not endorse the commercial sale of timber from our national forests, we believed that these methods would be worth considering as a more ecologically appropriate means for the Forest Service to meet multiple use objectives for harvesting timber.
In April, 2017, we emailed the following studies and reports to Mr. Calvert:
• Accelerating the Development of Old-growth Characteristics in Second-growth Northern Hardwoods, USDA Forest Service, Northern Research Station, General Technical Report NRS-144. Authors: Karin S. Fassnacht, Dustin R. Bronson, Brian J. Palik, Anthony W. D’Amato, Craig G. Lorimer, Karl J. Martin (February 2015).
• Managing for late-successional/old-growth characteristics in northern hardwood-conifer forests, Forest Ecology and Management 235 (2006) 129–142. Author: William Keeton (2006).
• Restoring Old-Growth Characteristics, University of Massachusetts-Amherst Extension. Authors: Anthony D’Amato and Paul Catanzaro
• Pioneer Forest - A Half Century of Sustainable Uneven-aged Forest Management in the Missouri Ozarks, USDA Forest Service, Southern Research Station, General Technical Report SRS-108. 2008.
• The Vermont Forest Ecosystem Management Demonstration Project, University of Vermont, Rubenstein School of Environment and Natural Resources. Presentation and summary of findings. Austin R. Troy, Allan M. Strong, Donald R. Tobi, Margaret Skinnerfrom William Keeton. 2008.
Combining these methods with group selection cuts, as discussed above in section 3. Ruffed grouse emphasis, could help meet the purpose and need of the project while supporting the development of old multi-age forest structure on the landscape, and further limiting the risk of erosion and stream sedimentation on these steep slopes. Or you could just let things be. But we assert that the above represents an extremely reasonable approach, and we are mystified as to why it was wholly rejected by the Forest Service in the development of the scoping document.
6. Oil and gas infrastructure
Before any decision is made, the Forest Service needs to conduct a thorough analysis and mapping of oil and gas infrastructure, including access roads, wells, collection lines, pumps stations, and holding tanks. This infrastructure is found throughout the project area, and may be contributing substantially to water quality issues, invasive species infestations, and habitat fragmentation. In the Spring Creek project, which is within the South Redbird project area, the Forest Service refused to acknowledge the presence of an oil and gas road running straight up a steep slope, through a proposed shelterwood harvest unit, and terminating in Spring Creek. The Forest Service improperly relied on gaps in split estate authority to avoid consideration of on-the-ground facts. This is unacceptable. The Forest Service needs to do better in the South Redbird analysis.
Among other obligations, the Candidate Conservation Agreement for the Kentucky Arrow Darter (Etheostoma spilotum), signed by former Regional Forester Tony Tooke in August, 2015, states:
“The DBNF agrees to:
“3.Work with the USFWS to inventory and map natural gas lines, oil wells, roads, other facilities, land ownership, and mineral ownership within Kentucky arrow darter watersheds on the DBNF.”
If the Forest Service has not done so, complying with the above language in the CCA should be a prerequisite to approving thousands of acres of logging in the project area.
7. Prescribed fire
The proposed action includes 7,400 acres of prescribed fire. We question why, when the Daniel Boone National Forest is already spread beyond capacity on approved prescribed burn areas, the Forest Service has chosen to add more burn units to the inventory (6). We don’t argue that fire is necessarily bad for all forest communities in the project area (it clearly is for some, e.g. beech-sugar maple forests), but fire is certainly less important here than in other portions of the Daniel Boone.
The Cooperative Inventory of Endangered, Threatened, Sensitive, and Rare Species, Daniel Boone National Forest, Redbird Ranger District (7) states that the available historical information on forest composition in the district suggests a relatively low influence of fire in the Redbird forests.
“Also, the lesser amount of Pinus in the RRD, and perhaps some of the Q. velutina group, may also be attributed to a lower fire frequency in previous centuries (see also Campbell et al. 1991). Two other successional species in the modern landscape -- Juniperus and Robinia -- were not listed by Barton (1919) at all in the RRD, in contrast to other DBNF counties.” (Report at 7)
McEwan et al. (2014)(2) state:
“Across all dates, the mean number of years between a detected fire was 9.3 (SD of the mean: 10.9). The composite fire record suggests that the study site experienced relatively infrequent fires in the pre-settlement period followed by an increase in burn frequency ca. 1870–1950 (Fig. 3). Only four fires were detected in the ca. 100 yrs from the beginning of the chronology to 1775 (Fig. 3).”
And:
“We detected many fewer fires in the 1700s and early 1800s than in the period from 1875 to 1950. Studies conducted in deciduous forests that have access to fire scars from prior to 1850 largely support these findings.”
Prior to Euro-American settlement, based on fire scar histories and historical accounts of vegetation, it appears that fire was an infrequent disturbance event on the landscape, and not a major driver of natural community composition at the landscape scale. This is quite different from some areas in the Stearns and London Ranger Districts (i.e., areas covered by the Cumberland River Fire Learning Network). It is entirely possible that the local pastime of arson is inducing more frequent fire return intervals that those that shaped the landscape. The Forest Service needs to take a hard look at fire in the project area, and consider the relative historical importance of fire in the area, and how committing to burn this substantially increased acreage in the Redbird District would divert resources from areas in the Daniel Boone with much higher frequencies of conservative, fire-adapted species.
In general, we suggest (and request) that the Forest Service take a good look at the 1993 Cooperative Inventory both to see what rare species may be present, and what gaps in information have been previously identified and are in need of filling.
Sincerely,
Jim Scheff, Director
Kentucky Heartwood
P.O. Box 1486
Berea, KY 40403
(859) 334-0602
jim@kyheartwood.org
Notes:
1 Jones, Benjamin Colter, "Ruffed Grouse Habitat Use, Reproductive Ecology, and Survival in Western North Carolina. " PhD diss., University of Tennessee, 2005.
2 McEwan et al. (2014). Fire and gap dynamics over 300 years in an old-growth temperate forest. Applied Vegetation Science 17 (2014) 312–322.
3 Scheff, Robert (2012). The Development of Old-Growth Structural Characteristics in Second Growth Forests of the Cumberland Plateau, Kentucky, USA. Master’s Thesis, Eastern Kentucky University.
4 USDA FS. 1997. Guidance for conserving and restoring old-growth forest communities on national forests in the southern region. Report of the Region 8 old-Growth Team. United States Department of Agriculture Forestry Report R8-FR, 56.
5 It cannot be stressed enough that gap formation in well-developed older (>140 year) forests is functionally different than in younger forests. Large trees in older forests, upon falling, are more likely to take out larger patches of canopy trees, thereby creating functional patches of early successional habitat within the old/mature forest matrix. Smaller-canopied trees in codominant stands tend to create smaller gaps upon falling. These smaller gaps experience quick, lateral closure rather than the establishment of a new cohort at the patch scale.
6 As we have pointed out to the Forest Service on several occasions, more than 100,000 acres of land on the DBNF are approved for prescribed burning, but capacity has been limited to about 10,000 acres per year treated. The resulting average return intervals of one burn every 10 years is insufficient to maintain functional habitat for our more conservative fire-adapted species and natural communities, which often need fire ever 2 to 3 years.
7 Cooperative Inventory of Endangered, Threatened, Sensitive, and Rare Species, Daniel Boone National Forest, Redbird Ranger District. 1993. USDA Forest Service, The Nature Conservancy, Kentucky State Nature Preserves Commission, and Kentucky Department of Fish and Wildlife Services.
A steep slope above Spring Creek approved for logging in 2015.
Massive new timber project threatens endangered darter:
Comments needed by April 2, 2018
Update posted March 29, 2018
Email Address Correction: We have heard from several people that the Forest Service email address we linked to is invalid. Thanks for letting us know! We tracked down the error in the email address and corrected it on our website. There was an invisible extra dash that was in the email address between the word southern and daniel. This happened because we copied the email address from the scanned pdf provided by the Forest Service, and the optical character recognition must have added this extra dash. Many programs will turn two dashes in a row into one dash, and that is what happened in this case, resulting in an invisible extra dash. I deleted it and now it should work. Sorry about that!!
The correct email is: comments-southern-daniel-boone-redbird@fs.fed.us
Make sure when you copy/paste that there is no space or period at the end of the email address as well. If you have any issues sending your comment in, please let us know. 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 note, if you go to the page for sending comments on the DBNF website, old information for sending comments to Jared Calvert is posted there. The correct instructions for commenting are in the scoping letter, posted on this page of the DBNF website.
Email Address Correction: We have heard from several people that the Forest Service email address we linked to is invalid. Thanks for letting us know! We tracked down the error in the email address and corrected it on our website. There was an invisible extra dash that was in the email address between the word southern and daniel. This happened because we copied the email address from the scanned pdf provided by the Forest Service, and the optical character recognition must have added this extra dash. Many programs will turn two dashes in a row into one dash, and that is what happened in this case, resulting in an invisible extra dash. I deleted it and now it should work. Sorry about that!!
The correct email is: comments-southern-daniel-boone-redbird@fs.fed.us
Make sure when you copy/paste that there is no space or period at the end of the email address as well. If you have any issues sending your comment in, please let us know. 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 note, if you go to the page for sending comments on the DBNF website, old information for sending comments to Jared Calvert is posted there. The correct instructions for commenting are in the scoping letter, posted on this page of the DBNF website.
Massive new timber project threatens endangered darter:
Comments needed by April 2, 2018
Posted March 28, 2018
The U.S. Forest Service has proposed 3,200 acres of intensive logging on the steep and rugged slopes of the Redbird District of the Daniel Boone National Forest. Comments need to be submitted by Monday, April 2nd. The "South Redbird Wildlife Habitat Enhancement Project" threatens critical habitat for the Kentucky arrow darter (Etheostoma spilotum), which was listed as "threatened" under the Endangered Species Act in 2016. The darter is found only in clean waters of the upper Kentucky River, and has disappeared from 44% of its range since 1990. Nearly 900 acres of proposed logging is in the watershed of Elisha Creek, which is also home to the federally-endangered Snuffbox mussel (Epioblasma triquetra). The snuffbox was protected under the Endangered Species Act in 2012 on account of a 62% rangewide decline. Unlike the mainstem of the Redbird River, which is too polluted by mining runoff, oil and gas development, and sewage for these species to live, the clean tributaries in the project area provide habitat needed for these species' survival.
The U.S. Forest Service has proposed 3,200 acres of intensive logging on the steep and rugged slopes of the Redbird District of the Daniel Boone National Forest. Comments need to be submitted by Monday, April 2nd. The "South Redbird Wildlife Habitat Enhancement Project" threatens critical habitat for the Kentucky arrow darter (Etheostoma spilotum), which was listed as "threatened" under the Endangered Species Act in 2016. The darter is found only in clean waters of the upper Kentucky River, and has disappeared from 44% of its range since 1990. Nearly 900 acres of proposed logging is in the watershed of Elisha Creek, which is also home to the federally-endangered Snuffbox mussel (Epioblasma triquetra). The snuffbox was protected under the Endangered Species Act in 2012 on account of a 62% rangewide decline. Unlike the mainstem of the Redbird River, which is too polluted by mining runoff, oil and gas development, and sewage for these species to live, the clean tributaries in the project area provide habitat needed for these species' survival.
Of the 32,300 acres of national forest land in the South Redbird project area, 27% has been harvested since 1980 and only 15% is over 100 years old. This is a stark contrast to the centuries-old forest at Lilley Cornett Woods, just 25 miles to the east. And yet the Forest Service is proposing to log 23% of all forest over 100 years old in the project area. Several areas ranging from 200 to 350 contiguous acres have been proposed for logging. Combined with previous cuts, some sections of forest, up to 800 acres, will hardly have any trees over 30 years old left standing.
Kentucky arrow darter (Etheostoma spilotum), photo USFWS
The Forest Service proposed the South Redbird project at the same time as a Forest Plan amendment to loosen logging restrictions designed to protect endangered Indiana bats. And another proposal to log several thousand more acres of the London District (the Pine Creek project) was just posted on the Daniel Boone National Forest website. Expect to see more on that soon.
The South Redbird project follows a series of public meetings that the Forest Service refers to as “collaborations.” While Kentucky Heartwood is listed as a “collaborator” in the scoping letter, our good-faith input throughout the process was largely ignored. In fact, the project reflects few of the concerns raised by participants – other than those of state and federal agencies pushing for more clearcuts and “regeneration” harvests for ruffed grouse habitat. While the forest has been characterized by some as “too old,” the fact is that less than half the forest is over 70 years old.
The South Redbird project follows a series of public meetings that the Forest Service refers to as “collaborations.” While Kentucky Heartwood is listed as a “collaborator” in the scoping letter, our good-faith input throughout the process was largely ignored. In fact, the project reflects few of the concerns raised by participants – other than those of state and federal agencies pushing for more clearcuts and “regeneration” harvests for ruffed grouse habitat. While the forest has been characterized by some as “too old,” the fact is that less than half the forest is over 70 years old.
Protected forest in the Right Fork of Elisha Creek proposed Research Natural Area.
In 2008, the Forest Service approved 1,200 acres of logging immediately north of the South Redbird project area as part of the Group One Redbird River Project. The Group One project included a Forest Plan amendment that established a 12,000 acre “Ruffed Grouse Emphasis Area” to be maintained under 60 year timber rotations in cooperation with the Kentucky Division of Fish and Wildlife Management. Kentucky Heartwood successfully appealed that project twice before it was approved after a third revision. Despite the specific grouse emphasis, after 10 years neither federal nor state managers can answer questions regarding the success or failure of their grouse management. And yet they insist we need more forests cleared across the district for grouse. Kentucky Heartwood suggested early in the process that the Forest Service consider meeting forage needs for grouse by incorporating small to medium-sized group selection cuts in a matrix of thinning oriented toward old-growth structural development. But this would mean less timber getting cut, and apparently that’s not worthy of serious consideration.
Despite its rugged beauty and rich diversity, the Redbird District is being treated like a throw-away district by the U.S. Forest Service. There are no hiking trails and no campgrounds – issues that were raised repeatedly during public meetings by members of the public and U.S. Forest Service staff. The only recreational infrastructure is the extensive Redbird Crest ATV trail, which the Forest Service proposes to reroute with 12 new miles of ATV trail construction. National forest lands in the Redbird District are an island in a landscape of vast strip mines and clearcuts. The forest here needs to be protected and nurtured, and we think that the Forest Service can do better. Please help encourage them to do so.
Official documents for the project can be found on the Daniel Boone National Forest website. And more information can be found on our website here.
Comments are due by Monday, April 2, 2018, and should be emailed to:
comments-southern-daniel-boone-redbird@fs.fed.us
Please note in the subject line that the comments are for South Red Bird Project.
Comments can also be mailed by U.S. Postal Service to:
Robert Claybrook
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914
Official documents for the project can be found on the Daniel Boone National Forest website. And more information can be found on our website here.
Comments are due by Monday, April 2, 2018, and should be emailed to:
comments-southern-daniel-boone-redbird@fs.fed.us
Please note in the subject line that the comments are for South Red Bird Project.
Comments can also be mailed by U.S. Postal Service to:
Robert Claybrook
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914
| redbird_map_2_28_18.pdf |
South Red Bird Landscape Improvement Project
(As of March 1 is now called the South Redbird Wildlife Habitat Enhancement Project)
Posted February 21, 2018
Here is a link to the Daniel Boone National Forest page which includes documents pertaining to the South Red Bird Landscape Improvement Project which is currently under development.
The forest service has provided the following information about the South Red Bird project:
This is a landscape-level vegetation and watershed improvement project, and will incorporate vegetation management (including harvests and reforestation), prescribed fires, habitat improvement, soil and water quality projects, and road maintenance. The project area covers approximately 55,000 acres, of which 32,300 acres are National Forest System (NFS) lands, within the Red Bird River Watershed near Big Creek, Kentucky.
Forest: Daniel Boone National Forest
District: Redbird Ranger District
State: Kentucky
Counties: Bell; Clay; Knox; Leslie
Project Purpose: Forest products; Road management; Wildlife, Fish, Rare plants; Vegetation management (other than forest products); Fuels management; Watershed management
Project Activity: Road decommissioning; Fuel treatments (non-activity fuels); Forest vegetation improvements; Species habitat improvements; Abandoned mine land clean-up; Special products sales; Noxious weed treatments; Species population enhancements; Road maintenance; Road improvements/construction; Timber sales (salvage); Travel management; Timber sales (green); Watershed improvements
Here is a link to the Daniel Boone National Forest page which includes documents pertaining to the South Red Bird Landscape Improvement Project which is currently under development.
The forest service has provided the following information about the South Red Bird project:
This is a landscape-level vegetation and watershed improvement project, and will incorporate vegetation management (including harvests and reforestation), prescribed fires, habitat improvement, soil and water quality projects, and road maintenance. The project area covers approximately 55,000 acres, of which 32,300 acres are National Forest System (NFS) lands, within the Red Bird River Watershed near Big Creek, Kentucky.
Forest: Daniel Boone National Forest
District: Redbird Ranger District
State: Kentucky
Counties: Bell; Clay; Knox; Leslie
Project Purpose: Forest products; Road management; Wildlife, Fish, Rare plants; Vegetation management (other than forest products); Fuels management; Watershed management
Project Activity: Road decommissioning; Fuel treatments (non-activity fuels); Forest vegetation improvements; Species habitat improvements; Abandoned mine land clean-up; Special products sales; Noxious weed treatments; Species population enhancements; Road maintenance; Road improvements/construction; Timber sales (salvage); Travel management; Timber sales (green); Watershed improvements
| redbird_map.pdf |
Commenting on the Red Bird Project
The Forest Service has provided the following information about commenting on this project. This information can be found on the Daniel Boone National Forest website here.
South Red Bird Landscape Improvement Project #52340
Comments, including anonymous comments, will be accepted at any time. However, comments posted after the close of a designated comment period may not be able to be given full consideration. Anonymous comments and comments submitted after the close of the final designated comment period will not provide the commenter standing for administrative review.
The Forest Service values public participation. Communications from the public regarding this project, including commenter’s names and contact information, will become part of the public record.
Comments, or in some cases other expressions of interest, along with respondent’s contact information, submitted during the comment period may be necessary to establish a respondent’s eligibility to participate in an administrative review for this proposed action. Interested members of the public should review the proposal’s information to determine the applicable administrative review process and the eligibility requirements for that process. The date of the legal notice of opportunity to comment on this proposed action is the exclusive means for calculating the comment period. For proposals to be documented with an Environmental Assessment, the legal notice announcing the comment period appears in the Newspaper of Record . For Draft Environmental Impact Statements, the Notice of Availability announcing the comment period appears in the Federal Register.
Submitting Comments
If you wish to submit a comment, please send it to:
Robert Claybrook (updated 3-28 - the old info said to send them to Jared Calvert)
Redbird Ranger District
91 Peabody Road , Big Creek, KY, 40914
jaredcalvert@fs.fed.us
The Forest Service has provided the following information about commenting on this project. This information can be found on the Daniel Boone National Forest website here.
South Red Bird Landscape Improvement Project #52340
Comments, including anonymous comments, will be accepted at any time. However, comments posted after the close of a designated comment period may not be able to be given full consideration. Anonymous comments and comments submitted after the close of the final designated comment period will not provide the commenter standing for administrative review.
The Forest Service values public participation. Communications from the public regarding this project, including commenter’s names and contact information, will become part of the public record.
Comments, or in some cases other expressions of interest, along with respondent’s contact information, submitted during the comment period may be necessary to establish a respondent’s eligibility to participate in an administrative review for this proposed action. Interested members of the public should review the proposal’s information to determine the applicable administrative review process and the eligibility requirements for that process. The date of the legal notice of opportunity to comment on this proposed action is the exclusive means for calculating the comment period. For proposals to be documented with an Environmental Assessment, the legal notice announcing the comment period appears in the Newspaper of Record . For Draft Environmental Impact Statements, the Notice of Availability announcing the comment period appears in the Federal Register.
Submitting Comments
If you wish to submit a comment, please send it to:
Robert Claybrook (updated 3-28 - the old info said to send them to Jared Calvert)
Redbird Ranger District
91 Peabody Road , Big Creek, KY, 40914
jaredcalvert@fs.fed.us
South Redbird Collaborative Under Way
July 3, 2017
The Forest Service has begun what it is calling the “South Redbird Collaborative,” part of the integrated resource management strategy (IRMS) approach to landscape analyses on the Daniel Boone. Two other IRMS processes are currently under way in the forest – the Blackwater IRMS in the Cumberland District and the Pine Creek IRMS in the London District. The South Redbird analysis area covers about 56,000 acres, including 32,000 acres of the Daniel Boone National Forest. The Forest Service states that they are “interested in projects that may improve wildlife habitat, soil and water quality, forest health, and road and trail surfaces.” Past IRMS processes have resulted in proposed timber sales, including Greenwood and the Crooked Creek Project – the latter being withdrawn after significant opposition to plans to log Climax Mountain and Little Egypt. However, other aspects of the landscape including watershed health, rare species, oil and gas roads, and recreational opportunities are also being looked at.
The first meeting of the South Redbird Collaborative IRMS was held on February 22nd in Manchester, and a wide range of interests and topics were discussed by members of the public, organizations, and state and federal agencies. The newly adopted Redbird River Watershed Plan was announced, with the new Redbird River Watershed Coordinator, Lois Smith, introduced. Through cooperative work with the Cumberland Valley Resource Conservation and Development Council, East Kentucky PRIDE, the Red Bird Mission School, and others, the Redbird River Watershed Plan will address watershed health through fixing and installing working septic systems, providing clean drinking waters sources, addressing trash disposal issues, and environmental education to local communities.
A subsequent field trip was held on May 2nd, where Kentucky Heartwood was invited to speak about managing for old-growth forest characteristics in the generally young forests of the Redbird District. We visited parts of the Group One Redbird Project (which was approved after being withdrawn twice in response to administrative appeals by Kentucky Heartwood) and the Steel Trap mine site. Issues discussed included mine reclamation opportunities, wildfire, grouse management, and oak regeneration.
The South Redbird watershed represents one of the more significant blocks of national forest in the state, and some of the only appreciable public land east of the Cumberland Plateau in Kentucky’s Dissected Appalachian Plateau ecoregion. The watershed provides critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum), but is degraded and at-risk due to coal mining, sewage, and oil and gas development.
The Kentucky Geological Survey has records of 285 gas wells in the watershed, with 85 of those on national forest land. The extensive network of access roads for gas wells and pipelines remains largely uninventoried, though the Forest Service is finally working to close this information gap. Timber theft, off-road vehicles, and illegal dumping provide further challenges. Still, the forest of the Redbird watershed is beautiful, ecologically important, and in need of protection and care.
If you are interested in participating in the Redbird Collaborative, please email jim@kyheartwood.org.
This article appeared in our Summer 2017 newsletter.
July 3, 2017
The Forest Service has begun what it is calling the “South Redbird Collaborative,” part of the integrated resource management strategy (IRMS) approach to landscape analyses on the Daniel Boone. Two other IRMS processes are currently under way in the forest – the Blackwater IRMS in the Cumberland District and the Pine Creek IRMS in the London District. The South Redbird analysis area covers about 56,000 acres, including 32,000 acres of the Daniel Boone National Forest. The Forest Service states that they are “interested in projects that may improve wildlife habitat, soil and water quality, forest health, and road and trail surfaces.” Past IRMS processes have resulted in proposed timber sales, including Greenwood and the Crooked Creek Project – the latter being withdrawn after significant opposition to plans to log Climax Mountain and Little Egypt. However, other aspects of the landscape including watershed health, rare species, oil and gas roads, and recreational opportunities are also being looked at.
The first meeting of the South Redbird Collaborative IRMS was held on February 22nd in Manchester, and a wide range of interests and topics were discussed by members of the public, organizations, and state and federal agencies. The newly adopted Redbird River Watershed Plan was announced, with the new Redbird River Watershed Coordinator, Lois Smith, introduced. Through cooperative work with the Cumberland Valley Resource Conservation and Development Council, East Kentucky PRIDE, the Red Bird Mission School, and others, the Redbird River Watershed Plan will address watershed health through fixing and installing working septic systems, providing clean drinking waters sources, addressing trash disposal issues, and environmental education to local communities.
A subsequent field trip was held on May 2nd, where Kentucky Heartwood was invited to speak about managing for old-growth forest characteristics in the generally young forests of the Redbird District. We visited parts of the Group One Redbird Project (which was approved after being withdrawn twice in response to administrative appeals by Kentucky Heartwood) and the Steel Trap mine site. Issues discussed included mine reclamation opportunities, wildfire, grouse management, and oak regeneration.
The South Redbird watershed represents one of the more significant blocks of national forest in the state, and some of the only appreciable public land east of the Cumberland Plateau in Kentucky’s Dissected Appalachian Plateau ecoregion. The watershed provides critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum), but is degraded and at-risk due to coal mining, sewage, and oil and gas development.
The Kentucky Geological Survey has records of 285 gas wells in the watershed, with 85 of those on national forest land. The extensive network of access roads for gas wells and pipelines remains largely uninventoried, though the Forest Service is finally working to close this information gap. Timber theft, off-road vehicles, and illegal dumping provide further challenges. Still, the forest of the Redbird watershed is beautiful, ecologically important, and in need of protection and care.
If you are interested in participating in the Redbird Collaborative, please email jim@kyheartwood.org.
This article appeared in our Summer 2017 newsletter.