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).
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.
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.
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.
- 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.
- 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.
Comments are due by Friday, June 21st, 2019
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