So, who’s right?
For any of this to make sense, an explanation of the term “basal area,” or just “BA,” is in order. Basal area is defined as the cross-sectional area of trees at 4.5 feet above ground in a unit area. In American forestry BA is expressed in square feet per acre. In academic research, and internationally, the units are square meters per hectare (a very un-fun unit conversion). Overall, BA provides a measure how much of an area is taken up by trees, and relates directly to the numbers and sizes of trees in the forest. Because measuring every tree in a forest usually isn’t practicable, basal area can be estimated by using a number of different tools and sampling protocols, each with their own limitations.
Just under one-third, or 674 acres, of the logging approved in the Greenwood project was ostensibly designed to restore mid-density, fire-mediated upland forest communities through the “Woodland Establishment” prescription. There’s good evidence that this type of forest was historically important in the area. Kentucky Heartwood did object, however, to some of the locations chosen for the Woodland Establishment prescription because site selection seemed to be more about access to large timber than actual restoration potential and need.
Despite our efforts, the Forest Service refused to include management of the Keno Road and Curt Pond Ridge areas (and other important sites) in the Greenwood project. The agency did, however, commit in their October 2017 response to our formal administrative objection to the Greenwood project, to working with Kentucky Heartwood and the Kentucky Office of Nature Preserves to develop a management strategy for the site. Unfortunately, other than a couple of on-site meetings in mid-2018, nothing has happened.
The formal description for the Action 2: Woodland Establishment prescription in the Environmental Assessment for the Greenwood project is as follows:
“A woodland establishment treatment is proposed on approximately 674 acres in 20 stands. This treatment would retain an overstory canopy of dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees, (e. g. shortleaf pine, chestnut oak, and white oak). The target leave basal area would be 30 to 50 square feet per acre.”
The selection of trees to be retained as “dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees” is not incidental. While hollow, rotten, and declining trees are important ecological elements (and some must be retained per Forest Plan requirements), most won’t last long after logging. Particularly for structurally compromised trees, the increased exposure to windthrow following the harvest of adjacent canopy trees will hasten their loss from the canopy. And fire-intolerant species, like red maple, scarlet oak, and eastern hemlock, will be injured and decline following repeated applications of prescribed fire.
And it’s worth comparing the language for the Woodland Establishment harvest to that of Action 4: Shelterwood Preperatory Cut (a separate logging prescription in the project). The Shelterwood Preperatory Cut prescription states that:
“Trees favored for retention would be healthy, dominant, codominant, long lived, and fire-resilient species such as shortleaf pine, white oak, chestnut oak, and hickory with the best crowns.”
The deliberate use of the word “favored” in the prescription for Action 4: Shelterwood Preperatory Cut, but not in the prescription for Action 2: Woodland Establishment, is important. The Forest Service could have used similar equivocating language in the Woodland Establishment prescription, but didn’t.
Their report states that “For all stands sampled, trees with undesirable characteristics will comprise a small, but tolerable, amount of the future stand.”
However, the various data presented in their report, and one of their concluding statements, contradict this interpretation. The Forest Service reports states that:
“For all woodland stands and the shelterwood preparatory stand, the results indicate trees with desired characteristics comprise over 60 percent of the BA to be retained. Specifically, these trees are of a dominant or codominant crown class, a desirable species, and have a tree class of desirable or acceptable.”
The corollary here is that up to 39% of the trees being retained (representing about 14.6 square feet per acre of basal area) do not meet the criteria of being long-lived, healthy, vigorous, and fire tolerant trees, and have a high likelihood of declining or dying within a short period after logging and burning. It is hard to see this as only a “small, but tolerable, amount.” The final BA of trees that actually do meet the criteria for retention, based on the Forest Service’s data, is around 22.9 square feet per acre, or about half of the target BA prescribed in the Environmental Assessment. This value is very close to the 20.5 square feet per acre that we reported in our initial complaint.
The Forest Service did concur that trees were inappropriately marked for harvesting in at least one of the riparian areas that we brought to their attention. In the Daniel Boone National Forest logging isn’t allowed within 50 feet of streams classified as “intermittent,” but is allowed in and along stream channels classified as “ephemeral.” Differentiating the two can be challenging. One location we took issue with was a headwaters tributary of Drury Branch, before it drops in to Beaver Creek Wilderness. The Forest Service did determine that the stream segment “confidently fits the definition of an intermittent stream,” but that the error was unintentional and understandable. However, the Forest Service is only reviewing the status of the approximately 300 acres that Kentucky Heartwood surveyed, and not any of the remainder of the more than 2,000 acres of logging in the Greenwood project.
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