A few months ago, Kentucky Heartwood released information and allegations that the Forest Service was selling more timber in the
Greenwood project of the Daniel Boone National Forest than what was approved in the 2017 project decision. We also asserted that trees had been marked for harvest in some riparian buffers along stream channels in violation of the Forest Plan. The Forest Service has since released their own data and analysis, insisting that everything (or most everything) is just fine.
So, who’s right?
Where reality stands is a bit complicated and muddy, and requires wading through some jargon and technical matters. I hope you’ll read on and get the details. They’re important. In summary though, our originally surveys overestimated the amount of timber being oversold. However, we believe that the data show that the Forest Service is still selling far more trees than approved (including in riparian areas) and, in some respects and locations, high-grading the timber.
For any of this to make sense, an explanation of the term “basal area,” or just “BA,” is in order. Basal area is defined as the cross-sectional area of trees at 4.5 feet above ground in a unit area. In American forestry BA is expressed in square feet per acre. In academic research, and internationally, the units are square meters per hectare (a very un-fun unit conversion). Overall, BA provides a measure how much of an area is taken up by trees, and relates directly to the numbers and sizes of trees in the forest. Because measuring every tree in a forest usually isn’t practicable, basal area can be estimated by using a number of different tools and sampling protocols, each with their own limitations.
Most “mature” and old-growth forests in our area have a BA ranging from around 90 to over 180 square feet per acre, but 110 to 150 is most common. Forest type, age, and disturbance history all play a big role. Several studies of regional old-growth forests have reported densities of trees over 4” (10 cm) in diameter ranging from about 65 trees per acre to around 250 per acre. A lot of small trees can be present in a forest and still contribute very little to overall basal area. On the other end of the management spectrum, most timber harvests on the Daniel Boone National Forest are shelterwood (or “regeneration”) cuts with a target BA of about 10 to 15 square feet per acre, and leave about 10 trees per acre.
Just under one-third, or 674 acres, of the logging approved in the Greenwood project was ostensibly designed to restore mid-density, fire-mediated upland forest communities through the “Woodland Establishment” prescription. There’s good evidence that this type of forest was historically important in the area. Kentucky Heartwood did object, however, to some of the locations chosen for the Woodland Establishment prescription because site selection seemed to be more about access to large timber than actual restoration potential and need.
We strongly advocated for the Forest Service to focus their Woodland Establishment and other management prescriptions in areas with known rare and declining grassland remnants, like those found along the Keno Road and Curt Pond Ridge area in Pulaski County. That particular area was identified in a 1988 Cooperative Inventory of Endangered, Threatened, Sensitive, and Rare Species for Daniel Boone National Forest conducted by the Forest Service, The Nature Conservancy, Kentucky State Nature Preserves Commission, and Kentucky Department of Fish and Wildlife Service. The 1988 report highlighted the Keno Road area and recommended establishing the area “as an experimental demonstration project.” Unfortunately, the site has been largely neglected, resulting in a major decline of this rare “Cumberland Barrens” remnant.
Despite our efforts, the Forest Service refused to include management of the Keno Road and Curt Pond Ridge areas (and other important sites) in the Greenwood project. The agency did, however, commit in their October 2017 response to our formal administrative objection to the Greenwood project, to working with Kentucky Heartwood and the Kentucky Office of Nature Preserves to develop a management strategy for the site. Unfortunately, other than a couple of on-site meetings in mid-2018, nothing has happened.
But let’s get back to talking about basal area. The formal description for the Action 2: Woodland Establishment prescription in the Environmental Assessment for the Greenwood project is as follows:“A woodland establishment treatment is proposed on approximately 674 acres in 20 stands. This treatment would retain an overstory canopy of dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees, (e. g. shortleaf pine, chestnut oak, and white oak). The target leave basal area would be 30 to 50 square feet per acre.”
The selection of trees to be retained as “dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees” is not incidental. While hollow, rotten, and declining trees are important ecological elements (and some must be retained per Forest Plan requirements), most won’t last long after logging. Particularly for structurally compromised trees, the increased exposure to windthrow following the harvest of adjacent canopy trees will hasten their loss from the canopy. And fire-intolerant species, like red maple, scarlet oak, and eastern hemlock, will be injured and decline following repeated applications of prescribed fire.
And it’s worth comparing the language for the Woodland Establishment harvest to that of Action 4: Shelterwood Preparatory Cut (a separate logging prescription in the project). The Shelterwood Preparatory 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 Preparatory Cut, but not in the prescription for Action 2: Woodland Establishment, is important. The Forest Service could have used similar equivocating language in the Woodland Establishment prescription, but didn’t.
In the Forest Service’s response to our complaint they report an overall retained BA of 37.5 square feet per acre. This is much higher than what we reported following our initial survey. Based on our subsequent surveys, we think that the Forest Service’s estimate for total, average BA is about right. The differences largely resulted from our use of transects instead of grid-based sampling. Despite our efforts to be non-selective while still collecting data representative of each harvest unit, we clearly missed some portions of stands which contributed substantially to the total basal area. However, reporting only the total BA misses a crucial part of the story. Their report states that “For all stands sampled, trees with undesirable characteristics will comprise a small, but tolerable, amount of the future stand.”However, the various data presented in their report, and one of their concluding statements, contradict this interpretation. The Forest Service reports states that:
“For all woodland stands and the shelterwood preparatory stand, the results indicate trees with desired characteristics comprise over 60 percent of the BA to be retained. Specifically, these trees are of a dominant or codominant crown class, a desirable species, and have a tree class of desirable or acceptable.”
The corollary here is that up to 39% of the trees being retained (representing about 14.6 square feet per acre of basal area) do not meet the criteria of being long-lived, healthy, vigorous, and fire tolerant trees, and have a high likelihood of declining or dying within a short period after logging and burning. It is hard to see this as only a “small, but tolerable, amount.” The final BA of trees that actually do meet the criteria for retention, based on the Forest Service’s data, is around 22.9 square feet per acre, or about half of the target BA prescribed in the Environmental Assessment. This value is very close to the 20.5 square feet per acre that we reported in our initial complaint.
Our subsequent surveys suggest that some of the harvest units are in compliance with the prescriptions in the EA. But some are not. To meet the letter and intent of the Woodland Establishment prescription, the Forest Service needs to retain, at a minimum, an additional 7 square feet per acre of the healthy, merchantable trees that they have marked and sold. If the pattern holds across the 674 acres of the Woodland Establishment prescription, that would amount to about 4,500 fourteen-inch diameter trees, or over 2,000 twenty-inch diameter trees.
The Forest Service did concur that trees were inappropriately marked for harvesting in at least one of the riparian areas that we brought to their attention. In the Daniel Boone National Forest logging isn’t allowed within 50 feet of streams classified as “intermittent,” but is allowed in and along stream channels classified as “ephemeral.” Differentiating the two can be challenging. One location we took issue with was a headwaters tributary of Drury Branch, before it drops in to Beaver Creek Wilderness. The Forest Service did determine that the stream segment “confidently fits the definition of an intermittent stream,” but that the error was unintentional and understandable. However, the Forest Service is only reviewing the status of the approximately 300 acres that Kentucky Heartwood surveyed, and not any of the remainder of the more than 2,000 acres of logging in the Greenwood project.
We’ve yet to decide how to proceed with the Forest Service. These issues represent serious errors on the part of the government and are a breach of the public trust. It also comes at a time when we know that the Trump administration is putting pressure on the Forest Service to increase the volume of timber being harvested from our national forest lands. Our frustration is even more pronounced given the Forest Service’s foot-dragging on their commitments to manage the rare plant communities in the Keno Road and Curt Pond Ridge area. But the environmental impacts of these overharvests in the Greenwood project are less severe than the
ongoing landslides resulting from recent logging in the Redbird District, and the thousands more acres of severe logging nearing approval in the
South Redbird project. Given our organizational capacity, we have to be judicious in where we apply our resources. It’s not an easy call.
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