Illegal Logging of Public Lands in Blackwater (Cave Run Lake)?
Project update 2-15-2022:
A recent court ruling has found a Forest Service project similar to Blackwater to be illegal for using “condition-based management.” Kentucky Heartwood worries that condition-based management is being misused by the Forest Service to avoid getting public input on the specifics of their logging projects. In this way, they can more easily log lands with high value timber that might just happen to have old growth trees and endangered species. Normally, the Forest Service would not do such actions to comply with their own forest plan and national laws but they often take a don’t ask don’t tell policy as in if we don’t look for old growth or endangered species than we have no proof they are there.
Kentucky Heartwood attended a public meeting over the Forest Service’s plans to log Upper Licking Fork near Cave Run Lake. We advocated for the Forest Service to stick true to their promise not to log forest stands over 120 years old. This 120 year old standard is something we have long advocated for and is very exciting to see put into practice. Kentucky Heartwood will monitor the forest stands aged 120+ years old by Forest Service to ensure the logging does not deviate from this promise. We also will continue to advocate for adequate field monitoring to properly age forest stands. Our work in Redbird has found forest stands whose age is hugely misclassified by the Forest Service. This creates a situation in Redbird where the Forest Service is on the brink of breaking their own forest plan by logging 250+ year old forest stands. These old sections of forest are incredibly rare and important for endangered species like the Indiana Bat, an endangered species that Kentucky Heartwood’s scientific monitoring has documented in Redbird.
It is possible that the Forest Service might legitimately not have enough capacity to be able to adequately look for endangered species or identify older growth forests. However, when Kentucky Heartwood does this important work (like we have done in Redbird) the Forest Service should at least be receptive to our findings and incorporate them into their plans. Instead, new information has been largely dismissed and ignored.
In an ideal world, the Blackwater project presents two opportunities despite its problems: 1) Kentucky Heartwood can join a growing rally cry of environmental groups that make it clear that condition-based management is illegal and not an acceptable loophole around fundamental environmental laws 2) Kentucky Heartwood’s can work with the Forest Service to find 120+ year old forest that they may have missed.
Project update 10-28-2020:
Blackwater watershed in Menifee, Morgan, and Rowan Counties, Cumberland Ranger District
Main concerns: The Forest Service has approved an open-ended logging project near Cave Run Lake without first identifying any specific locations where they will actually sell the timber, build roads, or perform other management. Known as “condition based management,” this approach does not allow for the public to provide the informed input and feedback on the project that is required by NEPA.
Scope: The forest service has provided maps showing nearly 12,000 acres of areas where logging could happen over the next 10 to 30 years. The actual scope of future logging is unknown.
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. This is a radical change from decades of management and planning on the Daniel Boone National Forest, and follows an alarming trend happening on other national forests.
What we do know is that most of the logging would be in the form even-aged shelterwood cuts, where about 85% of the canopy is cut across units (stands) of 20 to 40 acres. A small amount of the shelterwood cutting (less than 5%) would take place to restore ecologically important limestone and cedar glades. Depending on the specific locations and practices used, some timber harvest to restore these glades could be beneficial.
The Forest Service has also proposed a small amount of uneven-aged management through group selection. However, what the Forest Service is calling “uneven-aged” management would consist of 1 to 2 acre clearcuts, rather than more selective, finer-scale silvicultural approaches that could support the development of true, multi-age forest structure.
The project also includes a variety of activities meant to improve streams across the project area. 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 specifics matter, and we may support this work in some areas and oppose it in others.
A summary of our timber concerns:
- The Forest Service should not approve any logging projects without first disclosing the specific locations where timber harvests are planned.
- The Daniel Boone National Forest has a terrible track record of causing infestations of non-native invasive plants in interior forests as a result of their logging operations. Through the bulldozing of “temporary roads,” clearing and compaction of log landings, and creation of networks of skid trails through forest, infestations are regularly established. This is something that the agency has been unwilling to seriously reckon with. And experience shows that the predominantly oak forests being cut in the Daniel Boone National Forest have been coming back in tulip poplar and stump-sprouted red maple. Private lands in Kentucky are providing plenty of timber into the economy. There’s no reason to degrade our public, national forest lands to get logs to the mill.
- While we prefer that logging not occur (other than to support the conservation of rare natural communities), changes could be made to make the prescriptions better. The uneven-aged logging prescription in the current proposal should be modified, with group selection harvests reduced to less than 1 acre (typically 0.25 to 0.5 acres), with tree thinning oriented toward the development of complex, multi-age forest structure. This would better mimic prevailing natural disturbance events and could support the development of old-growth forest structure in some areas. The Forest Service should also avoid using shelterwood or other regeneration cuts. And no “temporary roads” should be constructed to extract timber. These features are ugly, lasting scars on the landscape and are where some of the worst infestations of non-native invasive plants get started. Lower impact timber harvest methods are available.
What we do support:
- 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.
Here is a link to the livestream of the November, 2017 meeting about openlands on the Cumberland district: https://www.facebook.com/danielboonenf/videos/1947105628638211/Here is a link to a Forest Service document from 2009, describing the IRMS process in general.