Jellico Project Area, Daniel Boone National Forest
The Jellico Vegetation Management Project is a massive logging project that the Daniel Boone National Forest (DBNF) announced in October 2022.
The proposal includes logging on 10,000 acres of national forest in the mountains along the southern border of Kentucky just to the west of I-75 between Williamsburg and Whitley City.
The Forest Service is proposing multiple forms of clearcut on about 5,000 acres and logging nearly half of the total land area on Jellico Mountain. The project would approve logging over an unprecedented 40-year time frame, which is problematic for a number of reasons that we outline below.
Why this forest is special?
The Jellicos are part of the Cumberland Mountains on the Kentucky-Tennessee border. Topping out at about 2,200 feet, and with over 1,200 feet in relief, the Jellicos are more mountainous than the rest of the DBNF.
The area is home to numerous rare species, including the two species of fish that live in Jellico Creek and are protected by the Endangered Species Act – the Cumberland darter (Etheostoma susanae) and Blackside dace (Chrosomus cumberlandensis).
The proposed logging area includes nearly 900 acres of forest that is over 130 years. Due to its age, this older forest should be protected by the Forest Service under an “old-growth” designation, but so far remains on the chopping block.
Resource extraction has already had a heavy toll on the forest. Nearly 2,700 acres were logged in the 1980s and 1990s. In 2011 the Bureau of Land Management and U.S. Forest Service leased over 3,800 acres for oil and gas development. And legacy impacts from coal mining, along with significant problems with invasive plant species, add to the challenges of protecting and restoring this unique area.
Current Project Status: Preparing for Environmental Assessment
We anticipate that the Forest Service will release their Draft Environmental Assessment around June 2023, with a 30-day period for the public to submit comments. The Environmental Assessment is supposed to assess the environmental impacts of the proposed project so that the agency can make an “informed decision” as required by the National Environmental Policy Act. However, due to the scale of the project and lack of specific information provided in the scoping document, we anticipate that the Environmental Assessment will be inadequate.
Landslide risks: This area has steep slopes, unstable soil, and is known to present significant landslide risks. Endangered species rely on the area’s streams for critical habitat, just like the Redbird district where we have documented numerous landslides due to the Forest Service’s logging. We have already documented one landslide in an area logged in the 1990s, and community members have raised their own observations of landslides and erosion following logging in the area.
- Our position: Landslide-prone areas should not be logged, and clearcutting and road building on landslide-prone slopes is grossly unacceptable. The DBNF Forest Plan needs to be amended to designate steep slope areas as “lands not suited for timber production.”
Old growth: The proposed project includes 3 forms of clearcuts on 397 acres of old growth forest(over 130 years old). None of this older forest is protected in the Jellico’s “Designated Old Growth” area despite meeting the Forest Service’s tree size and age requirements for old growth. Kentucky Heartwood has not been able to ground-truth each of the 256 stands of forest proposed for logging, so there could be more old growth to discover.
- Our position: Do not log trees over 80 years old and designate any existing blocks of forest with trees over 120 years as “Designated Old Growth” under the Forest Plan.
Recreational opportunity: Jellico contains over 19,000 acres of the National Forest, yet is without a single recreational trail.
- Our position: Work with the community and user groups to assess what types of recreation are compatible and desired in the Jellicos, and develop a plan. There are local, regional, and national efforts underway to work toward the transition of National Forests into National Parks, Monuments, and Recreational Areas. Kentucky Heartwood is currently assessing the vision that makes the most sense for Kentucky, but we know we cannot continue with “business as usual.”
Invasive species: Many areas of these mountains that were logged in the 1980s and 1990s are now overrun with the invasive Tree of Heaven (Ailanthus altissima), which is also abundant along forest roadsides. These uncontrolled infestations demonstrate that the Forest Service is already doing an inadequate job controlling the invasive species..Opening the tree canopy with logging will only worsen the growth of these species.
- Our position: The Forest Service should address the existing invasive species that are out of control before proposing new logging projects that will worsen the existing situation.
Lack of details: The project includes 256 stands (groupings) of forest proposed for logging across nearly 10,000 acres in McCreary and Whitley counties. But enough specific information has not been provided about how and when these stands will be cut. This includes what types of logging equipment will be allowed in which areas, where and how logging roads will be built, and how cutting will be distributed across the landscape over the 40-year implementation period.
- Our position: The Forest Service needs to disclose and analyze these and other details in an Environmental Assessment. This is required by the National Environmental Protection Act (NEPA) so that the public can provide meaningful input and the Forest Service can properly evaluate the impacts of the project before making a final decision.
40-year timeframe: The 40-year timeframe for implementing the project presents fundamental flaws in analyzing the project’s impacts and is not compliant with either the National Environmental Policy Act (NEPA) or the National Forest Management Act (NFMA). There is simply no rational way to informed decisions today that approve logging specific areas 20, 30, or even 40 years from now.
- Our position: Planning and implementation horizons for projects on the DBNF, including the Jellico Project, should not extend more than 10 years. The current Forest Plan for the DBNF is out of date, and is not aligned with modern Forest Plan requirements. No new projects should be proposed until the DBNF updates their Forest Plan to adhere to the 2012 Planning Rule. Moreover, the Jellico project is intended to implement an outdated 2004 Forest Plan (the management plan for the DBNF), which was written to guide forest management for “10 to 15 years.” Not only is the forest plan outdated, it was also developed under the 1983 Forest Planning regulations, which were revised in 2012 to shift away from agricultural, “rotational” wood production systems (like what’s proposed in the Jellico project) and toward a more contemporary understanding of sustainability and ecosystem integrity. Even if Jellico is approved, the project will have to be substantially revised when the Forest Service finally develops a new Forest Plan, making the current efforts a waste of public funds.
Road construction: Logging roads bulldoze the existing vegetation, disrupt the soil, and increase landslides and erosion. This project allows the Forest Service to construct unlimited miles of logging and skid roads anywhere in the project area, and specific information on the location of roads is not provided.
- Our position: Under NEPA, the Forest Service is required to disclose where they plan to build these roads before they complete their environmental analysis. They need to do this in order to evaluate how the roads will impact the biodiversity of the mountains and the lives and property of local residents. Road construction should be used sparingly, if at all, and never on steep and unstable slopes.
Loss of mature forests and climate impacts: Mature forests continue to draw down greenhouse gasses as they grow older, contrary to outdated forest models still promoted by the Forest Service and wood products industry. And while young trees can grow quickly, logging results in an overall net release of greenhouse gasses to the atmosphere over many decades to come. While some wood products serve as long-term greenhouse gas storage, logging releases large amounts of greenhouse gasses through milling and mill waste, transportation, soil disturbance, decomposition of slash (tree tops and branches), and other mechanisms. Those greenhouse gasses take decades or longer to be captured again by new tree growth – time we don’t have given current climate models and trajectories.
The Jellico project will result in major greenhouse gas emissions that will not be offset by growth during the life of the project. In spite of President Biden’s executive order to inventory and prioritize the preservation of old growth, the Forest Service is still proposing to log trees over 200 years old. Meanwhile, in other Forest Service districts, they are reconsidering decisions that conflict with recent directives on conservation of mature and old-growth forests for climate change. Daniel Boone National Forest should follow suit.
INTERACTIVE MAP OF JELLICO PROJECT
You can navigate this map on a touchscreen by panning with a single finger and changing the view angle and zoom with two fingers. To navigate on a desktop, use the cross icon to pan and the rotating arrow icon to change the view angle.
Interactive map created by staff ecologist, Jim Scheff using data from the U.S. Forest Service
KENTUCKY HEARTWOOD’S ORGANIZATIONAL COMMENT
Comment attachments and references directly below.
White Nose Bat
Southern Environmental Law Center Comments on Jellico
About Kentucky Heartwood
Kentucky Heartwood remains committed to providing a thorough analysis of proposed agency actions using the best available science and the law. Protecting and restoring biological integrity to the Daniel Boone National Forest guides our efforts. To make sure that you stay up to date on the progress of this project, be sure to sign up for our emails here.
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