Organizational Comments worth reading
Click the blue title for full comment
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"A nonprofit organization dedicated to protecting Kentucky's natural resources, environment, and communities. KRC submits these comments on behalf of the organization and its members and constituents who live, work, drink water from, and recreate in areas potentially impacted by this permit."
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"The Kentucky Herbalism Alliance (KHA) is an organization that seeks to educate its members and the public on the ethical and responsible stewardship and clinical use of medicinal plants. KHA is first and foremost an organization that holds plants and their ecosystems in the highest regard."
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"We need to preserve our oldest trees, not cut them down. Mature trees are critical in the fight against climate change and logging them would destroy this forest ecosystem."
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"The draft EA and its supporting materials suffer from systemic internal contradictions, resulting in abundant inaccurate, nonsensical, and patently self-contradictory statements of “fact” provided throughout. This problem renders the draft EA (when combined with its supporting documents) so difficult to make sense of that it precludes meaningful public review."
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"We are greatly concerned about both the sheer scale of this project and a timeframe that long exceeds the careers of any of the staff. A 40-year project covering 10,000 acres is new in the agency, all the more concerning with the way in which the process has unfolded in the last few years, with poor communication with the public and sometimes inadequate information. To be frank, a project that is essentially three times the lifespan of a nominal forest-wide Land Resources Management Plan (LRMP) would call for an Environmental Impact Statement (EIS), rather than an Environmental Analysis (EA)."
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"A 10,000 acre plan spanning 40 years is not manageable. The planners today will be long gone over 40 years and the project fails to account for emerging needs, long range ecological concerns and new silviculture knowledge and techniques that will certainly be developed. We prefer the No Action Alternative at this time with explicit attention to Tree of Heaven (Ailanthus) eradication as routine maintenance."
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"Old-growth stand conditions appear to have been inaccurately determined. Insofar as age is the primary determinant of old-growth forest conditions in your neck of the woods, it is critical that tree age be measured accurately. In the Jellico IRMS Virtual Field Trip, silviculturist John Hull explains how he used an increment borer to measure tree age. According to Mr. Hull, a tree's age equals the number of rings from a core sampled at a height of 4.5 feet above the ground. However, that's simply not true."
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"There is sufficient peer reviewed literature available to the US Forest Service (USFS) concerning the biological and climate crisis that we find ourselves in. I would hope that the USFS recognizes that we are in fact in a crisis and that we need to take appropriate rapid actions. However, projects such as the JVMP are out of step with current science concerning forest management."
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"We are strong advocates for national protection of mature and old-growth forests. Old-growth and mature forests are our first line of defense against the impacts of climate change. They capture and store atmospheric carbon, helping to alleviate the climate crisis. These large trees play a vital role in restoring our planet's health. It is in our national interest to take action to preserve these old-growth forests and trees."
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"Honey bees and native pollinators are declining due to a cocktail of pesticides, invasive species and habitat loss. The plans put forth by the Forest Service will further contribute to these problems when there are existing workable solutions that the Forest Service should take and incorporate into all their plans."
Our "Quick-ish" Take:
A 40-year logging proposal is absurd. Making legally binding, site-specific decisions 40 years in advance is grossly irresponsible, especially considering the entire Daniel Boone National Forest Management Plan is supposed to be revised every 10 to 15 years. Imagine if we were currently logging in 2024 based on a logging project that was approved in 1987, based on a Forest Management Plan that was implemented in 1967? This is bad management!
While Alternative 1 is the “least bad” logging option, it isn’t good! 3,000 acres is still a significant amount of logging that could worsen landslide risks and habitat impacts.
We encourage folks to make comments that criticize the Proposed Action as irresponsible. We encourage folks to make comments that criticize the Proposed Action as irresponsible. Please check out our Deep Dive for a detailed explanation of the proposal and Examples of Comments for ideas on how to craft your comment.
We encourage you to focus your comments on:
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Timber targets
The Forest Service is cutting our older forests because they are incentivized to do so with volume-based timber targets.
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Logging of mature and old-growth forests
The Forest Service is proposing regeneration cuts (heavy logging like clearcuts and shelterwood) is especially concerning given the important role mature and old forests play in mitigating climate change (as indicated in Biden’s Executive Order to conserve mature and old-growth forests).
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Interior Forests, cerulean warblers, and bats
The Forest Plan calls for a 7,400-acre area of mature and interior forest in the Jellicos for cerulean warblers, and the Draft Environmental Assessment makes no mention of it. However, the birds are there! We have recordings of them singing in the project area. This type of habitat is also necessary for several endangered bat species that are present in the project area.
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Landslide risks
The Jellico mountains are some of the steepest and most landslide-prone mountains in the state. The Forest Service’s analysis does not look at the most relevant issues related to landslide risk. This is such an important topic that Kentucky Heartwood has hired a geologist to analyze the proposal. We will incorporate their recommendations into our comment letter.
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Invasive species
The Draft EA downplays the extent to which tree of heaven is rampant in the Jellicos, with large infestations (from places that the Forest Service logged in the 1990s) that risk getting worse with logging. To make matters worse, tree of heaven can cause populations of spotted lanternfly to increase, impacting neighboring native species as well as agriculturally important trees.
Example comments available below. Copy or recycle these suggestions to make your own, unique comment.
The Deep Dive:
We recently learned through Freedom of Information Act documents associated with a lawsuit from the Southern Environmental Law Center that the Forest Service has mandated timber targets that include a more than 400% increase in logging in the Daniel Boone National Forest (DNBF) in the last 20 years. The documents clearly show that the DBNF is prioritizing the timber harvest mandate over other forest needs, including recreation, forest health, water quality, and more. To make matters worse, meeting these timber targets is directly tied to performance reviews of DBNF staff!
In forestry, timber volume is often expressed in terms of board feet, cubic feet, or cubic meters, depending on the region and specific measurement practices.
For example, "CCF" represents "hundred cubic feet," per the Daniel Boone National Forest Forest Management Plan, Appendix A, Page A-44 This means a volume of wood equal to 100 cubic feet.
For example, a document titled “Daniel Boone NF Timber Sale Schedule Expectations” includes volumes and acreages expected by the District from 2017 through 2026 states [1]
PERFORMANCE – This schedule is used as a performance element for line officers, IDT members, and others.
This document assigns a goal of 6,300 CCF to be sold from the Stearns District annually. [2] By our rough estimate, this is over 350,000 trees annually.
Another document titled “DBNF SALES PROGRAM” prescribes an annual harvest volume for the Stearns District of 7,500 CCF through at least fiscal year 2028. [3]
![FOIA [1] & [2], 2024-FS-R8-00752](https://e3caiphmd3c.exactdn.com/wp-content/uploads/2024/05/FOIA-1.jpg?strip=all&lossy=1&sharp=1&ssl=1)
![FOIA [2] 2024-FS-R8-00752](https://e3caiphmd3c.exactdn.com/wp-content/uploads/2024/05/FOIA-2_additional-1.jpg?strip=all&lossy=1&sharp=1&ssl=1 "FOIA [2]_additional")
![FOIA [2] 2024-FS-R8-00752](https://e3caiphmd3c.exactdn.com/wp-content/uploads/2024/05/FOIA-2_correct.jpg?strip=all&lossy=1&sharp=1&ssl=1 "FOIA [2]_correct")
![FOIA [3] 2024-FS-R8-00752](https://e3caiphmd3c.exactdn.com/wp-content/uploads/2024/05/FOIA-3_Jellico.jpg?strip=all&lossy=1&sharp=1&ssl=1 "FOIA [3]_Jellico")
Considering this information, it is no surprise that the Jellico proposal is so aggressive. It is clear that the DBNF is operating under an accelerated timber program with harvest volume quotas tied directly to job performance reviews.
This skews the ability of the agency to formulate, analyze, and modify any timber harvest proposal for the Jellico project area in a manner that responds to community or environmental concerns.
Kellett, Michael J., Joan E. Maloof, Susan A. Masino, Lee E. Frelich, Edward K. Faison, Sunshine L. Brosi, and David R. Foster. "Forest-clearing to create early-successional habitats: questionable benefits, significant costs." Frontiers in Forests and Global Change 5 (2023): 1073677.
Most of the project area is mature forest. We are conducting field work the third week of May to inspect stands that we suspect may be older than what the Forest Service has reported. We will update this section as we learn more.
In addition, President Biden issued an Executive Order to conserve mature and old-growth forests, and this project seems to fly in the face of that. Here is more information on the Executive order along with talking points from the Climate Forest Campaign.
As mention above in timber targets, we are concerned these mandates conflict with the best available science when it comes to clearcutting and forest extraction. Kellett (2023) brings some of our biggest concerns to to life saying,
"A campaign is underway to clear established forests and expand early successional habitats—also called young forest, pre-forest, early seral, or open habitats—with the intention of benefitting specific species. Coordinated by federal and state wildlife agencies, and funded with public money, public land managers work closely with hunting and forestry interests, conservation organizations, land trusts, and private landowners toward this goal. While forest-clearing has become a major focus in the Northeast and Upper Great Lakes regions of the U.S., far less attention is given to protecting and recovering old-forest ecosystems, the dominant land cover in these regions before European settlement. Herein we provide a discussion of early successional habitat programs and policies in terms of their origins, in the context of historical baselines, with respect to species’ ranges and abundance, and as they relate to carbon accumulation and ecosystem integrity. Taken together, and in the face of urgent global crises in climate, biodiversity, and human health, we conclude that public land forest and wildlife management programs must be reevaluated to balance the prioritization and funding of early-successional habitat with strong and lasting protection for old growth and mature forests, and, going forward, must ensure far more robust, unbiased, and ongoing monitoring and evaluation."
Forest wide Objective 1.1.B in the Forest Plan directs the Forest Service to “Create and maintain at least one approximately 7,400-acre area of cerulean warbler habitat in the Licking River Management Area, Upper Kentucky River Management Area, and the Jellico Mountains of the Cumberland River Management Area.” Specifically, it states that each 7,400-acre area be “composed of tracts at least 618 acres in size connected by corridors of either upland hardwood forest or riparian areas.
Upland hardwood forest corridors should be no more than two miles long, and at least ¼-mile wide…Contiguous is defined as having no more than 5 percent of the area in grassy openings, regenerating forest with less than 40 BA canopy, or roads greater than 50 ft. in width; tracts may be composed of blocks of minimum 618 acres in size connected by upland hardwood corridors approximately 0.25 mile wide or riparian corridors at least 100 ft. wide, neither of which is more than 2 miles long.”
The Draft EA makes no mention of Forest wide Objective 1.1.B., nor does it describe how the Proposed Action or Alternative 1 will help or hinder meeting this Objective. The Forest Service cannot simply brush aside this forest wide direction without substantial analysis and robust reasoning as to why it can be ignored.
![[1] BE/Wildlife Report Table 10 (p 63)](https://e3caiphmd3c.exactdn.com/wp-content/uploads/2024/05/table-10-cerulean-.png?strip=all&lossy=1&sharp=1&ssl=1)
![[2] BE/Wildlife Report Table 11 (p 65)](https://e3caiphmd3c.exactdn.com/wp-content/uploads/2024/05/table-11-cerulean.png?strip=all&lossy=1&sharp=1&ssl=1 "table 11 cerulean")
![[3] BE/Wildlife Report Table 12 (p 68)](https://e3caiphmd3c.exactdn.com/wp-content/uploads/2024/05/table-12-cerulean.png?strip=all&lossy=1&sharp=1&ssl=1 "table 12 cerulean")
The Biological Evaluation includes a brief discussion of Cerulean warbler (Dendroica caerulea) as Management Indicator Species (MIS) for “Closed Canopy, Mature Forest Species.”[1] The information that is included in this section of the report is confusing and misleading. For example, the report argues that approximately 5,200 acres of clearcut or near clearcut logging in the Proposed Action (which removes suitable habitat for the Cerulean warbler) will result in nearly three times as much suitable habitat as Alternative 1, which would approve shelterwood (nearly a clearcut) on 1,122 acres.
Table 11 [2] in the report states for “Proposed Action-Current” that “4,301 ac of potentially suitable habitat is widespread in the Proposed Action Area,” and anticipates “3,425 ac of potentially suitable habitat widespread in the proposed Action Area” following implementation of the Proposed Action.
But Table 12 [3], presenting information for Alternative 1, states that “1,311 ac of potentially suitable habitat is widespread in Alternative 1 Action Area,” and “1,173 ac of widespread potentially suitable habitat is anticipated” following implementation.
It is unclear how the current acres of suitable habitat could be both 4,301 acres and 1,311 acres. And while the differing temporal frames for the Proposed Action and Alternative 1 make projections complicated, it does not make sense to argue that cutting nearly all trees on 5,200 acres would result in more closed canopy, mature forest habitats than if the project was reduced to 1,122 acres.
A report by Wood et al (2013) for the American Bird Conservancy [4] explains that:
Ceruleans favor the complex canopy structure characteristic of unevenaged stands and old growth forest. Canopy gaps allow mid- and uppercanopy trees the growing space to form long horizontal branches and develop dense foliage. Tree species composition is relatively diverse with shade-intolerant species abundant in the overstory.
The authors add that Cerulean warblers “preferentially use canopy gaps ~400-1000 ft2 in size” and highlight the importance of grapevines, stating that “Cerulean nest success was positively associated with density of grapevines (Vitis spp.) in Ohio.” (emphasis added)
Forests in the Jellico mountains have a notable amount of very large grapevine. The Proposed Action proposes to use herbicides to control grapevine on “up to a total project acreage of 9,537 acres.”
The Report goes on to describe the Cooperative Cerulean Warbler Forest Management Project (CWFMP) which implemented a series of studies in Tennessee, Ohio, Kentucky, and West Virginia. Nest success was highest in unharvested controls, and next highest in the medium harvest treatment. For management considerations, the report states that “The results from the CWFMP indicate that retaining levels of ~40-90 ft2/acre after harvesting trees in 25 acre harvest units in oak-dominated stands creates a forest structure that is generally favorable for ceruleans.”
Contemporary research demonstrates that cerulean warblers benefit from intermediate disturbance in mature forests with large trees. While they can, and do, use forests subject to “heavy” logging treatments, these habitats are less than optimal.
The shelterwood prescriptions proposed in the Jellico project exceed the amount of harvest applied in the “heavy” treatments in the available literature. It is worth noting that “APPENDIX A. Cerulean Warbler Technical Group Forest Management Research Project Treatment Implementation Guidelines, May 3, 2005” in Hartman (2006) [5] states:
Intermediate Treatment: Between July 15, 2006 and April 1, 2007 this stand should be harvested by removing enough of the overstory to leave approximately 55 sqft BA/acre (12.6 m2/ha). The removal should be conducted such that the residual stand is comprised almost entirely of well-spaced dominants and co-dominants.
All other commercial stems (i.e., > 6” DBH) should be felled. The marking objective should be designed to roughly mimic a shelterwood harvest as commonly practiced in the region in question.
The recurring use of “shelterwood” by the Daniel Boone National Forest to describe harvests that remove substantially more timber than is typical under this terminology continually creates confusions and misapplication of research regarding the effects of “shelterwood” harvests on species and habitats.
[4] Wood, P.B., J. Sheehan, P. Keyser, D. Buehler, J. Larkin, A. Rodewald, S. Stoleson, T.B., Wigley, J. Mizel, T. Boves, G. George, M. Bakermans, T. Beachy, A. Evans, M. McDermott, F. Newell, K. Perkins, and M. White. 2013. Management guidelines for enhancing Cerulean Warbler breeding habitat in Appalachian hardwood forests. American Bird Conservancy. The Plains, Virginia. 28 pp.
[5] Hartman, Patricia J., "HABITAT SELECTION OF THE CERULEAN WARBLER IN EASTERN KENTUCKY" (2006). University of Kentucky Master's Theses. Paper 285.
Kentucky Heartwood raised concerns regarding landslides and slope stability in our scoping comments. “Slope instability and landslides are an ongoing concern in the Jellicos. The combination of steep slopes, highly erodible soils, and the hydrologic properties of coal seams predispose the landscape to mass wasting events. Road construction (including skid roads) and timber harvest can substantially increase the likelihood of a mass wasting event to occur.” [1A]
The Draft EA and associated Soils report purport to address this issue, but fall far short of what is necessary to make reasonably informed, site-specific decisions that will protect soil and water resources as the Jellico project is implemented. Landslides and other forms of mass wasting could significantly impact soil and water resources in the project area, including federally-listed aquatic species and designated critical habitat.
The recent report, “Flood Resilience in Appalachia: Policy Recommendations” [2A] (2024) states:
The American Communities Project has stated that “Appalachia is ground zero for rainfall,” the risk of increasingly extreme rainfall is particularly high for Kentucky, West Virginia, and Ohio. New precipitation frequency modeling by researchers at First Street Foundation found that extreme events (e.g. 1-in-100 year flood events) are likely to occur much more frequently than every 100 years, especially for the Ohio River Basin.
But rather than a futuristic scenario, these extreme rainfall and flooding events are already affecting our region. Over the last decade (2013 - 2023), there have been nearly 20 federally declared flooding disasters across Kentucky, Pennsylvania, Virginia, West Virginia, Tennessee and Ohio. The majority have occurred in Kentucky and West Virginia, often also affecting parts of Virginia. Total Federal Emergency Management Agency (FEMA) spending on these events totals nearly $1 billion and at least 230 lives have been lost due to flash flooding.
[1A] Kentucky Heartwood scoping comments, p19
[2A] “Flood Resilience in Appalachia: Policy Recommendations” (2024)
Daniel Boone National Forest lands in the Jellico project area represent a critical headwaters area that directly affects many families and landowners in the immediate vicinity - and many more downstream. The extent to which the Forest Service has, and continues, to downplay or ignore the relationship between logging and landslides, as well as overall flood risks, has gone well beyond any disagreements about science, methods, or even risk assessment.
To expand on our previously voiced concerns, and respond to the Draft EA specifically, we partnered with geological and geohazards consultant Bill Haneberg to provide additional expert analysis. Dr. Haneberg was state geologist and Director of the Kentucky Geological Survey from 2016 through 2023 and is a nationally-recognized expert in landslide-related issues with specific expertise in landslide hazards in eastern Kentucky.
The first document, “Recommended Best Management Practices to Minimize the Likelihood of Sediment Delivery to Streams by Logging Induced Landslides in Eastern Kentucky,” is included as Appendix A.
This document was prepared for the Appalachian Citizen’s Law Center, Kentucky Heartwood, and the National Wildlife Federation as part of an effort to inform federal flood policy in Appalachia in an era of climate change. Dr. Haneberg’s report describes the various factors affecting landslides and landslide susceptibility in eastern Kentucky, focusing on how logging and logging-related practices can significantly destabilize slopes for years, decades, or longer.
Many of the issues raised by Dr. Hanberg reflect information that Kentucky Heartwood previously provided to the Forest Service during the Jellico project analysis and, more extensively, through our various comments, letters, and litigation over the South Red Bird project.
The report also includes recommended Best Management Practices (BMPs) aimed at reducing the risk of landslides, including specific analytical methods relevant to land management planning. The Forest Service needs to incorporate the science and methodology and adopt the recommended BMPs into the Jellico analysis and any final approved action.
The second document prepared by Dr. Haneberg is “Review of the Daniel Boone National Forest “Jellico Vegetation Management Plan Project Soil Effects Analysis” Document.”
This review was prepared under contract for Kentucky Heartwood. Included below is the “Summary Comments” portion of Dr. Haneberg’s review. The entire review and Dr. Haneberg’s comments are incorporated in full as Appendix B.
Kentucky Heartwood described in detail issues with tree of heaven (Ailanthus altissima) in our scoping comments for the Jellico project. Tree of Heaven is a highly invasive, ecologically destructive non-native invasive plant species (NNIP), and its occurrence in the Jellico project area is extensive. As we previously described, in addition to its occurrence along roadsides, we have seen numerous stands that were logged in the 1980s or 1990s where tree of heaven represents a significant component of the forest canopy. In some locations, it is a dominant species. This is a pattern widespread across all portions of the project area.
The Forest Service’s failure to engage in responsible stewardship of these stands during the decades since they were logged has allowed tree of heaven to reach reproductive maturity and produce vast amounts of seed to further infest the forest.
The Vegetation Report downplays the impact that tree of heaven is having on the Jellicos, and does not acknowledge that it’s found in previously logged areas. The Biological Evaluation and Specialist’s Report provides a better discussion of tree of heaven specifically, as well as other problematic NNIPs, stating:
(T)hinning and regeneration activities are likely to increase the population sizes of tree-of-heaven, princess tree and Amur honeysuckle if existing individuals are not treated during or prior to activities. These three species have a high potential to interfere with tree regeneration.
Concerns about the spotted lanternfly (Lycorma delicatula) have become more pressing after it became documented in Kentucky in October 2023. Tree of heaven is its primary host species. Spotted lanternfly will preferentially feed on tree of heaven, and may induce declines in the species. But tree of heaven also attracts spotted lanternfly to forested areas where it also impacts native species. Reproductive success of spotted lanternfly facilitated by the abundance of tree of heaven is likely to cause a population explosion that will increase pressure on native tree species throughout the project area. Controlling tree of heaven at a landscape scale, and rapidly, is arguably the most pressing forest health issue affecting the Jellico project area at this time.
The Draft EA and BE describe how NNIPs, including tree of heaven, will be treated as part of other management actions, especially commercial timber harvest. The BE states:
Nonnative invasive plants in the general project area would likely respond to the disturbance with increase of current population sizes and increased establishment of new populations. At the same time, for some species such as tree-of-heaven, princess tree, Amur honeysuckle, multiflora rose, and Japanese honeysuckle, increased extent of management activities would make treatment easier by improving detection of and increasing access to interior populations.
However, the BE also states that Alternative 1, with a reduction in harvest acres, would result in fewer acres of tree of heaven and other NNIPs being treated.
As a more limited area will be affected by management activities, infestations are likely to be missed allowing them to continue producing propagules (p. 77).
For Alternative 2- No Action, the BE states that the lack of timber harvest may result in reduced spread of tree of heaven (and princess tree) but also allow for “These species (to) continue to produce and disperse seed throughout the general area increasing population size and difficulty to control" (p.77).
The project area includes a substantial portion of the designated critical habitat for the federally endangered Cumberland darter (Etheostoma susanae) as well as habitat for the federally threatened blackside dace (Chrosomus cumberlandensis). As their names imply, they are found only in high quality streams of Cumberland plateau, making them biological jewels of Kentucky.
Specifically, USFWS states regarding the blackside dace that “current land use practices (e.g., agriculture, residential development, logging, and surface coal mining) continue to influence sediment and water discharges into streams.” [7]
[7] U.S. Fish and Wildlife Service (2022) Blackside Dace, Phoxinus cumberlandensis (= Chrosomus cumberlandensis), 5-Year Review: Summary and Evaluation. Frankfort, Kentucky.
[8] Gray, B. Griffin, C (2022) Kentucky is getting wetter as climate change brings an era of extremes, data shows. Courier Journal
[9] Watters, G.T. and S.H. O'Dee (2001) Patterns of vertical migration in freshwater mussels (Bivalvia: Unionoida). Journal of Freshwater Ecology 16:541-549.
Record-breaking rains, including the 16 inches that fell on July 30th, 2022, have resulted in major landslide events and erosion on steep slopes, and have impacted streams through increased sedimentation. [8] As will be discussed in our section on slope instability and landslide concerns, the Forest Plan and Kentucky forestry BMPs are inadequate for preventing harm to the aquatic endangered species from extensive logging in the Jellico project area.
The Forest Service has a proactive duty to work toward the recovery of these species.
A delicate population of a federally-listed endangered mussel, the Cumberland Elktoe (Alasmidonta atropurpurea), has also been identified in Jellico Creek. [9] This is one of several populations which the USFWS describes as likely having low resiliency due to small and isolated population. One of the threats to this mussel species is excessive sedimentation from resource extraction. No comprehensive surveys have been conducted in Jellico Creek since 2005, making a full survey of the area absolutely necessary before logging.
The Jellico project area provides habitat for Indiana bats (Myotis sodalis)and Northern long eared bats (Myotis septentrionalis), both of which are listed as endangered under the Endangered Species Act (ESA). Tricolored bats (Perimyotis subflavus) are also in the project area and are proposed for listing under the Endangered Species Act.
These bats rely on large tracts of mature and interior forest for roosting, foraging, and raising young. Divoll et al. (2022) [10] state that:
Both M. sodalis and M. septentrionalis are more likely to occur in closed canopy forest (Ford et al., 2005) and thus may respond negatively to large regeneration harvests (e.g., as predicted by Loeb, 2020); however, they may respond positively to fine-scale disturbances within larger forest patches (e.g., Loeb and O’Keefe, 2006).
Northern long-eared bats display little tolerance for disturbance. Arant (2020) [11], researching bats and habitat use in southeastern Kentucky, found that northern long-eared bats avoided areas following harvest, stating
“The lack of activity of these bats in harvests, however, suggests they do not actively forage within cuts” (Arant at 71; See also Figure 18 at 46; Table 3 at 48; Figure 19 at 58).
Arant hypothesized that Myotis species avoided large openings in response to prey availability and exposure to predators. Divoll (2022) found that northern long-eared bats utilized lightly-thinned forest and small patch cuts (0.8 – 4.4 ha, or 2 – 10.8 ac) in a mature forest matrix, but generally avoided large clearcuts.
The scale, intensity, and distribution of regeneration cuts proposed in the Jellico project could lead to significant impacts to endangered bats.
[10] Timothy J. Divoll, Stephen P. Aldrich, G. Scott Haulton, Joy M. O'Keefe (2022), Endangered Myotis bats forage in regeneration openings in a managed forest, Forest Ecology and Management, Volume 503
[11] Arant, Phil (2020). Effects of Shelterwood and Patch Cut harvests on a Post White-Nose Syndrome Bat Community in the Cumberland Plateau in Eastern Kentucky. University of Kentucky College of Agriculture, Food, and Environment.
The Forest Service needs to commit to a concerted effort across the Jellico project area to treat and control tree of heaven. This includes all areas, regardless of planned timber harvest or other management. The EA and associated documents describe a situation where the only way that the Forest Service will commit to addressing this exceptional forest health issue is if it is paired with commercial timber management, with fewer commercial sales meaning less control of tree of heaven, and no commercial sales meaning that the Forest Service just won’t bother with it.
This is irresponsible.
The Draft EA contains hundreds of pages of information, and our comments are numerous. If you are looking for specific details or have questions about any piece of it, please feel free to contact us via info@kyheartwood.org.
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Join the local community in voicing opposition to Forest Service’s ten thousand acre Jellico Mountain logging project.
Dear Friends! We want to tell you about an opportunity to make a positive impact. The Jellico Vegetation Management Project is a massive logging project that the Forest Service announced…
Sample Comments:
COMMENT PERIOD CLOSED! Check back for more details as we learn more about the next phase of this project.
Timber Targets
- YOU SAY: "As part of the NEPA process, it's essential to highlight my opposition to the Forest Service's indiscriminate cutting of older forests driven by volume-based timber targets. Older forests are vital for biodiversity, carbon sequestration, and habitat preservation."
- YOU SAY: "It's concerning that the Forest Service is placing the timber volume mandate above other critical forest needs like recreation, forest health, and water quality. By prioritizing timber targets, the agency risks undermining the overall well-being of our forests and the communities that rely on them."
- YOU SAY: "Linking timber targets to performance reviews of Forest Service staff further exacerbates extraction from public land, potentially incentivizing actions that prioritize short-term gains over long-term sustainability. It's crucial for decision-makers to recognize the multifaceted importance of our forests and ensure that management practices align with broader conservation goals outlined in President Biden's Executive Order aimed at preserving mature and old-growth forests."
Landslide Risks
- YOU SAY: "The Forest Service's analysis of landslide risks in the Jellico Mountains does not address the most relevant issues related to this significant hazard. Given the steep and landslide-prone nature of these mountains, it's crucial for comprehensive assessments to be conducted. I urge the Forest Service to take a deeper look at the landslide risks and the serious issues raised by Kentucky Heartwood. By prioritizing thorough analysis and incorporating additional expert guidance, we can better safeguard against landslide risks and ensure the safety and stability of the Jellico mountains and surrounding areas."
Logging of Mature and Old Growth Forests
- YOU SAY: "Regeneration cuts, such as clearcuts and shelterwood logging, in mature and old-growth forests has no place in the Jellico Mountains. These practices pose a significant threat to the crucial role mature and old growth forests play in mitigating climate change, as emphasized in President Biden's Executive Order."
- YOU SAY: "The best available climate science unequivocally demonstrates the importance of mature and old-growth forests for climate change mitigation. These forests act as essential carbon sinks, helping to absorb and store significant amounts of carbon dioxide from the atmosphere. By acknowledging this science, the USFS should align its practices with broader conservation objectives and contribute meaningfully to climate action efforts. "
Cerulean Warblers, Bats, Darters, OH MY
- YOU SAY: "It's imperative that the Forest Service adheres to the Forest Plan and provides a clear explanation of how they intend to maintain the 7,400 acres of habitat required by Cerulean Warblers in the Jellicos. These habitats are essential for the survival and well-being of these species, and it's critical that they are preserved and protected."
- YOU SAY: "By removing regeneration cuts from the project scope and focusing on critical Cerulean Warbler habitat, as mentioned in Objective 1.1.B of the Forest Plan, the Forest Service can demonstrate its commitment to conservation and the broader goals of preserving biodiversity and ecosystem health."
- YOU SAY: "I strongly support the protection of the bats in the Jellico project area. This region is a critical habitat for the Indiana bat (Myotis sodalis) and the Northern long-eared bat (Myotis septentrionalis), both of which are endangered under the Endangered Species Act (ESA). Additionally, the Tricolored bat (Perimyotis subflavus), which is proposed for listing under the ESA, also resides in this area. Preserving their habitat is essential for the survival and recovery of these vulnerable species."
- YOU SAY: "I URGE the FS to prioritize the protection of endangered and threatened species within the Jellico project area. This region includes a substantial portion of the designated critical habitat for the federally endangered Cumberland darter (Etheostoma susanae) and habitat for the federally threatened blackside dace (Chrosomus cumberlandensis). These species are found only in the high-quality streams of the Cumberland Plateau, making them biological jewels of Kentucky. The U.S. Fish and Wildlife Service has highlighted that current land use practices, such as agriculture, residential development, logging, and surface coal mining, continue to impact sediment and water discharges into streams, further threatening the habitat of the blackside dace. It is crucial to protect these habitats to ensure the survival and recovery of these unique and vulnerable species. "
- YOU SAY: "A delicate population of a federally-listed endangered mussel, the Cumberland Elktoe (Alasmidonta atropurpurea), has been identified in Jellico Creek. This is one of several populations which the US Fish and Wildlife Service describes as likely having low resiliency due to its small and isolated population. One of the threats to this mussel species is excessive sedimentation from resource extraction. No comprehensive surveys have been conducted in Jellico Creek since 2005, making a full survey of the area absolutely necessary before logging. Please make this survey a requirement in the next phase of this proposal. "
Invasive Species
- YOU SAY: "The Draft EA's analysis of the rampant Tree of Heaven infestation in the Jellicos is grossly understated. Large infestations, particularly stemming from areas previously logged by the Forest Service in the 1990s, pose a significant risk of spread with the proposed logging activities."
- YOU SAY: "The potential for Tree of Heaven to foster explosive populations of the spotted lanternfly is alarming, as it can have detrimental effects on neighboring native species and agriculturally important trees, like fruit trees. Regardless of the which proposed action is selected, Tree of Heaven needs to be treated and maintained. The original proposed action addressed a large invasive issue and should not be dismissed regardless of timber volume extracted."