Up to four-thousand acres of logging in London District of the Daniel Boone National Forest
Official documents for the Pine Creek Forest Restoration project can be found on the Daniel Boone National Forest website.
Kentucky Heartwood Challenges Pine Creek Project
Posted 11-30-19
On November 14, 2019, Kentucky Heartwood filed a formal administrative objection (“pre-decisional objection”) challenging the approval of the Pine Creek Forest Restoration Project on the Daniel Boone National Forest. The Pine Creek Forest Restoration Project (“Pine Creek project”) proposes a wide range of vegetation management activities across 45,700 acres of the Daniel Boone National Forest in Laurel, Rockcastle, and Pulaski Counties, Kentucky.This complicated project has the potential to benefit some parts of forest by implementing well-thought-out restoration efforts, while degrading other areas through heavy-handed and unneeded logging operations. The Pine Creek project was originally proposed in March, 2018.
Kentucky Heartwood was joined in their objection by the Kentucky Resources Council, and Christopher Morris. KRC has also posted the objection on their website here.
Read the entirety of Kentucky Heartwood’s formal administrative objection here.
Background
The Pine Creek project covers 45,700 acres of the Daniel Boone National Forest in Laurel, Pulaski, and Rockcastle counties. The area is centered on the lower Rockcastle River, from near I-75 to the confluence with the Cumberland River. This area includes some of the most popular recreation spots in the Daniel Boone, including Bee Rock, Rockcastle Recreation Area, Little Lick, Scuttle Hole, the Sheltowee Trace National Recreation Trail, Pine Island Double Falls, and the Wild River segment of the Rockcastle River. The area also includes a wide diversity of forest types and rare species, including some of the best old-growth and mature second growth forests in the Daniel Boone. The Forest Service first proposed the Pine Creek project in February 2018. Since the initial proposal the agency has made some improvements, but there are still major problems.
Summary of our original concerns with the project
The Bad Stuff:
Shelterwood logging on 1,300 acres for early seral habitat
Our most significant concern with the Pine Creek project is the Forest Service’s intent to log 1,300 acres for early seral habitat (young forest) using shelterwood methods (Action 1.A: Two-aged shelterwood). A shelterwood cut is a type of “regeneration” harvest where about 90% of the trees are cut. The Forest Service says that individual shelterwood cuts would be limited to 40 acres each, but some of these logging areas would be clustered to create logged areas of several hundred acres. The Forest Service originally proposed to approve an additional 2,000 acres of shelterwood harvests that would occur after 10 years (in stands managed under Action 5: Midstory removal), but has since agreed to drop logging these acres from the proposal.
Early seral habitat is important for a wide range of species. However, there are less impactful ways to create and manage for this type of habitat that are more consistent with prevalent natural disturbance regimes. For example, research from the University of Kentucky has shown that logging small, roughly half-acre patches of trees, along with light thinning around the edges (also known as “femelschlag” or “expanding gap” systems), can result in much better oak regeneration than large even-aged harvests like those proposed in the Pine Creek project. While uneven-aged and lower impact methods like expanding gap management could meet the Forest Service’s habitat and multiple-use goals, these methods don’t produce as much timber.
We strenuously urge the Forest Service to drop the proposed shelterwood harvests and instead manage for early seral habitat and oak regeneration in the following ways:
1) Manage the nearly 5,000 acres of forests harvested in the project area since 1980. Many of these areas are now forests of poor quality, with prior logging resulting in conversion of oak-hickory forests to tulip poplar and red maple. Expansion and modification of “Action 6: Crop tree release” could meet the Forest Service’s goals for early seral habitat;
2) Support the existing proposal for 980 acres of commercial and non-commercial management to restore fire-adapted woodland community types (Action 2: Woodland and wooded grassland/shrubland communities);
3) Support variable thinning along certain roadsides to create early seral and edge habitat and support rare species on 280 acres (Action 9.B: Roadside thinning);
4) Consider uneven-aged management with small group selection using expanding gap or femelschlag prescriptions where the above approaches aren’t sufficient.
The Good Stuff:
The Forest Service is doing a lot in Pine Creek project that we largely support, and have made some changes since their original proposal that make it better. While Kentucky Heartwood generally opposes logging in our national forest lands, this project does include some commercial thinning prescriptions that offer a reasonable approach for restoring and supporting rare and declining species and natural communities.
1) The Pine Creek project proposes using a variety of methods, including non-commercial and commercial tree removal and prescribed fire to restore upland, fire-adapted wooded grassland and shrubland communities (“woodlands”) in areas that were identified through collaborative work with the Kentucky Office of Nature Preserves, Kentucky Heartwood, and The Nature Conservancy (Action 2: Woodland and wooded grassland/shrubland communities). Most of the areas identified in the proposal for woodland management are good, or at least reasonable, choices given the specifics of the existing and historical vegetation.
Integrated with the woodland restoration is the proposed restoration of shortleaf and pitch pine communities (which were decimated by the southern pine beetle 20 years ago) through “cluster planting” of pine seedlings. Unlike prior pine restoration activities on the Daniel Boone that are more akin to plantations, “cluster planting” would restore a pine component in a manner that supports mixed species, spatially diverse stands.
2) The Forest Service added to the proposal, as a response to input from Kentucky Heartwood and others, Action 8.D, which would approve thinning of the forest along the margins of a 1-mile section of powerline right-of-way that contains good quality native grassland remnants (read about the Cumberland Barrens here). Combined with ongoing application of prescribed fire, this management would create a gradient, or “ecotone,” between the native grassland remnants restricted to the right-of-way and the closed-canopy forest adjacent to them. This approach, which leverages existing native grassland flora as indicator species and seed source, offers a viable bridge between the Forest Service’s logging mandate and legitimate ecological restoration efforts. The Draft EA states that “If this activity successfully achieves the desired habitat condition, it may be replicated along other ROWs through separate project planning.” We have been working with the Southeastern Grasslands Initiative to promote a similar emphasis at Land Between the Lakes.
3) In response to our earlier comments, the Forest Service has proposed relocating 1 mile of the Sheltowee Trace National Recreation Trail off of Poison Honey Road and in into the forest, while also buffering trails and recreation areas from logging impacts (Action 9.D).
4) The Forest Service has also added Action 9.C to close and rehabilitate up to 23 miles of user-made trails that are negatively impacting the Rockcastle River.
The “Sounds Good But is Actually Underwhelming” Stuff:
The Forest Service has proposed adding 500 acres of “Designated Old-Growth” in the project area. This is good. However, the Forest Service has restricted these old-growth additions to hemlock mixed mesophytic forests below cliffline (where logging is already restricted), and neglected to allocate any upland forest communities to the old-growth management prescription. While the Draft EA points out the project area already includes 830 acres of an existing “Designated Old-Growth” prescription area, that particular area doesn’t actually include any old-growth or near- old-growth forest. Most of the best upland forests meeting, or nearing, operational old-growth definitions are being left out of the Designated Old-Growth management prescription. We wrote extensively about our old-growth concerns in our previous comments on the project in 2018, which can be read here.
Maps
Below is a large-format, georeferenced PDF map of the Pine Creek project area created by Kentucky Heartwood using data from the United States Forest Service and other sources. In this map you can see where the Sheltowee Trace runs north/south through the project area, in addition to other trails (red lines) including at Bee Rock, Scuttle Hole, and other popular sites. Also noted on this map are forests that have been logged since 1980, and the locations of some of the oldest forests in the area (over 130 years old).
The larger file size version (21MB) has better clarity, while the reduced file size version (4MB) may be easier to download and handle. Either version can be uploaded to your GPS-enabled phone or tablet and used to navigate the project area with the Avenza Maps application. We do not warranty the accuracy of the data provided, and recommend caution and multiple map sources any time you get out in the woods.
The map file in the reader above is high resolution. The files are also available for download, below. The _rfs is the reduced file size map.
Summary of issues
The Forest Service has proposed an initial 1,300 acres of logging to create early seral habitat (young forest conditions). Most of this logging will be in the form of even-aged shelterwood harvests, leaving 7 to 20 trees per acre in 40 acre patches. They also state that they plan to implement shelterwood harvests on 2,000 additional acres approximately 10 years after implementing the proposed midstory thinnings. Some proposed shelterwood logging is along the Sheltowee Trace National Recreation Trail. The combined 3,300 acres of intensive, even-aged logging represents our greatest concerns with the Pine Creek project.
Kentucky Heartwood often supports (or does not oppose) non-commercial midstory thinning, particularly in order to restore fire-adapted forest structure. However, most of the midstory thinning in the Pine Creek project aims to promote oak establishment in the understory in preparation for the next round of logging. The Forest Service could choose to approve a midstory reduction without subsequent logging, and allow turnover in the canopy to result from natural disturbance. Doing so could promote oak establishment over time while avoiding the damage caused by conventional logging. Early seral habitat is important for a wide range of species. However, this type of habitat is more sustainably created through the restoration of fire-adapted uplands and an acceptance of the role of natural disturbance in our forests.
The Forest Service is proposing to create or restore fire-adapted open forest and forest-grassland communities in the Pine Creek project area. Historical and botanical evidence suggest that these community types were important, and even extensive, in some parts of the project area. They plan to do this through 730 acres of commercial logging that would leave 5 to 40 trees per acre, along with another 160 acres of non-commercial felling. Implemented in the right locations with the right long-term management (particularly short fire return intervals), these natural communities can help support a variety of rare and declining plant and animal species. Most of the woodland and wooded grassland management is proposed for the southwestern section of the project area in Pulaski County, in an area that is generally appropriate for this type of management, and follows detailed discussions and field trips that included the Kentucky Heartwood, the Forest Service, Kentucky State Nature Preserves Commission, and The Nature Conservancy. Kentucky Heartwood prefers that the Forest Service rely on natural disturbance, non-commercial felling, and prescribed fire to manage for these community types. We will need more time to examine the specific stands proposed for logging for woodland restoration in order to assess whether or not the sites chosen for logging are reasonable.
Kentucky Heartwood has been urging the Forest Service for several years to incorporate good data, surveys, and site-specific information into projects to conserve and enhance declining and rare botanical communities that rely on open, upland conditions. Many of these specific plants and natural communities are relegated to roadsides and powerline corridors, and do not benefit from typical timber harvests. While such information was largely ignored throughout the planning and analysis of the Greenwood project on the Stearns District, there appears to be a genuine effort in the Pine Creek project to support these remnants of the Cumberland Barrens through cooperative work that includes Kentucky Heartwood and the Kentucky State Nature Preserves Commissions.
The Forest Service is proposing to create or restore fire-adapted open forest and forest-grassland communities in the Pine Creek project area. Historical and botanical evidence suggest that these community types were important, and even extensive, in some parts of the project area. They plan to do this through 730 acres of commercial logging that would leave 5 to 40 trees per acre, along with another 160 acres of non-commercial felling. Implemented in the right locations with the right long-term management (particularly short fire return intervals), these natural communities can help support a variety of rare and declining plant and animal species. Most of the woodland and wooded grassland management is proposed for the southwestern section of the project area in Pulaski County, in an area that is generally appropriate for this type of management, and follows detailed discussions and field trips that included the Kentucky Heartwood, the Forest Service, Kentucky State Nature Preserves Commission, and The Nature Conservancy. Kentucky Heartwood prefers that the Forest Service rely on natural disturbance, non-commercial felling, and prescribed fire to manage for these community types. We will need more time to examine the specific stands proposed for logging for woodland restoration in order to assess whether or not the sites chosen for logging are reasonable.
Old-Growth
The Pine Creek project area includes 830 acres of a roughly 2,200 acre Designated Old-Growth management area. However, like most Designated Old-Growth management areas in the forest, there’s little in the way of genuinely old woods included. The project area also includes another 11,000 acres of riparian and cliffline corridors that are largely excluded from logging, but represent narrow, linear features and not large blocks of forest. Kentucky Heartwood has urged the Forest Service for many years to delineate more old-growth prescription areas in an effort to conserve large sections of older secondary forest that could develop landscape-scale old-growth characteristics in coming decades. The Forest Service has proposed adding 500 acres of Designated Old-Growth in two areas within the Pine Creek project area, near Rock Creek and Angel Hollow. Both areas are good candidates, and should be designated for an old-growth emphasis in the Forest Plan. However, the additions are largely narrow zones in lower landscape positions supporting hemlock-mixed mesophytic forests, and do not include appreciable upland forests. We think that the Forest Service should expand the new Old-Growth Management areas to include appreciable upland forests. It is important to note that the Designated Old-Growth management prescription in the Forest Plan does not preclude the implementation of management activities. What is does mean is that any management that is done should be to support the development of old-growth forest ecosystems.
Shortleaf pine stand improvement
The Forest Service has proposed to restore shortleaf pine on 1,500 acres utilizing what we deem as some progressive and ecologically appropriate methods. Shortleaf pine was decimated by the southern pine beetle between 1999 and 2001. Previous approaches to shortleaf pine restoration, particularly those in the Greenwood project in the Stearns District, have relied heavily on logging healthy hardwood stands and planting pines in dense monocultures. The proposed action in the Pine Creek project would rely on noncommercial methods and planting trees in groups and interspersed with existing vegetation, better mimicking natural patterns.
Prescribed fire
The project area includes 9,300 acres of existing prescribed fire units that were approved in 2014. We believe that the evidence supports the use of prescribed fire in most of these areas. The Pine Creek proposal would add another 2,400 acres of prescribed fire in the project area. Some of the new areas we already know, and we support them being added to the prescribed fire program. Some areas we still need to evaluate, but generally do not have major concerns.