Forest Plan Amendment

​Posted April 3, 2019

​The Forest Service has granted an extension for submitting comments on the proposed Forest Plan Amendment. The new deadline is Monday, April 15th at midnight. Several important documents and reports that are incorporated by reference in to the Draft Environmental Assessment had not been made available to the public until recently after requests were made. The extension was granted by Supervisor Olsen to allow the public more time to send comments now that those documents are available on the Daniel Boone National Forest website.

Email comments to:​ comments-southern-daniel-boone@fs.fed.us

Be sure to include “Plan Amendment” in the subject line of your email.
​
Comments can also be sent via postal mail to:
Dan Olsen
Forest Supervisor
1700 Bypass Road
Winchester, Kentucky 40391
 
Documents for the project can be found on the Forest Service’s website here.

The Daniel Boone National Forest Service website has a comment form on their website here.
​They have also a reading room, where you can read comments that have been submitted by the public. 

Note: Make sure when you copy/paste that there is no space or period at the end of the email address. If you have any issues sending your comment in, please let us know. Feel free to copy kentuckyheartwood@gmail.com on your comment email. Also, you should receive a confirmation reply from the Forest Service letting you know your message was received. Sometimes it takes a few hours to receive the notice. If you do not receive a confirmation email, that means they did not get your message. ​

 ​​Update Posted April 19, 2019 (also appears in our Forest Blog here)

The U.S. Forest Service is proposing to reduce protections for endangered bats in an effort to increase logging on the Daniel Boone National Forest. Comments on the Draft Environmental Assessment (Draft EA) are due by Monday, April 8th. A public meeting is being held by the Forest Service in Berea on Tuesday, March 26th at 4:30 pm. Directions on how to submit comments are at the end of this alert. 

The Forest Service is proposing to amend the management plan (Forest Plan) for the Daniel Boone National Forest. The proposed amendments would weaken protections for federally-endangered Indiana bats (Myotis sodalis) and federally-threatened northern long-eared bats (Myotis septentrionalis).  The Forest Plan currently includes binding standards that restrict logging in some areas during certain times of the year to reduce risk of harming endangered bats. These restrictions are particularly important in protecting maternity colonies during the especially vulnerable period when young are nonvolant (cannot fly). The restrictions have also contributed to the Forest Service’s inability to log much more than about 1,000 acres per year on the Daniel Boone since the Forest Plan was adopted in 2004. But they want that to change.
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The agency, however, is not being honest about why these changes are being proposed. In the Draft Environmental Assessment, the Forest Service states that lifting logging restrictions is needed to shift logging to drier parts of the year, and therefore better limit sedimentation in streams which could impact aquatic species listed under the Endangered Species Act. These species include the Kentucky arrow darter, Cumberland darter, blackside dace, and a wide range of threatened and endangered mussels. That sounds reasonable, until you dig deeper.

In the environmental analysis for each and every timber sale on the Daniel Boone National Forest, the Forest Service states emphatically that the amount of sediment reaching streams from their timber operations is minimal, and will not impact threatened and endangered aquatic species and their habitats. Every. Single. Project. If the Forest Service needs to reduce protections for endangered bats to protect vulnerable aquatic species from logging, does that mean that their logging projects are, in fact, degrading aquatic habitats? If so, will the Forest Service commit to cancelling all active timber sales until the projects can be revised to adequately protect aquatic species? It’s doubtful. But the agency can’t have it both ways.
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So what’s this really about?

The need to increase the “pace and scale” of “restoration” (read: logging) has become an ongoing narrative across the U.S. National Forest system. In recent years, we’ve had to respond to a non-stop barrage of legal and regulatory attempts to roll back public participation and environmental protections on our public lands. From the “Resilient Federal Forests Act” to the Forest Service’s proposed revisions of its NEPA procedures to President Trump’s recent Executive Order on national forests,  it’s all about getting more logs out of the forest, and faster. 

Nowhere in the Draft EA does the Forest Service actually say that they intend to increase the amount of the forest getting cut. But it’s clear that increasing logging is the reason behind this proposal. The Draft EA states only that “The Proposed action will not increase vegetation management volume extracted identified in the 2004 Forest Plan.” What’s left out is that meeting the established Forest Plan timber harvest goals – which were widely opposed during the Forest Plan revision process – would mean nearly tripling of the amount of timber cut on the Daniel Boone National Forest.

Periodically revising management plans based on updated science and evolving conservation strategies can be a responsible thing to do. Amending the Forest Plan with respect to endangered bats or other at-risk species is not necessarily bad. But even the U.S. Fish and Wildlife Service has been critical of the proposal, stating in their early comments that “If the action is carried out as proposed, an increase in adverse effects on federally-listed species is anticipated.” This proposed Plan Amendment is not coming out of concern for protecting endangered bats, or protecting our most imperiled aquatic species. It’s coming from a desire to see more timber cut on more acres, and we think that’s a problem. If you share these concerns, please submit a comment to the Forest Service letting them know.

A public meeting hosted by the Forest Service is scheduled for Tuesday, March 26th from 4:30-6:30 pm at the Boone Tavern Event Center, 100 Main Street, Berea, KY 40404.

Comments need to be submitted to the Forest Service by Monday, April 8th, 2019.

Email comments to: comments-southern-daniel-boone@fs.fed.us

Be sure to include “Plan Amendment” in the subject line of your email.
​
Comments can also be sent via postal mail to:
Dan Olsen
Forest Supervisor
1700 Bypass Road
Winchester, Kentucky 40391
 
Documents for the project can be found on the Forest Service’s website here.

The Daniel Boone National Forest Service website has a comment form on their website here. They have also a reading room, where you can read comments that have been submitted by the public.

Note: Make sure when you copy/paste that there is no space or period at the end of the email address. If you have any issues sending your comment in, please let us know. Feel free to copy kentuckyheartwood@gmail.com on your comment email. Also, you should receive a confirmation reply from the Forest Service letting you know your message was received. Sometimes it takes a few hours to receive the notice. If you do not receive a confirmation email, that means they did not get your message. 

Posted March 25, 2018
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Kentucky Heartwood has submitted comments to the Daniel Boone National Forest concerning the proposed Forest Plan Amendment. (Scroll down for text or click here for a downloadable PDF of our comment letter).  As of this posting, 24 public comments have been submitted and are available to read on the Daniel Boone National Forest website  here, including comments from the U.S. Fish and Wildlife Service (USFWS) Kentucky Field Office (KFO). 

​Notably, the KFO states in their comment letter, “If the action is carried out as proposed, an increase in adverse effects on federally-listed species is anticipated.” The KFO also states, “While the existing standards are more restrictive, it is important to note that they were intended to avoid and minimize the potential for adverse effects and incidental take of Indiana bats on the DBNF that were likely to occur as a result of certain types of tree removal and prescribed fire. In some circumstances, the season restrictions, buffers, and other standards also provided protection for-federally-listed plants and aquatic species. Elimination of these restrictions is, therefore, likely to have the opposite effect and result in increased adverse effects on listed bats, plants, and aquatic species and designated critical habitat, especially in light of the increased amount of forested habitat proposed for treatment under the proposed Forest Plan amendments.”

It is very important that the Forest Service receive comments from the public. 
​We need to let them know that protecting endangered species is more important than selling a few more logs from our public forest. Feel free to use Kentucky Heartwood’s comments as a point of reference for writing your own. You are also welcome to copy our comments and state to the Forest Service that you agree with them, if that makes it quicker or more likely for you to submit comments.
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Here is a link to the page on the Daniel Boone National Forest website where the public can comment on this proposal. Comments are due by the end of the day on Monday, March 26, 2018. 

Comments can also be emailed to: comments-southern-daniel-boone@fs.fed.us

Or sent by postal mail to:

Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

Be sure to state “Plan Amendment” in the subject line when providing electronic comments, or on the envelope when replying by mail. ​
​

Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

March 25, 2018

RE: Forest Plan Amendment

Dear Supervisor Olsen,

Thank you for the opportunity to submit comments on the proposed Forest Plan Amendment with regards to Indiana bats and other federally listed species. The following comments are being submitted on behalf of Kentucky Heartwood and the Center for Biological Diversity.

To begin with, we have no immediate concerns with the proposal to update definitions in order to bring the Forest Plan in to alignment with current U.S. Fish and Wildlife Service (USFWS) terminology. This is reasonable and prudent. We do have concerns regarding changes to restrictions or parameters in the Forest Plan affecting vegetation management, and logging in particular. The removal or reduction of protective measures with regards to Indiana and northern long-eared bat maternity colonies are particularly worrisome. Both of these species of bats are in sharp decline, and immediately imperiled. The possibility that the Daniel Boone National Forest would change Forest Plan standards in such a way as to increase the probability of impacting or destroying a maternity colony is not something that we find acceptable. The loss of a single maternity colony at this juncture could be catastrophic.

The following are questions and concerns that should be addressed in the environmental analysis for the Plan Amendment:

1) What are the current protocols for identifying maternity colonies or other active roosts? When during planning and harvest operations are surveys made, and by whom? What training is received by personnel to identify active roosts?

2) How often have maternity colonies been found in project areas? Following the identification of Indiana (and northern long-eared) bats, how did the Forest Service modify or delay specific projects and operations in order to comply with Forest Plan Standards? Please be specific.

3) Please provide ample scientific evidence demonstrating that the newly proposed Forest Plan standards (e.g., changes to basal area standards, snag retention, seasonal harvest restrictions relating to habitat occupancy, etc.) are more or as protective for federally-listed bat species as the current plan standards. It does not appear to us that they are.

We expect the Forest Service to commit to a thorough, detailed, and reasoned analysis with regards to any changes to Indiana and northern long-eared bat management on the Daniel Boone National Forest. Any changes to the Forest Plan should be firmly rooted in evidence that future management will be as or more protective of Indiana and northern long-eared bats as the current procedures.

Sincerely,

Jim Scheff, Director
Kentucky Heartwood
P.O. Box 1486
Berea, KY 40403

(859) 334-0602
jim@kyheartwood.org

Posted March 19, 2018

​The Daniel Boone National Forest has proposed to amend the forest’s 2004 management plan with respect to the federally endangered Indiana bat. The Indiana bat (Myotis sodalis) was first listed as an endangered species in 1967, and has been in decline ever since. Since 2006, the spread of the disease White Nose Syndrome (WNS) has caused remaining populations of Indiana bats (as well as other species of bats) to crash. 

Some of the Forest Service’s proposed changes simply align terms and criteria with those currently in use by the U.S. Fish and Wildlife Service. However, the Forest Service is also proposing to loosen several protective standards that limit timber harvest near maternity colonies of both Indiana bats and northern long-eared bats (Myotis septentrionalis). Northern long-eared bats are listed as threatened under the Endangered Species Act on account of catastrophic declines from WNS.

One of the reasons provided by the Forest Service of the need for change is that logging restrictions near maternity colonies during the summer roosting season mean that more logging has to take place during the wetter winter months. But over last decade, several aquatic species have been listed as threatened or endangered, meaning that sedimentation of streams from logging has to be taken more seriously. For example, the Forest Service just proposed around 3,000 acres of intensive logging on steep slopes in the Redbird District in designated Critical Habitat for the Kentucky Arrow Darter, which was listed as threatened under the Endangered Species Act in 2015. The Redbird District includes most of the remaining habitat for this species. We’ll post more about the South Redbird Project in the near future.

The bottom line is that the only changes the Forest Service should be making with respect to Indiana and northern long-eared bats are those that are demonstrably protective and support their populations. These important, imperiled species cannot afford the loss of a single maternity colony – especially to facilitate logging on our public lands.

For now, the Forest Service is accepting comments on their proposal until Monday, March 26th. The agency will likely prepare an Environmental Assessment sometime in the near future.

Links to project documents can be found on our website here, and the Daniel Boone National Forest website here.

Here is a link to the page on the Daniel Boone National Forest website where the public can comment on this proposal. Comments are due by 3/26/2018.

Comments can be emailed to: comments-southern-daniel-boone@fs.fed.us

Or sent by postal mail to:

Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

Please state “Plan Amendment” in the subject line when providing electronic comments, or on the envelope when replying by mail. 

Here is where you can read comments that have been submitted by the public.
​

February 23, 2018

​​The Daniel Boone National Forest is proposing to amend the 2004 Daniel Boone National Forest Land Management Plan (Forest Plan). Kentucky Heartwood is currently reviewing the documents that have been provided by the Forest Service, and we will be posting more here as we form our opinions on this proposal.

The Forest Service provided the following brief description of this proposal: “Since the Forest Plan was signed in 2004, there have been changes in the science applicable to the management of bat habitat, changes to the number of threatened and endangered species, and additional designations of critical habitats on the Forest.”

Here is a link to the project page on the Daniel Boone National Forest website, that contains documents associated with this proposal.

Here is a link to the page on the Daniel Boone National Forest website where the public can comment on this proposal. Comments are due by 3/26/2018.

Here is where you can read comments that have been submitted by the public.