March 15, 2023
Tim Reed, District Manager
Daniel Boone National Forest
Stearns Ranger District
3320 Highway 27 N
Whitley City, KY 42653
Subject: Citizens Alternative to the Jellico Vegetative Management Project #63037
Dear Mr. Reed,
This letter is in response to U.S. Forest Service plans to log the Jellico Mountains of the Daniel Boone National Forest over the next 40 years. Prescribed treatments would occur on 9,798 acres (15.3 square miles) across 256 stands in the national forest just east of Interstate 75 in southern Kentucky. This includes 4,825 acres of clearcut or equivalent on mostly steep slopes, stripping bare a full quarter of the national forest there.
In response, citizens of Whitley and McCreary Counties in Kentucky formed a Jellico Mountains Task Force to educate the public on the potential negative impacts this large project will have on our forests and creeks. Our diverse coalition of citizens includes Republicans, Democrats, and Independents; white-collar and blue-collar workers; college students through retirees; even a miner and a logger.
Most members of our task force are not anti-logging, but we are united against irresponsible logging. Clearcutting the steep slopes of the Jellico Mountains will lead to flooding, landslides, invasive species, spoiled views, noise and pollution, herbicide in our drinking water, and sediment in our creeks. Residents know all this from past experience.
This letter respectfully requests the U.S. Forest Service include the following Citizens Alternative in your Environmental Assessment for the Jellico Vegetative Management Project #63037.
1. NO CLEARCUT OR EQUIVALENT ON STEEP SLOPES
No clearcut, two aged shelterwood, or deferment harvest treatments on steep slopes. Minimal clearcutting elsewhere, deploying uneven edges and diverse ecotones for a more natural look.
Why: Much of the Jellico Mountains project area has steep slopes, unstable soil, and is known to present significant landslide risks. Endangered species such as the Cumberland Darter and Black-Sided Dace rely on the area’s streams for critical habitat, just like in the Redbird district where numerous landslides occurred due to Forest Service logging. In the Jellico Mountains project area, a 2022 landslide that flooded Jackson Creek with sediment occurred in the middle of a 44-acre tract the Forest Service had clearcut with reserves in 1990. Slopes over 45% should not be clearcut to meet the legal requirements of the National Forest Management Act of 1976, specifically 16 USC §1604 (g)(3)(E)(i) and (F)(v).
2. 10 YEAR PROJECT
Reduce the scope of the Jellico Project to 10 years.
Why: The 40-year timeframe for the project is not compliant with the National Environmental Policy Act (NEPA) or the National Forest Management Act. Four decades is too long to confidently predict outcomes and side effects, and cannot benefit from future advances in silviculture and climate science.
3. SAVE MATURE FORESTS & OLD GROWTH TREES
Do not log trees over 80 years old and create a 1000+ acre “Designated Old Growth” section just south of Little Wolf Creek where a high density of old growth forest exists. Survey all other stands in the project area to determine if there are more old growth trees.
Why: The proposed project includes clearcut or equivalent treatments on 400 acres of known old growth forest (over 130 years old). None of this older forest is protected in the Jellico Mountains “Designated Old Growth” area, despite meeting the Forest Service tree size and age requirements for old growth. These forests are cherished cultural areas used for hunting, and they protect critical habitat for the endangered Cumberland Darter downstream in Little Wolf Creek. Additionally, designating this area as old growth would help meet Daniel Boone National Forest Plan Objective 1.4.B in Chapter 2 for underrepresented old growth forest types described in Section 1.I of Chapter 3.
4. MINIMAL HERBICIDES
Use herbicides only for direct stump treatment on non-native invasive species where mechanical treatment is impractical.
Why: Many beekeepers work hives in the Jellico Mountains, farmers rely on mountain creeks for livestock and crop irrigation, and some residents use ground water and wells for drinking. The city of Williamsburg depends on clean water draining from the eastern Jellico Mountains for its municipal water supply. Residents don’t want their fresh water polluted with herbicides and sediment from logging.
5. REMOVE INVASIVE SPECIES
Remove existing invasive species including Tree of Heaven and Autumn Olive that flourished in areas logged in the 1990s. For cleared areas, implement a revegetation plan that includes planting a variety of native hardwoods and removing new invasive species growth.
Why: Many areas contiguous to the proposed project area were mined shortly after the Surface Mine Act of 1977 went into effect. At that time, the Autumn Olive bush/tree was an acceptable revegetation species. By the time it was determined to be invasive, thousands of acres of Autumn Olive had been established throughout Kentucky. Many areas clearcut by the Forest Service in the 1990s have been overrun by Tree of Heaven. If the Forest Service does not implement an intentional revegetation plan, Tree of Heaven and Autumn Olive will once again proliferate in the national forest.
6. FOCUS ON RECREATION INSTEAD OF EXTRACTION
Build hiking and equestrian trails; create vistas, pullouts, and parking spots; construct campgrounds, remote campsites, cabins, and someday a lodge; maintain streams and fishing ponds for public use. Conduct a feasibility study to create a National Recreation Area or National Monument in the Jellico Mountains managed by the U.S. Forest Service.
Why: Jellico Mountains contain over 19,000 acres of National Forest but doesn’t hold a single recreational trail. Logging projects are well-documented money losers for the Forest Service and American taxpayers. The Jellico Mountains would better serve the surrounding communities and American people with its trees mostly intact, with the forest preserved and lightly developed for recreation, instead of being stripped of timber.
7. PERFORM STUDIES
Gather and publish baseline data that would determine whether the proposed project is ecologically appropriate. Model pre- and post-logging hydrology and sedimentology using a tolerance not to exceed 15% increase in runoff.
Why: The Forest Service has not surveyed for potential contraindications to management over the entire 9,800-acre treatment area. It has not surveyed for federally listed or rare species or assemblages. It has not surveyed for American Indian religious or cultural sites. It has not assessed site-level landslide risk, hydrology, or sedimentology. Nor, given the immense size of the project, will the Forest Service likely be able to study these issues across all 256 logging tracts for the Environmental Assessment, as required by the NEPA process.
8. PRESERVE THE VIEWSHED
No clearcutting or equivalent on residential-facing slopes, such as stands 8 & 9 in compartment 6252.
Why: Residents love the Jellico Mountains for their quiet and beauty, and some of the prescribed tracts to be clearcut would damage residential viewshed for a generation. The Forest and Rangeland Renewable Resources Planning Act of 1974, as amended by the National Forest Management Act of 1976 (16 U.S.C. 1601), as well as other laws and regulations, compel the Forest Service to include requirements for consideration, treatment, and protection of scenery and aesthetics.
Jellico Mountains Logging Task Force