Conservancy Provides Scoping Comments on Forest Service’s Proposed Greenbrier Southeast Project

By Kent Karriker

The Forest Service has proposed a new vegetation management project for a portion of the Monongahela National Forest called the Greenbrier Southeast project area. This project area is a 16,888-acre portion of the Greenbrier District.  It is located approximately 2 miles east of Bartow, WV, in Pocahontas County.  The project area covers part of the Headwaters of the East Fork Greenbrier watershed, in which the Forest Service has previously conducted extensive watershed and aquatic habitat restoration for the benefit of brook trout and other cold water species.

The Greenbrier Southeast project would focus on creating young forest habitat through the use of even-aged timber harvesting (popularly known as clear cutting). Such management is needed to meet Forest Plan objectives for the area, which include age class diversity, sustainable timber production, habitat for wildlife species that prefer early successional habitat, and long-term sustainable mast production (most mast-producing tree species require disturbance to regenerate).  The project would also pursue a variety of other objectives:

  • Pre-commercial timber stand improvement and wildlife habitat improvement in existing young forest stands.  Basically, this activity would thin young stands to favor trees that are preferred for wildlife habitat and timber production.
  • Site preparation in stands to be harvested to ensure that the stands regenerate to desirable timber and mast-producing tree species.  Site preparation would involve a one-time use of herbicides to control over-abundant competing species, such as ferns, striped maple, and beech brush.
  • Control non-native invasive plant species that threaten to spread in the areas of activity.
  • Create additional areas of early successional wildlife habitat, such as savannas and cutback borders around timber harvest units.
  • Construct approximately 8 miles of roads to facilitate management activities.
  • Use prescribed fire to restore oak-dominated habitats that are slowly converting to non-oak species due to decades of fire suppression.
  • Restore red spruce in key locations where evidence suggests the landscape was part of the historic range.  This would include planting red spruce or white pine in areas where hemlocks are being killed by the hemlock wooly adelgid.
  • Conduct additional watershed and aquatic habitat restoration activities, including decommissioning unneeded old roads, adding large woody material to stream channel and riparian habitats, and planting trees in open riparian areas to provide shade.
  • Develop the site of the former Smoke Camp Knob fire tower to include historic interpretation, dispersed camp sites, access road upgrades, and additional parking.
  • Various enhancements to the visitor experience at the Allegheny Battlefield historic site.
  • Provide dispersed camping opportunities above Lake Buffalo.
  • Rehabilitate the historic Max Rothkugel plantation of Norway spruce and European larch.  The Rothkugel plantation was one of the first attempts by trained foresters to re-forest cut-over areas in the eastern United States.

For more information on the proposed project, see the scoping notice that is posted on the Monongahela National Forest website:

The project’s initial scoping period was just completed.  Scoping is a process whereby the Forest Service solicits early public input on a proposed project.  At this stage the project has not been fully designed; rather, the agency outlines goals and objectives for the project area, identifies ways in which those goals and objectives currently are not being met, and proposes to use certain activities to meet the goals and objectives.  The scoping process serves to identify potential issues and concerns that the public may have, as well as to crowd-source ideas that the public has about ways to manage the project area.  Participation in scoping is a great way for stakeholders to influence the early development of a project, and, hopefully, deal with issues before the agency has invested a great deal of time and effort in the design of the project.

In our scoping comments we noted that the Forest Service appears to have correctly identified the management needs for the project area.  We agreed that the activities that the agency has proposed are appropriate for meeting the desired conditions that are specified for the area by the Forest’s Land and Resource Management Plan (“Forest Plan”).  We recognize that the Conservancy’s membership might hold a variety of opinions about timber harvesting and other forest management practices in the abstract.  However, in the context of this project area, those proposed activities are in accordance with the management direction laid out in the Forest Plan, and therefore are appropriate for the agency to pursue.

Despite our overall agreement with the proposed project, we did raise several concerns.  These concerns deal primarily with making sure that sensitive environmental resources are protected from adverse impacts.  

  • We expressed particular concern about the need to ensure that the proposed activities do not essentially “un-do” the good watershed restoration work that the Forest Service has already done in the area.  Important components of watershed protection that we felt needed more attention include decommissioning skid roads after use, constructing new roads only to the extent that they are needed to replace existing bad roads, following Forest Plan limits on amounts of harvest activity, avoiding ground-based harvest activity on steep slopes, and protecting stream channel buffers from all activities (including early successional wildlife habitat enhancement).
  • We asked the Forest Service not to refer to clearcutting as “ecological restoration.”  Although we agree that clearcutting is an appropriate technique for meeting the Forest Plan’s management objectives, even-aged timber management would not restore the ecosystem to its natural condition.
  • We emphasized the need to require all logging and construction equipment to show up clean so that the equipment does not spread non-native invasive species.
  • We expressed concern over the potential impacts on wildlife habitat of broadcast herbicide applications to control large areas of ferns.
  • We asked the Forest Service to ensure that fire line management does not result in cutting up large woody material in stream channels and riparian areas.
  • We noted the need for red spruce restoration activities to leave the tree canopy intact.
  • We asked that the Forest Service share information on any specific proposed activity units that they have already developed. 
  • We asked for information on the process of delineating suitable habitat for the West Virginia northern flying squirrel, and we noted the need for all even-aged timber harvest and similar cutting activities to completely avoid suitable habitat for this species.

Now that the scoping period is over, the Forest Service will be using the input they received to help them finish designing the proposed project.  The next formal opportunity for public involvement will be the release of the draft Environmental Assessment for a 30-day notice and comment period.  However, we are hopeful that the Forest Service will respond to our informal information requests prior to the formal notice and comment period, so that we can continue the process of addressing potential issues before the agency reaches “crunch time” at the end of the formal process.