An Initial Examination of National Forest Management Response to Endangered Species Listing of the Candy Darter

By Rick Webb

The candy darter is a brightly colored 2 to 3-inch fish of mountain streams in the Gauley and New River watersheds of Virginia and West Virginia. Streams that maintain the habitat requirements of the candy darter are now mostly limited to the upper reaches of its former range in relatively undisturbed forested watersheds of the Monongahela National Forest (MNF) and Jefferson National Forest (JNF). The future of the candy darter largely depends on preservation of watershed integrity in these National Forests.

This article provides a brief initial examination of Forest Service management response to listing of the candy darter based on the Gauley Healthy Forest Restoration (GHFR) project, a proposed resource management project in the Monongalia National Forest involving up to 3,000 acres of timber harvest and 60 miles of logging road construction and reconstruction. Most of the information concerning this project was obtained through a Freedom of Information Act (FOIA) request. 

Access to documentation for the Greenbrier Healthy Forest Restoration project has been limited, as described below, and this assessment is necessarily incomplete. The perspectives of more-informed experts, including those directly involved in Forest Service project review, would be valuable and welcome.

If the Greenbrier Healthy Forest Restoration project serves as a representative example, it seems there has been little if any actual response by MNF management to endangered species listing of the candy darter. Although multiagency restoration studies and initiatives are underway, the MNF is not directly addressing the need for preservation and restoration of the candy darter and its habitat at the project-development level. 

The Endangered Species Act requires the Forest Service to ensure, in consultation with the Fish and Wildlife Service (FWS), that any project it undertakes is not likely to result in destruction or adverse modification of designated critical habitat. Timber harvest projects, such as the Greenbrier Healthy Forest Restoration, pose a significant risk to aquatic habitats because they involve extensive ground disturbance on steep slopes, usually including a network of log-skidding trails, log-landing areas, and both newly constructed and reconstructed logging roads. The resulting stream sedimentation, soil damage, and hydrologic alteration can directly and indirectly degrade stream habitat. 

A reading of the available review documents for the proposed Greenbrier Healthy Forest Restoration project suggests that Monongahela National Forest management intends to minimize the significance of these risks to critical habitat.

Stream sedimentation

The Forest Service generally relies on standard best management practices (BMPs) for erosion and sediment control, despite recognition that standard BMPs fail to prevent soil loss and stream sedimentation on steep-slope timber operations. 

During the review process for the GHFR project, MNF scientists cited sediment reduction efficiencies between 53% and 94% for standard BMPs on timber operations. The review documents suggest that this unreliable degree of control will be considered acceptable because impacts will be temporary. The Forest Service, however, uses a ten-year window for evaluating most direct and indirect effects to aquatic resources. This limited timeframe fails to account for more-persistent sedimentation impacts associated with the failure of control measures over time, runoff from unrestored logging roads, and channel erosion resulting from altered drainage patterns. 

Planning for the Greenbrier Healthy Forest Restoration project has also been limited by a lack of information concerning existing stream sedimentation sources and impacts in the project area. The North Fork of the Cherry River, which would receive most of the runoff from the GHFR project area, already has a higher degree of embeddedness (infilling of streambed gravel and cobbles with sediment) than most other streams in the MNF. Actual integration of candy darter preservation and restoration objectives with the GHFR project would prioritize investigation and reversal of this existing degradation of designated critical habitat before accepting additional degradation.

Soil damage

Soil compaction and depletion of soil base nutrients will result because of the Greenbrier Healthy Forest Restoration project. Soil compaction, associated mainly with heavy equipment use on roads and landing areas, alters runoff properties by reducing infiltration and water retention capacity. Depletion of soil base nutrients, or base cations, is a significant existing problem in the GHFR project area and in much of the upper Gauley River watershed. Due to the lack of base nutrients in bedrock, together with losses of soil base nutrients caused by historic disturbance and acidic precipitation, many of the streams in this area are too acidic to support fish and most other aquatic life without neutralization by routine limestone treatment.

As described in the review documents, most of the base nutrients in GHFR area soils are concentrated in the organic soil horizon. Removal of this upper soil layer by construction and use of roads and log landings reduces watershed acid-neutralization capacity and contributes to ongoing acidification of soil and stream water. 

The review documents suggest that concerns about soil compaction, base-nutrient depletion, and acidification due to loss of the upper soil horizon will be dismissed based on the calculation that the surface area of new project roads and landing areas is only 3.6% of the surface area of the entire project. Regardless of how this is cast, some amount of damage will be accepted. Again, a focus on preservation and restoration of the candy darter and its habitat would first investigate existing habitat degradation and potential mitigations before accepting additional habitat degradation.

Hydrologic alteration

Logging roads on steep mountain sides intercept and divert both surface and soil water, rerouting flow, causing erosion and sedimentation, and contributing to loss of water retention function in the watershed. As described in the GHFR review documents, this is a long-term impact.

The Greenbrier Healthy Forests Restoration project area was heavily impacted by industrial-scale timbering in the early 20th century, and there are hundreds of miles of historic logging roads in the project area. The proposed GHFR project would involve reconstruction and use of about 30 miles of these existing logging roads and construction and use of about 30 miles of new logging roads. Although these roads will be considered temporary, plans for restoration are unclear. There is apparently no plan to restore the original contour or do much more than install waterbars after project completion.

Consistent with the approach for discounting concerns about soil damage, the GHFR review documents suggest that the Forest Service will dismiss the significance of hydrologic alteration by logging roads based on a relatively small area of direct impact (new road surface) compared to the area of the overall project. This line of thinking fails to account for problems associated with reconstruction and reuse of old logging roads, and it again ignores the real nature of the problem. As well described by MNF scientists in the review documents, the impact of roads on steep mountain slopes is due to interception and diversion of surface runoff and soil water, and not simply a matter of road surface area.

It appears, though, that the Forest Service is likely to accept further road-related hydrologic impact in watersheds that maintain candy darter habitat without first investigating the continuing impact of existing roads and the options for restoration. 

FINDING

Although long-term adverse modification of candy darter habitat through stream sedimentation, soil damage, and hydrologic alteration is a likely outcome of the GHFR project, the project may nonetheless be approved.

The Forest Service, or at least the administration of the MNF, has avoided real consideration of candy darter preservation and restoration requirements. There has been no evident change in Forest Service policy and management in response to endangered species listing. Rather than prioritizing the preservation and restoration needs of the candy darter, the MNF administration is taking a business-as-usual approach, relying on existing standards and guidelines to provide “favorable direction for the conservation of candy darter habitat on the Forest.”

Requirements for preservation and restoration of candy darter habitat should be a priority objective of MNF management, rather than a secondary objective or a problem to work around. 

It seems telling that planning for the Greenbrier Healthy Forests Restoration project has been marked by a lack of transparency, starting with the development of the project without the usual public review process of the National Environmental Policy Act. There has been a determined resistance to providing basic project information to the public. The initial Forest Service project announcement failed to even identify the specific project location. 

A Freedom of Information Act (FOIA) request for project review documents was submitted to the MNF in July of 2020. Four months later an incomplete set of documents, without requested GIS information layers, was provided. Following an administrative appeal and an additional FOIA request, it now appears that the requested project documents and map layers will finally be provided, about nine months after the original request. This information should prove critical for informing further review of the GHFR project and other National Forest projects proposed for watersheds that support the candy darter.

For more information about the GHFR project, including access to review documents, see the ABRA Conservation Hub’s GHFR Map Page. For a description of conservation group concerns about the GHFR project, see the March 2021 Highlands Voice.