By Kent Karriker

The Conservancy recently filed a comment letter on the Forest Service’s draft Environmental Assessment (EA) for the proposed Greenbrier Southeast project.  The project would pursue several management objectives, including timber harvest, spruce ecosystem restoration, wildlife and aquatic habitat enhancement, and recreation site enhancement. 

The project area, located about two miles east of Bartow in Pocahontas County, covers 16,888 acres in the watershed of the East Fork of the Greenbrier River.  As currently proposed, the Greenbrier Southeast project would include over 2,000 acres of commercial timber harvest, over 1,600 acres of non-commercial tree cutting and vegetation management, over 2,600 acres of prescribed fire, almost eight miles of road construction and reconstruction, almost 19 miles of soil restoration on old road beds, up to 40 miles of stream and riparian habitat enhancement, and various improvements to the historic Max Rothkugel plantation, the range allotment and historic site at Camp Allegheny, and the vista on Smoke Camp Knob.  More information on the project is available on the Monongahela National Forest’s web site: https://www.fs.usda.gov/project/?project=55797.  Click the “analysis” tab to find the draft Environmental Assessment.

The Forest Service engaged the Conservancy and other interested parties throughout the scoping process.  Overall, we have actively supported aspects of the project that address priorities that are important to us, like spruce restoration, watershed restoration, and recreational enhancements.  Likewise, we have not expressed opposition to the more consumptive components of the project (i.e., commercial timber harvest) because these activities are proposed for portions of the landscape that are designated for timber management by the Forest Plan.  As we stated in our comment letter, we generally support projects that have the potential to contribute to the local economy, enhance wildlife habitat, and enhance the visitor experience, provided they are conducted in a manner that protects sensitive environmental resources.

That last little dependent clause is always the rub.  The bulk of our comment letter focused on making sure that the Environmental Assessment adequately discloses the environmental impacts of the project, and that the project provides clear, enforceable protections for sensitive resources.  We found that resource protections were vague and inadequate in some cases, and that the analysis of impacts in the draft EA was largely lacking factual and logical support.  

The Forest Service is engaging in a nation-wide push to “streamline” its National Environmental Policy Act (NEPA) analyses, and this push has been causing National Forests to cut corners in their NEPA documents.  

The draft Environmental Assessment mostly presented a string of conclusions, and then referenced other unpublished documents for support.  Such incorporation by reference would be perfectly acceptable if the documents were readily available to the public, but the supporting analysis has not been completed yet, which makes one wonder about the basis for the conclusions in the draft EA.  Because this lack of information severely hampered our ability to conduct a meaningful review of the project, we have requested that the Forest Service provide the supporting information and then run another 30-day comment period on the draft EA.

Another major issue that we raised revolves around soil and water quality.  Although the project contains some very good proposed soil and watershed restoration activities, it also would conduct timber harvest on steep slopes and would construct 49 miles of tractor roads for skidding logs.  These tractor roads would be treated after harvest to mitigate impacts to watershed hydrology, but only tractor roads on the steeper slopes would be fully decommissioned.  Elsewhere, tractor roads would be treated with standard Best Management Practices, which the Forest Service has previously said are not fully effective at healing watershed hydrology.  

It is critical that the Forest Service gets the watershed treatments right, because the watershed of the East Fork is a regional stronghold for native brook trout, and it contains the most significant areas of proposed critical habitat for the endangered candy darter.  In our letter we asked the Forest Service to either decommission all tractor roads fully, or provide information that demonstrates the effectiveness of their proposed approach.

            The next step in the process normally would be issuance of a final Environmental Assessment and a draft Decision Notice, which would kick off the period for filing formal objections.  However, we hope that the Forest Service chooses to grant our request for a new comment period on the draft EA.  We will keep you updated.

Note:  If you want to see our entire comment letter to the Forest Service, it is on the West Virginia Highlands Conservancy website at : https://www.wvhighlands.org/wp-content/uploads/2020/05/WVHC-Comments-on-the-draft-Environmental-Assessment-for-the-proposed-Greenbrier-Southeast-project-1.pdf