Advocacy

In early August 2018, the Canaan Valley National Wildlife Refuge (CVNWR) announced that they would be using commercial logging on Refuge land, a practice that has not been previously used. At the time there was only a two week comment period, and the public meetings on the issue were not well publicized. Despite the short comment period there was an enormous public response, and many concerned citizens sent letters.

Thanks to those comments, the public comment period has been extended. The new deadline is September 11th. You can still submit a comment through our Take Action Page. You’ll see that the suggested text has changed to reflect the longer comment period. As always, you are welcome to write your own personal comments.

Here is some additional information about the proposed commercial logging and Friends of Blackwater’s concerns.

Background: The basic proposal is to timber 30 to 40 acres a year to convert existing forest to early successional habitat. A total of roughly 1600 acres would be eligible for commercial timbering, making up around 1/10th of the Refuge. The first project could take place as early as this winter and would use A-Frame Road and Middle Valley Trail as access routes, temporarily closing those routes to the public. The areas cut would mostly be northern hardwood or aspen ecosystems. Even-aged management techniques will be used, and clear-cutting was mentioned as an option at the public meeting we attended.

Process: The Refuge’s Comprehensive Conservation Plan (CCP) is the top-level plan that guides management on the Refuge, and it was approved after an analysis and public comment process. However, the CCP doesn’t say that commercial timbering could be done, and it states that only 10 to 15 acres would be cut for early successional habitat each year. However, the current proposal is 30 to 40 acres a year, more than twice as much timbering as originally proposed. The CCP also suggested that timbering would be done by hand-carrying in chainsaws, rather than using heavy equipment, but it is not stated in the new plan that this would be a condition for commercial timbering. For these reasons, the public engagement that was done for the CCP doesn’t alleviate the need for additional analysis and public engagement, because the nature and scope of the proposed management have changed.

Focal Species: Everyone knows that CVNWR is home to many rare and unique species. Indiana and Northern Long-Eared bats have been documented on the Refuge, and could potentially be present in some of the areas eligible for logging. We would like to know what kind of bat surveys have been conducted in the areas where logging is proposed. The West Virginia northern flying squirrel is another sensitive species, found on several areas in the Refuge including Cabin Mountain and Snowy Point. The flying squirrel is also presumed to be present throughout the higher elevations of the Kelly-Elkins Tract. Since some of the areas eligible for logging are in between proven flying squirrel habitat, we would also like to know whether any research has been conducted to prove or disprove the possibility that some of the tracts eligible for timbering might be wildlife corridors.

Cost: The compatibility determination includes a chart of predicted yearly costs, totaling $12,000, which the text indicates are “outside of costs offset by timber sales receipts”. Considered over multiple years, this is a substantial amount of federal funds being spent on management activities that facilitate commercial timber harvesting on federal property. What is the cost threshold at which commercial timber management would be considered to be a bad investment for the Refuge?

Invasive Species: Truck traffic and environmental disturbance are often associated with an increase in invasive species. Given the unique and delicate flora of the Refuge and the difficulty of eradicating invasive species once they arrive, this amounts to a significant risk.

Erosion: The first proposed timber harvest would use A-Frame Road and Middle Valley Trail for access and transportation. This will result in a temporary loss of public access, but could also create more long-lasting changes to the quality of the road and trail. The Refuge’s documents note that some of the soils found in CVNWR are particularly vulnerable to erosion, which is the justification used for not allowing most visitors to leave the established trails. If the impact of hikers or fishermen walking off trail is considered too much of a risk to soils, how is timbering acceptable?

Wilderness: At the time the CCP was written, a wilderness review was conducted which concluded that there were two sections of the Refuge that had potential to become wilderness areas. The conclusion of this initial wilderness review was that further study was needed on the two potential wilderness areas, identified as WIA7 and WIA10. That further study was supposed to be completed within 3 years of the CCP being finished. We do not know whether or not that further study took place, or what it concluded. Based on the maps we have, the proposed timbering may fall within the potential study areas, which would mean that the study should be completed before any timbering takes place.

Climate Change: The Refuge’s own analysis of management alternatives noted that not cutting timber and emphasizing natural regrowth would make the Refuge a better carbon sink. The environmental analysis also noted that allowing early successional habitats to grow and mature could have long-term benefits to air quality. There is already existing evidence that the climate is changing in Canaan Valley. We don’t know how this proposed timbering will impact the resilience of the Refuge and its ability to cope with a changing climate. This would be a good topic for study before timbering is undertaken.

For all of the above reasons Friends of Blackwater believes that a full Environmental Assessment of the proposed timber plan should be done.