A detailed backgrounder on the

Joyce Kilmer hemlock felling project

· “A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions, and which generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable … “

-- Definition of Wilderness from The Wilderness Act of September 3, 1964, PL 88-577

ROBBINSVILLE, N.C. -- Anyone visiting the Joyce Kilmer Memorial Forest since mid-November is in for a shock. Those who have visited it previously probably will not recognize it. New visitors might wonder why the two-mile loop trails of the Memorial Forest, part of the Joyce Kilmer-Slickrock Wilderness, looks much like the site of an artillery test range. That is because the U.S. Forest Service, the federal agency responsible for management of this national forestland and Wilderness, used explosives and chain saws to drop 150 large hemlock trees that were dying of the Hemlock Woolly Adelgid infestation and because a previous Forest Service effort to try to save some of these hemlocks failed. The dead hemlocks were alleged to be endangering safety of visitors along Joyce Kilmer trails. The explosives were used in an attempt to “mimic a natural event, such as strong down-drafts or thunderstorms,” in the words an agency planning document. Chain saws were to be used to down trees that were in danger of falling on top of pedestrian bridges and then were to be “fuzzed” with explosives to mimic natural events.

Whether one agrees with these justifications or not, this largely virgin forest now looks like an unholy mess. Fractured hemlock stumps are to be found at every turn of the trail, stump after stump after stump. Very big and solid boles lean up to the trail’s edge, spewing the acrid smell of the bark that was once a favorite of the leather tanning industry. No sound or birds. There is little natural about this forestscape.

Visitor reaction

My wife and I visited the site and walked the lower loop of the memorial trail on Monday, November 22, three weeks after the Forest Service first detonated the powder and cranked up the chain saws and one week after the project’s completion. “There was no regard for the spirit of the trees or of this forest. They were not allowed to die a natural death,” she said. “This was not natural, and it is going to affect the forest for years to come. If this was such a big problem, why didn’t they just move the trail?”

A first-time visitor from south Georgia came to Joyce Kilmer the weekend of November 20-21. “The place looked as if it had been shelled,” he said. “I have heard of the place and its wonders for many years, and it is ironic that when I should finally see it, it quickly brought to mind the photos by Matthew Brady, of Civil War battlefields immediately after the shooting stopped.”

Photos of the scarred stumps “underscore the impression of explosive violence,” that visitor added. “The appropriateness of this place as a memorial to a deceased soldier of the Great War, noted for a poem about trees, is perhaps temporarily enhanced by its present appearance as a battlefield. But as an example of the beauty of trees it has been rendered less than useful for the next several years by the current ‘improvements’ at the hands of the Forest Service and its contractors.”

A visitor from Atlanta that same weekend had this to say: “Joyce Kilmer Forest has been dynamited, literally. The massive 300-plus-year-old poplars remain, but 150 hemlocks in the virgin forest, killed by the tiny adelgid, were blown up two weeks ago by the [Forest Service] to remove hazards to hikers. It was like walking among the fallen on a battlefield.”

But not every visitor seemed taken aback by the man-made devastation of the hemlocks. One hiker from Florida on Nov. 22 had read a bulletin board that described the project in brief and expressed gratitude that the agency had removed hemlock debris from the trail. “As it is, there were a lot of roots covered up with leaves on the trail,” he said.

Forest Service claims support

The Forest Service did not attract much attention to its plans. For many, the first inkling of the agency’s intentions was made public in a news release of October 21, and subsequent newspaper articles. See the website for The National Forests of North Carolina (http://www.cs.unca.edu/nfsnc/) and click on the News Release entitled, “Joyce Kilmer closed until Nov. 14.”

That announcement also made plain that the agency had the support for its plans of at least two conservation and recreation groups, The Wilderness Society and the Partners of Joyce Kilmer-Slickrock Wilderness.

Although the Forest Service had never posted any kind of warning signs alerting visitors – some 30,000 per year – to a safety issue, Brent Martin of The Wilderness Society cited that factor as justification in the news release: “The Forest Service proposal will minimize the visual impacts of the loss of these great trees and greatly increase the safety of visitors to the area,’” he said.

The mission of the Wilderness Society is to protect wilderness and inspire Americans to care for our wild places.

The news announcement also quoted Robert Rankin, President of the Partners of Joyce Kilmer-Slickrock Wilderness. “We realize this project is vital to ensuring the continued safety of the many visitors to the Joyce Kilmer Memorial Forest. This special place will continue to be available for both present and future generations to enjoy,” he stated.

Officials of the Nantahala-Pisgah National Forest also asserted after the project was completed that the agency had secured verbal, tacit approval from three other North Carolina-based, non-profit conservation organizations, the Southern Appalachian Forest Coalition, WildLaw and the Southern Environmental Law Center, all based in Asheville, N.C.

Hugh Irwin, the conservation planer for the Forest Coalition said he “always thought that the biggest tragedy in this issue is the fact that the hemlock were allowed to die in the first place.” [See accompanying archive post for Irwin’s detailed statement on the issue and comments from other groups.]

News of the explosive plan, however, generated vigorous internal debate in a broader conservation community during the last week of October. Some members of Georgia ForestWatch, based in nearby Ellijay, Georgia, were definitely puzzled by the plan and the quasi-private process used by the Forest Service to define and approve the hemlock destruction plan. A top official of the Montana-based Wilderness Watch organization also engaged in that colloquy and urged the Forest Service to open its planning process to a broader constituency and to rethink the appropriateness of blowing up trees in a Wilderness.

This writer, while a member of ForestWatch, acted of his own volition in petitioning the agency on October 28 to halt implementation of its decision to dynamite hemlocks “so the proposed action can be fully re-scoped.” [Scoping is a Forest Service term of art that refers to the agency’s methods of engaging the public in planning such projects, a requirement of the National Environmental Policy Act.]

Most times, as required under the terms of the act, the Forest Service distributes “scoping” announcements of its plans to its mailing lists, and solicits written comments and questions from a fairly large number of individuals before making final decisions relating to management of the national forests. In this case, though, the agency only disclosed its hemlock proposal in a spreadsheet called the quarterly Schedule of Proposed Actions, in this case on four successive SOPA sheets during 2009-2010 (October 1 of last year and January 1, April 1 and July 1 of this year). No member of the public reacted to these brief notices.

Forest Service deflects last-minute appeal

Instead of a full scoping, the Forest Service apparently relied solely on verbal comments from a handful of organizations and arranged a telephone conference call on October 29, the Friday before the proposed beginning of the project on Monday, November 1. On the line: George Nickas, executive director of Wilderness Watch, Wayne Jenkins, executive director of Georgia ForestWatch, this writer, and three Forest Service officials with the National Forests of North Carolina.

It was to no avail. The final word came down in an e-mail from Nantahala deputy forest supervisor Monica J. Schwalbach on Sunday, October 31.

“I wanted to let you know the outcome of the conversation that I had with Forest Supervisor Marisue Hilliard and Deputy Ranger Lauren Stull after our call on Friday. I shared with her the concerns you relayed to me, including concern about the implications that our management actions could have in regard treatment of hazard trees in other wilderness areas across the country; your belief that wilderness values should be paramount above active treatment of the hemlocks for visitor safety; that the wilderness act trumps the memorial forest designation, or forest plan direction; and that instead of removing the hemlock we should consider using this as an opportunity to teach people about the impact of man's actions on the health of the environment through information and signing. I also relayed your request that we hold off implementing the project and take a second look at what the options are for addressing the problem of dead and dying hemlocks, and that we conduct broader scoping.

“Marisue, Lauren and I discussed the level of analysis already conducted, the growing concern we have about the rapid demise of hemlock in the memorial forest, the level of use experienced at that site along the national recreational trail, and our increasing concern for safety of visitors there. The overall sentiment we have is to err on the side of safety in the unique instance of the Joyce Kilmer Memorial Forest, and proceed with the hemlock removal project. We appreciate your concerns and hope that we can work together to address these types of issues into the future.”

Beginning Monday, November 1, Forest Service blasting experts lit the fuses on some $32,500 worth of explosive powder. Boom. boom, boom, tree after tree after tree, stump after stump after stump.

The Wilderness Watch position

A countervailing view was eloquently voiced by Nickas, the Wilderness Watch official.

“Wilderness Watch urges the Forest Service to reconsider its decision to remove the trees from Wilderness,” Nickas wrote in a letter filed with the Forest Service on October 26, a point reiterated during the telephone conference call. “The decision violates both the spirit and the letter of the Wilderness Act and is a sharp departure from Forest Service wilderness policy. We also urge you to keep the trails open to visitors so that those who chose to visit the area can experience Wilderness complete with all its risks and uncertainties. Visitors should be allowed to experience nature on its own terms.

“Falling trees are a natural hazard that anyone who enters a Wilderness must be willing to accept. These are not managed forests, gardens, or city parks. If visitors expect a manicured forest or a park-like experience in the Joyce Kilmer-Slickrock Wilderness, then the Forest Service has failed in its educational mission to inform visitors of what Wilderness is all about.”

Founded in 1989, Wilderness Watch’s sole focus is the preservation and proper stewardship of lands and rivers included in the National Wilderness Preservation System.

The Nickas letter continued: “Underlying the proposal is the premise that wilderness stewards should make visitors safe from natural hazards and conditions. This approach is the antithesis of Wilderness. Hazard trees are a natural part of a wilderness experience much like avalanches, flash floods, dangerous rapids, grizzly bears, and other natural elements are potential dangers to visitors. The role of wilderness stewards is to ensure that wild, untrammeled conditions are preserved for visitors seeking a wilderness experience, not to interfere in those processes so that visitors are assured of a safe and sterilized recreational outing.”

Another conservation group, Forest Service Employees for Environmental Ethics, based in Eugene, Oregon, also had weighed in with a website article on October 29, which pointedly asserted that “tree falling is precisely the kind of danger that inheres in primitive recreation; it is a risk that arises from an act of Nature.

“What makes the Forest Service decision to blow up these trees particularly ironic is that the agency took precisely the opposite position in litigation brought by hikers injured in this same wilderness when a “huge rotten tree” fell on them,’ the FSEEE article continued. [See accompanying post archive for entire article.] “In that case, the Forest Service argued that ‘the wilderness objectives of ‘solitude, physical and mental challenge, spirit of adventure and self-reliance,’ mean ‘that any trees — including rotten ones — should not be tampered with whatsoever.’ (See Wright v. United States, 868 F. Supp. 930, 931 (E.D. Tenn. 1994).”

The Forest Service itself said as much on an old bulletin board posting at the Joyce Kilmer trailhead. “As in other wilderness areas, no mechanized or motorized equipment is allowed. So, when a big tree falls, a Forest Service crew cannot use a noisy chainsaw to clear the trail. Instead, they remove sections of the tree with an old-fashioned crosscut saw. Human impact is kept to a minimum. Remember, here, nature is dominant and man comes only as a visitor.”

Forest Service planning process

The agency’s decision to do otherwise in this case is contained in a decision of June 3, 2010, as well as an accompanying “minimum requirements decision guide” used to justify the Forest Service actions. The guide detailed three alternatives considered in detail by the Forest Service to accomplish its aims:

Utilize crosscut saws to fell hemlocks, discarded because it would have taken about two months to complete the project.
Utilize external explosive charges only. Would have taken only two weeks to complete, at a supply cost of about $40,000, plus $15,000 in personnel time, travel and per diem. This plan would have required at least two certified blasters, plus an additional certified blaster “with tree climbing certification in order to vary blasting heights.”
Utilize external explosive charge method with limited chainsaw use to protect infrastructure, such as bridges. The Forest Service officials opted for this alternative on grounds that “Alternative 3 best achieves the balance between safety and wilderness character. We recognize that safety is not always the first consideration in wilderness and all considerations were considered prior to proposing Alternative 3.”

The decision guide, assuming approval by the Regional Forester, also presupposed use of chainsaws “on a case-by-case basis to fall trees that have the potential to cause damage to the trail surface or trail structures, such as bridges.

“This will be the exception to the rule and any cut stumps will be ‘fuzzed’ with explosives to mimic natural events,” the guide document said. (An agency spokeswoman subsequently added that “Forest Service personnel used crosscut saws on any trees which fell across the trail.” The decision memo also had suggested that the explosive charges would be placed “at various heights to mimic natural events, such as downdrafts or strong thunderstorms,” but it turned out that most of the stumps appear to have been severed about chest high.)

The minimum guide document also mentioned that three additional alternatives were considered but not analyzed in depth.

Allow the hemlocks to continue to degrade and fall as time progressed, said to have been “not feasible due to high visitation rates.”
Close the Joyce Kilmer national recreation trail until all the trees fell, also deemed “not feasible due to high visitation rates and the fact that this is a national and international destination of Forest visitors.”
Utilize power saws to fell hazard trees, ruled out because of the impact it would have to the Wilderness resource, including prohibited uses contained in the Wilderness Act.

That guide secured final approval from Elizabeth Agpaoa, the Atlanta-based Regional Forester for all national forests in the South, on September 13. Neither document is yet posted on Forest Service websites.

The agency has sought to explain its more recent action on another Joyce Kilmer bulletin board. “To enhance your safety, managers felled the standing dead trees in November 2010. As this is a wilderness area, the trees were felled in a way that mimics the effects of wind or ice storms. Explosives were used to bring down the dead hemlocks, instead of saws, so they would appear to have fallen from nature’s forces. The stumps and logs were not removed, but left to decay naturally.”

Further comment?

Comment below: The Moccasin Badlands Review welcomes further public discourse on this issue in the adjacent, moderated comment section, so long as contributors keep a civil tongue and sign their names to the comments. Or contact the author at jgatins@gmail.com

Contact the U.S. Forest Service: See accompanying posts for additional agency documents. And feel free to contact the officials below.

cnbrown@fs.fed.us Chris Brown, Director, Wilderness and Wild & Scenic Rivers, U.S. Forest Service Headquarters, Washington, D.C.
lagpaoa@fs.fed.us Liz Agpaoa, Regional Forester, U.S. Forest Service, Atlanta, Georgia
mhilliard@fs.fed.us Marisue Hilliard, Supervisor, National Forests of North Carolina, U.S. Forest Service, Asheville, N.C.

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