The Sierra Club Georgia Chapter, along with partners Georgia ForestWatch and Southern Environmental Law Center (SELC), has filed an objection to the Cooper Creek Watershed Project on the Blue Ridge District of the Chattahoochee National Forest.
In the spring of 2014, the Blue Ridge Ranger District of the Chattahoochee National Forest released plans for the Cooper Creek Watershed Project — a problematic plan at best. After the Forest Service released a Draft Environmental Analysis (EA) at the end of 2015, the Georgia Chapter delivered thousands of written comments from concerned citizens to the Blue Ridge District. In January 2018, the District released a Final EA and Draft Decision Notice on the Cooper Creek Project with a Finding of No Significant Impact (FONSI). We do not agree that there are no significant impacts to the environment with the current proposal and submitted an administrative objection in March with our partners Georgia ForestWatch and SELC.
Our objection focused on the following issues:
- The EA violates NEPA by failing to take a “hard look” at impacts to the following roadless areas: the Duncan Ridge roadless area, Board Camp roadless area, and Cooper Creek scenic area extension. To meet its “hard look” obligations, the Forest Service must consider the effects of logging and road building on currently unroaded areas, regardless of whether those areas have been formally designated “inventoried roadless areas.”
- The EA violates the National Forest Management Act’s requirements related to lands suitable for timber production. Over 300 acres of commercial logging is proposed in an area that the Forest Service previously designated for dispersed recreation and “unsuitable for timber production.” Compounding this error, the agency proposes to create early successional habitat in this area in excess of Forest Plan limits.
- The EA’s reliance on undisclosed mitigation measures to justify a No Significant Impact Finding for sedimentation effects on Bryant Creek is unsubstantiated and violates NEPA. Given the type of soils and intensity of cutting in the Bryant Creek watershed, there is a significant sedimentation risk to one of the best native trout streams in Georgia. Under NEPA, an agency can only rely on mitigation measures if it provides some evidence of their efficacy, which the Forest Service has not done.
- The Forest Service violated NEPA by failing to adequately consider project alternatives proposed by Georgia ForestWatch, Sierra Club - Georgia Chapter, and SELC. Our proposed Alternative Four involved the same management activities (e.g., thinning, canopy gap creation, early successional habitat creation, etc.) as the preferred project alternative, but in different quantities and locations in the project area.
The Forest Service’s proposal, released as part of a draft environmental assessment, would bring some 2,500 acres of cutting to the Cooper Creek and surrounding watersheds in Union County and lead to increased greenhouse gas emissions. The Forest Service originally announced the Cooper Creek Watershed Project in May of 2014 with a plan that would have cut 3,500 acres of trees in the Cooper Creek, Coosa Creek, Youngcane Creek, and Bryant Creek watersheds in North Georgia. The Forest Service has proposed a number of treatments but in most cases, half the trees would be cut.
These watersheds make up one of the most spectacular areas of the Chattahoochee National Forests and play host to a variety of recreational activities serving people from local communities and from across North Georgia.
The Cooper Creek Watershed Project is the most objectionable forest management project proposed since the clear cutting of the 70s, 80s, and 90s before a lawsuit by the Sierra Club and Georgia Forest Watch halted clearcutting.
The Georgia Water Coalition selected the Cooper Creek Watershed Project for inclusion on its 2015 Dirty Dozen list as one of the 12 worst offenses to Georgia’s waters.
The Forest Service has heard the concerns raised by the Wildlands & Wildlife Committee and is working with the Sierra Club and other groups to improve the project. View the Forest Service’s complete project record for Cooper Creek here.
While we continue to put pressure on the Forest Service to address all of our concerns, it is important to note the progress we have made. Thanks to our many members and volunteer activists who submitted comments, along with the combined efforts from other organizations, we not only increased awareness of the dangers of this project but were also able to effect significant changes as evidenced in the recent decision. Although problematic pieces of the project remain, positive changes have been made. This could not have happened without your support!
Water Issues
Cooper Creek, Coosa Creek, and Youngcane Creek are important streams located in Union County, Georgia. These watersheds combined contain 34,018 acres of National Forest Lands and 60,371 acres of land in total, and they contain 11 management prescriptions, including Designated Wilderness, Appalachian Trail Corridor, and Outstandingly Remarkable Streams. These watersheds support a variety of recreational activities, including fishing, canoeing, camping, hiking, and hunting. Cooper Creek is a seasonal trout stream. The Toccoa River is becoming one of Georgia’s most popular canoeing streams.
The waters from these streams also nourish old growth forests, and some of the southernmost stands of hemlocks and white pines grow along the banks of Cooper Creek. The project as proposed contemplates removing half the mature White Pines through commercial logging on over 1000 acres bordering these streams.
Threats posed by the project
Photo of the Brawley Mountain Project courtesy of Larry Winslett.
The Forest Service’s stated goals for this project include protecting native plants, restoring wildlife habitat and improving forest health. However, the project threatens to significantly disrupt one of Georgia’s healthiest forests and would increase greenhouse gas emissions while reducing an important carbon sink, but the Forest Service fails to provide meaningful analysis as to how this project will affect climate change.
The Cooper Creek Project will cause irreversible damage to the watershed because the project includes cutting on steep slopes.
Under the National Forest Service Management Act, the Forest Service can only harvest timber when it will not irreversibly damage watershed conditions. Such conditions exist when nutrient-rich soil is displaced through tree removal causing accelerated erosion. Logging on steep slopes under the best of circumstances causes the soil to be more susceptible to erosion.
Erosion caused by logging steep slopes is especially a threat with the Cooper Creek project, as over half the proposal, 1,900 acres, includes cutting on steep slopes greater than 35%. Georgia’s best management practices caution against logging on slopes greater than 35%. The threat of extreme weather events attributable to climate change compounds the risks associated with this project.
The Cooper Creek Project will cause Increased sedimentation from road construction impairing its fish habitat.
The 2012 Georgia list of impaired streams includes several watersheds in the project area due to their inadequate fish habitat. The Cooper Creek Watershed Assessment recognizes that impacts to these watersheds are due to excessive sedimentation, identifying old roadbeds as one of the causes. The existing permanent Forest Service road system in the Coopers Creek watershed is also clearly a source of sedimentation. All one has to do is to visit the area during a rain event to witness streams of red mud flowing off the roadways into the various streams that make up the Coopers Creek watershed. The Forest Service does not have appropriated funds sufficient to maintain the road system that exists on the Forest and it is reckless to embark on a large scale project such as this which will require the construction of many new miles of ‘temporary ‘roads in one of Georgia’s prime Brook Trout habitats.
The Cooper Creek Project will disrupt wildlife and threaten human health with the application of dangerous herbicides.
The Cooper Creek Project would employ the use of chemical herbicides to control plant growth after cutting. While the currently available project documents do not specify what herbicides the Forest Service would use in this project, the Forest Service has in the past used herbicides, like glyphosate, that have been linked to cancer in humans and that destroy critical habitat for native pollinators.
The Cooper Creek Project will increase greenhouse gas emissions while reducing an important carbon sink.
The Forest Service acknowledges that this project will lead to increased carbon emissions mainly be reducing the carbon sink provided by the forest. Unfortunately, the Forest Service has not provided a detailed assessment of how much the project might increase greenhouse gas emissions, but it has noted that rising temperatures caused by climate change are a major threat to the water resources in the project area.
Decision Point
The most effective action that could be taken to protect Cooper Creek, Coosa Creek, and Youngcane Creek would be for the US Forest Service to employ science-based ecological restoration that maintains the forest in a natural, undeveloped state and to end commercial logging and the construction of related roads on federal publicly owned lands. The increased runoff and other factors resulting from these destructive activities pose the greatest immediate threat to these pristine waters. A more tailored approach would be for the Forest Service to better align this project with its Land and Resource Management Plan for the Chattahoochee-Oconee National Forests by eliminating cutting on steep slopes and to remove areas under Management Prescription 7.E.1, “Dispersed Recreation Areas,” from the project during the current National Environmental Protection Act review process.
The Forest Service should also avoid the use of herbicides that could threaten human health and wildlife.
The Forest Service must include a better recognition of how this project will affect climate change. The Forest Service acknowledges that the project will lead to an increase in greenhouse gas emissions and should take steps to assess by how much it will increase emissions. The Forest Service should also describe how the plan will affect species whose ranges are shifting because of climate change, and the plan should provide steps for adapting to climate change in a way that best ensures the survival of species. The Sierra Club believes that protecting and maintaining ecosystems in their natural, undeveloped state will best preserve and maintain ecosystem services that we use and enjoy, as well as increase carbon pools, and should be prioritized.
Resources
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The Sierra Club Wild Legacy conservation initiative seeks to engage a broad spectrum of citizens around the value of protecting wildlife, public lands and special places and block threats to these lands from commercial logging, mining, abusive recreation, and overgrazing. We need your help to fulfill these visions!
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