by Jim Walker : District Leader


In the summer 2014 issue of Forest News I wrote that the Cooper Creek Watershed Project is by far the most objectionable project I have seen in 12 years of forest watching. Since then the Forest Service has modified its original proposal. The new proposal, Alternative 3, is a significant improvement (Alternative 1 is no action, and Alternative 2 is the originally proposed action). In this alternative, the area to be cut is reduced from 3,754 acres to 2,591, and the area in which herbicides will be used is reduced from 3,251 acres to 1,327. Despite these changes, the new alternative is still unacceptable from Georgia ForestWatch’s perspective.

Our primary concerns are with three parts of the project:

1. 7.E.1

Everything in the project area north of Duncan Ridge is in Management Prescription 7.E.1, which, according to the Forest Plan, is “unsuitable for timber production, not appropriate.” Alternative 3 decreases the number of stands to be commercially harvested in 7.E.1 from 30 to 14 and retains 15 stands proposed for noncommercial “Midstory Treatment,” which according to the scoping notice, would be “in preparation for stand regeneration,” i.e., harvesting of almost all of the canopy sometime in the future.

Prescription 7.E.1 does permit “sales necessary to protect other multiuse values, or activities that meet other plan goals.” However, as Sarah Francisco of the Southern Environmental Law Center has pointed out, the purpose of 7.E.1 is to prevent the degradation of recreational opportunities, and there is absolutely no reason why the objectives of the proposed timber harvests must necessarily be accomplished within Management Prescription 7.E.1.

2. “Woodland Restoration”

The Forest Plan defines woodland as, “A plant community in which trees are often small, characteristically with a greater proportion of their total height being crown than clear bole, and having trees spaced far enough apart that the canopies of adjacent trees usually do not touch and with the ground vegetation being mostly herbaceous, commonly grass.” There are very few naturally occurring areas conforming to this definition anywhere on the Chattahoochee National Forest, and the ones that can be found are very small, much smaller than the 720 acres proposed for “woodland restoration” in the Cooper Creek Watershed Project. Certainly there was a significant amount of open canopy when the mountains were full of people farming and cutting timber, but there is absolutely no evidence that a natural, self-sustaining woodland ever existed on this site.

Creation of woodland on a site like this requires cutting most of the trees, application of large amounts of herbicide, and frequent burning. All of this has been done at Brawley Mountain since the implementation of that project began in 2010, and so far the results are questionable at best.

The Introduction to the Forest Plan says that the Plan is based on “an adaptive management approach,” which means “practicing restorative ecosystem management with the understanding that we are students of nature, not masters of it.” As “students of nature,” the Forest Service should not attempt any extensive creation or “restoration” of woodland until it has demonstrated that it is capable of doing this on a much smaller scale, and even then only on sites that show clear signs of having supported natural woodland in the past.

3. Bryant Creek

Most of the Cooper Creek Watershed Project is concentrated in the watershed of Bryant Creek, a tributary of Cooper Creek. Some kind of treatment, mostly commercial timber production, is proposed for over 80% of the stands in that watershed. Alternative 2 calls for treatment of 1,707 acres in the Bryant Creek watershed, of which 104 acres were dropped in Alternative 3.

Bryant Creek is one of the largest and best, if not the very best, native brook trout streams in Georgia. Because native brook trout cannot adequately compete with stocked, non-native rainbow and brown trout, significant brook trout populations persist only above some barrier that keeps out the non-natives. Bryant Creek has such a waterfall barrier. In 2012, the Forest Service spent $170,000 to replace an old, deteriorating culvert with a new, bottomless arch where FS33A crosses Bryant Creek to connect brook trout habitat above and below the site.

In regard to brook trout habitat, Michael Joyce, the ChattahoocheeOconee National Forests’ Fisheries Biologist, has written, “Historic land use practices resulted in increased sediment into streams, which caused them to widen, resulting in shallow water depths with long stretches of homogenous run/glide habitat. The shallower water can lead to increased water temperatures. … Over the years the Chattahoochee National Forest has matured and most areas, including riparian areas, are well vegetated. This has resulted in a reduction in sediment delivery to the streams. … In addition, … brook trout populations are also subjected to extreme conditions as a result of droughts, warm summer water temperatures and flood events.”

And yet the Forest Service, counter to its own concerns about the future of brook trout and its efforts to protect them, is proposing a cumulative disturbance on the Bryant Creek watershed such as never been seen since the clearcutting era decades ago. The proposed timber harvest, with extensive temporary roads, skid trails, and landings, cannot fail to increase siltation, and removal of half or more of the canopy may raise water temperatures beyond what brook trout can tolerate.

The Forest Service’s draft Environmental Assessment finally came out in late December, and responses are due by February 5th. Georgia ForestWatch will have a lot to say, but we also need your help. Please let the Forest Service know how special the Cooper Creek area is. More information on how to comment can be found on our website at