MountainTrue’s Analysis of Henderson County’s Draft Comprehensive Plan

MountainTrue’s Analysis of Henderson County’s Draft Comprehensive Plan

MountainTrue’s Analysis of Henderson County’s Draft Comprehensive Plan

Update: We have added detailed analysis and recommendations to improve the Comprehensive Plan further down on this page. We are providing these recommendations to the Planning Board and Henderson County Commissioners. Scroll down to view.

On September 9, 2022, Henderson County released the first draft of the 2045 Henderson County Comprehensive Plan. You can view a virtual presentation about the draft plan here. MountainTrue is conducting a full analysis of the draft plan and will provide a detailed set of recommendations to the Henderson County Planning Board and County Commissioners to ensure that the plan addresses the priorities of county residents as reflected in the county’s own survey*.

The draft plan will guide Henderson County’s growth and services for the next 20 years. Overall, the draft plan includes a strong set of goals that MountainTrue fully supports. Those goals, found on p.34 of the draft plan, include:

  •  Coordinate development near existing community centers.
  •  Protect and conserve rural character and agriculture.
  •  Improve resiliency of the natural and built environments.
  •  Prioritize multi-modal transportation options and connectivity.
  •  Create a reliable, connected utility and communication network.
  •  Stimulate innovative economic development initiatives, entrepreneurship, and local businesses.
  •  Diversify housing choices and availability.
  •  Promote healthy living, public safety, and access to education.

These goals provide a solid foundation for a 20-year plan. MountainTrue’s recommendations below offer targeted strategies to help the county achieve these goals. We start, however, with one glaring omission in the draft plan.

Primary Recommendations

Include a Detailed Implementation Plan
The County Commission’s adoption of the comprehensive plan is just the first step towards realizing the goals within. The real challenge comes in translating the plan’s strategies into the day-to-day operations and actions of the government, and in making the plan work in concert with the County’s other strategic actions and policy documents. To date, the draft plan and recently released draft appendix do not include any guidance for implementing the plan’s recommendations. 

The 2020 Comprehensive Plan, adopted in 2004, is widely considered a success, as the county has accomplished a majority of the plan’s goals. This was no accident. That plan contained a detailed implementation schedule that held our county leaders accountable while allowing the public to track our progress. Henderson County needs to draw on this past success to ensure that the 2045 plan accomplishes its goals rather than gathering dust on a shelf. 

We strongly recommend developing a process to implement the plan’s priority strategies and track plan progress. Various ways to ensure the implementation of the plan include:

  • Establish a single point of contact who will oversee the plan’s implementation. This will ensure accountability and continuity in the years that follow adoption.
  • Form a county team with representatives from key departments who will meet to track the plan’s progress, develop action items to implement strategies, educate staff about the plan’s goals, and help shape departmental work plans around the Comprehensive Plan.
  • Review plan progress with applicable boards and commissions and recommend new priorities to the County Commission.
  • Conduct an annual report on progress of the plan to the County Commission and set priorities.
  • Evaluate the viability of the plan every three to five years, and update the plan accordingly.

Don’t Expand the Utility Service Area
We encourage the City of Hendersonville and the County to share in decision-making around where sewer services will go. The county should have representation on the City’s water and sewer governing bodies, have a say in where the pipes extend throughout the county, and whether annexation follows those pipes. Therefore, the county must work closely with municipalities to direct new growth where infrastructure already exists.

Expanding the Utility Service Area (USA) to include Edneyville and Etowah will only encourage the development of new sewer that exceeds the current needs of these communities. This is a recipe for suburban sprawl all along the US 64 corridor. We do not support the current draft Future Land Use Map calling for commercial shopping centers and dense infill development in Edneyville or Etowah, as the existing infrastructure in these communities cannot support such development. We recommend maintaining the Central USA, as presented in the 2020 Henderson Comprehensive Plan.

We do not support the residential density described in Infill Area (formerly Medium Density Residential) designations in the more rural areas of the county outside the Central USA, including Etowah and Edneyville’s proposed USAs. The density allowed within Infill Areas (8-14 units/acre) would likely require new sewer service or package plants, spurring additional suburban sprawl to areas of the county lacking the infrastructure and road networks to absorb such volume.

We also do not support the amended density allowances in the new Transitional Area (formerly Low Density Residential) designation, as this will drive suburban sprawl into the Tuxedo, Dana, and Gerton communities — all found well outside the Central USA. Allowing for developments as dense as quarter-acre lots would tax our existing roads and alter the rural character of these communities.

Address Water Quality Concerns in Edneyville and Etowah
Wastewater seriously impacts water quality, and the county should invest wisely in wastewater infrastructure. We strongly encourage Henderson County to address water quality concerns in Edneyville and Etowah without inviting suburban sprawl into these communities. 

Edneyville: Adding another municipal sewage treatment plant in the Mud Creek watershed may contribute to water quality concerns. Edneyville’s existing uses (Edneyville Elementary, the Training Academy, Camp Judaea, etc.) should tie into the city’s existing sewage treatment system, and the city should refrain from annexing these rural areas, as they lie outside the Central USA.

Etowah: It is foreseeable that Etowah’s aging private sewer system may one day be acquired by the Metropolitan Sewer District, given its proximity to MSD’s existing network. By connecting Etowah to MSD’s system, Etowah’s capacity for development could significantly increase in the next 20 years. With the highly anticipated construction of the Ecusta Trail about to begin, we must take measures to preserve the trail’s rural character that makes it such an attractive destination. 

Additionally, any expansion of sewer infrastructure should be constructed with limited capacity to service only existing businesses and residences without facilitating future growth. The county should implement strong land use protections to prevent sprawling and high-density residential development, high-intensity and industrial uses, and other uses outside of the Central USA that compromise the rural character and agricultural heritage of the area. 

Provide More Housing Options in the Central Utility Service Area
When people think of housing choice, they usually default to single-family homes or large apartment complexes. But we are missing the opportunity to provide new homebuyers and renters a wide array of housing choices, many that are more affordable than what the current market provides. 

To offer more housing choice in the areas that can best support it – the Central Utility Service Area – we recommend broadening the types of housing that can be developed in traditional single-family neighborhoods. Remove restrictive zoning that stands in the way of modest infill development, like duplexes, triplexes, and townhouses. Within the Central USA, we recommend amending the Infill Area zoning designations to include ADUs, townhouses, duplexes, and triplexes. We also support the new density allowances for Transitional Areas within the Central USA, as this housing would be located closer to the services, jobs and infrastructure already concentrated in our municipalities.

Adopt a Voluntary Land Conservation Fund
We fully support the development of a fund that focuses on preserving working farmland and parcels key to greenway, park, and recreational opportunities, and sensitive natural areas. Consider a bond referendum to establish the fund. Focus on the Purchase of Development Rights to preserve working farms and make them more affordable to new farmers. Consider easements that would improve water quality protection.

Consolidate and Strengthen Steep Slope Controls
Current steep slope regulations are found scattered throughout the Land Development Code, making it difficult to assess their impact on ensuring public safety, protecting water quality, and preserving scenic mountain views. Residents and developers would be better served if the steep slope controls were consolidated, transparent, and more concise. We applaud the Planning Board’s recent efforts to address this, and we encourage the county to include such improvements in the draft plan.

*The county has published a second public input survey. Click here to take the new survey.

Additional Recommendations & Further Details

In addition to our primary recommendations, MountainTrue makes the following suggestions specific to various recommendations found in the draft plan:

FUTURE LAND USE MAP (pp.38-44)

MountainTrue: We question whether the Dana community can support the recommended Industrial & Employment land use designation without sewer service. 

GOAL 2: PROTECT AND CONSERVE RURAL CHARACTER AND AGRICULTURE

R. 2.1.E. (p.57): Encouraging small businesses in rural areas can indirectly support agriculture by allowing non-farm income.
MountainTrue: To encourage appropriate small business development and maintain the rural and agricultural character of these areas, we recommend limiting the square footage of new structures and specifically defining what small-business activities are preferred in Agriculture / Rural Districts.

Rec 2.2.B. (p.58): Create a Voluntary Farmland Preservation Program to purchase farmland development rights and establish agricultural conservation easements.
MountainTrue: We recommend amending the Land Development Code to require that eligible applicants meet specific environmental standards or implement appropriate “best management practices” that protect water quality, such as undisturbed stream buffers.

Rec. 2.2.C. (p.58): Study potential mechanisms for private transfer of development rights program to allow for the transfer of density away from agricultural and natural resource areas to designated receiving areas.
MountainTrue: We strongly support the county in investigating a potential transfer of development rights program and would be willing to advocate for state authorization to provide Henderson County with this valuable conservation tool.

Rec. 2.3.C. (p.58) Consider zoning updates to reduce development pressure in agricultural areas.
MountainTrue: We recommend exploring new incentives to give farmers multiple options to preserve the working lands. We do not support the concept of downzoning Agricultural / Rural districts, such as requiring five-acre lot minimums, as this will only accelerate the development of undisturbed areas, while serving the few that can afford to purchase larger lots.

Rec. 2.4.A. (p.59): Provide incentives for revitalizing existing commercial and industrial sites.
MountainTrue: We strongly support this and encourage the Commission to prioritize commercial and industrial sites closest to main transportation corridors and in areas already serviced by existing water and sewer to disincentivize sprawl. 

Rec. 2.4.B. (p.59): Focus on higher-density housing closer to the city to reduce sprawl, provide affordable housing for the workforce, and relieve pressure on roads.
MountainTrue: We strongly support this designation, but we also recognize this requires coordination with municipalities, including participation in Hendersonville’s upcoming comp planning process. We encourage County staff and leadership to engage Hendersonville in developing plans that focus higher density development in appropriate areas already served by sewer and water, located closest to job and commercial centers, schools, and services.

Rec. 2.4.C. (p.59): Encourage industrial growth in areas away from large concentrations of farmland and agricultural operations.
MountainTrue: We question whether industrial uses and agricultural operations are mutually exclusive. Given the low residential density in such districts, there may be opportunities to cite appropriate industrial uses near working farmland, concentrating such activities away from established residential areas.

Rec. 2.4.D. (p.59): Carefully evaluate potential utility extensions that could impact large concentrations of productive farmland.
MountainTrue: See our Primary Recommendations above re: Edneyville and Etowah sewer expansion. 

GOAL 3: IMPROVE RESILIENCY OF THE NATURAL AND BUILT ENVIRONMENTS

GOAL 3 (p.60): Where risk reduction is not possible, careful planning and strengthening emergency response will help make recovery faster and more efficient when hazards do occur.
MountainTrue: We recommend: “Where risk reduction is not possible, careful planning could mitigate the impact of extreme events, thus reducing the costs of recovery for both private and public funds. Similarly, strengthening emergency response will save taxpayer dollars…”

Rec. 3.1.C. (p.60): Consider allowing for administrative approval for conservation subdivisions that meet certain criteria (i.e. are under a density threshold, have a minimum amount of open space, reserve priority open space types, and meet access standards).
MountainTrue: While we support this concept, we’ll note that administrative approval for conservation subdivisions works only if the thresholds are well defined. We recommend examining existing regulations and streamlining the project permitting and approval process so that development decisions are more timely, cost-effective, and predictable for the community and home builders.

Rec. 3.1.E. (p.61): Limit development on steep slopes and mountain ridges.
Rec. 3.3.C. (p.63): Discourage the amount of land disturbed in steep slope developments, including construction of roads, as well as decrease density.
MountainTrue: We strongly support these recommendations and would be willing to provide model ordinances from similar communities that have addressed steep slope development.

Rec. 3.3.D. (p.63): Continue to limit fill in floodplains unless additional standards are met.
MountainTrue: Under this recommendation, the County could further restrict the use of floodplains. Consider that multiple scientific studies now show that 100-year floods are increasing in frequency, including a Yale Environment study that predicts that Southeast counties like Henderson could experience such floods every one to 30 years.

Rec. 3.3.G. (p.64): Adopt best practice design standards for new construction within the wildland/urban interface.
MountainTrue: While we agree with this recommendation in concept, we seek clarification of the definition of “wildland/urban interface,” as the Future Land Use Map makes no reference to such designation. 

Rec. 3.4.E. (p.64): Educate the community and developers regarding green infrastructure projects, as well as state and federal rebates and tax incentives, which can lessen stress on natural systems.
MountainTrue: We strongly support this, and encourage the County to consider expanding streamside buffers to protect water quality. 

GOAL 4: PRIORITIZE MULTI-MODAL TRANSPORTATION OPTIONS AND CONNECTIVITY

Rec. 4.1.C.
Advocate for the French Broad River MPO (Metropolitan Planning Organization) to update the Comprehensive Transportation Plan, which was adopted in 2008, and focus improvements around active transportation options and transit.
MountainTrue: We strongly support this and ask the County to consider extending transit services to employment and commercial centers beyond the Central Utility Service Area. 

Rec. 4.2.B. (p.68): Consider reducing Henderson County’s Traffic Impact Study (TIS) threshold for developments located along specific road classifications.
MountainTrue: We support a reduction in traffic study thresholds in conservation/rural/ag-zoned areas, and recommend increasing the threshold for traffic studies in areas appropriate for denser development.

Rec. 4.2.D. (p.68): Consider amending the Land Development Code to allow for the integration of residential and commercial uses to allow for shorter travel time between destinations.
MountainTrue: Mixed-use developments are beneficial to combating sprawl, but the plan needs to specify where mixed-use would be deemed appropriate. Community centers and neighborhood anchors appear to be the most appropriate locations for mixed-use development. There will need to be adequate infrastructure already in place to support this level of development.

Rec. 4.3.A. (p.68): County staff should continue to seek grant funding (through the French Broad River MPO and other sources) for corridor studies along primary roadways throughout the county.
MountainTrue: We fully support commissioning a study of the Ecusta Trail corridor to inform appropriate land use designations along its path.

Rec. 4.3.B. (p.68): Establish a vision for significant roadway corridors and their surrounding land use, with input from the community they serve.
MountainTrue: This visioning process can be folded into an updated small-area planning process for Edneyville and Etowah. We would be willing to assist with gathering public input to inform these plans.

Rec. 4.3.D. (p.68): Support NCDOT with the ongoing corridor studies for US-64.
MountainTrue: This corridor study must consider future land-use recommendations for Edneyville and Etowah. We believe that an inappropriate expansion of sewer service in these communities will increase congestion along US 64 and contribute to suburban sprawl and loss of working farmlands.

Rec. 4.4.C. (p.69): Conduct studies of the transportation network surrounding County schools to identify deficiencies in safety and access.
MountainTrue: There is a critical need to address Etowah Elementary School and Etowah Park. We recommend investigating the Safe Routes to School program. We also recommend the County commission a bike/pedestrian connectivity study.

Rec. 4.5.C. (p.69): Initiate a study of Apple Country Public Transit to identify whether fare rates are a barrier to the use of the bus system and study the feasibility of a fare-free system.
MountainTrue: We support this and encourage the County to investigate the benefits of a fare-free system. 

Rec. 4.5.G. (p.70): Explore mechanisms to provide express routes to connect Hendersonville to Asheville and other destinations in Buncombe, Madison, and Haywood County, while focusing on regional mobility management, employee training, maintenance, and funding administration.
MountainTrue: We strongly support this and recommend advocating for transit connections to employment centers in Buncombe, Madison and Haywood counties to reduce traffic congestion along the primary north-south transportation corridors like I-26, US 25, and NC 191. We encourage the County to coordinate the comprehensive planning process with the ongoing planning process in Buncombe County.

Rec. 4.5.H. (p.70): Create connections between transit and greenways to help reduce traffic, vehicle miles traveled, and the county’s carbon footprint.
Rec 4.7.E. (p.71): Coordinate with the Rail Trail Advisory Committee, Transportation Advisory Committee (TAC), Planning Board, and Recreation Advisory Board on priority greenway implementation.
MountainTrue: We strongly support these recommendations and suggest hiring a sustainability coordinator to lead this important work.

Greenway and Sidewalks Map (p.73)
MountainTrue: Add language/graphics denoting the future regional Hellbender Trail and potential connections.

GOAL 5: CREATE A RELIABLE, CONNECTED UTILITY AND COMMUNICATION NETWORK.

Rec. 5.3.C. (p.75): Require conservation subdivision designs for all new major residential subdivisions residential growth in unincorporated areas tied to sewer infrastructure.
MountainTrue: We strongly support this and can provide Best Management Practices and precedent for sound conservation subdivision designs.

Rec. 5.4 (p.75): Take a leadership role in sewer and water planning by helping to foster intergovernmental cooperation.
MountainTrue: As stated in our Primary Recommendation, we fully support the County and Hendersonville to work together to address sewer expansion that does not promote suburban sprawl, while addressing current water quality concerns.

Rec. 5.4.B. (p.75): Conduct interchange studies with the City to evaluate and prioritize the development potential of key interchanges for future commercial and/ or industrial development.
MountainTrue: We strongly support collaborating with the City to coordinate development with existing sewer and water services.

Rec. 5.4.C. (p.75): Begin the development of a three, five, or ten-year capital improvement program and capital reserve fund to help implement planned investments in sewer infrastructure and other services.
MountainTrue: This requires coordination with MSD’s Capital Improvement Program and Hendersonville’s sewer & water services. We strongly encourage the County and City to work together on this.

Rec. 5.4.D. (p.75): The Environmental Health Department should identify areas of septic failure, areas where future septic systems may fail, and address these through existing remediation programs and by leveraging state and federal grants.
MountainTrue: We strongly support this and will work with our Legislative Team to advocate for adequate state funding.

GOAL 6: STIMULATE INNOVATIVE ECONOMIC DEVELOPMENT INITIATIVES, ENTREPRENEURSHIP, AND LOCAL BUSINESSES

MountainTrue: Add “conservation and outdoor recreation, bike/ped/transit” to initiatives, as they will bring in the kind of businesses the community desires.
Rec. 6.4 (p.79): Facilitate placemaking efforts to reinforce community character and attract businesses and investment.

MountainTrue: We strongly support this and would be willing to assist in community engagement around such placemaking efforts.

GOAL 7: DIVERSIFY HOUSING CHOICES AND AVAILABILITY

Rec. 7.1.B. (p.80): To avoid conflict with agricultural areas and natural resources, major subdivisions should be located near defined centers and within Medium and Low Density Residential areas as defined on the Future Land Use Map.
MountainTrue: Discourage rezonings for higher-density residential subdivisions outside the defined Utility Service Area and within the Agricultural/Rural districts identified on the Future Land Use Map.

Rec. 7.1.C. (p.80): Allow for a variety of housing types, including condos, townhomes, and multi-family complexes, in the defined Urban Service Area.
MountainTrue: We strongly support this and recommend that “missing middle” developments, including Accessory Dwelling Units, townhouses, duplexes, and triplexes, be allowed by right in Medium Density Residential districts. 

Rec. 7.2.E. (p.81): Continue to allow for manufactured homes in designated zoning districts in the county.
MountainTrue: Consider allowing manufactured homes by right in all residential districts. They represent the last option for truly affordable housing in the region.

Rec. 7.3 (p/82): Support the ability to “age in place.”
MountainTrue: Include language encouraging the implementation of Universal Design best practices that create homes that are accessible and habitable for all ages and abilities.

GOAL 8:PROMOTE HEALTHY LIVING, PUBLIC SAFETY, AND ACCESS TO EDUCATION

Rec. 8.1.B. (p.84): Address facilities and programming priorities, document ongoing maintenance needs, and provide benchmarking related to facilities and staffing within a master plan.
Rec. 8.1.E. (p.84): Develop a master plan for Jackson Park. The master plan should address connectivity, parking issues, and facility enhancements, and involve a variety of user groups.
MountainTrue: Jackson Park is already at capacity for hosting recreational events. We recommend expanding master planning efforts to encompass all county park facilities.

Rec. 8.1.L. (p.85): Require major subdivisions to provide pedestrian connections or provide easements to immediately adjacent greenway facilities.
MountainTrue: We support establishing concurrent sewer/trail easements where sewer expansion is permitted.

Rec. 8.3.  (p.86): Expand healthy food access.
MountainTrue: Add “F. Continue support for a food waste program.”

2022 Volunteer of the Year and Esther Cunningham Award Winners

2022 Volunteer of the Year and Esther Cunningham Award Winners

2022 Volunteer of the Year and Esther Cunningham Award Winners

Every year, MountainTrue recognizes five individuals from across the Southern Blue Ridge as our regional Volunteer of the Year and Esther Cunningham award winners. We look forward to celebrating these exceptional MountainTrue volunteers at our 40th Anniversary Celebration on October 12, 2022:

High Country Volunteer of the Year: Hayden Cheek

Hayden (pictured above) works at a local fly shop in Boone, NC. He’s an excellent angler and guide, and he often goes above and beyond to take care of his local waterways. His practice of giving back and leaving our rivers and woods better than he finds them permeates his friendships, work relationships, and his career. He’s a consistent water quality volunteer with our High Country water quality team and his impact is being passed on to those fortunate enough to spend time with him on the trail or in the river. Thanks so much for all you do, Hayden!

Central Region Volunteer of the Year: Jim Clark

Jim Clark has been helping us clean up the French Broad River for years. He’s been a Swim Guide volunteer for nearly ten years and has been a part of our microplastics sampling team from the very beginning. The data he’s gathered at Pearson Bridge has helped to get the new Real-Time E. coli Estimator (created in partnership with NCDEQ) up and running. He’s gone out of his way to keep trash out of the river, including lugging dozens of heavy, muddy tires out of its reach. Thanks for all your hard work to make the river a better place, Jim!

Western Region Volunteer of the Year: Stacey Cassedy

This year, Stacey has volunteered with both of our Adopt-A-Stream water quality monitoring programs (water chemistry and E. coli) and our Swim Guide program. Stacey’s unwavering dedication to our weekly Swim Guide sampling program helped many folks from across the Western Region know where it was safe to swim this summer! When her sampling site failed for the first time in August, she returned to resample and continued to check and photograph the beach for several additional days to monitor the source of the pollution: goose droppings! Stacey has offered to help with festival tabling events and is interested in doing anything needed to help with MountainTrue’s mission, particularly in the water quality program area. She’s a true super volunteer!

Southern Region Volunteer of the Year: Don Cooper

When Don learned about high bacteria levels in his community’s local waterways, he sprung to action and rallied the support of his fellow Rotarians. With his leadership, dozens of volunteers collected hundreds of water samples from streams in and around Hendersonville over the last several years. The data generated from his efforts helped us isolate the sources of bacteria pollution and direct our advocacy resources in the right direction to make meaningful change for water quality and public health. Thank you so much for your leadership, Don!

The 2022 Esther Cunningham Award Winner: Grady Nance

This award is given each year in honor of one of our organization’s founders, Esther Cunningham. Esther bravely stood in the face of opposition, rallied her community to stand with her, and tirelessly fought to protect and defend the forests of Western North Carolina. 

Grady and his wife, Kathleen, have been MountainTrue members since 2015. In that time, Grady has repeatedly stepped up to support MountainTrue and our region in a number of ways.  Grady spent his career in the electric utility industry and has been a crucial resource to our energy-focused work, especially as we were working both in opposition to and in partnership with Duke Energy. Grady also served on the Henderson County Environmental Advisory Committee for several years, pushing the county to do more in terms of energy efficiency and renewable energy. Finally, and perhaps most importantly, Grady has served on MountainTrue’s board as our treasurer since 2019. He has acted more like a CFO than just a board member and has been enormously helpful as our budget and the complexity of our budgeting have grown. Grady also says yes to every request we make of him. He has been a thoughtful, conscientious, and diligent board member and treasurer, and we will miss him terribly when he rolls off the board at the end of this year. Because of his commitment and service to MountainTrue and his dedication to the environment, we are pleased to award him with the 2022 Esther Cunningham Award.

ACTION ALERT: Protect Our Forests and Farms from Sprawl

ACTION ALERT: Protect Our Forests and Farms from Sprawl

ACTION ALERT: Protect Our Forests and Farms from Sprawl

We need you to email the Henderson County Board of Commissioners to ask them to take action to prevent sprawl and protect our forests, farmland, and rural communities.

Henderson County is drafting its new Comprehensive Plan — the blueprint that will guide growth and development here for the next twenty years. As part of that process, they have surveyed members of our community, and that survey shows broad support for conservation.

Henderson County residents identified:

  • protection of open spaces and forests (55.30%),
  • farmland preservation (45.16%), and
  • conservation (35.04%) of unique natural areas

as their top 3 priorities for the 2045 Henderson County Comprehensive Plan.

Unfortunately, MountainTrue has serious concerns that the comprehensive plan being created by the county’s consultants is out of step with the desires and needs of Henderson County residents. The County has circulated a draft Future Land Use Map that prioritizes sprawl — development that spreads too far into the countryside, unnecessarily destroying forests, farmland, and rural communities — at great expense to taxpayers and against the desires of county residents.

So we need you to act today. Email your Henderson County Commissioners, and ask that they adopt a smart, responsible and sustainable comprehensive plan.

Watch: How Henderson County can accommodate growth without sprawl.

Chris Joyell, MountainTrue’s Healthy Communities Director, discusses how Henderson County can welcome far more population growth than the state anticipates without causing sprawl. Watch.

Learn More About the Henderson County Comprehensive Plan

Henderson County’s new Comprehensive Plan will serve as the blueprint for growth and development over the next twenty years. Learn about how this plan will help determine how our communities grow and develop to meet the challenges of climate change, a growing population, and increased pressures on our built environment.

Get Your Gardening Gloves on Our New Native Planting Guide

Get Your Gardening Gloves on Our New Native Planting Guide

Get Your Gardening Gloves on Our New Native Planting Guide

MountainTrue has published a brand new guide to help you replace harmful non-native invasive plant species with native alternatives that benefit wild birds, hummingbirds, butterflies, and other wildlife. This beautifully designed and durable guide conveniently folds up to fit in your wallet — perfect for your next visit to the garden center or nursery. 

How can you get one? Guides are available for free at invasive plant workdays and events.

  1. Sign up to volunteer for one of our workdays or join us for a hike
  2. Meet us at a tabling event.
  3. Buy one for $5 and get it mailed to your door by filling out the form below.

Want free copies for your neighbors, gardening club, or organization? Contact bob@mountaintrue.org to arrange for one of our Resilient Forests staff to present to your group and bring free copies for all.

Want to purchase multiple copies for personal use? Contact members@mountaintrue.org.

2021 State of the River Reports

2021 State of the River Reports

2021 State of the River Reports

The 2021 State of the River Reports are finally here! In this blog, we’ll discuss the cleanliness and water quality of the French Broad, Broad and Green, and Watauga River watersheds. 

There are four sets of data that MountainTrue uses to formulate our water quality rankings for each stream, including:

  • E. coli data taken by MountainTrue’s riverkeepers and water quality monitoring volunteers.
  • Aquatic insect (a.k.a., benthic macroinvertebrate) data — part of the Stream Monitoring Information Exchange program (SMIE) — from the Environmental Quality Institute. Learn more about SMIE here
  • Chemical data — part of the Volunteer Water Information Network (VWIN) — from the Environmental Quality Institute.
  • Chemical, aquatic insect, fish, and bacteria data from the North Carolina Department of Environmental Quality (NC DEQ).

The data from testing sites in streams across each watershed are weighed, and each stream is given a letter grade. The grading scale is as follows: 

A (90-100): These streams have excellent water quality, low pollution levels, and healthy aquatic insect and fish populations.

B (80-89): These streams have good water quality but some impacts from pollution or development. The aquatic life and fish populations are relatively healthy.

C (70-79): These streams have average water quality. There are some concerns about pollution inputs and development impacts. Generally, aquatic life and fish populations are healthy but could become negatively impacted

D (60-69): These streams have below-average water quality. Pollution is a concern, and aquatic life and fish populations are not as healthy as they should be.

F (<60): These streams have poor water quality. Pollution levels are often high, and aquatic life and fish populations are impacted.

When comparing this year’s report to 2018’s report, it’s important to note that the way we process our water samples for E.coli at MountainTrue has changed. Up until 2018, we used an Environmental Protection Agency (EPA)-approved method using Coliscan Easygel. The results from this method were sometimes subjective and thus could be less accurate. In 2019, we switched to another EPA-approved protocol, using the Idexx system. Those results are quicker, more objective, and more accurate. This 2021 report includes E.coli data from both analysis methods (2018 Swim Guide data using Coliscan Easygel and 2019-2021 Swim Guide data using the Idexx system).

 Now, let’s review the findings from each of the three reports.

The state of the French Broad River Watershed:

 Of the 62 testing sites across the French Broad River Watershed, 16% received an A grade, 20.9% received a B grade, 29% received a C grade, 25.8% received a D grade, and 6% received an F grade. 

Overall, we observe a general decline in water quality. We attribute this to two primary factors — climate change and increasing construction and development throughout the watershed. Asheville and the surrounding region have experienced more frequent heavy rains in the last several years. Climate change in the Southern Blue Ridge region is expected to present random “boom and bust” patterns in precipitation, seen as floods and droughts in our region. This causes increased stormwater runoff from urban areas and agriculture operations, along with more sewer overflows and saturated septic fields surrounding failing septic systems. It also brings extra sediment into our waterways from construction sites and weak riverbanks, which can smother aquatic habitats, increase water temperature, and transport toxins into our rivers. All of this is happening during a period of unprecedented recreational growth on the French Broad. 

We documented the most dramatic change in Transylvania County, as the quality of the Upper French Broad decreased significantly. We attribute part of this decrease in quality to our transition to new, more accurate E.coli sampling protocols. However, that doesn’t explain the whole picture since water quality in other parts of the watershed didn’t drop as steeply. Notoriously the wettest county in the state, this drop in water quality is indicative of the effects that a changing climate coupled with increasing development is having on our region. 

On a positive note, the Nolichucky Watershed saw increased water quality with high grades in benthic and fish samples. Such pristine waters cannot be taken for granted, which is why we’re advocating for the Nolichucky River between Poplar, NC, and Erwin, TN, to be permanently protected with a Wild and Scenic Rivers designation.

Four Cleanest Streams:

  • Cataloochee Creek (A)
  • Cathey’s Creek (A)
  • Bent Creek (A)
  • South Toe (A)

Four Dirtiest Streams:

  • French Broad River – Pisgah Forest (F)
  • French Broad River – Etowah (F)
  • French Broad River – Hominy Creek (F)
  • French Broad River – Westfeldt (F)

 Learn more about the state of the French Broad River Watershed by reviewing last year’s Swim Guide results.

The state of the Broad and Green River watersheds: 

Of the 18 testing sites across the Broad and Green River watersheds, 27% received an A grade, 61% received a B grade, none received a C grade, 5.5% received a D grade (1 site), and 5.5% received an F grade (1 site). 

The Green River is the largest tributary of the Broad River in North Carolina, and its headwaters are largely protected. From its source in Henderson County to Lake Summit, the Upper Green is significantly impacted by agriculture, poor stream management practices, and lack of appropriate riparian buffers. 

The Green River flows into the Broad River near the Polk and Rutherford County Line. Major tributaries in the lower Green River Watershed include Walnut Creek from the north and White Oak Creek from the south. In a tale of two tributaries, the former touts excellent water quality and benefits from a large nature preserve while the latter suffers from degraded water quality as a result of development, land clearing, agriculture, and other intensive land use. 

By the time the First Broad reaches Shelby, it fails to meet EPA bacteria standards nearly 50% of the time. First Broad tributary Buffalo Creek has a history of high bacteria levels and feeds Moss Lake — Cleveland County’s only public reservoir and the water supply for Kings Mountain. In June 2020, NC DEQ documented Moss Lake’s first-ever harmful algal bloom (HAB) — this is a big concern for nearby residents, recreationists, and all who depend on Moss Lake for their drinking water supply. 

Overall, water quality in the most popular recreational area on the main stem of the Broad River is pretty good. The river is so large that contaminants of concern in the tributaries are diluted, and bacteria levels at the Broad River Greenway in Cleveland County almost always meet EPA standards for safe recreation.

Four Cleanest Streams:

  • First Broad River – North Fork (A)
  • Moss Lake (A)
  • North Pacolet River – Near Tryon (A)
  • Big Hungry River (A)

Four Dirtiest Streams:

  • Buffalo Creek – Above Moss Lake (F)
  • Sandy Run Creek (D)
  • Lower Broad River (B)
  • Upper Broad River (B)

Learn more about the state of the Broad and Green River watersheds by reviewing last year’s Swim Guide results.

The state of the Watauga River Watershed:

Of the 27 testing sites in the Watauga River Watershed, 37% received an A grade, 33% received a B grade, 11% received a C grade, 3.7% received a D grade (1 site), and 14.8% received an F grade. 

Overall, water quality is pretty good across the Watauga River Watershed, which originates at an elevation of 5,964 feet on the northern slopes of North Carolina’s Grandfather Mountain. The 78-mile-long Watauga River Basin includes the headwaters and tributaries of the Elk and Watauga Rivers, flowing northwest from North Carolina into Tennessee’s Holston and Tennessee Rivers before joining the Mississippi River and draining into the Gulf of Mexico. 

The Watauga River Watershed includes mountain bog wetlands that sit at the head of the basin and serve as an important water purification system and habitat for native wildlife. Nearly 90% of mountain bogs in North Carolina and throughout the Southeastern United States have been destroyed. The rapid elimination of mountain bogs poses a challenge for water quality and environmental conservation in the Watauga River Basin. 

Increases in development, plastic pollution, soil erosion, sedimentation, and excess nutrients are stressors on aquatic health and habitats. When combined, these stressors can significantly damage aquatic habitats and ecosystems. Much of the land disturbance in the basin takes place on steep mountain slopes, which are naturally vulnerable to soil erosion. As land is cleared due to urbanization and agriculture, rain and melting snow carry eroded sediments, pesticides, fertilizers, and road salt into the Watauga River. 

Fortunately, North Carolina has designated 18 miles along Boone’s Fork Creek for conservation to receive extra protection. More than half of the basin’s streams are classified as trout waters and thus require additional treatment at local wastewater treatment plants. In addition, 25-foot buffers of shrubs and trees must be maintained between trout streams and graded construction sites to filter runoff and prevent erosion.

Four Cleanest Streams: 

  • Watauga River @ Adam’s Apple Dr Bridge (A)
  • Watauga River @ Wilbur Dam Rd Bridge (A)
  • Watauga River @ Smalling Rd Bridge (A)
  • Elk River @ Lees-McRae Mill Pond (A)

Four Dirtiest Streams:

  • Watauga River @ Lover’s Lane (F)
  • Watauga River @ Hunter Bridge (F)
  • Watauga River @ Blevins Boat Ramp (F)
  • Watauga River @ Calloway Rd. Bridge (F)

 Learn more about the state of the Watauga River Watershed by reviewing last year’s Swim Guide results.

MountainTrue is Objecting to the Revised Forest Plan for the Nantahala-Pisgah National Forests. These are our Reasons.

MountainTrue is Objecting to the Revised Forest Plan for the Nantahala-Pisgah National Forests. These are our Reasons.

MountainTrue is Objecting to the Revised Forest Plan for the Nantahala-Pisgah National Forests. These are our Reasons.

After over eight years of work and more than 25,000 public comments, the United States Forest Service (USFS) has released its Revised Forest Plan for the Nantahala and Pisgah National Forests. Comprised of a 360-page plan, a 738-page Final Environmental Impact Statement (FEIS), and more than 1,000 pages of appendices to the FEIS, the Forest Plan provides a strategic framework for the next 20 years of management in the Nantahala and Pisgah National Forests. We offer this critique of the Revised Forest Plan so that our members and the general public can better understand the plan and its implications and why and on what grounds MountainTrue is filing formal objections to the plan.

MountainTrue is a longtime advocate for the sustainable management and conservation of Nantahala and Pisgah National Forests. Our members led the successful campaign to stop the practice of clear-cutting in the forests, and our staff conducted the first inventory of old-growth stands in the Nantahala and Pisgah National Forests. MountainTrue’s Public Lands Team members are intimately involved in protecting these public lands: monitoring timber sales to ensure old-growth forests, water quality, and sensitive habitats are protected, restoring and protecting native habitats by treating invasive non-native plants and pests, and helping the Forest Service design and implement restoration projects.

Our views are influenced by our intimate history with these national forests, but also by our membership in the Nantahala-Pisgah Forest Partnership (Partnership) and our endorsement of the Forest Plan Alternative provided to the USFS by the Partnership in June 2020.

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The Partnership consists of 27 active member and affiliate organizations representing conservation, economic development, forest products, recreation, water, and wildlife interest groups. The Partnership worked collaboratively to negotiate the outcomes presented in the Forest Plan Alternative. The Partnership hoped the heavily negotiated compromise would resolve the Draft Forest Plan’s key issues, streamline its implementation, and reduce future conflicts with the Forest Service and between user groups.

There were two key innovations in the Partnership’s Forest Plan Alternative. First, the group identified the largest broadly supported area for timber production — approximately 500,000 acres or nearly half of the Nantahala and Pisgah National Forests, where timbering could be done without impacting important recreation and conservation areas. The second innovation was the linking of objectives that are in tension with one another. For example, the Partnership Alternative required that roads and trails in a geographic area be well-maintained before the Forest Service constructed new ones, and base levels of timber harvest would have to be accomplished before any new Wilderness designation was sought. These innovative ideas would have incentivized collaboration.

The Partnership’s Forest Plan Alternative was a painstakingly negotiated road map that included maps and specific consensus recommendations that would have achieved:

  • the protection of old-growth stands, natural heritage natural areas, backcountry wilderness, and other sensitive recreation areas;
  • the protection, maintenance, and expansion of recreation areas and trail systems;
  • the creation of new young forest habitats at biologically significant levels for the benefit of wildlife and hunters alike;
  • and, at the same time, meet the Forest Service’s goals to increase timbering.

The Forest Services’ previous management plan suffers from some of the same issues as the proposed plan, namely inefficient management area allocation, and its implementation resulted in public controversy and conflict. Forest interests groups — such as timber companies, hunters, recreators, and conservationists — often perceived themselves to be in competition with one another when timber harvest was proposed in areas with multiple high values. The result was gridlock and damaged ecosystems: the Forest Service trampled on biologically sensitive areas without meeting their timbering goals, and forest interests groups blamed each other.

This was supposed to change with the 2012 Planning Rule adopted by Secretary of Agriculture Tom Vilsack, which sought to modernize forest management by addressing the “evolving scientific understanding of approaches to land management, changing social demands, and new challenges such as changing climate.”

At the core of the new planning rule was a commitment to a collaborative process that would ensure transparency and effective public participation. In its preamble, the Department of Agriculture states that the new rule “emphasizes providing meaningful opportunities for public participation early and throughout the planning process, increases the transparency of decision-making, and provides a platform for the Agency to work with the public and across boundaries with other land managers to identify and share information and inform planning.” In this spirit, the Nantahala-Pisgah Forest Partnership was established and painstakingly negotiated its consensus Plan Alternative.

Unfortunately, the Forest Service declined to adopt or even fully analyze the Partnership proposal as an alternative. Instead, the Forest Service has proposed a plan that offers vague assurances while placing important conservation areas in areas designed for timbering, expanding the road network without providing plans to maintain it, and establishing loopholes that undermine the protection of the conservation areas that are established by the plan. Many of our concerns relate to the potential for poorly conceived timber harvest to impact water quality, steep slopes, and areas critical for the preservation of biodiversity. We want to emphasize, though, that we fully support meeting the timber harvest goals agreed to by the Partnership, even going so far as to compromise in supporting rotational timber harvest in the consensus suitable timber base.

While there are some bright spots in the Forest Service’s Revised Plan — such as an increase in active fire management, recommendations for Wild and Scenic Rivers, and a recommitment to adequate streamside zones — they are far outweighed by its shortcomings:

Land Allocations Unnecessarily Prioritize Timber at the Expense of Conservation Areas

The Forest Services divides the Nantahala and Pisgah National Forests’ 1.045 million acres into 17 unique management areas with specific management needs in the Revised Forest Plan. Because many ecological communities exist at various elevations, the Forest Service’s management approach must be specialized and place-based to support each management area’s abundant biodiversity.

Ensuring the efficacy of the Forest Service’s proposed place-based management area allocations was a primary objective of the Nantahala Pisgah Forest Partnership as it negotiated its Forest Plan Alternative. Instead of adopting these recommendations, the Forest Service puts the ecological well-being of more than 100,000 acres of important conservation areas at risk. These conservation areas include North Carolina Natural Heritage Areas, existing old-growth forests, and potential Wilderness Areas.

In the chart below, you will see that the Partnership identified 501,646 acres (or roughly half of the Nantahala-Pisgah National Forests) to be included in Matrix and Interface — the two management area designations where the emphasis is placed on timber harvesting/production. This is more than sufficient for the Forest Service to meet its goal of harvesting up to 3,200 acres per year.

*The difference in acreage is not significant
**While the Forest Service did not include a specific Management Area for the proposed Craggy Mountain National Scenic Area, it does recognize the scenic value of an approximately 10,000-acre core.
***The Middle Creek Research Natural Area was included in the Black Mountains Recommended Wilderness by the Partnership
****Special Interest Areas are largely composed of North Carolina Natural Heritage Natural Areas. The Partnership recommended that most of these areas either be allocated to management areas not suited for timber production or protected through Forest Plan Standards.

The Forest Service’s Revised Plan includes an additional 108,723 acres in their Matrix and Interface allocations. All but roughly 8,000 (7,823) acres come from conservation areas that include North Carolina Natural Heritage Areas, existing old-growth forests, and potential Wilderness Areas.

As it currently stands,  at least 12,000 acres of inventoried, existing old-growth forest, more than 45,000 acres of Natural Heritage Natural Areas ranked “High” to “Exceptional” by the NC Natural Heritage Program, and over 100,000 acres of important conservation areas have been designated for “regularly scheduled timber harvest” within the Matrix and Interface allocations. Not all of the important conservation values designated to suitable management areas will be proposed for logging, but some certainly will.

This regrettable management area allocation prioritizes commercial timber harvest projects that will negatively impact these important conservation areas, making timber harvest unnecessarily complicated, controversial, and damaging.

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The Old-Growth Network Shell Game

Old-growth forests are vital for native species, scientific study, aesthetic and spiritual reasons, and are crucial for sequestering and storing carbon that would otherwise contribute to climate change. Before the industrial age, most of the forest in the Southern Blue Ridge were old-growth forests with complex structures and a vast diversity of tree sizes and ages. A wave of logging for national and international markets from 1880-1940 removed most of the original forest, and today only 10% of Nantahala and Pisgah and just 3% of the region as a whole are believed to be in old-growth condition. The analysis in the Revised Forest Plan acknowledged that approximately half of the tree canopy of Nantahala and Pisgah would have been in old-growth condition prior to European colonization.

The Forest Service has touted the Revised Plan as an improvement for old-growth forests because it designates approximately 265,000 acres for old-growth management (ROD p.22). While this is a big number, it’s important to note that all but 44,000 acres of old-growth designations are already protected at a higher level, such as by the Wilderness Act, the Inventoried Roadless Rule, the Wild and Scenic Rivers Act, Research Natural Areas, and others. So, these are primarily designations of convenience — in the sense that they are already off-limits to logging rather than because of their outstanding values.

MountainTrue and our predecessor organization, the Western North Carolina Alliance, began mapping the old-growth forests of Nantahala and Pisgah National Forests in 1994. Through that work, we have documented over 90,000 acres of old-growth on Forest Service lands. We shared that inventory with the Forest Service, and unfortunately, over 12,000 acres of field-verified old-growth remains in timber production management areas, where the plan direction is to create young forest through timber harvest.

What’s more, 110,000 acres of the designated old-growth network in the plan is relatively young — less than 100 years old, according to Forest Service Records. The Forest Service claims that by designating middle-aged forests, they are ensuring the development of old-growth in the future, even though they are leaving much more worthy forests unprotected.

The network of old-growth designations begins to look like a shell game when you realize that thousands of acres of small patch old-growth designations made in the last 28 years were not included in the Revised Plan. The Forest Service seems to be setting up a precedent where they can open up more mature, lucrative forests that had previously been “designated old growth” to logging now, and only protect middle-aged forests until the next plan — when they could theoretically open up some of those more mature stands to timbering. Examples of this dynamic include very high-quality designations that were made and subsequently discarded in the Upper Santeelah and Shope Creek Projects but have now been allocated to a timber production management area.

Another major concern is that the Forest Service is providing project staff and district rangers with too much flexibility and decision-making power to cut the last remnants of existing old-growth forests under their stewardship. The Record of Decision states:

“The District Ranger, or the Forest Supervisor for multi-district projects, will retain the option of how to manage old trees, old stands, or old growth forest patches in the project itself, depending on the management area direction, site-specific conditions, and ecological needs in the area” (ROD pp. 44-45, emphasis added)

In recent years, we have provided input on numerous projects where the Forest Service proposed to cut existing old-growth forests and only relented under vigorous public pressure (see the Globe Project, Big Choga Project, Haystack Project, Harmon Den Project, Mossy Oak Project, Buck Project, and more).

Old growth takes centuries to develop, and the fact that the Forest Service discarded thousands of acres of designations from the last plan, so casually and without analysis or effort to include them in the new plan, needs to be corrected. And protecting existing old-growth forests should not be up to the discretion of Forest Service staff at the project level. It is crucial that the Forest Service not just manage for future old growth but also protect the old-growth forests we have now. To be meaningful, old-growth designations need to be nearly permanent.

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The “such as, but not limited to” Timber Loophole

The USFS has historically focused on cutting and growing trees, emphasizing active forest management that prioritizes timber harvest revenues over economic activity and public benefits derived from outdoor recreation, wildlife, and clean water. This emphasis is reflected in the binary designation of Management Areas as either “suitable” or “unsuitable” for timber production:

TIM-DC-06 Lands identified as suitable for timber production have a regularly scheduled timber harvest program that contributes to forestwide desired conditions. Rotation ages needed to meet restoration and habitat objectives for young forest and future middle-aged mast producing forests are also compatible with the production of sawtimber and pulpwood products.

TIM-DC-07 Land identified as not suitable for timber production, but where timber harvesting could occur for other multiple-use purposes, has an irregular, unscheduled timber harvest program. Harvest meets management direction and desired conditions for the area while providing services and benefits to the public.  

(Forest Plan Page 91)

Now, let’s consider the Forest Plan’s definition of what is allowed in management areas classified as “not suitable for timber production.” The sections we have bolded create a loophole big enough to drive a logging truck through.

TIM-S-02 While timber harvest can occur on lands both suitable and not suitable for timber production, unless otherwise specified in management area direction, it can only occur on lands not suitable for timber production when it is determined that timber harvesting activities are needed for salvage or to protect multiple use values other than timber production, such as, but not limited to:

(1) addressing issues of public health or safety; 
(2) reducing hazardous fuels and managing wildfire; 
(3) restoring or maintaining a terrestrial or aquatic ecological system or wildlife habitat over time; 
(4) restoring or maintaining habitat for federally threatened and endangered animals or plants and SCC; 
(5) harvesting dead or dying trees due to fire, natural disturbances, insects, and disease; (6) restoring or maintaining recreation, scenery, or transportation management; 
(7) accommodating special use permits and outstanding rights; or
(8) for research, demonstration, or education purposes.

(Forest Plan page 91, Emphasis added)

The use of “such as, but not limited to” negates the purpose of the list that follows by allowing timbering for any reason that a ranger or project manager may contemplate in the future. As close observers of Nantahala and Pisgah National Forest know, every single timber sale in the past 40 years has purported to “restore or maintain terrestrial wildlife habitat.”

There is a common thread throughout the Forest Plan of delegating most decision-making to individual rangers at the project level with overly broad language. As it stands now, the binary distinction between what management areas are suitable and unsuitable for timber harvest is rendered moot by a set of criteria that neglects to exclude much of anything. Essentially, this makes no part of the Nantahala and Pisgah National Forests off-limits to logging. For there to be a distinction between the suitable and unsuitable management areas, the Forest Service must strengthen this language.

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Nantahala National Forest is Treated as a Second-class Forest by the Forest Service

Nantahala and Pisgah National Forest have equivalent acreages, physical features, biological values, and both are beloved by the public. Why then is the Forest Service proposing to manage the two forests so differently based on their management area allocations?

The USFS plan places approximately half (50.3%) of Pisgah National Forest in the Interface and Matrix designations, where active timber production is a primary or secondary goal. Nearly two-thirds of Nantahala National Forest, on the other hand, is open to rotational logging.

Of the two forests, Nantahala National Forest is certainly the more remote, and more of its acreage qualifies for the backcountry management allocation. Why then, is so much more land dedicated to timber production in Nantahala National Forest versus Pisgah National Forest? The USFS is proposing to only place 8.9% of the Nantahala National Forest in Backcountry designation (where logging is not supposed to happen) compared to an already modest 16.5% in Pisgah National Forest.

There is no analysis in the Forest Plan to support this discrepancy. We are concerned that this is the result of arbitrary decision making on the part of the Forest Service and, once again, a desire to delegate the decisions that should have been made by the Forest Plan, such as whether or not to cut old-growth forest, to District Rangers at the project level. If the Forest Service had adopted a more balanced plan, similar to the Partnership alternative, the land allocation would be more equitable for Nantahala National Forest.

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Highly Rated Natural Heritage Natural Areas Remain Vulnerable to Timbering

Every state in the United States has a Department of Natural Heritage whose mission is to catalog and preserve the natural diversity within the state’s boundaries. North Carolina has had a better-than-average Natural Heritage Program, though at times, protecting natural resources has been politically controversial, despite being overwhelmingly popular.

North Carolina’s Natural Heritage Program has inventoried Natural Areas in 97 of the state’s 100 counties. Many of North Carolina’s very best Natural Areas are situated within the boundaries of Nantahala and Pisgah National Forests. Unfortunately, the Forest Service has historically been ambivalent, at best, about these important areas. More recently, the Forest Service has acknowledged that some of these areas deserve special attention.

Natural Heritage Areas have a five-tiered ranking that categorizes natural values as General, Moderate, High, Very High, and Exceptional. In one of the bright spots of the Revised Plan, the Forest Service chose to place most of the acreage of Natural Heritage Areas rated as Exceptional in Special Interest Area Management. Unfortunately, over 45,000 acres of Natural Heritage Areas rated as High, Very High, and Exceptional were placed in timber production management areas, ensuring that some of these areas will continue to be proposed for timber sales. To reduce the potential for project-level conflict, the Forest Service should place these remaining highly rated natural areas in protected management areas.

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Water Quality at Risk from Logging without Steep Slope Protections or Adequate Road Maintenance

The Forest Plan is a mixed bag when it comes to protecting water quality. On the positive side, the new plan maintains the 50’ buffers on intermittent streams and 100’ buffers on perennial streams introduced in 1994. In these areas, trees must be retained and heavy equipment is excluded to prevent erosion and sediment pollution from stormwater runoff.

On the other hand, the Forest Service is proposing to remove the prohibition on ground-based logging for steep slopes, providing only vague assurances that new technology would prevent harm. In the previous plan, logging on slopes over 40% required aerial logging systems that lifted trees off the ground and negated the need to build logging roads on steep slopes. The revised plan proposes to remove this requirement. There may be new technologies that would be as protective as aerial logging methods, but the plan should continue to prohibit the creation of harvest roads on steep slopes and have stronger standards as to how logging methods on steep slopes are chosen.

Finally, sedimentation from forest roads is the primary threat to water quality and aquatic wildlife, and the Revised Plan should have made meaningful progress towards decreasing sedimentation from roads. Instead, the Forest Service is projecting 6 miles of road construction annually to meet Tier 1 timber harvest goals and an additional 4 miles to meet Tier 2 goals, while declining to produce a plan for meaningfully maintaining the 2,200 miles of roads already under Forest Service management. It would be more logical and more protective of water quality to require road maintenance goals from Tier 1 to be met before moving to Tier 2 levels of road building.

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Forest Service Drew Management Areas Around Controversial Projects

If the forest plans are the map given to Forest Service personnel to manage the land and water, then the projects proposed by Forest Service staff are the vehicles to get to the destination or the “desired conditions” identified in the Forest Plan. For the past 40 years, the Forest Service has struggled to propose vegetation management projects within the Nantahala and Pisgah National Forests that have been broadly acceptable to timber, recreation, and conservation interest groups alike.

Such controversial projects can damage important conservation areas, as occurred in the Pisgah Ridge Natural Heritage Area in the Courthouse Creek Project. In Courthouse Creek, logging on steep slopes caused severe erosion that led to a landslide during Tropical Storm Fred and turned Courthouse Creek the color of chocolate milk during the average rainy season of 2017. Such projects also tend to be less efficient and require a large amount of planning and analysis time. Only one-third of the approved timber harvesting at Courthouse Creek was ever accomplished.

Erosion and logging at Courthouse Creek. Photos by Nicholas Holshouser.

There is a spate of recent projects that were approved under the old forest plan but will be implemented under the new plan. Some like the Twelve Mile Project had consensus support and approved over 1,800 acres of timber harvest and wildlife habitat while protecting old growth and Natural Heritage Natural Areas. Others, like Buck and Southside, were very controversial because they proposed logging old growth, areas inventoried as potentially suitable for Wilderness Designation, and Natural Heritage Natural Areas, while also building miles of roads across steep slopes. Some projects, like Crossover and Lickstone, are still in development but have a high potential for controversy because of these same issues.

Reviewing the Forest Plan, it appears that the Forest Service has drawn management area boundaries in all of those projects that would support the controversial steep slope logging and excessive road building (8 miles) of Buck, the old-growth logging of Southside, and potential logging of old-growth and backcountry areas in Crossover. We believe that the Forest Service should not be building the new plan around poorly designed old projects, but instead, create a new plan that is consistent in its application and leads to more broadly supported and efficient projects.

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Curious Omissions Among the Designations

Wilderness Designations

There are several categories of designation requiring an act of Congress that the Forest Plan addresses. The first is Wilderness recommendation. The designation of new Wilderness areas under the Wilderness Act of 1964 requires an act of Congress and the Signature of the President. The first step in that journey is the recommendation of suitable areas by the Forest Service during the forest planning process.

The Revised Plan allocates just over 49,000 acres in 14 areas to Recommended Wilderness. Compared to the current Forest Plan, that is an increase of 33,000 acres. While over 100,000 acres were both suitable and had collaborative support, the Revised Plan offers more for those that appreciate Wilderness than any time since the RARE II process of the late 1970s.

Despite being an improvement over the old plan, there are some curious omissions in the Revised Plan’s designations and some strange logic in those omissions. For example, the Black Mountains were disqualified because you can see sights and sounds of human development from the area, but Mackey Mountain was included despite I-40 being in the foreground view and very audible. A portion of the Chunky Gal is recommended for addition to Southern Nantahala Wilderness, but about 1,000 acres of the Inventoried Roadless Area was not recommended — again due to claims that sound from US Hwy 64 disqualified the area. The truth is that all of these areas are suitable for Wilderness recommendation, and the Forest Service should acknowledge that, regardless of whether they decide to recommend them for designation.

Wild & Scenic Rivers

The second major type of designation is the identification of streams eligible for protection under the Wild and Scenic Rivers Act. The primary benefit of Wild and Scenic designation is to keep streams free-flowing and free of impoundments. There are three categories of Wild & Scenic Eligibility: recreational, scenic, and wild. Recreational is the least protective category, and Wild is the most protective. All three categories prevent eligible river segments from being impacted by dams once they are Congressionally designated.

The old plan recognizes 10 streams as eligible for Wild and Scenic designation, and the Revised Plan adds another 8 streams to that total. We were disappointed that the Forest Service did not find the North Fork of the French Broad, Panthertown Creek, and Greenland Creek eligible, and we believe the Forest Service should correct that error when the plan is finalized.

National Scenic Areas

The final designation opportunity in the Revised Plan is National Scenic Area (NSA) designation for the Craggy Mountains. This is perhaps the designation most likely to succeed in the next year because the people and government of Buncombe County support the protection of the area. Senators Burr and Tillis have indicated that they will not support federal designation without the endorsement of local governments. That box has been checked for the Craggy National Scenic Area.

The Forest Service has also designated over 10,000 acres of Big Ivy as a Forest Scenic Area. There is some ambiguity about the final boundaries of the Craggy NSA, as Buncombe County has endorsed a 15,000-acre area composed of all Forest Service Lands in the Craggy Mountains, while Forest Service has excluded Coxcombe Mountain, Snowball Mountain, Ox Creek, and Shope Creek from their recognition and placed them into areas where timber production is an emphasis. MountainTrue believes this should be corrected when the plan is finalized, and all these areas should be allocated to more protective management such as Ecological Interest Areas.

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Sensitive Wildlife Could Be Impacted by Faulty Assumptions

The Revised Forest Plan has laudable goals for wildlife and wildlife habitat. The Plan emphasizes the creation of young forest and open woods for the wildlife that benefit from those conditions, and also includes strategies and standards for protecting more disturbance-sensitive species like green salamanders, bats, northern flying squirrels, and dozens of rare habitats that support an abundance of rare species.

The new plan aims to create more of this young forest through timber harvesting, but the top levels of allowable harvest, while being three to four times higher than current levels, are no higher than what is allowed in the old plan. As discussed above, we believe that the timber harvest goals will be counterproductive until the Forest Service has consistent direction regarding Natural Heritage Natural Areas, old-growth forests, and potential Wilderness Areas that are currently allocated to timber production. As far as strategies for increasing timber harvest, we fail to see how the Revised Plan is an improvement over the status quo.

Perhaps the biggest flaw in the plan content on wildlife is that the Final Environmental Impact Statement fails to show any benefits or costs to the management strategies and objectives in the Forest Plan. As a rhetorical question, why manage the forest for wildlife at all if there will be no benefits? We suspect that there will be costs and benefits for the management the Forest Service is proposing and that the Environmental Analysis is either too flawed or lacks the sensitivity needed to detect the changes that will occur. We also suspect that increased levels of young forest habitat would benefit associated species and cause declines in disturbance-sensitive species, but the Final Environmental Impact Statement shows neither trend. In general, we have serious concerns that the Forest Service is relying on flawed assumptions and inaccurate analysis for many of the decisions (and in some cases, the absence of a decision) in the Revised Forest Plan.

On the other side of the coin are dozens of rare species, many of them unique to this region, that the Forest Service analyzes with a coarse filter and without plan content to protect them. In particular, disturbance-sensitive species reliant on closed-canopy forest, old trees, and down wood are presumed by the Forest Service to be well protected by the 40% of the Forest that will remain lightly managed in this Forest Plan, again, partly due to faulty modeling, and partly due to not making assumptions from the models (for example, that old-growth forests will not be cut), management standards, or guidelines in the plan. So the Forest Service is assuming that old-growth forest-associated wildlife will not be impacted because the models assume no old growth will be cut. All the while, the Forest Service is asserting the right to cut old-growth forest in the plan.

The Forest Service should address these issues by improving their environmental analysis, and making the assumptions in their analysis translate into management strategies.

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Recreation: Improvements to Trail Access but Too Restrictive to Other Activities

The Forest Service’s Revised Plan is an improvement over its own Draft Plan in terms of trail access. Two of the potential draft alternatives severely limited the potential to expand the existing trail network. Limiting opportunities for new trails would have been draconian considering the increasing demand for outdoor recreation, the already high use of Nantahala and Pisgah National Forests, and the social and economic benefits of outdoor recreation to our region.

The Revised Plan allows existing user-created trails and new construction to be added to the official trail system. However, the addition of any trails requires collaborative planning processes that consider supply and demand issues and have committed resources for long-term maintenance.

Overly restrictive limitations on other recreation resources — like rock climbing — lack the specificity needed to protect those resources and provide equitable public access. The Forest Service did not adopt Partnership’s suggestions regarding limitations on rock climbing as a recreation resource, nor is there a process for rock climbers or other recreationists to engage in collaborative management like there is for trail users.

The Forest Service should treat all user groups as potential partners and extend opportunities for collaborative management in the text of the plan to all interest groups.

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Support Healthy, Resilient Forests

MountainTrue’s Public Lands Team tracks and analyzes every timber project in the Nantahala and Pisgah National Forests to protect old-growth forests, sensitive habitats, and rare species. We help protect the places we share to ensure they stay healthy and beautiful for future generations. Support this work by making a donation to MountainTrue.