Public Comment on Logging: IFA’s Response to DRMG

Proposed Logging in Four Clark State Forest Tracts Includes Proposed Knobstone Wild Area

December 13 is the deadline to submit your comments.

The Indiana Department of Natural Resources has issued logging plans in Clark State Forest. The deadline for public comments on these plans is midnight December 13.

Please take 30-40 minutes to:

  1. Submit opposing comments via the Division of Forestry website;
  2. Submit your comments to Governor Holcomb and your state legislators (state senator and state representative); and
  3. Send a copy of your comments to IFA.

Applying pressure to officials lets them know we are watching and that we want our state forests protected for their recreational, natural, and ecological values. Read on to see how to comment, and points you can make.

Background and Tract Overview

IFA’s Conservation Director, Rae Schnapp, Ph.D., has reviewed the logging plans. The following tracts in Clark State Forest will be logged:

  • Compartment 15 Tract 3
  • Compartment 10 Tract 4
  • Compartment 11 Tract 5
  • Compartment 11 Tract 6

Dr. Schnapp has called for a statewide action alert to protect these four tracts. She found the following concerns in all of the tracts:

Overall Concerns: The IDNR’s Draft Resource Management Guides (DRMGs), or logging plans, state that virtually every type of harvest method will be used: single tree, group tree, patch openings, shelterwood, and regeneration cuts (a.k.a. “clearcutting”) as well as prescribed burning in all four of the tracts. Yet they provide only general ideas on where these methods might be used and no estimate of the timber volume to be removed. The DRMGs are too vague.

Forest Health Timber harvests degrade the recreational enjoyment and ecological value of state forests. The DRMGs do not demonstrate that logging will restore or maintain forest health. Forest health should be defined by ecological complexity and indicators such as floristic quality, not the quantity of commercial timber.

Nonnative invasive plants are one of the most significant factors attacking forest health. These plans state that invasives such as Japanese Stiltgrass and Tree of Heaven are likely to be introduced or increased by logging and logging roads built through these four tracts. The prospect of these tracts being logged at the same time by the same timber buyer, given their harvests are being posted in one document raises additional concerns about spreading invasives from one area to another.

Erosion and Water Quality These tracts contain highly erodible soils on severe slopes that are as steep as 60 to 75% and not suitable for logging. The DRMGs recognize that portions of these tracts are very steep, but there is no indication that logging activities will avoid these areas. Best Management Practices are inadequate to protect soils and water quality in these areas.

Three of the tracts include streams that flow into the South Fork Blue River, the last home of the hellbender salamander, endangered in Indiana. Hellbenders are extremely sensitive to sedimentation from soil erosion that coats gravel river bottoms and suffocates their young.

Wildlife The DRMG suggests that “A Natural Heritage Database Review is part of the management planning process.” But the Natural Heritage Database is merely a collection of locations where Rare, Threatened or Endangered (RTE) species have been seen and should not be presumed to indicate the presence or absence of species in a given tract of forest. No logging should commence without a comprehensive wildlife inventory on these tracts and a specific plan for preventing adverse impacts on RTE species.

Concerns Specific to Each Tract

Compartment 15 Tract 3
This tract contains 222 acres and is located partially in the northern portion of the Deam Lake State Recreation Area as well as IFA’s proposed Knobstone Wild Area. The tract contains five multi-use recreational trails (Cross Country Trail, Deam Lake Loop, Flower Gap Loop, Tree Lane Loop, and the Three Hills Trail), and a portion of the Knobstone Trail that may be temporarily closed and negatively impacted by the logging. Steep west-facing slopes drain into Deam Lake. Invasive species that are present within this tract could be spread throughout this area by logging equipment and by opening up the canopy.

IFA will strongly oppose logging on this tract and the substantial damage it will do to its recreational value.

IFA believes that logging in the other three tracts should at least be prohibited on slopes exceeding 25% and not undertaken until a wildlife inventory has been completed ensuring that no RTE species or their habitats will be harmed.

IFA will also push for water quality monitoring of streams draining from these tracts to ensure that Best Management Practices are adequately controlling sediment runoff.

We will push for limits on the prescribed fire to avoid burning up Eastern box turtles, state endangered timber rattlesnakes and several species of salamanders, and the young of ground and shrub nesting birds.

Compartment 10 Tract 4
This 123-acre tract includes horseback riding trails. Its steep slopes and streams drain into the Poplar Branch Creek, which empties into the South Fork of the Blue River a half-mile further.

Compartment 11 Tract 5
This 102-acre tract contains few trails and very few invasive species in its current undisturbed condition. Its waters drain into Honey Run and then into Whiskey Run, which empties to the South Fork of the Blue River less than a mile away.

Compartment 11 Tract 6
This 74-acre tract also drains into the South Fork of the Blue River via Honey and Whiskey Runs. Some invasive species have been found but are somewhat localized. Like the other tracts, opening up the canopy and moving equipment around is likely to spread invasives.

How to Comment

Review the IDNR’s proposed logging plan/DRMG. For tips on how to comment on proposed logging, visit

The IDNR is taking public comment until December 13, 2019. Submit comments at:

For IDNR accountability, please send a copy of your comments to your state legislators. Find your legislator.

Most importantly, send a copy of your letter to Governor Holcomb.

Find more tips on how to comment on the IFA website.

Thank you for your participation in the public comment period and your forest advocacy and support! Together we can work to protect Indiana’s priceless remaining wild nature.