
Dawn from Shenandoah Mountain. Photo: Steve Krichbaum.
The corruption of the US Forest Service is manifest nationwide, not just in the West. Numerous huge desecrations, such as at Buffalo Springs on Indiana’s Hoosier National Forest (“NF”) or the Jellico Project on Kentucky’s Daniel Boone NF, are proposed/happening all over the East, and Virginia is no exception.
The public have submitted formal Objections to three recent projects on the George Washington NF in Virginia: the Dunlap Creek (“DC”) TS on the James River RD, the North Shenandoah Mountain (“NSM”) TS and Archer Knob (“AK”) TS on the North River RD. The project areas (”PAs”) are some of the most exceptional lands I have ever encountered on the Forest. Nonetheless, at just these three sites the FS is proposing to log almost 10,000 cares, burn 7,912 acres, and build 28 miles of so-called “temporary” roads.
As usual, their disclosure/analysis of these projects is biased, deceptive, omissive, and obscurant. Aspects of the Forest Service’s documentation and analysis demonstrate unsound assumptions, misrepresentations of science, omissions of relevant studies/data, and illogical or unsupported reasoning that are the hallmarks of arbitrary and capricious decision-making. In addition, by flagrantly refusing to fully develop and analyze action alternatives to their proposal, they turn the National Environmental Policy Act (“NEPA”) into a joke and disregard clearly controversial public issues and concerns. The agency also explicitly claims that there are no “conflicts” involving the disposition of NF resources. All of which are an abuse of their discretion that numerous court rulings have found to be illegal under the Administrative Procedures Act (“APA”).
The agency’s Environmental Assessments (“EAs”) and supplementary documents/appendices are loaded with conclusory assertions without validation by empirical evidence. When an EA is “woefully light on reliable data and reasoned analysis and heavy on unsubstantiated inferences and non sequiturs … [t]he record simply does not provide a rational connection between the licensing decision, the record evidence, and the finding of no significant environmental impact.” (Am. Rivers v. FERC, 895 F.3d 32, 51 (D.C. Cir. 2018))
RED FLAGS at NSM, DC, and AK
For the NSM, DC, and AK Projects, a multitude of red flags are extremely prominent — Present in/associated with the PAs are priority watersheds (“functioning at risk”), “impaired” waters, at risk watersheds, rare and vulnerable taxa (such as Threatened, Endangered, Sensitive, and Locally Rare species), large unroaded tracts that are Virginia Mountain Treasures [“VMTs”], large tracts in the project areas that the FS identified during the GWNF Plan revision as Potential Wilderness Areas (“PWAs”), mature and old-growth forest [“OG”], Conservation Areas (“CA”) explicitly identified by the VA Dept. of Conservation and Recreation [“VDCR”] (e.g., Peter’s Mountain CA at the DC PA is “one of the largest intact patches of old growth forest in Virginia and possibly the central Appalachians”), ecologically critical areas — sites with “Outstanding or Very High Ecological Integrity” rankings, identified “ecological cores”, steep slopes, group D soils, soils susceptible to compaction and erosion, clear public issues/concerns (“controversy” and “conflict”), site-sensitive species not adequately represented/analysed by use of the current FS Management Indicator Species, great uncertainty (e.g., status and distribution of numerous affected species, lack of pre-fire and post-fire population monitoring data), burning that is NOT targeted at restoring fire-dependent communities, and existence of a nation-wide movement and process to amend Forest Plans to protect and recruit OG/mature forests on NFs.
And yet despite all this, the GWNF managers still unlawfully fail to fully, and fairly consider/analyse any action alternatives for managing the project areas aside from their preferred proposed action. And their “no action” alternative disclosure fails to honestly and adequately disclose/analyse the “existing conditions”.
A full and accurate appraisal of the “existing conditions” is the sine qua non of informed decision-making and honest public disclosure of impacts and rationale. Without this, logging decisions on NFs are unreasonable, an abuse of agency discretion, and illegal (in violation of the NEPA and APA).
The potential for reasonably foreseeable significant effects from implementing these projects is clear (with regard to the NEPA factors of “intensity” and “context”). The projects are proposed in and adjacent to “ecologically critical areas”. In addition, that “the effects on the quality of the human environment are likely to be highly controversial” is an absolute certainty – there is definitely a “substantial dispute [about] the size, nature or effect” of the projects. Further, the FS disclosure indubitably reveals that “the possible effects on the human environment are highly uncertain or involve unique or unknown risks”.
The agency’s consideration and disclosure are inadequate and lacking in supporting data and reasoning. From their flippant dismissal of significant issues and concerns clearly raised by the public, one would think that these Forest lands are the private property of FS bureaucrats.
ECOLOGICAL INTEGRITY and CORES
According to the Virginia Natural Landscape Assessment by the DCR, unlike the vast majority of the state of Virginia the PAs have sites of “Outstanding” and “Very High” “Ecological Integrity”; such as the Peters Mountain North (Snake Run Ridge) area (“ Outstanding”) and the Slaty Mountain area (“Very High”) at the DC PA – see VANLA map (“Virginia Natural Landscape Assessment : 2017 Ecological Cores Ranked by Integrity” – available at https://www.dcr.virginia.gov/natural-heritage/image/vanla-2017-resize.jpg).
Also here is the Peters Mountain North Conservation Site which the VDCR identifies as a key area for preserving natural heritage species, communities (such as OG), and habitat (see, e.g., Dec. 2023 & April 2024 letters to the FS from the VDCR and the April 2000 Natural Heritage Technical Report 00-07 by Fleming & Moorhead).
“Ecological Cores” are significant aspects of the PAs that these timber sales would harm. “Ecological Cores are areas of at least 100 acres of continuous interior, natural cover that provides habitat for a wide range of species, from interior-dependent forest species to habitat generalists, as well as species that utilize marsh, dune, and beach habitats. … The proposed project will impact multiple cores with very high to outstanding ecological integrity.” (VDCR 2023) See Ecological Core(s) (C1, C2, C3 and C4) as identified in the Virginia Natural Landscape Assessment.
Here, the FS fails to fully and fairly consider and take a “hard look” at these important and significant red flag areas. This reprehensible disregard by this big federal bureaucracy for conditions in the state of Virginia is simply unreasonable and an abuse of discretion; yet another violation of the APA and NEPA on exhibit in the agency’s documentation and Decisions. This abusive disregard is also made explicit by the fact that the FS only designated a small portion of the Peters Mountain North Conservation Site as a “Key Natural Heritage Community” (MPA 4D1) in the Forest Plan.
MOUNTAIN TREASURES
VMTs are also a significant part of the GWNF and of these three FS projects. Over 20 years ago conservationists in the Central & Southern Appalachians worked with The Wilderness Society (“TWS”) to identify and delineate unprotected unroaded tracts in the seven National Forests in the mountains of Virginia, North Carolina, Tennessee, Georgia, and South Carolina. These wildlands were called “Mountain Treasures”. The results of this work were published in six booklets, e.g., “Virginia’s Mountain Treasures: The Unprotected Wildlands of the George Washington National Forest”. Mountain Treasures are tracts at least 2500 acres in size, with an average size of almost 6600 acres.
Virginia may have more NF unroaded acreage than any other state in the East (excluding Minnesota). There is more Mountain Treasure acreage identified here than that identified by conservationists in the 5 other Southern Appalachian NFs in four states put together (I do not have info on WV’s Monongahela NF and KY’s Daniel Boone NF tracts at least 2500 acres in size identified by conservationists). In all, 262 areas were identified, totaling 1,720,537 acres; 130 of the MTs are in Virginia’s two NFs, totaling 878,530 acres, with 602,432 of these acres on the GWNF.
Mountain Treasure acreage identified in the TWS publications for five states (Virginia, North Carolina, Tennessee, South Carolina, and Georgia):
State/National Forest/ # Mountain Treasures/ Acreage MTs / Roadless Areas / Acreage of Roadless Areas / Percentage of National Forest
VA GWNF 63 602,432 IRA 242,278 40%
VA JeffersonNF 67 276,098 IRA 161,702 59%
GA ChatoogaNF 44 235,700
TN CherokeeNF 43 228,407 IRA 86,805 38%
NC Nantahela & Pisgah NFs 35 323,000
SC SumterNF (only Andrew Pickens RD) 10 55,000
Most of the MT acreage is neither formally “inventoried” by the FS as “roadless areas” (in VA only ca.45% is included in IRAs [Inventoried Roadless Areas]), nor ‘protected’ in the current NF Management Plans.
VMTs are de facto roadless areas. The FS states that “IRAs are characterized as having an undeveloped character and are valued for many resource benefits including wildlife habitat, biological diversity, and dispersed recreation opportunities.” (AK EA-90) Due to timber extraction desires, much VMT acreage was improperly not “inventoried” as roadless and/or placed in protective management prescriptions by the agency (e.g., 12D, 4D). VMTs “are not recognized as protected areas (Forest Service 2001).” (DC EA-16-17)
Various sites in the VMTs would be logged and roaded under the Projects’ Decisions. Including lower elevation slopes that are generally richer sites. And the anthropogenic disturbances would whittle away at the Treasures and reduce interior habitat and remote experiences. This is particularly egregious at the Elliot Knob site, where the FS proposes going around mile into the VMT at the Augusta Springs area.
The Archer Knob project includes regeneration logging units totaling 398 acres, 16 thinning units totaling 531 acres, and 1.6 miles of temporary road in the Elliot Knob VMT, plus regeneration units totaling 81 acres and 4 thinning units totaling 69 acres in the Archer Knob VMT.
The Dunlap Creek project includes 475 acres of “vegetation management” and 1.9 miles of temporary road within the Snake Run Ridge VMT, plus 37 acres of cutting in the Slaty Mountain VMT.
In the North Shenandoah Mountain Project Area are seven Mountain Treasures totaling almost 60,000 acres on the NF in the PA. None of this roadless acreage was “inventoried” by the FS. Three of these Treasures are threatened by this timber sale: in Hogpen Mtn. (9,229 acres) are logging, thinning, burning, and road building; in Little Cow Knob (5,335 acres) are logging & thinning; and in Beech Lick Knob (17,152 acres) are logging, thinning, and burning, including 355 acres of logging and 371 acres of burning within the agency’s own identified 14,085-acre Potential Wilderness Area.
The VMTs’ roadless character and their naturalness would NOT be maintained and Project implementations would diminish their ecological integrity.

Lush Spring. Photo: Stave Krichbaum.
CUMULATIVE IMPACTS TO VMTs
Numerous recent projects/timber sales have failed to adequately protect VMTs. The cumulative impacts to VMTs on the GWNF, such as reducing or not maintaining their roadless or remote character and degrading, fragmenting or perforating their ecological integrity, is a significant issue of great concern. This is NOT meaningfully addressed in any of the agency’s EAs.
In just the recent couple of years on the GWNF, the Sandy Ridge, Potts Creek, Green Hill, North Shenandoah Mtn., Dunlap Creek, and Archer Knob projects ALL affect and degrade numerous VMTs. Many other projects since the 2014 Plan revision also have been significantly reducing roadless/unroaded acreage and degrading the ecological integrity, non-motorized recreation, and scenic qualities associated with VMTs.
Roadless areas/unroaded tracts/roadless blocks and Virginia Mountain Treasures have been diminished in size and degraded in quality on the GWNF. Implementation of these most recent proposals would continue this harmful pattern; the Forest Service typically and oftentimes fails to protect roadless tracts administratively. The direct, indirect, or cumulative impacts of the Projects to the Forest’s Roadless areas/Unroaded tracts/Roadless blocks/ PWAs/VMTs can certainly be considered to be significant.
The GWNF has 23 Inventoried Roadless Areas (IRAs) with a total of 242,278 acres. And as part of the 2014 Plan revision process, the FS identified 37 areas as Potential Wilderness Areas (PWAs) with a total of 372,631 acres. The PWA inventory includes all of the IRAs, with the exception of Southern Massanutten and The Friars (FEIS 2-56).
Only ca. 40% of VMT acreage on the GWNF is included in the current IRAs. Hundreds of thousands of acres of VMTs are not considered as PWAs or IRAs and are open to “active management” (e.g., logging and roading). Further, even 85,500 acres of PWAs that are outside of IRAs are open to “active management”, plus more acreage in S.Massanutten and The Friars.
The actions the agency wants to impress upon the VMTs are done in order to fabricate/perpetuate an artificial (i.e., human caused/controlled) environment regarding forest structure and composition. That is what attaining their so-called “desired conditions” there would result in; basically converting the land from the forest’s attempt at recovery from past anthropogenic disturbances to a human-designed/maintained plantation, a crop. These croplands do not provide all the ecosystem services which need to take priority here over timber production.
In addition to significant harm to wild habitat, Project implementation would significantly decrease recreational value at VMTs. A noticeable loss of contrast value would ensue, vegetation treatments would make them more like other places. That they provide other conditions different from the developed landscape (such as interior forest) is why we and wildlife go to such places — to get away from the alteration/anthropogenic disturbance that pollutes much of our landscape. With these Projects, the FS is intent on making the sites more like everywhere else — homogenizing the overall landscape, decreasing beta/gamma diversity.
And one must never forget that implementation of these Projects irreparably results in incomprehensible amounts of direct mortality of wildlife — squashing and burning turtles and toads and snakes and salamanders and nestlings and snails and slugs and other invertebrates, all those small and slow creatures who cannot run away or fly away from harm, including those who live in trees; these are all significant components of the GWNF. And any survivors would be left in intensively altered habitat conditions, conditions that would alter plant composition and structure as well. “Harvest” does not just alter landscapes, it erases lives. Now more than ever we need to be on the side of life and be kind.
SHENANDOAH MOUNTAIN
The crown jewel of the Central Appalachians, Shenandoah Mountain constitutes what I believe to be the largest single contiguous tract of National Forest in the entire eastern United States (ca. 390,000 acres). As such, it is of national significance as one of the largest relatively intact wildlands of any kind in the entire East. Shenandoah Mountain is the largest massif in the 29 million acre Ridge and Valley Physiographic Province, rising above the valleys of the Shenandoah and South Fork of the South Branch Potomac Rivers to elevations over 4000 feet. The area is topographically unique within the Ridge and Valley PP in that rather than being a narrow linear ridge of resistant sandstone it is a broad dissected ridge of interlayered sandstones and shales.
Shenandoah Mountain provides some of the most rugged and remote land still left in the Appalachians. With ever increasing population and development pressures, places to escape to the “sounds of silence” and bask in nature’s song are increasingly rare in our landscape. Places to be treasured, they are where the wild things are. These sanctuaries are our natural heritage and a vital necessity for sustaining the health of not only ourselves, but also all that we call home. In a sea of noise and development, this place we call Shenandoah Mountain is nothing less than a modern-day Ark, precious and irreplaceable.
Here on Shenandoah Mountain are twenty-three identified “Mountain Treasures” (unroaded areas) totaling around 262,000 acres (see Virginia’s Mountain Treasures: The Unprotected Wildlands of the GWNF available from The Wilderness Society) – probably the greatest amount of roadless tracts and back-country recreational lands to be found in any single site between the Great Smoky Mountains National Park (NC-TN) and the Adirondack State Park (NY). Here too are rare habitats such as shale barrens and tracts of old-growth forest, with around 75,000 acres in this condition. Here are endemic species such as the Cow Knob Salamander, Shenandoah Mountain Millipede, and Virginia Least Trillium, as well as Wild Trout streams, quality Black Bear habitat, and the southernmost Wood Turtle populations in the world.
GLOBALLY SIGNIFICANT
The remnant temperate mixed and deciduous forests on the public lands of the Appalachians offer a unique opportunity for ecological recovery, an opportunity certainly unmatched in the East, perhaps anywhere in the world. The wild old-growth forests that not long ago naturally blanketed this region have been extirpated, devastated, and dismembered. In 300 years, less than the life span of many a tree, we have gone from pockets of human development occurring in a matrix of natural landscape to natural areas – habitat fragments – eking out a living in a sea of human development. Now, in today’s world, islands of habitat like the George Washington National Forest have paradoxically become the floral and faunal source pools of the region.
For the world’s temperate deciduous forests, there is probably more unroaded acreage in these Southern/Central Appalachian public lands than in all of western Europe. And perhaps in China as well — but with a billion more people living there in the same area as the continental US, there is probably not much. The unique opportunity in the Central/Southern Appalachians makes this a place of global significance. These NF Mountain Treasures and other unroaded areas (e.g., Wilderness Areas in the NFs, plus acreage in the Shenandoah, New River, and Great Smoky Mountains National Parks) are important reasons to implement the Appalachian Ecosystem Protection Act (“AEPA”) proforestation proposal (citation 1&2). Truly protecting these vital lands under the AEPA means even the acreage not in large unroaded tracts is still protected from commercial logging and other destructive activities.
As Beverly Law and colleagues explain (cit. #3), key strategies for mitigating climate change and preventing biodiversity losses include:
1,) Establishment of national strategic reserves that protect existing mature and old forests from resource extraction, and expand wilderness areas.
2.) Resilience-building strategies that address elements of biodiversity (preventing extinctions, ecoregion diversity) and facilitate animal movement by connectivity of protected areas, and new and expanded protected areas.
“An integrated climate-biodiversity agenda is gaining momentum at multiple levels. We propose Strategic Forest Reserves for permanent protection of forest carbon and biodiversity at the highest levels (GAP 1 and 2, IUCN categories I–VI) to support targets that protect 30% of the area by 2030 and 50% by 2050.” (Law et al. 2023)
Stopping the NSM, DC, and AK projects, as well as numerous others in our National Forests, and implementing the AEPA (or some truly protective legislation like it) are essential for meaningfully addressing the climate, biodiversity, and pollution crises confronting the world and all Americans (see e.g. cit. #4). Never before in human history has there been such a need to truly protect lands and keep our grasping extracting and exploiting hands off of them; especially the public lands that are virtually the only very large relatively undeveloped tracts left.
For managing our precious National Forests we need a true Forest Service, not a Timber Service. We must think Big and think Connected — the FS, politicians, and their corporate overlords are. They are increasing logging, altering natural conditions, and getting rid of laws and regulations all over our country. So, big regional and national legislation is vital for making fundamental systemic change in management and achieving true protection (cit. #5).

Big snags. Photo: Steven Krichbaum.
WE NEED A TRUE FOREST SERVICE, NOT A TIMBER/PROFITEERING SERVICE
For managing our precious National Forests we need a true Forest Service, not a Timber Service. We must think Big and think Connected – the agency, politicians, and their corporate overlords are. They are changing laws and natural conditions nation-wide – increasing logging all over the country and getting rid of or circumventing numerous laws and regulations. So, big regional and national legislation is vital for making fundamental systemic change in management and achieving true protection.
Remember that “forest” is a single small word that refers to the most complex of terrestrial ecosystems. Yes there are trees, but it is far more than that — all the flora, fauna, fungi, microbes, soil, and water make up a forest. Current politicians in control can’t see the forest for the trees, that is the focus — more numbers of “desirable” species of trees, those wanted by the timber industry. Everything and everybody else is secondary at best. The FS is not in service to forests, it’s money. Turning our living world into dead money for the enrichment of the oligarchy.
It’s always the same prescription for our National Forests and Bureau of Land Management lands – doesn’t matter what state, what ecosystem, what forest type, what tree species, or what ecological conditions – it’s always: “We need more trees with diameters greater than their height” (aka stumps). Stumps for timber, stumps for wildlife management, stumps for so-called ‘restoration’, and stumps for fire management. The underlying consistency behind these rationalizations is the habitual dismissal of the critical importance of old and dead trees, wilderness conditions, natural disturbances, and limited roads to healthy forests (see, e.g., cit. #6).
The FS has timber quotas to meet, set in D.C. and Regional offices that the individual Forests are required to achieve. And now they prominently use fires to speciously rationalize using taxpayers money to subsidize the timber industry. It seems both major parties can be sadly misinformed about forests and fires. The President and his minions have promoted logging as a way to curb fires even though studies have clearly shown it to be ineffective. Logged-over areas actually aggravate wildfire growth and intensity. The most comprehensive scientific analysis conducted on the issue of forest management and fire intensity found that forests with the fewest environmental protections and the most logging actually tended to burn much more intensely, not less (cit. #7, 8).
Nonetheless, the agency’s focus is on commercially valuable trees. Is there a quota for numbers of salamanders or Box Turtles per acre ? Of course not. All this results in below cost timber sales that cost taxpayers billions of dollars a year (cit. #9). Will DOGE put an end to that and similarly money-losing and harmful subsidized grazing on BLM public lands? Don’t hold your breath. And this benighted approach to forests gets even worse. To expedite logging, bills such as “Fix Our Forests” (H.R. 471) limit litigation involving fireshed management projects and limit remedies that courts may provide. In effect, locking the public out of management decisions on our public lands. We “frivolous” taxpayers get to subsidize the degradation and destruction of our precious homelands, we just don’t get to have a say in it. Whenever politicians feel compelled to pre-emptively lock the public out of our day in court, it’s a sure tell that something is rotten.
It is not just the Trump administration that is the problem, it is the Republicans in Congress – along with a bunch of Democrats as well. We do need new legislation, but not the toxic brew cooked up by Trump and the “Forest Fixers” (cit. #10). We need legislation and policies that free the US Forest Service and Bureau of Land Management from the internal and external pressures that promote and prioritize commercial logging and other exploitation. Not legislation that exacerbates these pressures as well as the underlying fire problem. The focus must be on real protection, not profiteering that gives the false appearance of dealing with a problem.
Congress needs to instead facilitate protection of the “defensible space” around homes and development. We must all urge our Senators to oppose the disastrous, dishonest, and destructive FOF Act (H.R. 471) and instead support H.R. 582, which focuses protection where it matters — where people live.
Since the Trump administration and its DOGE say they are so concerned about wasteful federal government spending, then obviously the first things that need to go are the entire below-cost logging program on our National Forests and the entire below-cost grazing program on our Bureau of Land Management lands (as well as hugely altering the payments from & the language of the 1872 Mining Act). And all the so-called ‘fiscal conservatives’ should be in support of all this and thereby discontinuing the federal government being in flagrantly unfair competition with private landholders. Obviously, right ? But of course not for Trump and his lying minions. It’s not like what they are up-to is nuanced or difficult to understand. The money-loving creation-hating anti-lifers want to convert our living world into dead money for their personal enrichment, end of story.
Citations
1.) S. Krichbaum. 2023. The Big AEPA: A Last Chance to Save the Appalachian Ecosystem. https://www.counterpunch.org/2023/08/14/the-big-aepa-a-last-chance-to-save-the-appalachian-ecosystem/
2.) S. Krichbaum. 2024. Protection And Connection: Reasons for an Appalachian Ecosystem Protection Act. https://www.heartwood.org/heartbeat/HBeat-Spring-2024.pdf (at pp. 26-27)
3.) B.E. Law et al. 2023. Southern Alaska’s Forest Landscape Integrity, Habitat, and Carbon Are Critical for Meeting Climate and Conservation Goals. AGU Advances, 4, e2023AV000965. available at https://agupubs.onlinelibrary.wiley.com/doi/pdfdirect/10.1029/2023AV000965
4.) C. Freund. 2019. Biodiversity loss is the very real end of the world and no one is acting like it. https://www.salon.com/2019/05/27/biodiversity-loss-is-the-very-real-end-of-the-world-and-no-one-is-acting-like-it_partner/
5.) S. Krichbaum. 2021. Protect Life Itself and Make Proforestation the Driving Policy on Public Lands. https://www.counterpunch.org/2021/08/25/protect-life-itself-and-make-proforestation-the-driving-policy-on-public-lands/
6.) K. Zimmer. 2025. The teeming life of dead trees. https://knowablemagazine.org/content/article/living-world/2025/rotting-logs-mini-ecosystems-habitat-and-food
7.) C.M. Bradley, C.T. Hanson, D.A. DellaSala. 2016. Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States?https://esajournals.onlinelibrary.wiley.com/doi/full/10.1002/ecs2.1492
8.) K. Lincoln. 2019. Study Finds Old Growth Forests Burn Slower and Cooler, Preserving Habitat. https://kymkemp.com/2019/07/06/study-finds-old-growth-forests-burn-slower-and-cooler-preserving-habitat/
9.) M. Garrity. 2025. The Forest Service Loses Billions Subsidizing Logging. https://www.counterpunch.org/2025/02/28/the-forest-service-loses-billions-subsidizing-logging/.
10.) G. Wuerthner. 2025. The Fix Our Forests Act – A Trojan Horse for Logging. https://www.thewildlifenews.com/2024/09/20/fix-our-forests-act-trojan-horse-for-timber-industry/
The post Appalachian Mountain Treasures Under Attack appeared first on CounterPunch.org.
This post was originally published on CounterPunch.org.