Black Hills Resilient Landscapes (BHRL) Project

Received this press release today — see below. The Norbeck Society objects primarily to overstory removal, which it sees as “a threat to the long-term sustainability of the timber industry in the Black Hills.”

This is a very large project to be carried out over 10 years. From the draft RoD: “Combined, all of these defined areas total approximately 676,600 acres. Because each activity will occur on a fraction of its defined area acres, and because more than one activity will occur in some areas, the total area where activities will actually occur is estimated at 400,900 acres. This includes approximately 298,900 acres of mechanized activities.”

Includes 185,210 acres of overstory removal.

“Overstory removal harvest is a substantial component of my decision. This treatment method will release young stands from competition with older, overstory pine and reduce stocking levels in overstocked stands. Based on the analysis in the FEIS (pages 58, 60-63, 65), I believe this activity contributes significantly to meeting the purpose and need for this project. Overstory removal treatments will increase the acreage of early succession, younger pine across the project area.”

And: “Among planned activities, overstory removal and patch clearcut will result in the greatest change from existing visual conditions. Because harvest units will be designed in accordance with Forest Plan guidelines, they will appear different from the existing condition but similar to natural forest openings or young stands. The resulting appearance will not be out of character for the area.”


Norbeck Society

P.O. Box 9730

Rapid City, SD 57709

For Immediate Release 

New Proposal Kills Timber Industry by Logging Black Hills to Death 

RAPID CITY (May 22, 2018) — The Black Hills Resilient Landscapes (BHRL) Project that is on the brink of approval by the Black Hills National Forest is a threat to the long-term sustainability of the timber industry in the Black Hills.  Further, the plan threatens ecosystems needed to support diverse habitats for wildlife, the associated regional tourism industry, and the high quality of life enjoyed by area residents.  The proposal also decreases resilience to wildfire and insect infestation in the Black Hills and focuses its efforts on areas that are currently at low risk to insect infestation and wildfire.

For many years, those concerned with widespread logging in the Black Hills have been dismissed by the timber industry as radicals who oppose all forms of thinning.  This is an untrue and unfair description of the concerns shared here.

The current proposal, and the annual timber harvest levels for which it opens the door, kills the long-term viability of the local timber industry with overly aggressive commercial logging on more than 185,000 acres. The timber harvest method proposed for these acres is “overstory removal,” which when implemented will look a lot more like clearcutting than the thinning that has traditionally been used in the Black Hills. Many of these stands proposed for cutting were heavily thinned in the last 10 years. The objective of the heavy thinning was to lower the risk from mountain pine beetle and wildfire. Now, the Forest Service is proposing to cut them again.

To implement the massive harvest, the plan also calls for more than 3000 miles of road work which will further divide and damage forest ecology.  According to required public disclosures, the Forest Service states that the project will cause an increase in noxious weed infestations which they will not have the means to control.

The Forest Service is required by law to manage the National Forest for sustainability — to manage for the “long-term sustained yield” of the timber supply. This simply means that they cannot cut more trees/wood on an annual basis than what grows every year. This is basic forestry that is taught at every Forestry school in the country. Yet, the Forest Service cannot assure us that they are managing the National Forest for long-term sustained yield. It is not addressed in the BHRL project document.

The annual, allowable timber harvest for the Black Hills National Forest was developed in 1997 as part of the current Forest Plan for managing the Forest. Since that time, there have been many, significant impacts to the Forest and its timber inventory, such as large wildfires (Jasper Fire and others) and an extensive mountain pine beetle infestation. Common sense tells one that with these impacts the annual timber harvest should be lowered to a sustainable level. However, the Forest Service continues to harvest as many trees as it has for the past decade even after the mountain pine beetle infestation officially ended in 2016. They have offered no assurance that there will be any reduction in annual harvesting levels with the BHRL project.

If the BHRL project is fully implemented at the current levels of timber harvest, local saw mills could close in the next few years due to a significant reduction in the number of trees left to harvest. This could mean losing all of the 1400 timber industry jobs rather than keeping some to manage a smaller, more appropriate timber program. If the timber industry is shut down completely, it would leave the Black Hills National Forest without an important tool to effectively manage the forest in the future.

The currently planned annual harvests violate standards for a sustained yield. The annual net growth of the forest has been in negative territory for the past decade. (Net growth is simply the total growth minus losses due to timber harvest, insects, and fire.) Yet, those backing this plan, including the timber industry, are advocating for short-term profits for the few over the long-term viability of a healthy timber industry and a sustainable multi-use forest.

In truth, the heavy commercial logging treatments in the Black Hills Resilient Landscapes plan do very little to support the claim of reducing risk of insect infestation and catastrophic wildfire in the Black Hills.  Forest managers have many other tools including prescribed burning and non-commercial thinning to maintain resiliency to wildfire and insect infestation in our forests.  The benefits of these types of tools are high and their use is needed now more than ever to move the Forest to a resilient status. The number of acres set for prescribed burning in this plan should be increased and should be the focus of the BHRL project.  Large fires are weather and climate driven, and the Forest that people depend on needs to be prepared.  Note that the largest fire in Black Hills History, the Jasper Fire of 2000, burned over 83,000 acres through one of the most heavily logged areas of the Hills. The Black Hills Resilient Landscapes project as proposed will also increase the number of large slash piles that can contribute to the spread of catastrophic wildfire, as noted by Dr. Darren Clabo the state fire meteorologist in his analysis of the recent Legion Lake fire (53,000 acres) of December, 2017. (Rapid City Journal, April 21, 2018)

The Norbeck Society will be attending an Objection Resolution Meeting on Friday, May 25, 2018 when objection issues and suggested remedies will be discussed. The meeting is arranged by the Deputy Regional Forester for the Rocky Mountain Region.

Members of the press or public may wish to see the official objections of the Norbeck Society and read about the Black Hills Resilient Landscapes Project

Media Contact:

on behalf of Robert Burns, Norbeck Society President,

Mary Zimmerman


6 thoughts on “Black Hills Resilient Landscapes (BHRL) Project”

  1. “Overstory Removal” seems quite heavy-handed, to me. My timber career started out with OR forestry in the late 80’s. I was never a fan.

    My experience in the Black Hills points to selective logging as being better, with a ‘gaps and clumps’ strategy used. Many parts of the Black Hills are even-aged, and those stands seem to be hitting a wall, at those current densities. Those trees are extremely uniform, and the logging style is based on that current condition. This unusual style of logging includes self-loading log trucks and the logs are almost always the exact same lengths.

    Since there are rare birds in the Black Hills, I expect there will be some areas that will be dropped. Northern Goshawks like the bigger timber, for their nesting habitats.

  2. Larry, the FEIS does a good job of explaining the rationale. “In many areas, existing structural stage percentages are above or below objectives. As Figure 4 shows, open, mature pine (SS 4A) is well above objective levels while several other stages are below.” The photos of each stage are very helpful. The aim is to have no more than 25 of each successional stage, from grassland to late successional forest.

    • This is a forest in a steep inventory depletion trend with an Allowable Sale Quantity in need of dramatic adjustment downward.

  3. Steve, I assume that’s 25% of each successional stage? That sounds like a traditional “regulated” forest, but does it bear any relation to what is ecologically desirable or sustainable? It would be a rare national forest that has too much “open, mature pine” (but I suppose the Black Hills could be the one).

    The issue of sustainable timber volume does seem relevant on forests that have seen large mortality events. There is no requirement to recalculate sustained yield except when forest plans are revised, but there is a requirement to revise forest plans when conditions significantly change. Also after 15 years, and their 1997 plan is over 20.

    The NFMA requirement to not exceed long-term sustained yield is based on a decadal calculation, so they could be making up slack from prior years, but that doesn’t seem likely since it is a 10-year plan (which extends way beyond when they should have revised their forest plan that it is based on). There could be a question about the harvest levels and/or the current plan violating NFMA.

    • Structural Stage 1997 Forest Plan Objectives Current estimate
      1 5% ~ 11%
      2 5% ~ 8%
      3A 10% ~ 5%
      3B 15% ~ 4%
      3C 5% ~ 3%
      4A 25% ~ 45%
      4B 25% ~ 16%
      4C 5% ~ 7%
      5 5% ~ <1%

  4. During the Black Hills Resilient Landscapes project Objection Resolution Meeting this morning with the Region 2 Deputy Regional Forester, Jacqueline Buchanan, the Norbeck Society used the allotted time to discuss the depletion trend on the standing inventory which is currently being ignored:
    The Allowable Sale Quantity (or ASQ) for the 1.2 million acres Black Hills National Forest was developed in 1997 for the Forest Plan when it was set at two hundred and two thousand ccf and we proceeded with what is known as a sustained harvest since growth and harvest/mortality were generally at equilibrium. At the time the standing inventory was about 6 bbf; now it is likely below 4 bbf.
    Since 1997, over 400,000 acres have suffered mortality due to wildfire and insect infestation. These impacts alone should amply indicate that the ASQ from 1997 is no longer valid. The Forest is in a depletion trend and harvest and mortalities have outstripped growth
    The 2016 Forest Inventory and Analysis report for our Forest (FIA) contains strong evidence indicating the Forest has not been operating the timber program in a long-term sustainable manner. Logging has been very aggressive — in fact, timber harvest levels above the 1997 ASQ occurred for much of the past decade. Perhaps this was understandable during the mountain pine beetle infestation. But since the infestation was declared over in 2016, there is no longer a justifiable or responsible reason to be operating the annual harvest at or even near the ASQ.
    What does this have to do with Black Hills Resilient Landscapes project?
    Simply, with the 185,000 harvest acres in BHRL, the door is opened for the unsustainable pace of consumption of our forest to continue.
    The danger of this is that it’s very likely that, at these levels of harvest, the timber industry will soon leave the Black Hills.
    If current annual harvest levels are maintained at 202,000 ccf, we anticipate that the 185,000 acres of BHRL harvests will be completed in 3.5 to 4 years.
    To simply state that the ASQ is from the Forest Plan and that it is outside the scope of the BHRL project is not acceptable to a concerned public.
    The Norbeck Society views it as unfortunate—that what was supposed to be a project to promote resilience on the Forest is really a front for unnecessary and even harmful harvesting of big trees from areas that essentially pose no threat of insects and fire.
    What we recommend as resolution to these issues are as follows:
    The Norbeck Society wants concrete assurances that the Harvest Volumes on this forest will be reduced to a measure commensurate with the standing inventory.
    We estimate that number to be somewhere in the neighborhood of 60-70,000 ccf. per year.
    However, we have some understanding of the pain that would cause for the timber industry, and in order to ease that pain, we suggest a level of 100,000 to 120,000 ccf. sold per year starting with FY19 — that would be the total harvest volume off the forest including all projects. That level of annual harvest would occur only until the upcoming completion of the new FIA report which is expected in about 18 months upon which time an accurate ASQ can be instituted.
    In terms of acres, we estimate that it would be about 25-30,000 acres per year if volumes are taken just from the BHRL Project. That acreage number will have to be lower if sales are made out of other projects since those projects are in acres with greater density.
    In the context of the BHRL project and our Objections, we request that additional language be added to the final Record of Decision that puts caps on acreages allowed to be sold out of the BHRL project until the upcoming completion of the FIA Report.
    We would also like assurances that the FIA Survey will happen and that we will be kept in the loop regarding the process and decision-making surrounding the ASQ and volumes being sold out of all current projects.


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