Norbeck Society: “Alarming New Report Indicates Unsustainable Logging on Black Hills”

Interesting press release….


Norbeck Society
P.O. Box 9730

Rapid City, SD 57709

For Immediate Release

Alarming New Report Indicates Unsustainable Logging on Black Hills
National Forest

RAPID CITY (July 10, 2018) – A just-issued United States Department of
Agriculture report, Forests of South Dakota 2017, shows a trend of
depletion of standing merchantable timber on the Black Hills National

The 2017 report reveals that for the study period ending in 2017, there
was 10 times the volume of timber harvested compared to net timber
growth on all forest land within South Dakota.  Further, the report
shows that for ponderosa pine (the primary commercial species in the
Black Hills), there was more volume lost to mortality or damage, rot,
etc. than there was volume gained in growth.  The ponderosa pine forest
was dying faster than it was growing primarily due to the mountain pine
beetle infestation.  This trend will diminish as the mountain pine
beetle activity decreases, but it still indicates that there have been
significant impacts to the standing inventory on the forest.  The Black
Hills National Forest needs a chance to recover, and this report shows
that there are serious issues with the sustainability of timber
management on the Forest at the current timber harvest levels.

The Forest Service is required by law to manage the National Forests for
multiple uses and sustained yields of timber. This simply means that
they cannot cut more wood on an annual basis than what grows. This basic
forestry tenet is taught at every Forestry school in the country. The
tool that ensures these sustained yields is known as an Allowable Sale
Quantity (ASQ), and it is used as a ceiling, not a target.  For the
Black Hills, the ASQ was set in the 1997 Forest Plan and was based on a
forest with almost double the current standing inventory.

Since 1997, about one third of the Forest has experienced mortality due
to wildfire and insect infestation.  These impacts alone should amply
indicate that the ASQ from 1997 is no longer valid. In response to a
mountain pine beetle epidemic, logging operations were increased and for
much of the past decade, harvests have been above the ASQ.  Harvests
have not been lowered since that time even though the mountain pine
beetle epidemic was declared over in 2016.
Awkwardly, the Black Hills National Forest is in the process of
approving the Black Hills Resilient Landscapes Project, which calls for
185,000 acres of logging and clears the way for high harvest volumes to
continue. Concerns are growing over the long-term sustainability of the
forest ecosystem and the timber industry it supports.  Further concerns
are for the associated regional tourism industry and the high quality of
life enjoyed by area residents.

During a recent Black Hills Resilient Landscapes Project Objection
Resolution Meeting with the Rocky Mountain Region Deputy Regional
Forester, Jacqueline Buchanan, the Norbeck Society used part of the
allotted time to discuss the depletion trend of the standing inventory
of timber.  Norbeck Society asked that language be added to the final
Record of Decision that would put limits on the amount of acres that
could be released out of the BHRL project each year, so that annual
sales of timber could be tapered down until an ASQ commensurate with
current standing volumes could be determined.

The Objection Response by the Forest Service is an assertion that the
ASQ set in the Forest Plan of 1997 is valid and that they plan to
continue with the high harvest volumes until the Forest Plan is revised,
which could take as long as eight more years.  Despite losing a
significant portion of the forest to several large wildfires and
mountain pine beetle infestations since 1997 the Forest Service
maintains that the ASQ from the 1997 Forest Plan is still valid, and
shows no inclination to make adjustments to annual timber sales.  This
is a cavalier response that ignores the reality of the current

The Norbeck Society views it as unfortunate that what was supposed to be
a project to promote resilience on the Forest will actually result in
unnecessary and even harmful harvesting of big trees from areas that
essentially pose no threat of insect infestation or catastrophic
wildfire.  In addition to the worry over the viability of the timber
industry in the future, being unwilling to manage for sustained yields
also has serious implications for the balance of uses on the forest and
for the livelihoods and quality of life for people in all walks of life
who depend on the health of the Forest.  A concerned public cannot
accept this.  The Black Hills National Forest is part of a portfolio of
assets owned by every American and it is important that it is managed
for sustainability.

Members of the press or public may wish to see Annual Reports of Forests
of South Dakota from previous years:

Forests of South Dakota 2017 report:

Black Hills Resilient Landscapes Objection Response:

Black Hills Resilient Landscapes Project page:

Media Contact:
David Miller, Norbeck Society Steering Committee
[email protected]

14 thoughts on “Norbeck Society: “Alarming New Report Indicates Unsustainable Logging on Black Hills””

  1. “The Objection Response by the Forest Service is an assertion that the ASQ set in the Forest Plan of 1997 is valid…” We should expect them to provide the factual basis for this statement; otherwise it (and their decision) is arbitrary (and they don’t talk about ASQ in “their side of the story”).

    Black Hills National Forest Supervisor Mark Van Every says, “We have an overabundance of larger trees that are widely spaced out. We have about 50 percent of the forest in that condition and our objective is for about 25 percent. We’re trying to get back in balance where we have that diversity of sizes and ages of trees across the landscape. And that will involve taking some of those older trees off and allowing those new younger trees that are coming in to grow.”

    Everywhere else this is the desired condition, and the problem is an overabundance of smaller trees too close together. Is this objective for the Black Hills ecologically sustainable or does their forest plan call for the “diversity of sizes and ages found in a tree farm” (a “regulated” forest)?

  3. The danger is the forest being logged out so rapidly that the agency is no longer compliant with the Multiple Use Sustained Yields Act. It’s not really “Chicken Little” once you consider that the Black Hills Resilient Landscapes Project was in part designed to meet very high timber targets and to follow up on “promises made to the Governors and Congressional Delegation”. See pages 17-18 of the National Forest Advisory Board minutes from September 2017:
    The Norbeck Society is interested in retaining industry to meet the needs of the Forest Service as they manage the forest in a sustainable way. We are working hard to see that sold volumes are commensurate with the standing inventory of the forest. Many of the stands in the BHRL Project were just recently harvested under another project and they need to recover from that. The plan to conduct staged clear-cuts on 185,000 of these acres in the next 4 years is just unacceptable. It is important for the Forest Service uphold its original mission of regulating the flow of timber in a sustained fashion and the agency should strongly resist doing otherwise.

  4. I haven’t commented on this site in a long time, but I just saw this…after “googling” BHNF timber Inventory. First off, thanks for the link to the “USDA Forests of South Dakota FIA, 2017” inventory.
    2nd off, I think the Norbeck Society should consider changing the way you think about the forest.
    On page 4 of the “Inventory” it shows the 2007 “Gross Growth” to be 30 Million cu.ft. OR around 150 million board feet/year (MMBF)…(I’m sorry, I’m a board feet guy from the old days…I can “visualize” how much board feet on a log truck, not how much “cubic feet” conversion from cubic feet to board feet is 1 cu.ft.= 5 bd.ft.). The ASQ for timber harvest according to the “1997 Plan” is 86 MMBF…in other words they were only supposed to log “half” of what grew every year. Basically, over the last 10 years, the pine beetle “logged the other half”.

    You have to be careful when analyzing, and drawing conclusions from, the apparent “net growth” deficit shown for for 2017. The mountain pine beetle epidemic ended in 2016…therefore 90% of the “mortality” has ended…so the “Gross Growth” shown for 2017 is now essentially “net growth” (of course there will still be some mortality from root rot ect. ect.) Therefore, we are seeing a “net Growth” in 2017 of around 125 MMBF (25 Million cu.ft.)…and they’re still “constrained” to log only 88 MMBF. Frankly, that’s good news to me. I’m really dying to see the results of the “total inventory” of trees. It used to be 5 billion board feet in “pre-beetle” times…I’m guessing the beetle killed around a billion board feet. The 2013 FIA inventory for the Black Hills basically stated the pine beetle was “logging” around 100 MMBF/year at that time.

    I would also like to point out that the USFS logged 250,000 acres over ten years from 2007-2017. 250,000 that was thinned to a basal area of 50BA…while MPB “thinned” stands that I’ve looked at had a BA of around 5-10…essentially a clearcut (with reserves LOL). The 1997 “Plan” (amended in 2005) calls for 10% of the stands to be managed in a >16″ DBH condition…or “large tree.” I’ve looked at the “thinning release” growth rate on the USFS thinned stands…pretty impresive (2″ dia. growth in ten years)…I’m gonna guess that in 20 years the Black hills is going to have more >16″ DBH trees than at any time in natural history. Well, that’s perhaps a bit bombastic…but they will have way over the 10% threshold. Now you might like to compare that with the “post MPB” condition on some of our neighboring forests to the south in Colorado. the Medicine Bow National Forest had 125,000 acres in an “old growth” condition pre beetle…they’re predicting now that none to very little of that has old growth conditions anymore. I’ve seen where 85% of the BA in old growth stands on the Snowy Range are dead…and only 15% on the old clearcuts from the 60’s…with 6″ DBH trees. It’s ironic to me, that the “oldest stands” on the MBNF…are now the regenerated clearcuts from the 60’s.

    I’ve done some “back of a bar napkin” research on the BHNF for a story I’d like to do some day. The BHNF “1985 Forest Plan” called for logging 120 MMBF/year (remember, the “net growth” was 150 MMBF back then). The 1997 “Plan” reduced that to 88 MMBF…due to “changing public values” and “other resource issues.” I think the idea was to grow more old growth…but the “reality” was it grew more pine beetle. (I find it “ironic” that designated “old growth” and 4C stands that were set aside for “future old” growth…got hammered by the MPB epidemic.) Now, even before the 1997 plan was implemented…timber harvest had fallen off drastically in the Black Hills during the 90’s. And yes, I blame “changing public values”…within the Clinton Administration. Reducing “timber sale” budgets is just as effective as “revising a forest plan” in reducing timber harvest. And there was some timber sale litigation as well, even though not near as much as our friends in Colorado or Montana. If I recall, without digging through my files for that bar napkin, in the 15 years prior to the MPB outbreak in 2007…they harvested about 60MMBF/year…half of the 1985 plan “outputs.” Anyway…according to the back of my bar napkin…”If the timber harvest in the 80’s, as outlined in the 1985 plan, would have “continued” from 1992 to 2007…an additional 230,000 acres would have been thinned in the Black Hills.” Frankly, if “changing public values” hadn’t gotten in the way….I doubt we would have had much of a MPB epidemic.

    Look, I think the folks at the Norbeck Society are good people and well intentioned and aren’t of the “radical litigating variety” of environmentalist (you see, I live in the BH’s too). But I wish they would consider the following. The first USFS “timber inventory” was done 100 years ago by a guy…I can’t remember his name right off…wasn’t Lieberg…he was a crony of Pinchot…Graves I think. And this is all from memory…so take it with a plus or minus. He found the following: 5% of the timber in the Black Hills was “old growth” (>10,000 bd. ft./acre)…another 15% had 5,000-10,000 bd.ft/acre….40% had 2,000-5,000 bd. ft. /acre…and here’s the “Zinger”….40% he classified as “scattered timber”. He didn’t even bother to estimate board feet. Now, in those days, anything >14″ DBH was classified as sawtimber…so that means that even 2000 bd.ft./acre is about 20-14″ DBH trees…that’s pretty slim…that’s a shelterwood harvest. When the USFS thins down to a 50 basal area…that’s 75-12″DBH Trees per acre.

    My point being…that the “biggest missing ecosystem component in the black hills”…is early seral young trees! The BHNF has NO age diversity. Pre MPB…like 85% of the stands were in the “mature” stage…very little “pole stage.” Nothing but 100 year old stands…all made up of the “Fire suppression generation” of trees. My theory, is that 70 years of fire suppression, created this “visual” myth amongst baby boomers in the 70’s that the endless green forest that they’re about to clearcut…WAS the natural forest. Maybe on the Oregon coast…but not here.

    Frankly, if you want to practice in the name of “diversity”, you have to embrace the young trees as well as the old growth. I agree that there is a dearth of O.G. in the Black Hills. Homestake logged off the O.G. Grave’s saw around Nemo and Moskee back in the 30’s. My generation logged off the last of Grave’s “scattered trees” that had matured into old growth in the overstory of the fire suppression generation stands. But as I said before…I think in 20 years…the USFS will have their pick of 16″ DBH trees to designate Old Growth…and let’s protect them by thinning the matrix around them and RX burning under them instead of blindly proclaiming “if we stop logging, with love and care we’ll have Old Growth” cause that don’t work. Frankly, I think nature abhors old growth, unless you happen to be a spruce/fir forest at 10,000 feet or a rainforest on the coast.

    Anyway, this is why I don’t post on the blog anymore. I work for a living and I just ate up half my Saturday afternoon writing this…when I was supposed to be re-reading Forest Fenn’s book so I can go find the treasure!!! LOL.

    • I appreciate your efforts and insights. I can confirm what you are saying, from my several assignments to the Black Hills. It’s very much an even-aged forest, with trees all the same size. Yep, you look at the log trucks and the logs are all exactly the same length. Very uniform stands.

    • Derek, you have written quite a bit here and it certainly reflects your interest in the Black Hills NF. I am having difficulty following your information. Firstly, there are 12 board feet in a cubic foot. The ASQ for the Forest from the 1997 Forest Plan is 202,000 ccf, or roughly 100 MMBF. Of the 202,000 ccf, 20,000 is for POL and 182,000 is sawtimber.

      Yes, the MPB epidemic is over and the net growth will improve over time. Still, one must account for all of the acres that were converted by the MPB from POL/sawtimber (where all of the growth occurs) to seedlings with much less overall growth volume. This will take some time turn this around, possibly decades.

      You say that you have seen thinning release of 2″ of growth per decade. That is very impressive. I wonder what the size of your sample is. On average, the Forest produces about 1″ of growth per decade. Tens of thousands of acres were thinned in the last few years and one is not able to look at a 10 year average for them. You make a prediction that in 20 years there will be a significant inventory of 16″ dbh trees on the Forest as a result of all of the recent thinning. However, you must take into account that the BHRL project will be removing 180,000 acres of these 40 BA thinned stands and converting them into seedling/sapling stands. Much of your predicted growth into 16″ trees will be removed by this project. Many of the open 4A stands that will be left will be the 10-20 BA stands that were affected by the MPB that do not have sufficient volume to make for economical timber harvest. It may take 80-100 years before these stands will once again be eligible for economical timber harvesting. They will probably have some 16″ trees in them, but not in significant numbers.

      The Black Hills NF is in a very difficult situation, due to the impacts of the MPB and wildfires. This will require some serious people taking the effort to understand the situation and leadership making some tough decisions. You certainly appear to have the interest and it will take people such as yourself to be engaged and be part of the solution. There is so much information that it is hard to get a handle on what is the truth and what is not.

      One basic truth is that since 2000, the Forest has had approximately one third of its acres heavily impacted by fire and/or insects. One cannot “whistle past the graveyard” and pretend that this has not affected the standing timber inventory on the Forest. This requires serious leadership that is willing to make difficult decisions for the benefit of the Forest and the people that live in the Black Hills Region.

        • Dear Andy, a board foot is 12″ by 12″ by 1″. Simple math, how many of those are in a cubic foot? That was the simple statement. Derek did a lot of math in his comments and since the Forest Service has been dealing with ccf for a long time now, it is best and less confusing to just use that. Now, a simple, practical method at large scale is 100,000 ccf roughly equals 50 MMBF. That was generally explained in my next sentence. Please read the entirety of my message and then if you have something to respond with, feel free. I know who you are and have read your stuff for years. Much of the time in the past, I have not agreed with you but occasionally I do and I think that your organization does some good things. I am disappointed that you dismissed my comments in such an arrogant way. You say it was fundamental to my thesis but then state you did not read any further. How did you come to the conclusion that it was fundamental to my thesis? That is not a good reflection of someone from an organization that presents themselves as being ethical. If you read my comments, who knows, you may actually agree with some of it.

          • Maybe foresters are no longer taught the finer points of mensuration in school? Back when I taught timber harvest scheduling to Forest Service planners (circa 1979), we covered board foot/cubic foot ratios. In a nutshell (to mix plant metaphors), the ratio of board feet to cubic feet is directly proportional to tree diameter (i.e., “increases”) and indirectly proportional (i.e., “decreases) to tree taper. Understanding these ratios is relevant to figuring out a forest’s sustained yield, which was the topic of your post.

            When buying boards for your new house in a lumber yard, you are welcome to use a 12 bf to 1 cf ratio, although I’d suggest that square feet might be more useful. Just beware that a 2×4 isn’t 2″ by 4” any more than a cubic foot of tree volume has 12 board feet.


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