Black Hills Timber Growth and Yield Draft General Technical Report- Including Stakeholders/Tribes/Public in Peer Review

Thanks to the Norbeck Society for posting a link to this recent draft report on the Black Hills as part of the comments on Steve’s post yesterday.

One of the interesting things about this paper is the peer review process- internal, external, and stakeholders and the public- the review period is from 3/15 to 4/15. I think it’s a great idea to have a variety of perspectives. Some of the most rigorous scientific reviews I’ve seen are when people with different opinions, interests, and experiences on the ground review a paper.

A key point from page 4.

These findings are dependent on estimates of standing live volume, tree growth rates, and especially mortality rates disclosed by Forest Inventory and Analysis (FIA) data. Future climate, weather, mountain pine beetle activity, and wildfire are unknown and potential forest dynamics and growth can only be inferred from past conditions.

These are almost the exact words I used in another thread- perhaps these scientists’ inclination is that the future may not be like the past, but it’s the best data we have. Perhaps that’s a disciplinary perspective, or the effect of watching trees grow and views about the future change over the latst 40 years or so. The reason I’m pointing this out is that scientists from different disciplines or inclination might have chosen to try to predict future impacts of insects, fire, climate and so on, and then claimed that those projections/guesses/assumptions were the “best science.” Since this is an important topic to a wide array of stakeholders, in my experience, concerns about the future might be better dealt with through some group scenario discussion/planning exercise.

87 thoughts on “Black Hills Timber Growth and Yield Draft General Technical Report- Including Stakeholders/Tribes/Public in Peer Review”

  1. I’ve never seen the Forest Service seek internal, external, and stakeholder review of a GTR or similar publication before, and would support a lot more of this kind of outreach. Has anyone else seen this kind of review in the past?

    • The Northwest Forest Plan Science Synthesis was published as a GTR by the PNW Research Station. Because of the level of potential “controversy” over it, the Ecological Society of American facilitated an outside review of that publication in its draft form. There was an internal review of the draft as well that included both scientists and managers. Depending on the topic, research station scientists will ask a wide variety of people to review GTRs in their draft form. FS Research serves a variety of clients, both federal and non-federal. I have been involved in Forest Service EIS projects where a portion of the draft DEIS went out for a peer review. So, it’s certainly not unheard of nor uncommon.

  2. Reading the multiple scenarios that were analyzed, I could find no mention of where “harvest” was generated–no mention of harvest of mortality. So are we to infer that all mortality will be left in place & that harvest will come from green growing stock? In the absence of study information maybe someone smarter than I can look at the numbers to make a determination.

  3. The Black Hills Timber Growth and Yield draft report is of high interest to many and there is an opportunity to hear about the report from the scientists and various stakeholders on Friday. There will be a public meeting held virtually on Friday, April 3, 2020 from 1:00 – 4:00 Mountain Time.

    This is public information for attending:
    You can listen to the meeting and see the presentations by using the two methods here:
    • To listen, dial-in: 1-877-369-5243 or 1-617-668-3633
    Access Code: 0799254##
    • To simultaneously see the presentations in real time, the Adobe Connect link for the meeting is:
    Simply sign in and “enter room”… the virtual room is big enough for 500 people.

    Furthermore, if you wish to view presentations ahead of time, there is a public link to all of them:

    Facilitator introduction (Ben Irey)
    Welcome and Opening Comments (Jen Eberlien, Regional Forester)
    Discussion of Meeting Protocols (Ben Irey)
    Background – How We Got to This Point – shared stewardship agreements (Jen Eberlien)
    The Five Questions – Andrew Johnson
    Designated Stakeholder Opening Comments (Round Robin format – time limit 1 minute each)
    Presentation of FIA Data (Dr. Charles Perry)
    Presentation of GTR results: harvest sustainability scenarios (Dr. Mike Battaglia)
    How the FIA data and analysis relates to the Forest Plan and available timber (Andrew Johnson)
    Stakeholder Presentations or Analysis (based on pre-meeting input)
    Order of stakeholder presentations:
    1. Jim Neiman, Neiman Enterprises
    2. Jim Margadant, Sierra Club
    3. Jeff Parrett – Wheel Timber
    4. Ben Wudtke – Black Hills Forest Resources Association
    5. Bob Burns – Norbeck Society
    6. Tim Danley – Forest Products Distributers
    7. Jack Baker – Baker Timber
    8. Dave Mertz – Forest Service Retirees
    9. Greg Josten – SD State Forester
    Facilitated discussion of the pathway forward

  4. If this is just a compilation of existing data, that’s one thing. If this will be their basis for future planning, and they are saying they are going to ignore future climate change, it might be hard to argue that’s the best available science.

    • Jon, we are very interested in the factors that you would impose on the data and decisions to adjust for climate change. Can you elaborate?

      • Norbeck, if you’re going to the Friday discussion, I think that that would be a good question for the scientists who did the report. I hope you ask them and post the answer here.

        • Projected future timber yields need to reflect future conditions (not past), and sustainability calculations may affect near-term allowable harvest. I was thinking along these lines, however it might apply to the Black Hills (which I know nothing about other than a 1975 backpack through cow pastures). But maybe the loss of standing inventory there minimizes the influence of future conditions.

          • I think we might get mixed up with a lot of somewhat different/somewhat not things here…
            1. the utility of LTSY calculations at all.
            2. What they’re required to do vis a vis regs, and how they are required to be calculated.
            3. How they could be more useful.
            4. Other ways of setting annual harvests (most forests I think are way below LTSY, so they must be using something else)
            5. Generally good ideas for planning approaches about the future, with all topics included (say, scenario planning).

  5. I have to respond to this; if ever there was a smell of “vindication”, this is it!

    In 2016, I was Regional Planning Director for Region 2. I had come to Region 2, from Region 3 where I was Forest Supervisor for the Apache-Sitgreaves NF. In Region 2, I was party to VTC communication between the RO and BHNF on several occasions, concerning the Forest’s (BHNF) opinion that their current harvest was not sustainable, due to the MPB epidemic. All to often, when the camera shut off, the conclusions of RO Leadership had more to do with an opinion the Forest wasn’t doing enough, instead of facing reality. Having never set foot on the BHNF I had no opinion other than follow RO Leaderships rationale.

    Then, after Craig Bobzein retired, I was reassigned to the BHNF as Forest Supervisor (May, 2016). Upon arrival, it became clear Forest employees were genuinely concerned with over harvest. Multiple field trips, with me in tow, demonstrated the visual reality of the absolute mess MPB had made of that Forest. As I brought this to the attention of the RO, I was labeled as lacking in the leadership role because I sided with the Forest. My team and I were the ones to begin developing the additional 2019 FIA increased sampling protocol; the obvious excuse given for our concerns was there was no data to support our assumptions.

    Well, now we have the data; the Forest employees (and myself) were correct and questioning employees concerns as “being lazy” hasn’t panned out too well, My interest was to at least inform industry that the light at the end of the tunnel was an oncoming train! I was not allowed to divulge any information to industry, nor were we able to at least inform industry that their investments in maintaining a higher sell volume might not be the best bet in 2016.

    During my career, I worked in five Regions, mainly timber, and the employees on the BHNF were some of the best I ever saw at managing a timber resource!

    • Jim, I graduated from being Planning Director for Region 2 in 2012. I think most of the folks who were on the RLT with me were retired by the time you came along, so I am curious about how this worked. Without naming names, how do you think “RO Leadership” (RF and Deputies?) got the impression that the employees were wrong. Were there different employees with different perspectives who told them different things? No one would think that the BH Timber (and NEPA) folks weren’t on the ball. But in the interests of an after action review, what do you think went wrong?

        • If you are Jim, I think it’s important that we retirees tell our stories, including why we think things went right or wrong. I don’t think it’s important to attach specific names, especially since they will be gone and the dynamics or world views or reticence to challenge might still go on.

          • It was Jim….

            Writing about this brought up many more events in this debacle; most of what I represented is in writing, in official correspondence and email traffic.

            Thankfully, the data is now available to make informed decisions.

            • Well, Jim, I wouldn’t subject the R-2 FOIA folks to asking for the info on this. I was interested in your story of why (as different personalities in the RO and WO and Administrations changed through time), why these concerns didn’t get acted on sooner. Especially since it is getting acted on now, with an R administration and the same (or not) usual political suspects in SD.

    • Jim, thank you so much for writing this! You did an excellent job of representing the Forest while you were the Acting FS! For anyone else reading this, I was the Natural Resource Staff Officer on the Black Hills NF from 2011 to 2017. Jim states the situation very accurately. The Forest was trying to inform the RO of the situation but they did not want to listen. They listened to the timber industry much more than they listened to their own employees. Yes, they thought we were lazy or not trying hard enough. After all that the Black Hills has done to help the RO carry the timber target accomplishment over the years. Brian Ferebee was the RF and I would say that he should shoulder the blame for how the Forest was treated. He was not helpful at all on this matter.
      This report is certainly no shock to BHNF employees. The handwriting has been on the wall for years. This is a sad chapter in the history of the FS. The Black Hills NF could actually cut itself out of a timber program. To give credit where it is due, the Forest and RO are going through a process of reviewing the draft GTR trying to reach consensus. I wish I had some faith that consensus will actually be reached on this. I highly doubt it. Things are too political. If consensus is not reached, the timber industry’s fallback has been to go to the congressional delegations of SD and WY and they sign a letter to the Chief, and then things move along as they always have.

      Thanks Jim for your time on the Black Hills. You gave us some hope while you were here!

      • You may have seen recently the FS is sending a “team” from the Tongass to the Black Hills NF. The Tongass has always had the best timber beasts for slicking off timber. When I read it, I knew it was more bad news for the BHNF. The RO wants the people who will get the cut out no matter what – laws be damned. I went to the BHNF back in 1991 or 1992 for a forest plan revision meeting and it was butchered then. With all due to respect – and I sincerely appreciate the honest comments here – the BHNF is one of the worst managed NFs in the country IMO. It is more like a tree farm in some areas – trees grown like corn crops. There has never been any respect for endemic processes, much less acknowledgment of climate change. That meeting I went to – about 700 loggers showed up, pissed off, and threatening people. The FS folks just sat there and didn’t say a word. The conservationists had to have a police escort to leave the room. Talk about undue influence. The sad thing is this type of industry and political interference has been going on for decades everywhere. Our NFs aren’t managed for multiple use – they are managed primarily for timber use – and subsidized at economic loss – in other words welfare logging. It is a sorry situation and everything else pays the price – wildlife, hydrology, soils, spread of noxious weeds, etc.. When I worked for our state wildlife agency I was the liaison to the FS. That was back in the late 80s. It was bad then but now it is even worse. The FS has lost its soul so to speak. I have never understood why the FS resource professionals haven’t revolted in mass. There is strength in numbers, and it didn’t have to be this way.

        • The accusations just aren’t true for all Sierra Nevada National Forests. Timber volumes have been reduced to between 1/10th to 1/15th of the 80’s timber volumes, while eliminating clearcuts and old growth harvesting since 1992. Employees are behind this plan except for the slow pace and scale of thinning projects.

          • Who said they were true for all Sierra Nevada NFs? I didn’t. You always seem to twist words Larry which is why I don’t trust what you say. As to old growth logging being stopped that is simply not true. The Six Rivers, Shasta-Trinity, Mendocino and Modoc NFs all continue to log old growth despite all being in violation of old growth retention standards under the NWFP (applies to part of Modoc).

            • “The sad thing is this type of industry and political interference has been going on for decades everywhere.”

              Show us all how this is currently happening in the Sierra Nevada National Forests!

              BTW, the Modoc is considered part of the group of Sierra Nevada National Forests covered under the 1992 (and other) rules regarding timber harvesting.

              Thinning from below is not “corporate welfare logging”.

        • Nor Region 6, nor any other R-2 forests.. And I was there also in the 80’s in R5 and R6, and it is not worse than then.. if you’re against timber harvesting, you can just look at the numbers. I do think every Forest and Region may have a unique history on this, but the trend in harvesting is down since the 80’s.

          • Of course the volume is down. How could it be otherwise when the FS allowed unsustainable logging for decades? Trees take decades to grow back and when you log unsustainably you run out of marketable trees. One of the reasons the FS is going after the little old growth that remains. How often do you get out on the ground? I have photos taken last summer on a NF I won’t name because it is being litigated with marked trees 60 – 120” DBH. Some ancient trees and the analysis says no old growth will be logged. Liar, Liar.

            • I get out on the ground at least once a week. I think the problem is that you are talking about one place/forest and I usually deal with another, as do Larry and Bob and John and Matthew. So we see different things. I can’t extrapolate from the PSICC to the St. Joe to the Klamath.

              Defining old growth has been an issue even in the wet NW- here’s an example
              And that’s for one area, not the whole country. So it’s one of those words (like WUI) with multiple definitions where people can talk past each other. Anyway, please link to the project you are talking about and we can discuss it.

        • Yet here in Southern Oregon the FS is viewed as pro environmentalists. It can take forever to get something done and when a sale does gets puts together it is all about what the biologists will accept. Timber takes what it can get.

      • Dave and Jim, I’m curious about a couple of things…
        What was the role of the Renewable Resources staff and the DRF in all this? Dave, you point out that Brian was not helpful but when I worked in the RO, there was a whole lot of staff support from the RO staffs that influenced the RF. Also in our day, the DRF for resources would have had the major influence. I think it’s important for people outside the Forest Service to understand the moving parts and how decisions are made.

        Second point, when I was Planning Director, I would never have been involved in discussions of sustainability of timber harvests. that would have been totally a Renewable Resources discussion.. only if they needed to change their plan. Maybe that’s why I’m curious as to the role Renewable Resources played.

        • Sharon, you are absolutely correct in assuming that they certainly played a role in this also. My shouldering Brian with the lion’s share of the blame kind of comes down to that he was Captain of the ship. He had numerous, in person briefings with the Forest Supervisor, so he was totally knew what was going on with the Black Hills.

          There is also the WO factor here. Some of this we will never actually know what went on up there regarding this situation. Let’s just say that the message was clear and the message was, get the cut out. I am sure that Brian had his marching orders from them also.

          Regarding Planning, in November of 2018, the Forest Supervisor said that he had RO support to begin Forest Plan Revision. Then the Chief received the letter from the SD and WY congressional delegations where they expressed their desire that plan revision not be undertaken. The message from the RO was to postpone revision. The Forest Plan is 23 years old and clearly outdated with all of the changes that have occurred on the Forest.

          Unfortunately this is how things play out sometimes. Politics certainly plays a role in FS operations. I remember reading in Jack Ward Thomas’ book how he was very unhappy with a decision forced on him and went across the street to the Dept. of Ag and said if things were going to play out that way, they could have his resignation. It ended up working out his way. That kind of courage is probably not all that common in senior FS leadership. Of course they can’t fall on their sword for everything that comes up, but when something like this is so clearly wrong, they should take a stand. Just my opinion.

          • I remember when the Phase II amendment came out in 2005, it seemed like people were glad to get the Phase I/II amendment effort out and it was intended to update the plan. So I would have counted back to 2005 because (some) changes to the Forest since then had been considered. Especially when many other R-2 forests have older plans.

            Question 1. What role did the Advisory Committee play in the discussion of harvest if any?

            Question. 2. While looking up some of this stuff to try and remember, it looks like a sample of forests have not issued monitoring reports since 2013. I wonder why that might be?

            • That’s true, the phase II was a pretty extensive update, however it did not update the ASQ. The issue of standing inventory was not that apparent back then although the Jasper Fire had a big impact. Changing the ASQ (or its modern equivalent) would be a major component for a revision. Not sure what would happen with structural stages in a revision.

              Question 1. The NFAB has had discussions about the issue and I believe there is a subcommittee for the topic but nothing really definitive has come out of it that I know of. Certainly nothing of any consequence.

              Question 2. That last forest plan monitoring report for the Black Hills was in 2014. When the question would come up for doing another report, it would get tabled. Why did that happen? Well, it seemed like no one out there was interested in a report and we were busy with other things. They really are past due to produce one. The GTR could provide a lot of the necessary information.

              • Thanks, Dave. I really appreciate your taking the time to answer my questions. Maybe all they need is a Phase III amendment that targets the ASQ/structural stages issue.

                It seemed like all the R-2 forests were producing monitoring reports for a while and stopped, wonder if it was for the same reasons.

                Your observation that “no one was interested” I find a little surprising. Maybe not every year, but it seems to me like the NFAB, at least, would want one produced regularly. Seems like that would be where the FS, the NFAB and the public might pick up a “need for change”. At least I think that’s the way it was intended to work…

                  • As far as I know, that’s always been the case, though. Back in the day, it was a pot of $ allocated to the Forest (I&M) that could be used for a variety of different things. I don’t know how the FS budget works now. If someone had some time and interest, it might be worth looking at.

  6. Later, we will follow up here on the issue of how factoring in climate change would change predictions in the report and influence the subsequent decisions. Unfortunately, there was just not time in today’s meeting format to find that out. We are grateful for retirees who will speak up (including Jim) to help us understand these issues. As novice members of the public and as volunteers, we are often in the dark when it comes to figuring out what’s really going on. It is highly disturbing to realize how good management of our national forests can be derailed.

  7. To answer Sharon’s question about the Advisory Board, below are the comments on the Draft EIS the Advisory Board developed in October 2017 in response to the Black Hills Resilient Landscapes (BHRL) project. They were developed by a working group, and then the 16 member board (very diverse interests including the timber industry) went over them and things were deleted and added (like the item on goats). Notice the plethora of direction on Resilience, Old growth, Rx burning, etc.

    However, the BHRL project seemed very much like a project with pre-determined outcomes (massive harvests) dressed up as “restoration and resiliency”, and comments like the ones from the advisory board and, for that matter, the Norbeck Society, were just “talking to a wall”.

    The Norbeck Society would sure be interested in some monitoring at this point. We see forest health and possible resilience to future stressors declining as a result of the BHRL project, and we lament the opportunities that exist(ed) being lost along the way.

    National Forest Advisory Board (NFAB) comments:
    Dear Forest Supervisor Van Every:

    The Black Hills National Forest Advisory Board (BHNFAB) submits the following comments in response to the Black Hills Resilient Landscapes Project DEIS Request for Comments. The BHNFAB is a Federal Advisory Committee Act chartered Black Hills advisory collaborative group with 16 primary board members representing a variety of interest areas.

    The Black Hills National Forest Advisory board thanks the Forest Service for producing an EIS that is comprehensive and actionable. The BHRL project as proposed should enhance the resilience and health of the forest. The recent mountain pine beetle infestation has left behind a changed landscape and if well implemented this project could provide a renewed focus on ecological resilience.

    The following is a list of comments and recommendations for your consideration:

    Preserving and increasing resilience must be the highest priority of this project. Black Hills ecological systems must have the ability to absorb disturbance while retaining the same basic structure and ways of functioning, the capacity for self-organization, and the capacity to adapt to stress and change.

    Prescribed Burning
    The DEIS calls for up to 10,000 acres of prescribed fire treatments per year or up to 100,000 acres for the length of the project. This is a commendable goal since it is the primary tool for promoting a healthy understory and for invigorating hardwood species. The potential prescribed burn areas (page 21) of 225,000 seems too limiting to achieve this objective. Prescribed burning is one viable option to reduce understory vegetation in Structural Stage 5 stands, however, many of the existing SS5 stands are outside of the
    area designated for burning. We recommend that the potential area be widened. We also recommend that when setting objectives for prescribed burns that a mortality limit of <5% of overstory be included in the prescription. 
    Where prescribed burning has been done in the past 20-30 years, repeat prescribed fire in order to mimic native fire regimes. A fire dependent forest ecosystem that is resilient is substantially in touch with natural fire regimes. We commend the USFS for placing high priority on prescribed fire as a management activity in this project. It is important that prescribed fire, especially broadcast burning, is carried on as a viable means of reducing regeneration of young pines and promoting resilience. 
    Where appropriate, burn in logged areas within eight years of harvest. Seek collaboration with communities and individuals on projects that aim to reduce surface fuels.

    Aspen, Birch, and Oak 
    The DEIS has lowered the number of acres for protection and promotion of aspen and therefore lowered its aspen regeneration estimates. Current acreages of aspen (40,500) are less than half of the minimum called for by the Forest Plan objective 201 (92,000). 
    Regarding the removal of encroaching pine/spruce from aspen/birch stands, we recommended raising the number of acres from 6,000 to 15,000 acres. To our dismay, the DEIS has further lowered this acreage to 2,400. We find this level inadequate and falling short of the objective of perpetuating aspen and oak to diversify habitat and scenery. The same commitment should be shown to protecting oak, grasslands, and uneven aged pine stands as per objectives. We advise the Forest Service to take advantage of opportunities where they exist.

    Disturbance and Weeds 
    Ecosystem resilience can be achieved by keeping native plant and animal communities intact. Non-native invasive plants could flourish and threaten the integrity of Black Hills plant communities. When disturbance is necessary, continue to work with USFS foresters, silviculturists, botanists and wildlife biologists, and follow their advice. When necessary to achieve resource objectives, schedule logging activities and associated road construction activities during dry or frozen conditions to minimize ground disturbance. This prevents noxious weeds from germinating, results in less regeneration of pine seedlings, and preserves native forb communities. 
    We suggest the FS explore the use of goats for weed management and for eliminating underbrush.

    Climate Change 
    As it relates to the idea of resilience, climate change will “push certain ecosystems and species beyond their capacity to recover” (West and others 2009). Additionally, aspen stands are expected to decline by 40% within 50 years as reduced soil moisture and changing fire patterns affect the trees. Within BHRL it is imperative that climate change is taken into account in action so as not to place resources on fragile stands or species whose viability may not be assured moving forward.
    Impacts from insects, wildfire, drought, and heat are being exacerbated by climate change. The trend indicates potentially hotter and drier conditions that amplify existing stressors and also create their own. Even a degree or two of temperature rise is known to have an exponential effect on fire behavior. Resiliency to stressors must be viewed in the light of climate change.

    Structural Stage 5 
    Special attention needs to be given to a management strategy for Structural Stage 5. As research and history have shown, stands of older, larger pines are difficult to maintain when fire is removed and historically dense conditions are widespread across the forest. The Forest should develop a long term, science-based plan for these stands. Actively support stands being managed for SS 5 by removing the understory in these stands with cutting and/or burning.

    Timber Harvest 
    We recommend flexibility be built into the potential Commercial Treatment Areas when onsite analysis occurs and there are updates to stand conditions, so that this plan will allow treatments to still be carried out. 
    The land management activities in the DEIS include goals for maximum treated acres for harvest, burns, and hardwood enhancement. We recommend that these goals also include achievable minimums per year for each management activity so that the project moves forward in a balanced way, so it truly results in a more resilient landscape. 
    The effects of precommercial thinning/POL thinning are not adequately addressed in the DEIS as to how it relates to meeting the goals and objectives of specific Management Areas of the Forest Plan. Identifying a broad range of tree sizes (1 foot in height to 8.9" DBH) and a narrow range of spacing (12×12 to 24×24) fails to provide adequate information as to the effects and consequences of this action. For example, thinning 8” DBH trees to 24' x 24' spacing will produce a much different stand than thinning 1 foot tall trees to 24' x 24' spacing. That wide of spacing of 1 foot tall trees will not be adequate to stock stands with trees, will eliminate self-pruning & increase fire hazard, it will create too open of a stand which will promote noxious weeds, it will not provide screening for wildlife, it will allow another crop of regeneration to become established, and it will not promote good tree form for timber production. We recommend categorizing the expected spacing to be used for each size class and include what the desired condition will be.

    Monitoring 
    Whenever feasible, identify benchmarks of success as management activities are implemented. Post treatment monitoring should be employed in a method consistent with the Forest Plan. In ten years, BHRL will be deemed a success if the described treatments for Rx burn, thinning, aspen/birch, are accomplished. There will undoubtedly be tests of ecosystem resilience in the coming years and we should use those to gauge success and alter management approach as time goes forward.

    Thank you for your consideration of these suggestions. We continue to be in full support and look forward to the implementation of this project.
    cc: Anne Davy, Project management, and Elizabeth Krueger, Team Leader

  8. It should be noted that the large amount of commercial harvests in the BHRL project are taking place within the span of just a few years, while other elements of the project are moving at a snails pace and may never be performed.

  9. On that last point, why can’t they make future timber harvests contingent upon prior completion of other restoration? A forest plan could require this. Conversely, if a national forest has a track record of restoration not occurring, then it can’t project benefits from future discretionary restoration.

    • Jon, that is exactly the point made in the Advisory Board recommendations under Timber Harvests:
      “The land management activities in the DEIS include goals for maximum treated acres for harvest, burns, and hardwood enhancement. We recommend that these goals also include achievable minimums per year for each management activity so that the project moves forward in a balanced way, so it truly results in a more resilient landscape.” 

      • What happens with these “Big Gulp” NEPA projects is that everything gets thrown into them. The thinking usually is “well, we’ll have the NEPA clearance for those things if we get the funding for it”. And, occasionally some extra funding comes along and strides are made to get those things done. However, past funding is almost always a guide to what the future funding will be, and provides the likelihood of those projects getting done and to what level. The question that should be asked during the comment period is “what is the likelihood of these other types of actions actually getting done, based on past funding”? The standard answer for future funding is “we don’t know”. But, they do know their past funding and that really gives you the idea of whether or not something will happen or not. Good intentions are fine, but reality is often something different. Unfortunately, sometimes these “white hat” activities help provide a purpose and need for a project and then don’t really happen, at least to the level described in the project. Another good reason for project monitoring.

      • My comment was provided in the context of forest planning. It would be possible to write a plan standard that would prevent some actions from occurring until other actions had been completed or until certain conditions are achieved, and that would be mandatory under NFMA. Within the context of a project decision, I think you are left with NEPA. The FS should not be able to claim beneficial restoration effects unless they are reasonably foreseeable, but the question is how you can structure a project decision to make them foreseeable (and how to stop implementation if that structure is not followed).

  10. I don’t know who wrote these statements for the committee:

    “As it relates to the idea of resilience, climate change will “push certain ecosystems and species beyond their capacity to recover” (West and others 2009). Additionally, aspen stands are expected to decline by 40% within 50 years as reduced soil moisture and changing fire patterns affect the trees. Within BHRL it is imperative that climate change is taken into account in action so as not to place resources on fragile stands or species whose viability may not be assured moving forward.
    Impacts from insects, wildfire, drought, and heat are being exacerbated by climate change. The trend indicates potentially hotter and drier conditions that amplify existing stressors and also create their own. Even a degree or two of temperature rise is known to have an exponential effect on fire behavior. Resiliency to stressors must be viewed in the light of climate change.”

    but some of the claims are a bit off… what is an “exponential effect on fire behavior?”
    “Aspen stands are expected to decline by 50 % in 50 years”… but aspens like fire.. and fires cause them to seed and provide lots of genetic variation for evolution to work on. So I think that there are two possibilities that both might be considered about how climate change affects aspen.

    As to this “As it relates to the idea of resilience, climate change will “push certain ecosystems and species beyond their capacity to recover” (West and others 2009).” This is not known. It depends on a variety of factors that are currently unknown.

    One more example shows more annual precipitation for the Hills, may have different timing.. how would this affect different species .. we don’t know. Also, there is this map from this report
    I couldn’t copy Figure 7.5 but check it out for future projections in the Black Hills (or your own) area.

    • Basically 16 people with varied interests wrote the Advisory Board recommendations. It seems that part of the task of FS personnel recording these would be to interpret them, ask for clarification, or engage in a discussion about them – if they cared to. As mentioned earlier, the BHRL project seemed very much like a project with pre-determined outcomes (massive harvests) dressed up as “restoration and resiliency.” And that appears to fit with the rest of the story and the GTR that started this thread. The big question is “Now that the science is out, will Forest Service choose to manage with that, or will they have to go along with politicians and industry, i.e. they have no choice?”

    This article is on the response of the State to this GTR, and this line got may attention: “The General Technical Report conducted by the United States Forest Service Rocky Mountain Research Station says the current forest management plan is not sustainable.” With this kind of best available science from the Forest Service, staying the course isn’t likely to be an option. Sustainability is a legal requirement, and this report should lead to a conclusion that conditions on the Forest have significantly changed, which would trigger a need to revise the plan under NFMA. It also would violate the non-declining flow limitation, which can only be done using the procedures to establish a departure sale schedule contained in NFMA. I don’t believe it requires a forest plan amendment to recalculate the ASQ (though effects of changing ASQ may need to be subsequently evaluated and possibly addressed). That’s a short-term fix that is probably required, and subsequent harvest levels should not exceed that.

    • I agree with everything you have written here. The report makes clear that the Black Hills National Forest has clearly changed over the last 20 years. Staying the course can only happen due to politics, not science. If that happens, the Forest would certainly be vulnerable to a lawsuit. It would be sad if that is the only remedy to this situation. This is an opportunity for the Forest Service to do the difficult, right thing. I have some faith that they will. By making the necessary changes now, there will be impacts to the timber industry and Forest employees but it would allow the timber industry to remain viable in the Black Hills for the long-term. It would not be the size that it is today, but it could be viable well into the future. It has become clear that when you have a timber industry that is largely dependent upon federal timber, that they really struggle with long-term forest management and planning. They are focused on getting log trucks into the mills and product out of them. It is very hard for them to think of 10-20 years out, let alone 100 years down the road. That is why it is the Forest Service’s job do that management.
      Let’s see how this goes and if we’re able to do the right thing.

    • Jon Haber, the article is about the Pennington county commissioners, although the South Dakota state forester Greg Josten has taken a similar stance of questioning the data and conclusions in the GTR.

  12. And now this:

    Excerpts with [Norbeck Society commentary in brackets]:

    “…proposed change to the sawtimber harvest in the Black Hills National Forest could devastate the timber industry…” [In actuality, it will reduce, not devastate industry, and would save jobs in tourism (a 2.6 billion dollar industry) and recreation, maintain property values, preserve quality of life, etc.]

    “Guffey said reducing the harvest that much would do more damage than good to the forests here.” [In reality, it is a good thing to regulate timber sales; we found that out 120 years ago, thus Case #1.]

    “I think the forest industry is vital,” Guffey said. “If we didn’t have them here, the last pine beetle epidemic would have been a lot worse. Same with fires.” [Fire and bugs are coming with the doghair now liberated by recent logging.]

    “He said the conclusions reached by the GTR were based on incorrect assumptions and produced invalid results.” [The GTR is peer reviewed science, and more review is ongoing.]

    “The use of 2.98 percent or 2.5 percent rate of mortality in the scenarios is not representative of the current condition of the Black Hills,” Guffey said in his comments. “The current conditions of the forest more reflects 1962 to 1999 mortality rates of 0.16 to 0.26 percent.” [van Mantgem et al. (2009) indicated that recent trends in mortality in pines across the Western United States over the past 4 decades have been increasing.]

    “We have known we were coming to this crossroads for some time,” Wudtke said. [In fact, as timber industry lobbyist, he has used the expectation of this report coming out this year to kick the can down the road – to ignore the changed condition of this forest. He has pushed (even via politicians) to continue with excess harvests while agreeing to the process carried out by this report and the data that supports it.]

    “Some of these decisions are being based on faulty information,” Wudtke said. “We want to keep our capacity moving forward. There is just no reason to grow the forest back to the conditions that started the pine beetle epidemic and fires in the 2000s.” [Decisions have yet to be made and there is another meeting of stakeholders on May 1. Logging is not stopping the forest from growing into unhealthy conditions.]

    Guffey also pointed out that the GTR doesn’t account for harvest outside of “suitable” timberlands. [It also does not account for restricted lands inside the suitable base.]

  13. Even as a fan of active management, I’m not sure of the path forward. The Black Hills are where east, north and west meets. Many of their pine stands seem to be even-aged, and very uniform. Log trucks have logs that are all the same lengths, it seems. I’m not sure how the leave trees would respond to thinning in a near-mature stand, in the Black Hills. The more mixed conifer forests would probably benefit from thinning, at the higher elevations. This is just my ‘anecdotal’ opinion from 6 weeks of field work there.

    • The question at hand is not “Should we log or not log?”

      The question is “Should volumes be reduced so that yields can be sustained in perpetuity or not (whereby we will be out of timber in 34 years)?”
      Another way to put it is “Should we ignore laws and rape and pillage, or not?”

      Active management includes being mindful of the limits of your resource.

  14. Dear Norbeck.. not to be snowflake-y but I don’t think it’s appropriate to use the term “rape” to apply to excessive timber harvests. Rape is about lack of consent for an act that is otherwise a wonderful act that gives rise to human beings, good feelings and all that. The difference between that wonderful and joyous act and rape is all about consent. I don’t think that that is really a good analogy to describe “cutting too many trees” when if you asked a tree, probably none would want to be cut.

    Perhaps the word “castration” carries some of the same emotion you want to invoke without going there? As in should we “castrate and pillage?”

  15. Dear Sharon… nice distinction, thank you: “castrate and pillage” then. A rose could be called by any name and smell just as sweet. And no matter what we call this topic, it is rotten to the core…

    Some of what is being cut in order to fulfill the inappropriate volume targets:
    1. Healthy trees on the small side that are still putting on good growth
    2. Stands that could and should be kept because of nice old growth characteristics (while falling short on SS5 objectives of the Forest Plan)
    3. Stands where the regen is not established
    4. Mature trees swimming in unaddressed doghair surrounded by over 8,000 acres with virtually no other mature stands in sight (“distribution of structural stages over the landscape??)
    5. Stands outside of the sites designated in the NEPA document map
    6. Stands where the paint markings from the last sale are still present

    So, even if we just call it “pillage”, the situation is an affront to honest forestry. Most would agree that perhaps the first principle to be observed should be that of sustainability; and many can surely understand that forestry can be taken to the level of the exercise of skilled mastery – an art. None of that is happening here. No, in the Black Hills National Forest we pillage nature and cut down our own future for the insatiable hunger of big timber and politicians.

  16. Dear Sharon… thanks for the distinctions. So, maybe it is “castrate and pillage” then. A rose called by another name would smell just as sweet. And circumstances like these labeled otherwise (and perhaps slightly off definition), just as rotten.

    And maybe some of the things happening here go beyond “excessive timber harvest”:

    1. Trees on the small side and still putting on good growth are being cut

    2. Mature stands lonely in a more than 8000-acre landscape of young trees are taken

    3. Trees swimming in unmitigated doghair are being snatched, doghair driven over and left

    4. Stands are being cut under Projects but are outside of the specific sites designated in the public-disclosure NEPA maps of said Project

    5. In a forest short on structural stage objectives for old growth, old growth is cut down

    6. Sales are laid out where the paint from the previous sale is still bright

    … all done to meet inappropriate timber targets.

    Most would agree that when it comes to honest forestry, one of the first principles to observe is that of sustainability. Many would recognize that true forestry can also be brought to a level of the exercise of skilled mastery – an art.

    But none of that is not happening here. No, here on the Black Hills National Forest, we shamelessly pillage nature and castrate our futures to feed the insatiable hunger of the timber industry and politicians.

  17. Well I missed the boat here, and am jumping on the thread late but… I worked on BHNF from 1971-1976 doing mostly timber work (prep, admin). While Deputy Chief (circs 2000), BHNF plan appeal was remanded for further work, then there was huge Jasper Fire, and goshawk nesting habitat issues. Can’t recall all the details but Sierra Club sued for injunction on timber sale harvest, precipitating shut down and I was more or less “frog walked” into Tom Daschle’s office (D-SD, Senate Majority Leader) to explain how the FS (me, really!) could let this happen? I recall talking with Daschle’s staff after meeting noting that I was a bothered at how “pro-logging” he appeared, displaying little interest in some important env issues.

    As it turned out, DOJ and Sierra Club immediately began bargaining for interim measures — complicated, but we essentially came up with about 2 years of available volume outside of goshawk habitat for industry while BHNF fixed their plan. Not a bad outcome, but one I could not guarantee in prior meeting with Daschle.

    BHNF has always had a robust timber harvest. What I’m curious about — especially comments from Zornes/Mertz — is how did RO “Make the BHNF cut more than the forest staff want to”? That’s a pretty hard one to swallow, particularly in an Obama admin. What leverage did RO have on BHNF? I have a hard time imagining Bobzein kneeling for that.

    • Well, we spent years talking with the RO about the timber supply issues and for some period of time, I think that they just did not believe that we truly had a problem. They were being told by the timber industry that we were overreacting. I think at some point they started to accept that there was indeed a problem but the politics directed at both the RO and WO kept them from allowing the Forest to make changes. With regards to this issue, they truly were micro managing the Forest. I was just the Natural Resource Staff Officer and I was not really in on the behind closed door conversations, but from what I was told, they were giving strong direction to the Forest Supervisors to keep up the volume until at least the data came in, and I believe that is what happened. The leverage was they assigned a target and a budget and that was the program of work. I guess if they had a Forest Supervisor that couldn’t do that, they would find one that would.

    • Thanks for jumping on, Jim. As you say, for some things the FS proceeds along regardless of national Administration. I think it’s interesting to explore these and what forces are operating to have this happen. Some of that is probably responding to litigation, and some of that may be the effect of elected officials that administration are not interested in expending the political capital to overrule. Would the dynamics have been different if Daschle had not been a D, and/or had not been Majority Leader? If an Administration wants legislation passed (and who wouldn’t), the Majority Leader is highly important. If Daschle wanted to be re-elected it would be helpful to support SD industries, including the timber industry. So it’s easy to see how this could happen.

      During the Obama administration, I might have mentioned that CEQ basically told EPA to stand down on a Black Hills analysis that was not site-specific. Was the BH selected as a place for large-landscape NEPA pilot project due to some political thing, or due to the diligent staffwork of the FS NEPA staff in selecting great NEPA people for the pilot projects? Probably somewhere out there someone knows, but not me.

  18. I was on BHNF 1988-2019. As Forest Silviculturist the projections started in 2011 are bearing fruit now. The past…the 1983 forest plan timber projections were trashed because not politically accurate. The 1997 forest plan had last minute adjustments. The lawsuit negotiations had common sense out the door per DOJ orders. I was the USFS hotseat person with negotiations. Enter Phase I & II …recalculated volume output from lawsuit effects tiering to species assessments but resulted in lower numbers so kept 1997 level. Then came 225,000 wildfire acres, 225,000 tree mortality acres from bugs, and accelerating timber harvest to capture trees before bugs eat em starting 2007 to today. Year 2013, FIA growth to removal ratio less than 1.0 …or trees removed more than growth…and has declined since every year since. It’s now a negative net growth per FIA. Oh and the 1997 forest plan had LTSY adjusted and non-declining even flow calcs turned off to be more politically correct. This reared its head again when contracting or 3rd party analysis was done. Contractor brought up skeletons of the past. Dave Mertz and I had many meetings with timber industry per Bobzien’s direction…they do not believe numbers. To Bobzien’s credit we voiced concern to WY and SD congressional reps in 2015 and 2016 and even voiced to USFS RF….and got silence. USFS RO informed Forest Sup Van Every to inform me I was not allowed to talk at meetings on this subject. All collaborative groups agreed on process to gather data. Got data now. During process, the Forest kept cranking out the volume. The numbers are obvious. The Forest is managed from Washington. The GTR displays the routes. There is no forest management. The priority is volume sold target. The problem is pine regeneration…very little funds for thinning. Forest needs to thin 50,000 acres per year…it’s about 6,000 per year. The standing volume has been cut in half from year 1999…per FIA. Numbers now that mirror calcs that I did years ago…that some internal employees will attest. Do the math…cannot harvest that high. Harvest acres will be increasing to 35,000 to 50,000 acres per year to reach volume sold target. Timber industry never has and never will agree with USFS. Congressionals always side with timber industry. BHNF employees not believed, their work not accepted (like me), told to not speak….all in pursuit of volume sold. The end is in sight. Leadership will be credited for the fall. Leadership wants no conflict, push the nasties under the rug and kick the can to the shift and they retire, move up or move out. Trust me…forest supervisors know, they’ve seen the forest, they get gag orders too like Jim Zornes stated. BHNF is public land, there are laws, so why does short term economics rule ? Ask Washington. They kick the can too. In the meantime …the forest is changing. The lorax is motion.

  19. I wonder now if there is a need for some context here for the more casual observer – how unusual is the Black Hills story for this era of the Forest Service? (I was never in the room for these kinds of conversations.)

  20. Blaine!! Welcome to the fray, Baby!! Thx for perspective and field trips with you…
    As to Daschle. He was: 1) Dem, 2) Majority Leader (who got upset by Republican Representive John Thune – perils of being a D in a red state. Mitch McConnell beware!), 3) deeply beholden to timber industry, who I assume showered him with $$ to curry favor, 4) eager to flex his muscles on their behalf.

    Haber: I think you can assume such shenanigans are not unusual, especially where you have a significant volume involved and a Congress willing to flex their muscles. My experience in PNW is that the entire region was basically run this way for decades. What changed was when judiciary got involved making it impossible to mess around. UNLESS they changed the laws!! This is one case of silver lining of an incompetent Congress makes new legislation impossible. You know they’ve taken runs at “fixing” NFMA, NEPA etc to no avail.

    • “You know they’ve taken runs at “fixing” NFMA, NEPA etc to no avail.”

      Yes, but the Forest Service is nearing finalization of its proposed NEPA regulation re-write, and CEQ is also marching forward. Under both rules, it will be MUCH more likely that situations like what are going on in the Black Hills will happen much more frequently, to the detriment of our public lands and the communities they support.

      If the rules survive judicial review, of course.

      • I don’t think so. The Hills is very unusual, both biologically and politically. What if Daschle had been an R? (not unusual in that part of the world) And a D national administration had had a large contributor/contributing interest group with a strong interest in reducing harvesting?

        For whatever reason, the same groups who otherwise litigate seemingly small projects have not brought the same degree of litigatory enthusiasm to the Hills. Lack of an ESA nexus? Lack of local interested deep-pocket folks? I don’t know.

        I just don’t see this kind of thing happening in Oregon or Montana or California or Washington – because they have more litigatory watchdogs, because the timber wars have been effectively won (NW Forest Plan, Sierra diameter limits), and people have had 25 years or so to become accustomed to it Meanwhile, in Utah, Arizona, New Mexico and Colorado, the timber industry does not seem to be a significant factor.

        As we watch our friends on the Pisgah-Nantahala grapple with their competing interests, it’s also hard to see that kind of thing materialize.

        • Respectfully, I think you misunderstand my point, Sharon. My point is that the Forest Service’s and CEQ’s proposed NEPA regulations do things like eliminate the requirement to consider cumulative and indirect effects, shift most of the USFS’s decision-making to CEs that are not subject to public review and comment, and allow for timber harvest on up to 7,300 acres with a CE (not subject to public review and comment). If these efforts are successful, it is more likely that environmental harm – over logging – may occur.

          And, I already see “this kind of thing happening in Oregon.” The timber industry is doing its best to reignite the timber wars by advancing a so-far-mostly-successful campaign to expedite unsustainable timber harvest on the O&C lands here, with an eye towards extending that to the national forests. While there is a lot of ongoing litigation challenging this move, as a student of forest history, I feel like I’m trapped in a 1989 loop with the federal agencies (particularly the BLM) disregarding the best available science in an effort to get out the cut.

          • I still think that our differences are mostly geographic (like I see western Oregon as one of many forests, many of which do not have a politically/litigatorily enhanced timber industry.)

            1. I think the CEQ and FS nepa regs will be litigated, and a D will be elected Prez in the fall who won’t defend them.
            2. I think scoping is in fact a form of public comment and I think it would take a great deal of pressure (which R administrations are unlikely to have at the ground level) to force people to do 7300 acres CE’s.
            3. However, I don’t know what the sale quantity is on O&C compared to the 80’s. Does BLM have LTSY calculations? Is there some reason they haven’t been litigated if they have exceeded them?

            • Actually, we’re already seeing very large CEs, and given the direction from the WO to use CEs wherever possible, I fully expect this to continue. I also suspect that in its final rule, the Forest Service will actually retain the scoping requirement for most CEs, even though the draft rule eliminated this requirement.

              The sustained yield calculation for the O&C lands has fluctuated over the years, and the lands often produced more than a billion board feet per year in the 1970s-1980s. The conservation community’s focus has been on protecting wildlife and water quality on those lands, and tools such as NEPA and the ESA have been easier to utilize than going after the BLM’s sustained yield calculations and any exceedances.

              • Source:

                This paper draws on systematic data from the US Forest Service’s (USFS) Planning, Appeals and Litigation System to analyze how the agency conducts environmental impact assessments under the National Environmental Policy Act (NEPA). We find that only 1.9 percent of the 33,976 USFS decisions between 2005 and 2018 were processed as Environmental Impact Statements, the most rigorous and time-consuming level of analysis, whereas 82.3 percent of projects fit categorical exclusions. The median time to complete a NEPA analysis was 131 days. The number of new projects has declined dramatically in this period, with the USFS now initiating less than half as many projects per year as it did prior to 2010. We find substantial variation between USFS units in the number of projects completed and time to completion, with some units completing projects in half the time of others. These findings point toward avenues for improving the agency’s NEPA processes.

                • And here’s one of my favorite findings:

                  “There is a widespread perception that NEPA analyses are frequently litigated. Our data show this is not the case. Less than 1 percent of all completed NEPA analyses in our dataset led to litigation (292 cases), including less than 1 percent of [categorical exclusions], 2 percent of [environmental assessments], and 12 percent of [environmental impact statements].”

                  NEPA is NOT the litigation bottleneck, at least for the Forest Service, that so many suggest it is.

            • Sharon:

              Echoing Susan Jane here and providing a couple of examples of super-sized CEs. The Ashley National Forest has scoped and may soon approve a CE to undertake aspen management treatments (some fire, some logging) across the entirety of a ranger district’s 170,000 acres of aspen; the vast majority is within inventoried roadless areas. See

              The Dixie NF similarly scoped a project for “wildlife habitat improvement,” including prescribed fire and mechanical treatments, across the entire ranger district outside of designated wilderness. “Approximately 320,000 acres of the Pine Valley Ranger District are under review for treatments including the 250,000 acres in IRA.”

              Both proposals are effectively programmatic decisions allowing thousands of acres per year of treatments for a decade or more. Parts of these proposals may have merit, but the breadth and duration of these projects are, one might say, potentially significant, requiring at least an EA (as numerous groups told each forest).

              Add these proposals to the FS draft NEPA regs proposal to eliminate the scoping process for CEs and you have a recipe for a lot less accountable, review, and public support,

              • Hi Ted, good to “see” you here! I did review what I call the CEs from the Rissien study and where they were in the process in these posts

                I hadn’t got to posting about the Ashley aspen project yet, but in an email about the East Zone project, the ranger said “After receiving some comments concerning the project scope and acres (area of scope) for the East Zone Fire Management CE I decided to look at each proposed project individually rather than as a whole.”

                It’s interesting to me that scoping apparently led the ranger with the East Zone project to go another NEPA route, which would be “using public comment from scoping.”

                I agree with you, though, on the general concept of large programmatic CE’s, though, when these little projects do seem to fit the wildlife habitat improvement category. If they were my projects I would use multiple CE’s and streamline the process (have ID teams visit a bunch in one day, have a standard template, and so on). Of all of them, I like the White River because of the open nature of site-specific reviews and public involvement. But you might argue that I have a soft spot for the White River, and you would probably be correct.

                You might be surprised to know that one of the major opponents to using CE’s when I worked in Region 2 was Tom Troxel of the timber industry. They liked certainty and didn’t like potential litigation-related drama. My point being that I don’t think the idea of programmatic CE’s is necessarily about getting trees to mills.

                • Sharon:

                  Thanks for the welcome back, and for continuing to provide a venue for civil discourse on these issues. It’s important. And I didn’t see your conversation about Adam R.’s analysis before wading in; there’s a lot to read here!

                  Very interesting re: Tom Troxel. Certainty is something industry likes.

                  The East Zone CE is an interesting case. Local and regional groups raised issues about the scope of that project which in part, I think, led the District Ranger there to choose annual CEs rather than one covering a decade or more of work. I’m of mixed mind about that approach. Annual CEs will provide more transparency than a programmatic CE b/c it will require the FS to identify specific proposals – the where and when of treatments – which is important for NEPA review and public understanding. On the other hand, if these annual CEs are all related, or part of a program, or likely to have cumulative impacts, it would make more legal sense to undertake a programmatic review of some kind, with site-specific step-down NEPA later if necessary.

                  I’m happy to share comments submitted on East Zone, Pine Valley, and Ashley Aspen if you’d like to see them (I don’t know how to upload them here.) Comments on the White River CE, raising the transparency issues, are here: I’ll add this link to that thread as well.


                  [Aside – I value the FS practice of posting comments on projects to the web, and wish they’d do it for more projects.]

                  • My goodness, those White River comments were extensive!
                    Here’s what I think.
                    #1 the wildlife CE is fairly unique, as other, more current CE’s have acreage limits.
                    #2 But given that, in practice, what’s wrong with using a CE when it fits?
                    Here’s an example of a CE that made it through court (not the wildlife category)- it got public comment via scoping (as you all commented on the other CE’s through scoping) and the scoping doc has much information, photos, and maps in 26 pages. They even have an appendix with response to comments. . And as CEQ says “While the regulations do not contain page limits for EA’s, the Council has generally advised agencies to keep the length of EAs to not more than approximately 10-15 pages.”
                    So I think that the key info, public comment, and response to comments fitted the requirements, and it was good NEPA practice, and also legal, according to the court. Do you think it should have been an EA? What additional benefits would that provide?

                    #3. I think your point about “how many little things make a big thing” is a great question. Some would argue that that is the point of a Forest Plan EIS- to analyze impacts of all planned programs in one fell swoop. However, it does not seem to work that way. So does it make sense to analyze all kinds of projects on a landscape at a time? So-called big gulp projects? Or do it program by program (the prescribed burning program, the aspen restoration program and so on?). Some programs, as you know, like oil and gas, and travel management are traditionally done by programmatics, so FS NEPA tends to be a mixture of all of the above.

                    Perhaps more importantly to the CE discussion though, I see your same concern arising if a District did lots of EA’s, say for prescribed burning, perhaps there should be a Forest-wide PB cumulative effects analysis? But wouldn’t that be covered in the Forest Plan EIS? So given, say, a Forest’s standard kinds of activities, how would you see an optimal NEPA design?

  21. The second Timber Sustainability Stakeholder meeting is this Friday, May 1, 2020, 1 – 3:00 Mountain Time

    You may post or share this conference line information with others – this line is for our non speaking stakeholder representatives, members of the public and media who are interested in listening to the meeting and viewing the presentations.

    Phone lines and Adobe Connect will be active no later than 12:45 p.m.

    Adobe Connect Information (visual):
    Once you have launched Adobe Connect, enter your name in the sign in box – this is how you will be identified as a speaker or non-speaker with the associated privileges.

    AT&T Teleconference line Information (audio):
    Dial-in: 1-877-369-5243 or 1-617-668-3633
    Access Code: 0830314##

    The meeting is being facilitated by Mr. Ben Irey from the National Forests Foundation.

    The following list of participants have been identified as representatives of the Forest Service, State, interest group organization, and industry.

    USDA Forest Service
    • Jacque Buchanan, Deputy Regional Forester, Rocky Mountain Region
    • Steve Lohr, Acting Deputy Regional Forester, Rocky Mountain Region
    • Andrew Johnson, Acting Forest Supervisor, Black Hills National Forest
    • Jerry Krueger, Deputy Forest Supervisor, Black Hills National Forest
    • Alison Hill, Deputy Director, Rocky Mountain Research Station

    Commercial Timber and Forest Products Industry
    • Jim Neiman, Neiman Enterprises
    • Jeff Parrett, Wheeler Treated Wood Products
    • Adam Gahagan, TimberWest
    • Jack Baker, Baker Timber Products
    • Ben Wudtke, Black Hills Forest Resources Association

    State Government
    • Bill Crapser, Wyoming State Forester
    • Greg Josten, South Dakota State Forester

    Randy Deibert, Lawrence County Commissioner

    Forest Advisory Board, Environmental organizations and Forest Service Retirees
    • Danielle Wiebers, Chair, National Forest Advisory Board for the Black Hills NF
    • Bob Burns, Norbeck Society
    • Jim Margadant, Sierra Club
    • Nancy Hilding, Prairie Hills Audubon Society
    • Dave Mertz, Forest Service Retirees

  22. Could part of this problem be the differences between even-aged management, and all-aged management? I do think that wildlife would benefit from more all-aged stands. There would certainly be pushback from the timber industry, as they have made significant investment into their ‘style’ of logging, which is very different from the western US.

  23. The final Black Hills Timber Growth and Yield General Technical Report has not yet been released, but is expected soon.

    However, the BLACK HILLS NATIONAL FOREST ADVISORY BOARD meets this Wednesday, October 21, 1:00 – 4:30 to review (among other items) a recommendation from a working group tasked with development of a five-year plan to meet sustainability requirements for the timber program. A dissenting commentary and recommendation will also be presented.

    Members of the public can virtually attend the meeting by following these instructions:

    To see the meeting agenda:…/FSE_DOCUMENTS/fseprd830773.pdf

    A listen-only telephone conference line has been set up for the meeting. Call 888-251-2949; when prompted, enter access code 9272339##

    To view PowerPoint presentations on your computer during the meeting:
    Once you have launched Adobe Connect enter your name or “guest” and click on “Enter Room.”

    Members of the public can comment on agenda topics by sending comments by the end of Thursday to: [email protected]

  24. The vote was actually 11-5 in FAVOR of increased logging. Norbeck Post is confusing… Question is whether the FS is bound by this vote or can they simply choose to ignore it — like ignoring 95% of comments in Alaska to protect Tongass Roadless?

  25. The Forest Service is not bound by this vote in any way. The National Forest Advisory Board only provides advice to the Forest Service. In this case, this advice is extremely flawed, in my opinion. The problem with this is that I have heard that the timber industry lobbyist already contacted Jim Hubbard with the outcome of this vote. Senior FS leadership simply loves to hear something that had the appearance of collaboration, so they will think this is great. Cut more timber and the advice is from a collaborative group, well that’s great! Line up the log trucks! Never mind the devil is in the details.

  26. This past summer on the Black Hills National Forest, I performed a post-harvest soil disturbance audit on a unit in the Merlin Timber Sale. The prescription for this unit was “overstory removal”. I also noted fire hazard issues & ecologic trends. We performed the survey using the Forest Service Monitoring Protocol. I have performed hundreds of these surveys as a contractor to the agency. Forest Service soil quality standards require work that does not exceed 15% detrimental soil disturbance within the activity area. Our findings document detrimental disturbance over twice the allowed coverage.

    Clearly no soil scientist or technician visited the described unit before the harvest. On this unit sensitive soils are easily observed just by noting the sedge beds, large spruce trees (now missing), and dark moist soils.

    Overstory removal in a ponderosa forest is nothing less than ridiculous. These trees are just old enough to survive a low severity fire. The dense stands of remaining small trees are a hazard. If you were a forest landowner, would you do this to your own forest? The overstory trees are not worth the ecological damage.

    The upshot, if this small unit is indicative of the type of work the Forest Service promotes, then expect the expense of restoration activities (including weed abatement) to add to the taxpayer’s burden into the future as we the people attempt to fix this mess.


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