A Cautionary Tale – Too Much Sawmill Capacity, Too Little Trees

Everyone wants a solution to the wildfire dilemma across the west. A very common answer is we need more logging. So many sawmills have closed and gone away and now the chickens have come home to roost, they say. There is certainly some element of truth there but what happens when you have the opposite problem? When you have too much sawmill capacity and demand for volume exceeds timber sustainability? How does a situation like this come about and does it even exist?

I am Dave Mertz and I was the Natural Resource Staff Officer on the Black Hills National Forest (BHNF) from 2011 to 2017 when I retired. I provided oversight and management of the Forest’s timber program. One thing that I regret from that time is that I wish I had gotten out of the office more and out on the Forest. I should have had better knowledge of what was really going on out there. Fortunately, since I retired, I have been able to spend quality time on the Forest and learn a whole lot more about the situation we are in. It’s a somewhat complicated story and I am going to try and tell it here.

Prior to 2000, the BHNF was sitting fat, dumb and happy.  There were plenty of trees, you could argue too many trees.  There was certainly lots of sawmill capacity.  The 1997 Forest Plan had set an Allowable Sale Quantity (ASQ) of 202,000 ccf.  This was an achievable goal and would be met or exceeded many times over the next 20 years.  Then the mountain pine beetle (MPB) came to the Forest with a vengeance.  Along with that, a series of large fires including the Jasper Fire in 2000.  This is the largest fire on the Forest at over 80,000 acres. 

The MPB epidemic continued until 2016.  In the meantime, the Forest carried out an aggressive thinning program to mitigate the epidemic.  The timber industry was happy, they were seeing years where the timber volume sold exceeded the ASQ, sometimes significantly.  There was a problem though, the good times would eventually end.  The Forest Silviculturist began warning as far back as 2012 that there would be a future problem with timber sustainability.  The MPB had killed over 200,000 acres of trees and wildfire another 200,000 acres on a 1.2 million acre Forest.  Meanwhile, the timber industry was modernizing their mills and making them more efficient.  They needed fewer employees and could run more volume through their mills even faster.  If they ever believed that there would be a future problem with timber volume, they certainly didn’t act like it and never admitted it publicly.

Finally, by 2016, when the MPB epidemic ended, the Forest took a drawn-out approach to addressing the timber sustainability problem.  They would work with Forest Inventory and Analysis (FIA) to intensify their survey by doubling the plots.  They did this in response to the timber industry’s insistence that the data was not good enough to make a reduction in the annual volume sold.  They insisted that in spite of the beetle epidemic and wildfires, the timber volume sold could continue on as before.  Of course, they had some assistance from SD and WY politicians putting pressure on the Forest Service (FS).  Not that the Regional Office and Washington Office took much convincing.  They had no interest in reducing the volume sold.  It would go against the narrative that the FS wasn’t cutting enough.  Oh no, they weren’t sticking their necks out for the BHNF!  The Forest was often in the lead or top 2-3 of annual timber volume sold for the Agency.  They needed that volume!

Once the FIA gathered the additional data, which took three years, the Forest worked with FS Research to analyze the data and develop a scientific recommendation for long-term sustained yield.  A General Technical Report (GTR) was produced in April of 2021 that recommended an annual volume of 72,000 CCF to 90,000 CCF would be sustainable.  The day before the GTR was released, it was announced that one of the local sawmills would be closed.  The FS was blamed for the closure because timber sold in the current and previous fiscal years was below ASQ.

Six months later, the Forest came out with a tentative three-year plan to reduce timber volume sold to 80,000 CCF by FY 2024.  With much negotiation, alignment was reached with the Regional Office and Washington Office to make this tentative plan possible.  Meanwhile, significant pushback from the timber industry and politicians continues. 

It should be said that the BHNF is one of the most managed Forests in the National Forest System.  Much of the Forest’s suitable timber base has been thinned, either through logging or the MPB.  What do you do to keep the timber volume sold levels up when much of the Forest has already been thinned?  Well, in 2016 a Forest-wide project was developed to conduct overstory removal (OR) on 183,000 acres.  Never mind that many of these acres were not ready for OR due to insufficient regeneration or that they were still putting on significant growth resulting from the recent thinning.  This was really the Forest’s only option to keep high timber volumes flowing. 

A major justification from timber industry to keep sale volumes high is that the Forest needs to be thinned to save it from wildfires.  As stated earlier, much of the Forest has already been thinned.  Also, even though the Forest has been heavily logged for decades, this had minimal impact on the MPB epidemic (until they started thinning down to 40 basal area) and very little, if any impact on mitigating catastrophic wildfires. 

I took a look at the Jasper Fire from 2000 using Google Earth to see how much logging had occurred in the fire’s footprint prior to the fire.  I was able to go back to 1986 and look year by year to see what logging had occurred there.  Much of fire area had been thinned prior to the fire.  This thinning did little to mitigate the fire’s impact.  Granted, the fire occurred in late August in very dry, windy conditions, resulting in extreme fire behavior.  Extreme conditions, however, have been present for all of the large fires in the Black Hills, that is why they get big.  Thinning alone, without prescribed burning, has not proven to be effective in the Black Hills for mitigating catastrophic wildfire.  Very little prescribed burning takes place on the Forest for a variety of reasons.  The Forest uses wildfire mitigation to justify most of its timber projects.  They should be up front about its effectiveness.    

Attached is a link for a video that I produced which shows what occurred in the Jasper Fire. 

Jasper Fire before and after – YouTube

Not having enough sawmill capacity is a problem but what happens if you have too much?  All it takes is one large wildfire and a Forest can be in that position, when you have an industry that is highly dependent on FS timber.  The FS has not proven itself to be very adept at handling this kind of situation.  It has shown that overcutting can continue for years in spite of significant evidence that it is unsustainable.

Here are a couple of interviews that I have done with South Dakota Public Broadcasting regarding this topic.

Dave Mertz: The forest simply cannot sustain current logging levels | SDPB

Anatomy of a cut: We look at the Bull Springs Timber Sale in the Black Hills National Forest | SDPB

32 thoughts on “A Cautionary Tale – Too Much Sawmill Capacity, Too Little Trees”

  1. I want to make sure I’m understanding this correctly: the essence of the story is that BHNF was intensively harvested for decades; thinning had no impact on the pine beetle outbreak or on fire; and the timber industry is now resisting attempts to reduce harvest to sustainable levels, and arguing that continued high harvest rates are necessary to reduce fire risks?

    • Yes, that pretty well sums it up. I would add a little on the impact of thinning. For a long time, the thinning was down to 80 basal area or so. When the MPB epidemic began, this level of thinning proved to be largely ineffective. Once they began thinning down to 40 basal area, it proved to be much more effective. Thinning down to 40 basal area is not conducive to maximizing growth volume in ponderosa pine, however. Thinning alone has also proven to be largely ineffective in mitigating high intensity wildfire in the Black Hills. I am not aware of any instances where it was successful with high intensity fires. There may be some instances but I am not aware of them. The conventional wisdom that thinning moderates wildfires may be true for low or moderate intensity fires (which are really not the major threat) but not for high intensity fires, not in the Black Hills anyway. But yet, that is the major justification for much of the logging.

  2. Thanks for contributing this, Dave!

    I’ve heard this story from some other FS folks who agree that ratcheting up (which did work for MPB as you said when it was done to 40BA) was not followed by ratcheting back down or below to make up for the increase due to MPB efforts.

    But now it has been via the efforts of people bringing it to folks’ attention, the GTR and the analysis for reduction. So the problem was some kind of internal/external dynamics that didn’t lead quickly enough to “ratcheting back down.” But ultimately the right thing happened.. or did it in your view?

    My visits to the Black Hills showed me that PP there grows like nothing I’ve ever seen in all the PP country I’ve worked and lived in, Oregon, California, Colorado, Wyoming, So I wouldn’t make claims about any other parts of the country and apply them to the Hills, nor vice versa.

    I’d like to get an idea of some of the overstory removal projects, but couldn’t find one in the current projects https://www.fs.usda.gov/projects/blackhills/landmanagement/projects
    Can you point me to the ones you are talking about?

    • The right thing has happened if the tentative three-year plan to reduce the annual volume sold, doesn’t get hijacked. If politicians influence the right pressure, it could get blown up and volume levels would be right back up again.
      I agree that the Black Hills ponderosa pine forest is somewhat unique. I worked on the Kaibab NF and it is different here. Regeneration is usually not a problem, often times there is too much. I think some of the fire issues are similar though.
      It is difficult to find documents on sales once they are sold. I will email you the report for the Bull Springs Stewardship Sale, which is the one that people are currently upset about. I do like the fact that it is a Stewardship sale, that way the money goes back into the sale area without the overhead cost.

      • OK if this is the decision document. https://www.fs.usda.gov/nfs/11558/www/nepa/103904_FSPLT3_4389333.pdf

        Thanks, Dave!
        It sounds like overstory removal is not about fuel treatments, it’s about releasing young trees from competition. I’ll grant that that’s a timber-y rationale, but it’s not about wildfires. There’s also the idea to have forests in different stages across the landscape, which is a bit too complicated for me to get my arms around, but perhaps is related to HRV or NRV, but it also in the stated purpose and need.

        “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 will not be occurring in any areas classified as late succession forest (structural stage 5)”

        • Yes, the overstory removal in this project (Black Hills Resilient Landscapes Project) BHRL was justified on structural stage objectives from the Forest Plan. Based on the objective percentage for large, open stands, which was above the Forest Plans objective, this project said there was a need to conduct overstory removal on 185,000 acres. Now, here’s the funny thing about this. The Forest also had the Pine Beetle Response Project (PBR) from 2012, which was created to make large, open stands to mitigate for the pine beetle. The MPB epidemic ended in 2016 but guess what continued? The PBR project. So, on the one hand with PBR, they were creating more large, open stands while on the other hand, with BHRL, they were cutting them down because there were too many large, open stands. Guess where they are with the structural stage percentages for large, open stands after three+ years of overstory removal? Roughly the same because they were creating it as they were trying to reduce it. One can’t make this stuff up.

  3. Thank you, Dave. Super informative and interesting. Can you speak to fuel treatment longevity on the BHNF? You mentioned lots of regen. Thick regen is a ladder fuel. How long after a thinning project does it take for the ladder fuels to represent a wildfire hazard? That amount of time should dictate the maintenance cycle of ladder fuel treatments.

    In my experience in thinning western frequent fire forest, ladder fuels typically grow back faster than the commercial board feet. Prescribed fire, hand cut and pile burn, or mastication must happen between commercial entries to mitigate fire hazard at the stand scale and treatment areas must be large to address the issue at the landscape scale. I have heard UCB fire scientist Scott Stephens state on many occasions that treating surface and ladder fuels is 90% of the fire hazard reduction need in many frequent fire western forests, with canopy fuel reduction only about 10% of the issue. There’s also been some work suggesting that low intensity Rx fire alone, without density reduction, can increase resistance to beetles in ponderosa, by affecting the size and distribution of the resin ducts.

    • Thick regeneration is a real problem here. Not everywhere but it is very common. Especially in the stands that were heavily thinned to mitigate for the mountain pine beetle, as well as the stands that were haphazardly thinned by the beetle. Depending on stand conditions, the regen can present a problem within 10 years or so. Certainly, this regeneration is a fire hazard that is difficult to deal with. They have done some understory, prescribed burning that was successful at thinning and reducing that understory, went it was still small enough to be effective (>5 feet or so). Precommercial thinning of understories is not common here. It is more common in younger stands but there is way more work to do than there is funding. I think you are correct that the core of the problem in wildfire mitigation is treating regeneration and ladder fuels, not large sawtimber. The problem is there is not sufficient funding to deal with the issue. With FS sales, KV dollars can help to an extent but our sales (low bid prices) here do not generate significant dollars for that.

  4. I was reassigned to the Black Hills in 2016 as the Forest Supervisor; the job was mine for the taking; of course beknownst only to me and my wife, I was on my second iteration of retirement papers. Had I been a couple years younger, I would have jumped at the chance!

    About my second or third day on Forest, Dave Mertz, Blaine Cook and Jerry Kruger loaded my keister into a vehicle and we hit the road. I was earlier privy to the discussions around harvest volume, but from the Regional Leadership stance.

    Now I’m a pretty good timber forester, having worked all over the US; big timber in the Northwest back in the day, cut skidded and logged early in my career. Anyway, it doesn’t take me long to see something out of alignment on the Black Hills – they were over harvesting!

    Don’t get me wrong, the FS must have industry to carry out meaningful management of forest lands. It is a working partnership between industry and the Feds, for sure. And, I have never seen a Forest so ravaged by mountain pine beetle, or any other natural disaster as the Black Hills! Add in the Jasper fire in “suitable acres”, and the lack of reforesting these burned over acres and you have a recipe for disaster!

    Realize, I heard everything from the Forest is just lazy, they aren’t really trying, etc. These guys (Blaine, Dave and Jerry) had lived the story, and I found their approach absolutely sound!
    After requesting funds for the FIA work to redefine the Forest Growing Stock Level, and creating quite a stir representing my newfound appreciation for what was going on, I myself, was called a “non-leader”, “we’re going to yank him out of there”, and my personal favorite – “if he can’t get it done, we’ll find someone who can”!

    My vindication came in the GTR, and I do believe this crap will settle down to a sustainable harvest level of somewhere around 80,000 CCF.

    I’m all my working life, I’m 67 years old and started paying into Social Security in 1971, I was never as ashamed of a timber program as I was, for what the FS was doing to the Black Hills! Dave, Blaine, Jerry and many others certainly deserve our gratitude for fighting the good fight!

    • Thank you, Jim, so much for your words of support! You did grasp the situation here quickly and were a breath of fresh air when you came to the Forest! The Forest has a lot of great employees that are some of the hardest working people that I knew in my career. That is why it was so sad and frustrating when the concerns about the timber program were run up the chain, that the concerns were dismissed, and the Forest employees were basically treated like a rented mule. It’s been a long road but I believe that things are finally turning in the right direction. There seems to finally be some alignment with the RO and WO about the problem. The next six months or so will be telling. What’s happened here could be a case study for the rest of the Forest Service to learn from. Thanks for your support Jim, hope you are doing well!

      • Jim and Dave,

        I don’t know about your experience, but most Forests I’ve worked on have not had the same growth/ unique political/business situation as the Black Hills. So I think the direction they’re going is great, getting R&D involved to put a mark in the sand is great, and the resolve and support of upper levels is great.

        But I don’t know… are there other forests that have gotten into a pattern of overcutting? being depended on by the Region to make its target? In a relatively unpopulated state with no other National Forests and the politicians focused on it?

        I guess the BH is recognizably unique.. but how unique is the overcutting?

        Granted that many TSW readers may think that any commercial harvests are overcutting?

        • That is an interesting question. I worked on nine other Forests and I never saw where the timber industry had as much power over a Forest as the Black Hills. I think you listed some of the factors – low population State where the politicians can really focus on something, one Forest with a timber program, the timber industry highly dependent on Forest Service timber. I think that most places now have the opposite problem where there is way more timber than sawmill capacity, but when that gets turned around, things can get ugly. I worked on the Mt. Baker-Snoqualmie NF in the early 90’s with the onset of the Spotted Owl issues. I knew things would get ugly and left there. I recently listened to a great podcast by Oregon Public Broadcasting called “Timber Wars” based on that time period. It was interesting to hear some of the same things that happened back then which reminded me of what has happened here on the Black Hills. Of course, on a much smaller scale but there are some similarities.

    • Larry, it sounds like they have a bug festival..with a pub crawl. This sounds pretty community building (and fun) to me.

      “Burning Beetle was created to help the Custer community and the Black Hills come to grips with the beetle pandemic. Last year, the event was disrupted by a pandemic of a different kind. The COVID-19 pandemic which began less than two months after the 2020 Burning Beetle observance, caused the annual afternoon talent show before the burning to go virtual and the bug crawl events afterward to be scaled back as well.
      “If ever we’ve needed a way to come together safely and celebrate who we are as a community, it’s now,” said Hank Fridell, Burning Beetle organizer. “Custer is ready to light the beetle!”
      That first beetle in 2014 was built by master carpenter Karl Svensson with the help of a few volunteers. Sversson, who had been a boat builder, used that expertise in the design and construction of the beetle. It had a plywood frame and was covered on the outside with thin and flexible strips of wood cut from beetle-killed trees.
      “Karl has headed up the building of all nine of the beetles,” said Fridell. “Over the years we have made a number of small changes to the beetle, mostly to strengthen it and make it safer, but it is the same basic design.”
      In recent years pyrotechnics have been added to the inside and around the rim of the bug to make the burning even more spectacular.”

  5. Thank you for this well-written post and the informative answers to the questions. I have been warning forests of this elsewhere – primarily based on lack of reforestation after large-scale fires, and I think there are some big surprises coming in ASQ when their forest plans are revised in the next few years. As one of my silviculture acquaintances used to say – “you cannot thin to nirvana”…The only place I have seen ASQ reduced is in British Columbia after the large scale beetle outbreaks there. The BC government announced a cut in ASQ due to their inability to reforest after the beetle outbreaks. A few years later when they announced an initiative to reforest for carbon sequestration, they adjusted their ASQ back upwards. The cut in ASQ was surely not popular, but it was the right thing to do in response to the beetle outbreak.

    • I think you are right on track with the concern about the lack of reforestation after fires. There is a price to be paid for that it needs to be recognized. I really like the “you cannot thin to nirvana”! I may have to use that one!

  6. “The Forest uses wildfire mitigation to justify most of its timber projects. They should be up front about its effectiveness.” Well, yes that’s actually a required NEPA disclosure. I don’t think of the Black Hills timber sales getting litigated much though.

    The first round of forest plans often led to reduced ASQs, reflecting the recognition of other resources (especially wildlife) that NFMA required. This second round (at least in the west) should recognize the resetting of large chunks of its timber base to zero by unplanned beetles and fires (in addition to planned logging) that have occurred in the 30 years since the original plans were written. They should also reflect that changes in regeneration success and growth rates expected over the next rotation due to climate changes (mostly downward?).

    • The Black Hills NF has not been litigated since 2011 and the most impactful litigation was back in 2001. So yes, litigation has not really been an issue. I would have never dreamed I would say this back when I was working, but occasionally, litigation may be needed for a Forest to get back on track. It can be a legitimate check and balance. If the Forest Service had absolutely no fear of litigation, I really wonder what path it could go down.
      The Forest has begun the Plan Revision process so yes, all of the things you mentioned should be considered.

      • But you could also say that in this case, the Forest turned around without litigation. In this case, would a DOJ person working it out with an ENGO be any better than the Forest working it out with local folks of all environmental stripes, gaining knowledge from a variety of experts, and so on? In my experience, the push may be helpful but the settlement process, not so much.

        • That’s a really good question! I believe in this instance, not going to litigation has worked out and has been the right thing to do. If it was litigated, it would be by some of the ENGO’s and they would then be the scapegoat for the timber industry’s problems. It would also potentially shut down the whole timber industry, for a time anyways, and most people do not want that. So, without the litigation, the focus has been on the science and getting the Forest Service to do the right thing. They are finally coming around on that. The downside to this though, has been that overcutting has continued for a number of years and has made the issue of sustainability all the more problematic.

    • No worries….

      There’s probably not enough loggers left in some parts of the country, to match the “pace and scale” of what Congress expects. Plus, we’ll just have to see how many timber sales can be put together with the number of ‘peasant workers’ that are hired.

  7. I think there’s more to the story. But first let me commend two FS retirees (Blaine Cook, 25 yrs as BHNF timber expert, and Dave Mertz, Resource Staff Officer) who have been pushing relentlessly to reduce logging to lower, sustainable, former levels. They asked me, Ret Dep Chief, to get involved after they were largely ignored by FS. We sought and got good media coverage (AP, Greenwire, and continuing SDPB) to expose what was going on. FS slow-walked a FS Res Gen Tech Rpt delaying release for more than a year; GTR 65-pg analysis clearly showed BHNF standing timber volume had decreased >50% in the last 20 years due to fire, bugs (200,000+ acres), and heavy logging. Years ago FS authorized “departure harvest”of 200,000 ccf/yr to address bug problem (epidemic ended in 2016) but DID NOT drop harvest later. Worse they began using OVERSTORY REMOVALS of ALL trees 9″dbh+ on several hundred acre units that had been thinned (quite nicely I thought) only a few years earlier. For all intents and purposes massive clearcuts. You can see evidence on FB posts by People for Sustainable Logging in BH.

    This past Fall, Supv Tomac finally decided to step down logging to 124k ccf in 2022, 90 in 23, and 82 in 24. Better late than never, but still exceeding Res GTR finding that sustainable level was NO MORE THAN 60-70. There was no press release, but prying eyes (mine) revealed this and made it public. Now the battle is on. Industry and SD and WY Reps and Govs are going nuts. Nieman Industry had 3 mills; closed Hill City last Spring and another closure will likely follow soon. And they blame the FS after modernizing to expand capacity and improve efficiency. Reminds me of a similar pattern in PNW – screw your employees, act like you never saw it coming, and blame the Feds. I feel bad for the loggers and millworkers but have no sympathy for industry.
    Color me outraged.

    • I don’t understand all the complexities of the BH for sure, but the “timber industry” is more than Neiman (as I understand it, there are also small folks) and their business is more than the Hills. I know Montrose is happy to have them there. So perhaps your beef is not so much with “industry” as with certain folks having political clout that they use in ways you don’t prefer? I can certainly empathize with that! I think we all can.

  8. The vast majority of BHNF harvest is with Nieman. Maybe smaller mills will step into the void if they leave. I get that BHNF may have been over a barrel with Trump and Sonny Perdue at USDA … but now?? Stop the madness.

    • My understanding (perhaps incorrect??) is that when Neiman purchased the Gilchrist mill, the business became too large to qualify for small business purchases (I’m not a timber expert) so if true that will change the dynamics. I also heard they were exploring getting trees from elsewhere for the mill via rail ( we have 99 car empty coal trains going from here back to Wyoming regularly…). From what I hear, they are in the process of stopping “the madness” as you say and looking for solutions at “the right” level of sustainable growth. So thank you for what you have contributed to pushing this forward!

      • It is true that Neiman no longer qualifies for SBA so that has changed the situation to a degree. I heard that the logs on rail thing fell through because of the potential of transporting unwanted bugs from California.

  9. https://www.bhpioneer.com/local_news/county-officials-continue-blazing-trail-to-cooperating-agency-status-with-usfs/article_3333f20e-8061-11ec-a0c3-f7e84d8a7b3e.html
    Here’s a bit more on the Black Hills forest plan revision process. They are in the assessment phase. The Planning Rule says, the forest supervisor “shall provide opportunities to the public for participating in the assessment …” This sounds more like, “I’ll show it to you when we’re done.” It is technically true that it is premature to be invoking “cooperating agency” status for the counties until there is a proposed action subject to NEPA.

    • Jon, what was interesting to me was that the assessments are being contracted. Should be interesting to see what they come up with.

  10. Beware of monkey wrenching! Cooperating agency status is generally reserved for other federal agencies, and is ALWAYS discretionary. I recall when numerous western states pursued “Coop” on the Roadless rule, I asked them why. MT rep stated “We want to stop the process” – TRUE! We said “No. Thank you, but no.” Given the nature of planning efforts, counties may not be trying to make the process smoother and outcomes better for all. There are other ways to assure their voice is heard.


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