Public comment sought for first phase of forest management plan

The first stage of the process to update and revise the Land and Resource Management Plan for the Black Hills National Forest is complete and the U.S. Forest Service (USFS) is now seeking public comment.

The Forest Plan Revision Draft Assessments are available for viewing and the public comment period is open until August 1.

"The forest plan tells us how we will manage the forests for the next 15 to 20 years," says Scott Jacobson, Public Information Officer.

"People who would like to see the forest managed in a particular way that supports their engagement or involvement have the opportunity to comment now."

The first phase of revising the plan is to draft a number of resource assessments, which involves evaluating the existing information about ecological, economic and social conditions, trends and sustainability. This information will then be analyzed to provide insight into the relationship between the current plan and the broader landscape.

The assessments lay the groundwork for the next two phases: developing the plan and monitoring.

Have a Voice

"The forest plan revision process is really a process where we want the most input from the public that we can get, because the way we manage the forests is generally the way our public wants us to manage them in the long run," says Jacobson.

Comments are welcomed regarding any aspect of the assessment, which is split into topics ranging from recreation to water management.

"We're looking for comments from anybody that has something constructive they are willing to offer," he says.

"There are 15 different areas of interest within the assessments, and the assessments are based on the current conditions as we see it today in the forest. Looking forward, if there's a need for change, the comments will direct us towards that need for change according to those assessments."

This won't be the last chance members of the public have to add their two cents, but it's a good idea to get involved in these early stages, according to Jacobson.

"This will be about a three- to four-year process," he says. "People willing or wanting to have a voice should do that starting now, and there will be more opportunities throughout the revised plan as well."

Comments are welcomed from anyone and everyone, he says – not just stakeholders and cooperating agencies, but any member of the public.

Forest Management

Of particular local interest since the planning process began has been the USFS's evaluation of the available timber in this area. A timber assessment is included in the documents and broadly supports the opinion that there is a need for change within the local timber program.

Driving this need, according to the assessment, is the fact that the 1997 forest plan timber program was, "based on ideal net growth that assumed in an increase of the standing inventory for the next five decades." In other words, they were not consistent with the actual, on-the-ground conditions between 1996 and 2021.

"The combination of the major ecosystem drivers and stressors, timber production, bark beetles and wildfire during this time have caused long-term changes to the forest," states the assessment, which claims the volume of trees with a diameter at breast height between five and 14.9 inches has decreased by between 32% and 42%.

"This also indicates that actual average annual program levels of 162,500 CCF sold and 178,000 CCF cut, 1997 to 2021, were not sustainable," states the assessment, noting that the timber production increase between 2007 and 2016 in response to the mountain pine beetle epidemic was necessary, but not realistic as a long-term program level.

A reduction in the available timber sales has been of great concern to the Crook County Commissioners since the planning process began a year ago. In response, at the suggestion of Commissioner Jeanne Whalen, a socioeconomic supplement was added to the county's natural resource management plan.

The supplement focuses on the impact of natural resources on the health of Crook County and was funded through a state program. Whalen suggested performing the study to create the supplement in direct response to the potential for the USFS to make drastic reductions in the timber sale limits within Crook County.

Meanwhile, an advisory board formed to gather data about the standing forest inventory and provide advice to the USFS argued that the best way to manage the negative impacts on the forest from wildfire and the mountain pine beetle is to maintain commercial timber programs at their current levels.

According to the National Forest Advisory Board for the Black Hills, the commercial timber program funds the thinning program that keeps the forest healthy; without that program, there simply won't be enough funding available to reduce wildfire risk and promote growth.

Public Comment

"There will be several months where we take comments and look at those and the next step will be to develop a revised forest plan," says Jacobson.

"The whole National Environmental Policy Act process takes quite a little time, but the purpose of that is to allow people opportunity to provide comment and give us the opportunity to see those comments, assess those comments and incorporate them where we can."

Jacobson estimates that it will take approximately six months to review and analyze the public comments.

The Forest Plan Revision Draft Assessments can be viewed at http://www.fs.usda.gov/goto/blackhills/forestplanrevision/assessments, while an electronic comment form can be found at https://cara.fs2c.usda.gov/Public/CommentInput?project=NP-3204. Written comments should be mailed to Black Hills National Forest Supervisor's Office, c/o Forest Plan Revision Team, 1019 N. 5th Street, Custer, SD 57730.

The deadline for commenting is August 1.

Other Topics

Numerous assessments have been developed for this stage of the revision, focusing on various areas of interest for the forest. Many include suggestions for change to the forest management plan.

• Aquatic, Riparian and Groundwater Dependent Ecosystems: the assessment suggests several potential needs for change within this area, such as broad-scale assessment and improvement of road-stream crossings and changes to water management in reaction to predictions that climate change could lead to hotter, drier summers. Uncharacteristic fire events are becoming more prevalent in forested areas, according to the assessment, and detailed evaluation and analysis of the impacts to the watershed are needed.

• Insects, Disease and Invasive Species: this section of the assessment does not include any specific suggestions for needed change, but does include the "what if?" question of the impact of climate change on invasive species such as the mountain pine beetle. Earlier snowmelt, a shift from snow to rain and prolonged growing seasons, it suggests, could prolong fire season and increase fire intensity, while a major population controller for beetle populations is extreme cold. Without this, outbreaks could become more frequent, reducing tree populations and creating higher forest fuel loads. "There will likely be dramatic interactions between climate change and invasive species infestations that are not yet understood," the assessment adds.

• Soils and Watersheds: suggestions for change in this assessment include better maintenance of roads and trails to reduce the impact they are having on the condition of the watershed; improvement of the fire regime; conservation of water in the winter to balance the decreased runoff expected in the summer due to climate change, which would keep rivers and streams wetter for longer; removal of instream barriers at road-stream crossings to promote stream connectivity; and wetland restoration for improved water flows, habitat quality and stability.

• Socioeconomics: this assessment notes that the population is growing in the majority of the Black Hills, which is increasing demand for recreation opportunity, ecosystem services such as drinking water and jobs. Climate change is also suggested to be an impact on the contributions the forest makes to social and economic sustainability, mainly through the benefits of recreation opportunities to such things as jobs and quality of life. It suggests planning for this by taking a direction that takes into account a changing climate and focuses on resiliency to continue to provide multiple uses and ecosystem services.

• Recreation Settings, Opportunities and Scenic Character: according to the Recreation Program Manager, "the current level of recreation is sustainable if recreation is diversified across the forest," states the assessment. Most recreation is located in a few hotspots, where the human impact is also magnified. Much of the southern end of the forest has little usage. The assessment suggests diversifying the type and geospatial location of available activities and the season in which they take place.

• Potential Wilderness Inventory: the revision process includes identification of lands that may be suitable for inclusion in the National Wilderness Preservation System. Locally, three locations were identified, including the Inyan Kara roadless area and the Sand Creek roadless area. Once the forest plan is finalized, these lands could potentially be recommended for designation, which is ultimately a decision for Congress.

• Infrastructure: suggested changes include prioritizing subwatersheds for detailed inventory and analysis of road problems and risks and possible limitations on total road length and density by subwatershed.

• Ecological Integrity of Non-Forested Ecosystems: the assessment suggests changes including promotion the protection of montane grasslands, a unique plan community considered critically imperiled globally; and a change in the definition of satisfactory or unsatisfactory range conditions to acknowledge drivers not related to livestock grazing.

• Fire and Fuels: changes to the plan that are suggested in this assessment include tiering the forest plan to the National Cohesive Wildland Fire Management Strategy; and an analysis of current and potential surface fuels and their role in fire severity.

• Cultural Resources: this assessment calls for more management flexibility, such as to update the historical context to include knowledge of the specific movements and groups that influences the sites and cultural development of the Black Hills and evaluate eligibility on the National Register of Historic Places for remaining unevaluated sites.

• Rangeland Management: an increase in non-native cool season grasses is a concern that the assessment notes should be addressed through early season intensive grazing. The assessment also suggests changes such as additional prairie dog management and updated range improvement guidelines to allow for new technologies, such as safer fence construction for elk passage.

• Areas of Tribal Importance: changes to the plan that are suggested by this assessment include elevating the tribes to a higher level of consultation and including the Crow Tribe of Montana as an official consultation partner, as well as including potential impacts and management strategies on the effects of hunting rights legal decisions, which have recently further defined tribal hunting rights on federal lands.

• Energy and Minerals: another assessment that includes a "what if?" question about the future impacts of climate change, stating that extreme events such as drought and wildfire are likely to become more common in future decades and may affect energy and mineral resources. For example, it may affect the availability of water for processing minerals, while renewable resources could be impacted by forest fires.