Biodiversity Associates

Black Hills: Endangered Forest Alert
The Black Hills National Forest Needs Your Help!

Your comments needed by January 28th to
protect wildlife & wild places on the Black Hills National Forest

Issues and Concerns     Long-term Survival
    Roadless Areas
    Old Growth Forest
    Reesearch Natural Areas
    Sensitive Species
    Impact Assessment
    Reduce Road Density
    Natural Processes

Where to Write

The following is a more detailed explanation of what you may want to include in your comments to the U.S. Forest Service for the Phase II Amendment. The following bullets include more in-depth information, which, when presented to the Forest Service, will provide them with stronger and more specific information that is necessary for them to fully protect the natural values of the Black Hills through this Forest Plan amendment. Please take the time to include this information, and any other information you may feel is necessary, in your comments. Thank you for taking the time to write a letter, the future of the Black Hills is dependent on our voices!

The "Restoration Alternative"

Ask the Forest Service analyze and select a "Restoration Alternative" that emphasizes protection and natural restoration of all native plant and animal communities, including aquatic communities and those dependent on old-growth forest. In order to ensure the long-term survival of the Black Hills ecosystem and all native plant and animal communities within, the U.S. Forest Service cannot merely "maintain" the existing conditions on the forest. In order for plant and wildlife populations - especially those with isolated habitats or rare occurrences - to persist across the landscape, the Forest Service needs to emphasize restoration of the entire Black Hills ecosystem. In your letter, please express to the Forest Service your support for a Restoration Alternative and explain the need for this alternative to include the following points:

Fully protecting all existing old growth forest habitat from logging, road building and off-road vehicle use and allowing a large amount of younger trees to reach old growth conditions. The amount of younger trees recruited as old growth should be dependent on the need to provide large blocks of old growth greater than 1,000 acres, the need to provide a large amount of old growth ponderosa pine forest across the landscape, and the need to provide unfragmented old growth habitat.
Developing a forest-wide travel management plan that analyzes and assesses the need and the environmental damage associated with every vehicle route on the forest, significantly reduces the road density on the forest by obliterating unnecessary or environmentally damaging routes, and restricts off-road vehicle use only to designated routes and trails.
Fully Protecting all roadless areas - inventoried and uninventoried - greater than 1,000 acres.
Developing conservation strategies for individual sensitive species, management indicator species, threatened/endangered species and other vulnerable species of plants and animals (special status species) and their habitat. Given that many special status species' populations and their habitats are not viable or well distributed, conservation strategies should elevate current populations of special status species and their habitat. .
Designating aquatic management indicator species (MIS) (ecological health indicators) other than fish and designating plant and invertebrate MIS.
Restoring stream, spring, meadow and riparian health by disallowing livestock grazing, mining and other damaging activities within these areas.
Restoring and promoting natural processes such as wildfire, insect outbreaks, and vegetative succession to ensure long-term forest health and provide wildlife and plant habitat.
Designating Research Natural Areas to protect the best examples of all native plant communities and other natural features on the Forest-for their natural wealth and scientific value.
Establishing an educational program that teaches forest users and the general public about the Black Hills forest ecosystem and the natural processes that shape this forest. Due to a severe lack of communication, the Forest Service has essentially fostered an atmosphere of indifference and open hostility toward protection of the natural values of the Black Hills. This has resulted in a severe misconception of Congressionally recognized values of National Forest lands, primarily those values related to wildlife, plants, habitat and wildlands protection. This misconception needs to be corrected by the Forest Service. Primarily, The Forest Service needs to convey to the public the values and importance of less charismatic wildlife and plant species such as the goshawk, snails and rare orchids.

Issues and Concerns that Need to be Addressed, Analyzed, and Assessed in an Environmental Impact Statement

Ask the Forest Service to address, analyze, and assess the following issues and concerns in their environmental impact statement. Include the following in your comment letter and feel free to add-on or elaborate however you feel is necessary.

Guarantee long-term survival of all native Black Hills animals and plants, not timber industry demands to "get out the cut."

The U.S. Forest Service is legally and ethically responsible for maintaining viable and well distributed populations of all native wildlife, fish and plants and their habitat in all National Forests. However, on the Black Hills National Forest, the Forest Service has been skirting this responsibility, electing instead to cater management actions primarily to maximize economic gain for the timber industry and other extractive industries, with little to no consideration given to plant and animal populations. Unfortunately, this has resulted in severe habitat degradation for many species, obviously leading to severe population declines.

While this practice has been determined to be illegal by the former Chief of the U.S. Forest Service Mike Dombeck, it is also a direct slap in the face to present and future generations that value and depend upon healthy forest ecosystems and the life therein. Viability is a guarantee that, native plant and animal species will continue to thrive. Given the geographic and biological isolation of the Black Hills, viability is of particularly great significance. Once a species is extirpated from the Black Hills it may never again exist within this forest. The only way to bring a species back is through costly restoration and, given the current anti-environmental sentiment dominating management of the Black Hills, it is highly unlikely that such restoration may occur at all. All viability determinations made for the Phase II Amendment should therefore be backed by a significant amount of credible, consistent and up-to-date scientific data that ensures an accurate and defensible viability determination and that habitat is in fact enhanced across the forest.

For the Forest Service to meet its viability responsibility, the Phase II Amendment environmental analysis should include actual population data. Without this information, it is unknown if viable populations actually exist. Where population or habitat data is lacking in the analysis, the Forest Service should disallow activities such as logging, grazing and off-road vehicle use in all existing or potential suitable habitats and ensure no impacts to populations while obtaining this information. Where viability is determined to be threatened for a particular species, no activities - including fire suppression - should be allowed in all existing or potential habitat or where populations are known to or may occur. The Phase II Amendment should provide management direction that errs on the side of wildlife, instead of subjecting native species of plants and animals to unnecessary risks.

Protect all roadless areas over 1,000 acres.

The importance of roadless areas on the Black Hills to wildlife and plant species that are sensitive to human disturbance are unmatched anywhere else on the forest. Access is extremely limited, much of these areas have never been subjected to logging, and natural processes have - for the most part - been allowed to run their course, creating and sustaining healthy and natural habitat. Unfortunately, roadless areas on the Black Hills are few. Only two are over 5,000 acres and all are threatened as logging and road building encroach upon their undeveloped interiors. The Phase II Amendment needs to provide full protection from logging, road building, livestock grazing and off-road vehicle use to roadless areas over 1,000 acres in size in order to maintain the near-pristine and undisturbed habitat within. Protection should come either from research natural area (RNA) designation, wilderness recommendation, or from site-specific management direction within the Phase II Amendment. The following roadless areas should be fully protected by the Phase II Amendment:

Beaver Park roadless area
Inyan Kara roadless area
Sand Creek roadless area
Sheep's Nose roadless area in the southeast of the Bear Lodge Mountains
Black Elk Wilderness Additions

Additionally, the Phase II environmental analysis should include a new on-the-ground roadless area inventory in order to identify previously unidentified roadless areas over 1,000 acres in size. This inventory should use only well-developed, constructed (bladed or cut and fill only), regularly maintained (once a year) and regularly used (at least once a week throughout the year) routes as criteria for determining roadless area boundaries. Routes such as two-tracks, user-created routes, routes with year-long closures, unmaintained routes, or environmentally damaging routes should not disqualify lands from roadless area designation.

Protect existing old growth forest and allow a greater amount of younger forest to reach old growth stature.

Species such as the Northern goshawk, three-toed woodpecker, black-backed woodpecker, Lewis's woodpecker, American marten and brown creeper depend on large amounts of old growth for survival. However, less than 5% of the Black Hills National Forest exists in an old growth (i.e. late successional stage) condition, far below historical amounts and far below what experts recommend for wildlife habitat. This percentage includes white spruce and ponderosa pine. Additionally, much of this old growth is unsuitable as wildlife habitat as it is next to roads, on steep slopes, restricted by tree species or lacks adequate canopy cover. The Black Hills National Forest and the wildlife therein are truly in need of more, better quality old growth forest.

Protection and recruitment of old growth on the Black Hills should be a fixture of the Phase II Amendment. Old growth retention and recruitment should be based on the need to provide high quality ponderosa pine nesting, fledgling and foraging habitat for known and potential (i.e. unknown) Northern goshawk territories across the forest, large blocks of white spruce and ponderosa pine old growth habitat (at least 1,000 acres in size) for woodpecker species and unfragmented old growth ponderosa pine and white spruce habitat for American marten.

The Forest Service should ensure that all white spruce is protected from logging and fragmentation and at least 20% of the ponderosa pine forested landscape exists in an old growth condition, as experts have recommended. While 20% of the forest does not currently exist in an old growth condition, the Phase II Amendment should ensure this amount is attained as soon as possible. All existing stands of old growth should be fully protected from logging, thinning and road building and a large number of recruitment stands of old growth, primarily ponderosa pine, should be fully protected as well. Recruitment stands of old growth should be well-distributed across the forest and should be abundant enough so that the viability of these stands will be maintained even if natural disturbances such as fire, windthrow and insect mortality disturb the natural succession of stands. Additionally, natural processes should be allowed to run their course undisturbed within these stands.

Designate Research Natural Areas to protect the best examples of all native plant communities and other natural features on the Forest-for their natural wealth and scientific value.

Research Natural Areas are designated in order to provide protection to unique and rare plant communities, geological features, and other natural features, as well as ecological representatives of forest environments for the purpose of scientific research and educational opportunities. In the selection of representative areas, a pristine condition is the goal. However, when candidate areas in a pristine condition are unavailable, then areas that reflect the pristine conditions closely as possible may be selected. These areas are highly limited on the Black Hills due to the impacts of past human activities on the Black Hills and through major ecological transformation, such as the introduction of nonnative species. Although RNAs may exhibit impacts of human activities, they are generally pristine and their size is commensurate with the natural value that is protected. It is imperative the Forest Service designate a system of RNAs on the Black Hills because of its unique ecoregional characteristics, because of the existence of rare plant communities that are threatened, and because future opportunities to protect RNAs are becoming fewer and fewer.

View a list of potential Research Natural Areas that should be designated.

Devise and implement conservation strategies for all individual "sensitive species" and their habitat, and for other vulnerable plants and wildlife on the Forest.

Management direction for the Phase II Amendment should be based on goals and objective for individual sensitive species, management indicator species, threatened and endangered species and other vulnerable species (special status species) and their habitat. The following species should be included in, but not limited to, the Phase II Amendment analysis and are of significant concern:
Birds

Northern Goshawk
Black-backed woodpecker
three-toed woodpecker
Lewis's woodpecker
Fox Sparrow
Golden-crowned Kinglet
Loggerhead shrike
Merlin
Olive-sided Flycatcher
Osprey
Purple Martin
Pygmy Nuthatch
Upland Sandpiper
Brown Creeper
American Dipper
Townsend's Solitaire
Bald Eagle
Peregrine Falcon

Mammals

Northern flying squirrel
Mountain lion
American marten
Townsend's Big-eared bat
Fringe-tailed myotis
Spotted bat
Dwarf shrew
Swift fox
Black-tailed prairie dog
Black-footed Ferret
Black Bear
Bison
Plants

All sensitive plant species

Aquatic Species, Reptiles and Amphibians

Mountain Sucker
Finescale Dace
Lake Chub
Longnose sucker
Creek Chub
Fathead Minnow
Longnosed Dace
Leopard Frog
Tiger Salamander
Black Hills Red-Bellied Snake
Milk Snake

Invertebrates

Regal Fritillary Butterfly
Tawny Crescent
Cooper's Rocky Mountain Snail
Striate Disc
Vertigo arthuri
Vertigo paradoxa
Catinella gelida
Oreohelix strigosa n. subsp.
Oreohelix strigosa berryi
All Species of Ephemeroptera and Plecoptera

Rather than making uninformed assumptions that protection of one species and its habitat will inevitably protect another, the Forest Service should analyze and assess the needs of these individual special status species and develop strategies accordingly. Since populations of many special status species are neither viable nor well distributed, management emphasis should be to elevate populations and improve habitat forest-wide, rather than maintaining existing populations and habitat. Conservation strategies should analyze and assess the effects of wildfire, windthrow, storm damage and other natural occurrences on the Forest Service's ability to restore populations of special status species and their habitat. Forest activities such as logging, grazing, recreational shooting, mining and off-road vehicle use should be restricted in order to achieve conservation goals as soon as possible.

A conservation strategy and management direction for the Northern goshawk should be developed for the Black Hills -- similar to (though stronger than) that developed for the Southwest -- in order to ensure viability of this imperiled forest raptor. Similar conservation strategies should be developed for snag dependent species in order to determine the soft and hard snag densities, heights, and widths and snag retention numbers necessary to ensure viability of these species on the Black Hills. Additionally, a conservation strategy should be developed for all native fish species that analyzes and assesses the impacts of nonnative fish species on native fisheries and provides management direction that restores native fish populations.

The Forest Service needs to conduct a thorough analysis of the status of the black bear on the Black Hills National Forest. Several reports of black bears on the Black Hills have been made recently. One was most recently observed on Middle Boxelder Creek. There still exists no reasoning or data that suggests the black bear is nonexistent on this forest. Even if there is one black bear on the forest, the Forest Service is obligated to manage for viable and well-distributed populations of black bear. A conservation strategy should be developed, in cooperation with the South Dakota Department of Game, Fish and Parks to rescue the black bear from near-extirpation on the Black Hills.

Conservation strategies should also be developed for species that have been extirpated from the Black Hills. The U.S. Forest Service is obligated to return species that have been allowed to be extirpated from the Black Hills through irresponsible management and misguided priorities. Strategies to reintroduce the black bear, grey wolf, grizzly bear, river otter and other extirpated species should be developed in cooperation with the South Dakota Department of Game, Fish and Parks.

Seriously and honestly assess the impacts of logging, road building, livestock grazing, mining, and off-road vehicle use on wildlife, plants and their habitat. Previous assessments have been disingenuous.
There is no question that, since the advent of European settlement of the Black Hills, the Black Hills National Forest has undergone immense transformation. Once a healthy ecosystem that sustained bison, wolves, and other species, the forest is now considered a "working forest", responsive only to the needs of those who derive direct economic gain from extracting natural resources. This mentality has infected past Forest Service environmental analyses and decision-making as the cumulative impacts associated with past logging, road building, livestock grazing and mining have been disregarded as insignificant. A century ago, the impacts of one timber sale may have been minor, but the impacts of a century of nonstop timber harvest has been significant.
When analyzing the impacts of logging, grazing, road building, mining and off-road vehicle use, the Forest Service needs to fully analyze and assess the cumulative impacts of these activities with regards to the past, present and reasonably foreseeable future. The Phase II Amendment should contain a serious and honest assessment of the cumulative impacts of these activities. Management direction should restrict these activities in order adequately minimize cumulative impacts and aid in restoring the Black Hills ecosystem.
Significantly reduce the road density on the forest by prohibiting future road construction and obliterating unnecessary and environmentally damaging roads and two-track routes.
Currently, 8,000 miles of roads are in place on the 1.2 million acre Black Hills National Forest, most created to facilitate logging. In the past, the Forest Service has not provided any rationale that supports maintaining 8,000 miles of roads, nor have they adequately maintained this excessive road system. Indeed, many experts have cited excessive road densities and lack of road maintenance on the Black Hills as negatively impacting wildlife and their habitat. It is time for the Forest Service to seriously address this issue and provide management direction that significantly reduces road densities on the forest as soon as possible. While we recognize the need for access to the forest, the current road densities are ridiculous - access is clearly not an issue. There are very few areas available for nonmotorized or primitive recreational opportunities and very few areas of undisturbed wildlife and plant habitat. (see map gallery on our website for a road map of the Black Hills)
The Forest Service needs to complete a detailed forest-wide analysis of routes within the Black Hills National Forest for the Phase II Amendment in order to accurately and effective obliterate all unnecessary and environmentally damaging roads, two-track routes and user-created routes and effectively reduce road densities. Additionally, the Forest Service should prohibit all future road construction - temporary and permanent -- through the Phase II Amendment.
Allow natural processes such as wildfire and insect outbreaks to provide wildlife habitat and ensure long-term forest health. Logging or spraying chemicals can not mimic nature.
If the Phase II Amendment will provide management direction that maintains viable and well distributed populations of wildlife, then natural processes need to be allowed to occur. Experts have observed that natural processes such as wildfire, insect outbreaks, windthrow and storm damage are essential to maintain forest health and provide wildlife habitat, yet the Forest Service has made a priority of suppressing these processes to protect merchantable timber and "salvaging" the damaged timber. The excuse that logging is necessary to maintain forest health is an arbitrary statement, as natural processes that maintain forest health have been in place for millions of years. It is obvious that logging to maintain forest health is not desirable for wildlife species and their habitat, and is a myth perpetuated by the timber industry. The Phase II Amendment needs to allow these processes to naturally occur on a large-scale and should prohibit all salvage logging in order to provide adequate and well-distributed snag habitat, insect prey for insectivorous species, restore meadows and hardwoods, reduce fire risk and aid in nutrient recycling. While we understand protection measures that reduce fire risk need to be taken for those residing within the forest, we believe the most effective action that landowners can undertake to protect their property is to create defensible spaces around their structures. Logging roadless areas or other patches of uncut forest is not necessary to protect private property. Additionally, removal of livestock should be a priority where noxious weeds are a problem, meadows are being encroached upon by pines and where hardwoods are diminishing.

Please send a letter to the Forest Service by January 28 at:

Black Hills National Forest
Phase II Amendment
USDA Forest Service CAT
PO Box 7669
Missoula, MT 59807

email address: mailroom_wo_caet@fs.fed.us
You need to add "Black Hills NF Phase II Amendment" in the subject line.

List of Potential Research Natural Areas

Black Fox
Mesic coniferous forests and woodlands (including old growth) are well represented. There is a large complex of riparian forest, shrubland and herbaceous types.

Canyon City
Mesic coniferous forests and woodlands (including old growth), dry riparian types and high elevation riparian types are well-represented. The best example of water birch shrubland, a type that is relatively uncommon and restricted in the Black Hills, was found at this site.

Cranberry Springs
The area is a mosaic of community types. Mesic coniferous forest and woodlands (including old growth), dry riparian types and upland hardwoods are well-represented.

Sand Creek Headwaters
Upper headwaters area has mosaic of bulrush/cattail. Beaked sedge and Bebb willow shrubland communities are present in wet meadows. Paper birch/ beaked hazel communities in the drainage bottoms. Hawthorne stands in gulches as well.

Elk Mountain (site #41)
Dry coniferous forests and woodlands (including old growth), and dry and mesic mixedgrass prairies are the types best represented.

McIntosh Fen (site #38)
A relatively small site, but is located within a unique habitat in the Black Hills. Only four community types were identified at McIntosh Fen, but the small pockets of willow shrublands are rare, and may be the last relics of a once-more-extensive type. Currently managed as a Botanical Area, and restoration of the natural water regime is underway in hopes of reinvigorating the native plant communities.

Beaver Park
Ranks relatively high due to the roadless nature of the area. Community types include: Paper birch/ hazel forest, ponderosa pine/ little bluestem woodland, ponderosa pine/ rough-leaf ricegrass woodland, bur oak - ironwood forest, ponderosa pine/ bearberry woodland, ponderosa pine/ chokecherry forest.

Hell Canyon North
This site is a large area with a mix of coniferous types, including old growth stands. Community types include: Aspen/ chokecherry forest, ponderosa pine/ bearberry woodland, ponderosa pine/ little bluestem woodland, ponderosa pine/ mountain ninebark forest, ponderosa pine/ rocky mountain juniper woodland, ponderosa pine/ common juniper woodland.

Hell Canyon South
On this site community types include:Mountain mahogany/ side-oats grama shrubland, ponderosa pine/ rocky mountain juniper woodland, western wheatgrass - green needlegrass mixedgrass prairie.

Vanocker Creek
Contains at least one high quality example of plains riparian forests and shrubland.

Community types include: Bur oak - ironwood forest, ponderosa pine/ bur oak woodland, western snowberry shrubland, creeping juniper/ little bluestem dwarf-shrubland, northern great plains little bluestem prairie, ponderosa pine/ little bluestem woodland.

Little Spearfish Creek
Includes a diversity of high ranking riparian and wet meadow types.

Little Elk Creek
Contains at least one high quality example of plains riparian forests and shrubland.

Community types include:Beaked willow shrub, western great plains streamside vegetation, narrowleaf cottonwood/ red-osier dogwood forest, northern great plains cattail marsh.

Spearfish Creek
Community types include:White Spruce Alluvial Black Hills Forest, Beaked Willow Scrub, Narrowleaf cottonwood/ red-osier dogwood forest, Nebraska sedge wet meadow, peach-leaf willow woodland (lower quality stand, but only occurrence found in BHCI).

Buskala Creek (site #29)
Community types include:White spruce/ grouseberry forest

Gillette Canyon Headwaters & Upper Gillette Canyon
Headwaters of Gillette Canyon and Ditch Creek in vicinity of Sixmile and Ditch Creek Roads. NW of Bear Mountain lookout. Forb-rich grassland in very broad drainage bottoms; mostly native species; more cover in more mesic areas (bottoms vs. slopes). Mostly native species; allotment north of Sixmile road is more heavily utilized and soon drops in condition going north.

Reynolds Prairie
Large prairie on rolling uplands with shallow drainages; grassland with areas of high forb density.

Battle Creek
Community types include:Aspen/ beaked hazel forest, BH streamside vegetation, bur oak-ironwood forest, paper birch/ hazel forest, ponderosa pine/ bearberry woodland, ponderosa pine/ bur oak woodland, ponderosa pine/ chokecherry forest, ponderosa pine/ little bluestem woodland, ponderosa pine/ common juniper woodland, and sandbar willow shrubland.

Geis Spring
Community types include:Bur oak-ironwood forest, paper birch/ hazel forest, ponderosa pine/ bur oak woodland, ponderaoa pine/ rough-leaf ricegrass woodland.

The USFS should also designate at least one limestone plateau RNA, and RNA's that would protect unique zoological areas as well.

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Biodiversity Associates, P.O. Box 1512, Laramie, WY 82073
(307) 742-7978 - maggie@voiceforthewild.org