BHNF “Phase II” Forest Plan Amendment:
Background:
All National Forests are required to devise, using public input and
current scientific information, a Land and Resource Management Plan (Forest
Plan) every 15 years. Forest Plans
lay out goals, objectives, standards, guidelines, and a strategic framework for
the way the Forest Service will manage their land.
All projects the Forest Service proposes to perform over the life of the
Plan (e.g., recreation improvements, road-building, fire risk reduction, timber
sales, etc) need to comply with Plan direction.
In 1997, the Black Hills National Forest (BHNF) completed a
wholesale Revision of its Forest Plan; the product of nine years’ hard work by
the BHNF and many local stakeholders. The
plan was appealed by a host of interest groups, and in 1999, former Forest
Service Chief Mike Dombeck issued a despicable, politically-motivated blind-side
decision on the appeals: he declared the 1997 Revised Plan illegal and sent it
back to the Black Hills on the grounds that it did not “adequately consider”
habitat for certain wildlife species, and had not “adequately analyzed” the
potential for designating “Research Natural Areas” on the BHNF (RNA’s are
essentially mini-wilderness areas).
Mr. Dombeck also issued with his decision something called
“Interim Direction”, which was an unprecedented and basically illegal way of
making a unilateral decision (without your input) about how the Black
Hills National Forest ought to deal with the “problems” he identified until
the “inadequate” analyses could be remedied.
The combination of Dombeck’s decision and “Interim Direction” had
the effect of entirely shutting down management on the Black Hills for more than
a year, while the Forest figured out what their next steps ought to be.
The uncorroborated restrictions that were put in place continue to hamper
the BHNF’s ability to manage the forest to this day.
Here’s where the Phase II Amendment comes in.
In May, 2001, as-required by a lawsuit settlement related to Dombeck’s
decision, the BHNF completed what was called the Phase I Amendment.
Phase I was a maximum-restriction measure put in hack until the Forest
could actually perform scientific studies of the Chief’s issues (so that no
species were “harmed” by the Forest’s activities in the meantime).
Phase II is the vehicle through which the Forest will study those issues
and derive new management direction to address them if any is necessary.
The Phase II Amendment got underway in December, 2001, and is scheduled
for completion in September, 2003. Opportunities
for public comment have and will continue to occur throughout the Phase II
process, and we are happy to bring you up to date on the latest issues.
UPDATE; September 16, 2002:
The Phase II Amendment to the Black Hills’ Forest Plan is progressing, and
another opportunity to provide input is upon us. Right now, the Forest has completed a lot of preliminary
analysis, and is moving into the alternative development stage.
A Forest Service newsletter was recently published, summarizing of the
comments they received back in January, outlining the framework of Phase II’s
decision elements, and identifying some of the preliminary issues they’re
addressing in their range of alternatives.
If you didn’t receive one, the newsletter is available on the Web at:
http://www.fs.fed.us/r2/blackhills/fp/planning/99Amend/Amend.htm
or from any of the BHNF District Offices.
The Forest conducted a series of open houses from September
9-13 to help get everyone more informed about the Amendment.
These meetings were a good conduit to provide comments and suggestions to
the Forest Service, so thanks to all who attended. The
deadline for the last submission of written comments was September 16, but this
shouldn’t discourage you. If
you’re interested in commenting on Phase II, send your letter to:
Mr. Jeff Ulrich
BHNF Phase II Amendment
25041 N. Hwy 16
Custer, SD 57730
The following are some key issues that will be important to
bring up as the Forest Service begins to craft its alternatives:
1. In the
latest newsletter, the Forest asserts that, “the current Forest Plan has ample
direction to reduce fire-and-insect risks”.
This is plainly false; one need only look around at the stirring amount
of charred or insect-eaten acres on the Black Hills NF to realize that Forest
Plan direction promoting aggressive forest health treatment is insufficient.
If fire and insect problems are not to be analyzed formally in Phase II,
the Forest’s alternatives ought to, at minimum, include the following:
• A new Goal in the Plan’s Goals & Objectives
section to acknowledge the importance of these concerns to the forest and to the
public. All perceived protections
for wildlife habitat are moot if the act of ‘protection’ causes it to burn
or be eaten by bugs. We like
wildlife, and we like a healthy forest; the two things are not, however,
mutually exclusive and are, furthermore, dependent on active management.
• The Forest’s discussion and analysis of alternatives
ought to clearly address and disclose the interrelation between targeted habitat
levels, forest health, and fire risk.
• Currently, the Forest is harvesting far less timber
than the Black Hills grow annually. Many
of the Forest’s fire and insect problems are related to this over-growth
issue. The re-evaluation of Forest
outputs should include an analysis of how changes in output levels will affect
forest health and fire risk in the long-term.
2. Ask the Forest to cast aside the politicized idea that
healthy wildlife populations and active forest management cannot coexist.
We’ve been making it work here in the Black Hills for 100 years, and we
can make it work another 100!
• Alternatives should contain an honest analysis of their
social and economic impacts as well as their ecological ones.
• Management ought to occur wherever it is needed on the
Black Hills National Forest. Under
their current system, the ability of the Forest Service to manage a given piece
of land begins with whether or not the land is designated “suitable”.
In Phase II, the Forest is re-evaluating their “suitability”
classifications. As the Forest does
this, they should give themselves as much opportunity to manage as possible.
The Forest can address this issue two ways; either designate more land as
“suitable” to help promote active management or develop management
strategies that work on non-suitable lands.
• Wildlife is one of the many tremendously important
multiple-uses, not the trump card of multiple-use. The alternatives’ approach to wildlife species viability
should be framed in the context of all other multiple-use considerations because
the cornerstone of good natural resource management is balance.
• Wildlife standards should be constructed to give
considerable discretion to scientists on the ground, so that they have the
ability to assess and prioritize resource management concerns when working on a
given project. They are the
experts, and deserve expert judgment in setting management priorities.
• The Forest should consider broadening the range of its
Management Indicator Species to include those dependent on young forest
conditions, as well as the more popularized species that need mature forest.
This will help create diversity, be good for all wildlife, help reduce
the spread of fire and insects, and promote multiple-use management.
• The broad-scale road closures and obliterations the
Forest seems to be partial to instituting shouldn’t be concealed behind the
guise of wildlife issues. The Black
Hills’ elk population has somehow skyrocketed in the past ten years, despite
the level of road densities some want to decry as debilitating to elk and other
species. If forest roads were doing
those critters as much harm as some believe, we wouldn’t have any
wildlife at all! We need to
maintain the recreational opportunities, level of fire suppression and
management access, and our wildlife -- we can do all those things, just look
around.
• Research Natural Areas (RNA’s), while valuable ways to gain better understanding of our natural world, should not be included in any alternative unless a discrete and meaningful purpose has been established for their creation. Some would force the Forest to designate RNA’s as another way (like Wilderness and Roadless designations) to lock-out the public and curtail management. This is not their purpose and is a disingenuous way of furthering a hidden agenda.