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Comments on forest-thinning plan rife with disagreement
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Comments on forest-thinning plan rife with disagreement


Written public comments on a proposed forest-thinning project near Custer reflect the widely divergent ways that people think the Black Hills National Forest should be managed.

“Please cut down as many trees as you can!” wrote Todd Craig. “Our forests are way overgrown!”

Those were the entirety of Craig’s comments.

The Norbeck Society, which promotes the sustainable use of public land, submitted six pages of commentary on what it described as the “deeply complex” issues surrounding the management of the forest.

Regarding the proposed thinning project, the Norbeck Society said prescribed fires would be more effective than the logging that is planned.

The Society said “there is not a community safer from fire than one that has had fire,” and it said the proposed thinning project is “unlikely to make much of a difference in the intensity, severity and effects of a wildland fire in the area.”

The opposite viewpoint was expressed by the Black Hills Forest Resource Association, which is a timber-industry trade group. It said the thinning project will “reduce the likelihood of stand-replacing fire and bolster the resilience of forested stands if a wildfire does occur.”

“This provides for safer fire suppression activities, and protection of communities and forest resources,” wrote Ben Wudtke, the association’s executive director.

The project in question, the Tepee Canyon Project, would be conducted on 2,669 acres of land (about 4 square miles) located 17 miles west of Custer, along the south side of U.S. Highway 16 between Jewel Cave National Monument and the Custer Highlands residential area.

Matthew Daily, the acting timber program manager for the Black Hills National Forest, told the Journal last month that the area targeted by the project is prone to dry conditions and is densely forested, making it susceptible to the kind of wildfire that spreads quickly and climbs to the treetops while wiping out everything in its path.

That kind of fire could endanger lives and property in the neighboring residential area and at the national monument, so Forest Service officials hope to thin the area with methods including selective logging of larger trees and the removal of smaller trees. Project documents say the project would create a “defensible space.”

“The whole premise here,” Daily said, “is we’re trying to break up the landscape to avoid a running, catastrophic fire event.”

Daily said part of the project would be accomplished with a timber sale, which would be open to logging companies. He said the timber sale could be prepared this fall and conducted next summer. After the sale, the logging company that wins the contract could take up to five years to do the work.

Daily said the project area could be subjected to a prescribed burn at some point, but he said logging and other related methods of thinning are proposed for the project because it’s difficult to find a time when the forest is neither too wet to do a prescribed burn nor too dry to do a prescribed burn safely. He said logging projects, which are put out for bids to commercial contractors, also help pay for thinning projects; prescribed burns, conversely, require the Forest Service to invest planning time and personnel.

To get a quicker decision on whether to approve the project, the Forest Service is using a tool it was given by federal legislation last year. That tool — an expansion of an existing power called “categorical exclusion” — allows the Forest Service to forgo the preparation of an environmental assessment or environmental impact statement for projects that affect 3,000 or fewer acres and are intended to make forests more resilient to wildfires.

Categorical exclusions have been criticized for their diminished public involvement. Unlike the process for drafting an environmental impact statement, which includes an initial public comment period and a later objection period, the process for a categorical exclusion includes only the initial public comment period.

The public comment period for the Tepee Canyon Project ended July 5. It’s now up to the district ranger of the Black Hills National Forest’s Hell Canyon District, Tracy Anderson, to consider the comments and decide whether to proceed with the project and whether to make any changes to the project plan.

Comments favorable to the project came from several sources, including the National Wild Turkey Federation, which said it believes the project will accomplish its intended objectives. Additionally, the federation said, “we also believe that it is appropriate for the U.S. Forest Service to use the Wildfire Resilience categorical exclusion to avoid a lengthy and unnecessary NEPA process.”

The acronym “NEPA” stands for the National Environmental Policy Act, which is the federal law that requires environmental assessments or environmental impact statements to be prepared for many projects undertaken by the federal government.

Commenter Steve Baldwin, of Custer, said, “I have witnessed the worst fires in the Black Hills over the years and no doubt they were worse because of over growth and over abundance of forest floor fuels. Please proceed with the project as proposed and in a timely manner before we have another catastrophic fire in the area.”

Mike Trier, also of Custer, wrote, “I applaud your proactive approach and urge prompt implementation.”

Neiman Timber Co., of Spearfish, said it agrees with the purpose and need for the project.

“Manipulation of fuels will help decrease the chance of stand-replacing fire, provide safer fire suppression activities, community fire protection and the protection of other valuable resources on the landscape,” wrote the company’s resource manager, Dan Buehler.

Comments against the thinning project came from the Black Hills Group of the Sierra Club, which said, “We disagree with the federal legislation tool of categorical exclusion to forego public involvement from we, the American people, about our lands.”

The group also said it agrees with many of the Norbeck Society’s comments.

The Norbeck Society not only criticized the methods for the proposed thinning project but also urged a new approach to forest management in general.

“The past century of logging has helped to rob the ecosystem of large fire resistant stands of pines and gradually reduced the ability of the forest to cope with fire and insect outbreaks, dealt a sentence of botanical chaos and habitat loss, and jeopardized a plethora of other human interests on the forest,” the Society wrote.

The Society said logging opens up areas of the forest for thickets of young trees that can serve as fuel for fires. The Society urged more prescribed burning to thin or remove such “understory pine growth."

“If we do not reintroduce more fire to this landscape via prescribed burns, we will likely be introduced to fires beyond what we’ve ever experienced,” the Society said.

Contact Seth Tupper at

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