Forest Service completes assessments for revised forest plan

The assessment phase is now complete for the Black Hills National Forest Plan Revision process and a total of 20 revised, forest-wide resource assessments have been released.

The 20 assessments evaluate existing information about current and relevant ecological, economic and social conditions, trends and sustainability on the Forest, according to a press release from the U.S. Forest Service (USFS). The purpose of conducting assessments is to identify the need to change the Land Management Plan.

These will be used, according to the USFS, alongside best available scientific information and new information as it becomes available to revise the current plan.

Draft assessments were released in June, 2022 and 128 comment letters were received in the comment period thereafter. Some of these comments expressed significant concern.

Crook County, for instance, joined the call for USFS to rethink its draft assessments, touting “significant concerns” with the science used to create the drafts and with the level of public input solicited so far.

A 21-page letter from the county commissioners expressed concern that the draft assessments fell short of meeting the 2012 Planning Rule objective, which requires “the use of best available scientific information to inform planning and plan decisions” and emphasizes the need for meaningful opportunities for public participation.

The letter also listed several pages of specific issues within the draft assessments, ranging from a “a lack of consistent and thorough monitoring” in assessing aquatic, riparian and groundwater dependent ecosystems to the black-footed ferret being listed as present in the Bearlodge Ranger District with no supporting documentation.

The commission also pointed out that several statements made within the timber assessment suggested that the Forest Service had “already determined their preferred alternative for the revision process”.

Governors Mark Gordon and Kristi Noem (SD) also penned a joint letter to request a rethink, concerned over the potential impact of the plan on the timber industry within the Black Hills.

The letter sent by Gordon and Noem claimed the assessments contained “countless statements that are not backed by scientific material”, and that making such assertions without scientific authority “hinders our ability to meaningfully engage in the revision process”.

“The assessments also fail to include critical and readily available information that accurately portrays the current conditions of the Forest,” stated the letter.

Specifically, the letter claimed there were errors in the data analysis and assumptions from the Black Hills Timber Sustainability General Technical Report (GTR), including a failure to properly account for merchantable tree species, tree growth, reduction in timber resources and inaccurate mortality rates.

Since the comment letters were received, all have been reviewed by the USFS and they say feedback was used to revise assessment where appropriate.

The revised assessments and other information about the revision process can be found on the Black Hills National Forest website at https://www.fs.usda.gov/detail/blackhills/landmanagement/planning/?cid=FSEPRD955187 

Individual responses to the comments received on each draft assessment are also available to review, detailing how the USFS responded to the comment, either altered the assessment and/or plans to tackle the comment during the next phase.

The second phase of the plan development will begin when the notice of intent is published in the Federal Register, expected in spring of 2024. The final phase, the Monitoring Phase or phase III, will begin once the current Forest Land Management Plan has been revised.

“The Plan Development phase will be a very robust public engagement process that will include many public meetings and provide various opportunities for the public’s voice to be heard,” said acting Forest Supervisor, Ivan Green. “The diverse public interests must be considered to ensure we maintain a healthy, productive, and resilient forest.”

According to the press release, the Forest Plan revision process is being completed pursuant to the Forest Service Planning Rule (36 CFR 219), and as directed by the National Forest Management Act. This process generally takes several years to complete and will result in a revised Land Management Plan that will be effective for approximately the next fifteen to twenty years.

The Black Hills National Forest Land and Resource Management Plan was first released in 1983, revised in 1997, and amended in 2006. The 2006 version serves as the current Forest Plan for the Black Hills National Forest.