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Comment deadline on Spruce Draft Environmental Assessment, BHNF

September 25, 2023 @ 11:50 pm - 11:59 pm

Comment Period on Spruce Draft Environmental Assessment, BHNF originally ended on Monday, Sept 25th. The Forest Service later (on 10/2/23)  granted a 4 day extension till Friday October 6th. Go to Oct. 6th calendar day alert for info on that. Comments are e-mailed to Matthew Daily for later (10/6/23) deadline Matthew.Daily@usda.gov.


Link to view documents > – https://www.fs.usda.gov/project/blackhills/?project=61599

There are a bunch of documents to unload – The Draft EA & 11 specialist reports.

First below is an alert from the Norbeck Society and then a quote from the BHNF.

Please note, Forest Service comment deadlines that would fall on weekends or Holidays (due to  counting days from announcement) move to the next working day, so the deadline is the 25th, not the 23rd. It actually says the 25th in the public notice.  If sending by e-mail, do so a bit before midnight, which is the deadline.

On Friday afternoon of the 22nd,  Saturday  23rd and Sunday 24th, the FS portal for Spruce was not working.  It was fixed on late afternoon  of Monday 25th (3:11 pm or earlier),.. This e-mail  is Matt Daily’s – Matthew.Daily@usda.gov –  if you want to complain about impact of the web site not working on you or if you want to send comments directly to him.

PHAS sent a letter requesting an extension. If they give that, it will be for 30 days. You can download documents once again and Nancy Hilding (nhilding@rapidnet.com) has a copy of the documents, if anyone wants them e-mailed by her directly.

Also, the Reading Room is still available and contains comments submitted up to the time that the project webpage failed (Friday afternoon).:  US Forest Service NEPA Project Public Reading Room (usda.gov)

Quote from the Norbeck Society’s Alert:

“Important Comment Opportunity – Spruce Project comments due Sept. 23 [25th]

Black Hills Projects lead to Timber Harvests on our already overcut forest – please take a moment to submit your comments!

The Black Hills National Forest proposes management activities on approximately 3,614 acres in mixed conifer stands.

The modified proposed action includes:

  • @493 acres overstory removal with reserves
  • 831 ac. shelterwood
  • 888 ac. commercial thinning
  • 720 ac. group selection
  • 682 ac. precommercial thinning restoration

Associated road activities being proposed include:

  • @41 miles temporary road construction and closure
  • 22 miles of road reconstruction, and road maintenance

Black Hills National Forest is requesting your comments on the Spruce Project (click here).This comes after an initial scoping comment period in March 2022 when around 170 people (overwhelmingly in opposition to the project) wrote comments. This public attention made a big difference: the project was reduced from about 20,000 acres of spruce logging to 3600 acres. While to their credit, Forest Service scaled the project down significantly, there is still substantial reason to be concerned and in opposition to the project for these reasons:

  • The Spruce Project potentially authorizes more unsustainable logging simply to appease the timber industry, without care for the needs of the forest.
  • According to the Forest Plan, the Forest Service is supposed to provide diverse habitats (and tree sizes and densities) to provide for a variety of life. However, in the majority of proposed cuts, the spruce project removes the few remaining dense stands that are essential for plant and wildlife habitats. These are currently islands of ecological integrity that we can’t afford to lose. The Spruce project leads to contiguous disturbed, cut-over forest.
  • The Spruce Project proposes that Spruce should be cut out of these areas in order to plant pines for future harvests. However, Forest Service has already recently over-committed to replanting trees to the tune of thousands of acres with no hope of actual achievement (Alvin, Simon, and Theodore Projects: 3500 acres, Artemis Project: 2000 acres, Moskee Burn Project: 250 acres, Fish Fire Project: 600 acres, for a total of about 6350 acres. This is in addition to the ongoing Jasper Fire (2000) replanting. Basically, planting of pine in these areas will not happen for a long time because of a deficit of seedlings, infrastructure, and personnel.
  • Historically and recently, industry does not want spruce because it is an inferior wood product. If the Spruce project goes forward, and if planting takes place in 50 years, a pine product may be available for harvest in about the year 2175. Meanwhile, we have lost these intact forests that are the wells of biodiversity we hope can move back into the already-cut areas around them over time.
  • Spruce forests do not suffer from Mountain pine beetle outbreaks, and mixed Spruce-Pine forests have been determined to be more resistant to Mountain pine beetle. Many mixed pine and spruce stand have been logged and the (undesirable-to-industry) spruce was left behind. So, Pine was removed from Spruce and now they want to remove Spruce from Pine?? This is nonsensical. Example from 2018 southwest of Black Fox:
  • Damage to soils and water tables can take a century or more to recover from logging. Logging disturbance is of a magnitude greater than historical disturbances on the forest. The Black Hills have been recently logged at an unprecedented rate.
  • Add the reasons you want to keep your Spruce and mixed Spruce forests!

Below is a direct quote from the BHNF:

“Release Date: Aug 28, 2023

Contact(s): Media Contact: Scott Jacobson, 605-440-1409

Custer, S.D., Aug. 28, 2023 – The Black Hills National Forest is announcing the availability of the Draft Environmental Assessment (EA) for the Spruce Vegetation Management Project and is seeking public comment on the proposed project.

The project is located on National Forest System lands south of Spearfish Canyon, east of the Wyoming/South Dakota border, north of the Crazy Horse Memorial and west of Interstate 90.

The project includes management activities on approximately 3,614 acres in mixed conifer stands. The modified proposed action includes approximately 493 acres of overstory removal with reserves, 831 acres of shelterwood, 888 acres of commercial thinning, 720 acres of group selection, and 682 acres of precommercial thinning restoration.

The purpose of the project is to re-establish ponderosa pine and aspen in mixed conifer stands currently dominated by spruce; increase structural heterogeneity in spruce stands lacking age and size class diversity; provide site-specific fuels reduction to protect infrastructure at risk and create defensible space; and provide economic support to local communities.

Comments are encouraged to be specific, within the scope of the project, have a direct relationship to the proposed project activities, and include supporting reasons for the responsible official to consider (36 CFR 218). The 30-day comment period for this project started with the publication of the legal notice in the Rapid City Journal on Aug. 24, 2023. The comment period will end on Sep. 25, 2023.

Comments can be submitted electronically through the project webpage at: https://www.fs.usda.gov/project/blackhills/?project=61599Written comments may be submitted to: Matt Daily, Black Hills National Forest, 1019 N. 5th Street Custer, SD 57730; or can be dropped off in person (Monday through Friday, 8:00 a.m. to 4:00 p.m., excluding holidays).

For more information on the Black Hills National Forest, visit http://www.fs.usda.gov/blackhills, follow the Forest on Facebook: https://www.facebook.com/blackhillsnf or Twitter: https://twitter.com/BlackHillsNF.”


September 25, 2023
11:50 pm - 11:59 pm