And now:Ish <[EMAIL PROTECTED]> writes:

Date: Fri, 17 Sep 1999 10:47:11 -0600
To: "Wild Rockies Alerts" <[EMAIL PROTECTED]>
From: Wild Rockies InfoNet <[EMAIL PROTECTED]>
Subject: Black Hills Proposed Wilderness Under Attack

From: Jeff Kessler <mailto:[EMAIL PROTECTED]>

Black Hills Proposed Wilderness Under Attack

Comments Needed by SEPTEMBER 20
to Protect Beaver Park Roadless Area

For the third time in two years, the U.S. Forest Service is proposing to have a 
massive commercial timber sale in the Beaver Park Roadless Area in the Black Hills 
National Forest (BHNF).  Due to extensive logging everywhere else on the BHNF, Beaver 
Park may be the last forested Roadless Area in South Dakota that remains eligible for 
wilderness designation;  the proposed logging would eliminate the "wilderness" 
eligibility.

Last year, the Forest Service (USFS) issued an Environmental Impact Statement (EIS) 
and decision to log a portion of Beaver Park as part of the "Veteran/Boulder timber 
sale."  Biodiversity Associates appealed that decision and the Veteran/Boulder sale is 
now on hold.   However, earlier this year the Forest Service issued a draft 
"supplemental" EIS (SEIS) proposing to expand the Veteran/Boulder sale further into 
the roadless area.  Even thought the first sale is currently on hold and the second 
proposed sale's SEIS has yet to be completed, the USFS issued an August 18, 1999 
"scoping" letter announcing a proposal to have an even bigger timber sale in the 
Beaver Park area.  The proposal allows for commercially logging on up to 4,000 acres, 
non-commercial logging/felling of another 2,000 acres, burning up to 2,000 acres. 
About half of these activities would occur inside the Roadless Area and in a part of 
the Forest designated for emphasis on "semi-primitive non-motorized" recreati!
!
on (
so-called Management Area MA 3.32).

This latest proposal--like the two before it--is being justified under the guise of 
suppressing purported pine beetle "epidemic" in the Beaver Park area.

The USFS's scoping letter says the agency is considering 3 "action" alternatives for 
controlling beetles:

1) Maximum suppression--commercially logging up to 4,000 acres inside and outside the 
roadless area, non-commercial logging/felling of another 2,000 acres, burning up to 
2,000 acres);

2) Suppression with no roads in Management Area 3.32 designated for semi-primitive 
backcountry recreation -- a part of the Beaver Park Roadless Area less than 5,000 
acres in size;  logging and road construction would still occur in other parts of the 
Roadless Area and would eliminate its wilderness eligibility;

3) Suppression outside the Beaver Park Roadless Area.

Letters are urgently needed BY SEPTEMBER 20, 1999 to let the USFS the Beaver Park 
Roadless Area and MA 3.32 should NOT be logged.

Here are some points you may want to make in your comments:

-The Beaver Park Roadless Area is too special to be logged for any reason.  The entire 
Roadless Area should be set aside for Wilderness or a Research Natural Area (RNA) to 
allow the USFS to study natural processes.

-Beetles and snags (standing dead trees) are natural and important parts of the forest 
ecosystem; the USFS should allow these to exist in the Beaver Park area--without 
suppression--because of how much suppression has been done everywhere else on the 
Forest.

-Beaver Park is not the source of the purported beetle outbreak;  trees are dying in 
pockets in many other parts of the Black Hills, and this is OK.

-Logging will not have a significant effect on beetle populations, as evidenced by the 
fact that areas which have been recently logged are also experiencing beetle kill.

-The only thing that will control beetle populations (assuming they should be 
controlled) is cold weather, and this is outside of the USFS's control.  Furthermore, 
it is likely that a cold snap will occur before the USFS completes its proposed 
logging activities, thereby eliminating the USFS's justification for logging.

-The Beaver Park Roadless Area does not belong solely to citizens of South Dakota and 
should not be logged simply because some local citizens want to log it;  this special 
place is part of a National Forest which should be managed in a natural state for the 
benefit of everyone.

-If the USFS believes any beetle "suppression" is to be done on the Forest, tell the 
agency to use non-commercial logging methods such as prescribed fire and pheromone 
baits to lure beetles out of sensitive areas (methods the USFS has admitted can be 
used).

-If the USFS believes any logging should be done, tell the agency you do NOT want any 
logging (commercial or otherwise) or road construction/reconstruction in the Beaver 
Park Roadless Area.

-Tell the USFS it cannot "save" the Forest by cutting it down.

Send your comments BY SEPTEMBER 20 to:
        Gary Say
        Acting District Ranger
        Spearfish/Nemo Ranger District
        2014 North Main Street
        Spearfish, SD  57783
        (605) 642-4622
        email:  mailto:[EMAIL PROTECTED]

If you have questions about this alert, please contact us at:

Biodiversity Associates
PO Box 6032
Laramie, Wy  82073
(307) 742-7978
[EMAIL PROTECTED]


***** ADDITIONAL INFORMATION ****

Here are some other points you may want to make:

The USFS scoping letter asserts that "pine beetle populations are growing, and timber 
has been damaged by snow and wind."  The agency regularly exaggerates such "problems" 
to justify ill-conceived logging proposals.  Ask the USFS to provide all the evidence 
-- in the draft EIS -- documenting the extent of any "beetle populations" and "tree 
damage" throughout the project area.

The USFS scoping letter says ""Beetles go ... into an epidemic stage where 10% or more 
of the stand is affected in a three year period."  Ask USFS to analyze in the draft 
EIS the likelihood that the beetle population will eventually be naturally suppressed 
by weather before logging occurs.

The USFS scoping letter describes purported "problems" beetles may cause, such as 
increasing risk of forest fire, altering "scenery," and affecting the "Centennial 
Trial."  However, the scoping letter fails to describe the benefits of beetles to the 
Forest ecosystem, such as providing snags for wildlife habitat, helping to recycle 
nutrients back into the soil, and providing food for sensitive species such as the 
ovenbird.  Tell the USFS its draft EIS must fully analyze and disclose these benefits, 
i.e., the benefits of not suppressing beetles.

Tell the USFS you do not mind seeing dead trees that provide habitat for wildlife, but 
you detest seeing stumps, slash, and skid trails from logging activities;  logging 
creates more visual scars than beetles.

The Black Hills National Forest has been subject to some of the most intensive logging 
and suppression of natural processes (i.e., fire and beetles) of any forest ecosystem 
in the country.  Tell the USFS its draft EIS must disclose how this "suppression" has 
altered the ecosystem and adversely impacted wildlife.

Other Forest Plan Objectives

The Forest Service scoping letter lists several forest plan "goals & objectives" that 
suggest that logging must be done to control beetles. However, there are many other 
forest plan "objectives" that dictate that beetles are OK and that "suppression" 
should NOT take place.  For example, the forest plan directs the agency to manage the 
forest to benefit wildlife such as the Brown Creeper, Black-backed Woodpecker, 
Three-toed Woodpecker, and Pygmy Nuthatch which depend on forest insects or snags (old 
dead or dying trees). Tell the USFS it cannot arbitrarily select "goals and objects" 
that favor logging.

The BHNF "Forest Plan" only directs the USFS to "control" beetles "where appropriate"; 
 tell the USFS controlling beetles in the Beaver Park Roadless Area, in MA 3.32, and 
on lands deemed "unsuitable" for timber harvest is NOT appropriate.

************************************************************************

Reprinted under the Fair Use http://www4.law.cornell.edu/uscode/17/107.html doctrine 
of international copyright law.
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