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Position Statement


Since 2005, the Norbeck Society has provided input and comments on a number of issues/projects planned for the Black Hills National Forest and other regional public lands, including national grasslands, and lands under the jurisdiction of BLM, NPS, state and county agencies.  Below is an attempt to summarize our primary concerns and our positions that we take on a consistent basis:


General guiding statements

Comments on USFS Management

Comments on Major Threats

Other Issues



General guiding statements


§  The forest is a living natural environment, supporting native species, and providing a plethora of goods and services for human communities.   


§  Emphasis must be on establishing, enhancing, and maintaining a sustainable habitat for wildlife and botanical resources.  It is critical that species diversity and biocomplexity have first consideration in management issues.  A reasonable goal would be moving towards a sustainable forest similar to that which existed before 1875.  Diversity of habitat equates to a healthy forest.


§  Emphasis should be on enhancing and restoring a natural ecosystem, and not on managing for a tree farm.


§  Non-motorized recreation is encouraged, including opportunities for peace and solitude.


§  Motorized recreation continues to have a negative impact on the natural environment.


§  Dispensation of forest resources should only be done at fair market value.


§  We encourage everyone to use our public lands in a respectful and sustainable manner.



Comments on USFS Management


(a)    There should be a readily-available timetable and annual monitoring plan for USFS to follow, and for accountability on specific projects.

(b)   There should be emphasis on application of best science, importance of input by scientific professionals (notably the Rocky Mountain Forest Research Station, SD state agencies, US Fish and Wildlife Service, and EPA), need for plant and animal surveys and consistent application of  research studies.  The USFS must address science that points towards conclusions other than those by which they have elected to manage.

(c)    There should be greater use of science-based scenario modeling for analyzing proposed actions/alternatives.

(d)   For projects, multiple alternatives must be proposed “in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public”  (S1502.14 NEPA).


Law Enforcement

Law Enforcement Officer (LEO) staffing must be adequate for effective enforcement.  Volunteers are no substitute for full time LEO’s.  Forest Protection Officers (FPO) may be useful as long as employees are committed to this role.  The USFS should establish a TIPS program.


Botanical areas and RNA areas

(a)    Botanical areas are set aside by the USFS because of special plant species and ecosystems. Additional areas should be actively sought.  The USFS must place highest priority on protection of botanical areas from impacts of motorized recreation, grazing and logging.

(b)   Fens should be inventoried and monitored in order to fully comply with the requirements of the Forest Plan.

(c)    Non-vascular plants should be surveyed.


Comments on Major Threats

The USFS has identified 4 major threats to the national forests: Loss of Open Space, Fire and Fuels, Unmanaged Recreation, and Invasive Species.


Loss of Open Space

Roadless Areas: 

(a)    In the BHNF, the amount of area that is wilderness and open space (13,426 acres equivalent to 1.1% of the BHNF)  is far below the average for other Region 2 forests (21.7%).  We need to protect and increase these areas which are typical of natural ecosystems.

(b)   The Norbeck Society’s proposal to establish and preserve certain non-motorized, “walk-in” areas, absent of motorized trails, must be constantly emphasized.


Habitat : 

(a)    There should be botanical diversity, manifested in more meadows, aspen, spruce, oak, and old growth for preservation of plants and wildlife.  This would help the USFS to meet their objectives regarding mountain pine beetles and fire.

(b)   Fragmentation caused by a myriad of actions, such as construction of roads, logging, grazing, and development has negative impacts on habitat and the plants and animals that depend on it.



(a)    Support efforts to establish or expand wilderness areas.

(b)   Avoid any treatments within wilderness, but establish buffers outside of wilderness to protect against wildfire spread and mountain pine beetle spread.


Fire and Fuels

Fire risk:

Fire risk has been increased by “tree farm” management practices of maximizing tree growth.  The resulting dense stands are most susceptible to crown fires.  Fire risk would be minimized by establishing a landscape similar to that which existed prior to 1875 – e.g. mosaic of  diverse habitats, including clearings, forest stands of pine, hardwoods, etc


Mountain Pine Beetles:

Mountain pine beetles are native to the Black Hills, and “infestations” are the product of 110 years of “tree farm” management practices.  We encourage management with prescribed burns and logging to establish habitat diversity of clearings, pine forest, pine savannah, and hardwoods.


Unmanaged Recreation

Roads/travel management. 

(a)    Oppose construction of new roads and motorized trails, and discourage reconstruction of old roads. 

(b)   Suggest alternative treatments in areas that would require roads (especially new/reconstructed) for timber sales and other treatments. 

(c)    Close and obliterate roads after treatments, using gates with pedestrian access.



(a)    Minimize impacts of project activities in vicinity of hiking and horse trails.

(b)   Maintain, enhance, and add non-motorized trails using forest resources.


Invasive Species

Invasive species: 

Minimize and mitigate invasive species resulting from motorized activities and project timber sales.


External Factors

Global Climate Change :

The potential influence of climate change should be addressed in project planning.



Other Issues

Timber Harvesting:

 Past and current management has created conditions that put the entire forest at high risk for fire and bugs.  Additionally, the average ‘treatment’ plan compromises watersheds and habitat as well. For timber-related projects, we would like to see more than just emphasis on timber sales. For example, we 

(a)  Support establishment of meadows and clearings among diverse forest landscape.

(b)  Oppose overuse of revegetation methods (replanting and scarification) to reestablish trees for future sales.

(c)  Advocate ‘logging lite’ policies which would require tracks instead of tires on skidders, suspending the lead end of logs, and chipping slash to the extent possible.

(d)  Suggest elimination of subsidies to the timber industry.

(e)  Suggest that the USFS should seriously address ‘Landscape Restoration’, and move towards a more-natural landscape similar to that that existed at the time of Custer’s expeditions in the Black Hills.



We suggest that

(a) Grazing should not exceed forage capacities.

(b) Riparian areas should be protected from stream bank degradation and plant and habitat destruction.

(c) Surface and ground water resources should be protected from contamination.

(d) The USFS must enforce grazing standards.


Water Resources:

“A broad-scale assessment should be completed to determine the polluted acres and specific locations of sites capable of being restored to a riparian …….community (p.19, FY 2006 BHNF Monitoring and Evaluation Report).