Appendix D Mountain Pine Beetle Response Project Insect and Disease Determination Letters 

APPENDIX D 

Insect and Disease Determination Letters 

Appendix D Mountain Pine Beetle Response Project Insect and Disease Determination Letters D - 1 

APPENDIX D – Insect and Disease Determination Letters 

Forest 

Service 

Black Hills National Forest 

Supervisor’s Office 

1019 N. 5th Street 

Custer SD 57730-8214 

Tel. 605/673-9200 

FAX 605/673-9350

File Code: 1950 Date: August 11, 2011 

Subject: Determination of an Insect Epidemic in the MPB Response Project 

To: Dennis Jaeger, Deputy Forest Supervisor 

 

 

The mountain pine beetle (Dendroctonus ponderosae) is the number one insect killer of pines 

throughout the west. It is a native species and attacks ponderosa pine in the Black Hills. The last 10 

years have seen significant tree mortality caused by the mountain pine beetle throughout the Black 

Hills. We are at a time when large groups of trees are being killed across all areas of the forest on a 

yearly basis. Much of the mortality is occurring where epidemics are spreading to surrounding areas, 

but there are new, larger pockets showing up in areas that have not had significant mortality to date. 

Ground observations and aerial survey detection over the past year indicate new and rapidly growing 

beetle pockets in areas that had largely been beetle free. Information presented in Mountain Pine 

Beetle Conditions Across the Black Hills NF, prepared by Kurt Allen, Entomologist, Rapid City 

Service Center, specifically addressed the MPB Response Project. Data presented in this report 

concludes that the project area is experiencing widespread beetle mortality and brood sampling 

suggests that mortality will continue to increase. 

Although we have had a beetle epidemic occurring for 10 or more years, in 2010 the acreage affected 

by the beetle doubled over 2009, based on aerial survey. There were about 12,000 acres affected in 

2010 that had not been mapped as having any beetle mortality over the previous 14 years. Both of 

these trends indicate that there is still an increasing and spreading beetle epidemic occurring across the 

forest. 

There are some areas that have little or no beetle activity at this time and others with very high beetle 

mortality. The numbers indicate that tree mortality is increasing. During outbreaks, periods of higher 

than normal beetle activity, stand mortality can easily reach 50% and often go higher. During this 

outbreak of mountain pine beetle we have seen stands sustain better than 80% tree mortality. Most of 

the mortality is in trees that are greater than 7 inches in diameter, with lesser amounts in small trees. 

Mortality is usually concentrated in stands where tree density is highest, typically over 120 square 

feet per acre of basal area. However, once beetle populations have built to epidemic levels, any 

stands containing pine can have mortality. 

The only effective long-term strategy to minimize beetle caused mortality is controlling stand 

conditions through silvicultural means over large landscapes and monitoring areas of beetle buildup 

(USDA Forest Service, Forest Health Evaluation RCSC-03-11, February 2011). 
Appendix D Mountain Pine Beetle Response Project Insect and Disease Determination Letters D - 2 

Given the information referenced above, I conclude that there is a mountain pine beetle epidemic in 

the MPB Response Project area that meets Section 102(a)(4) of HFRA. I believe that the continued 

spread of this epidemic includes: Increased tree mortality across the landscape; further accumulation 

of hazardous fuels and increased potential for severe large-scale wildfires threatening the values of 

the wildland urban interface within and beyond; major changes in the scenery; and alteration of 

wildlife habitat. 

Therefore, I support using the authority provided in the Healthy Forests Restoration Act to address 

this epidemic in the Mountain Pine Beetle Response Project. 

/s/ Craig Bobzien 

CRAIG BOBZIEN 

Forest Supervisor 

Forest 

Service 

Black Hills National Forest 

Supervisor’s Office 

1019 N. 5th Street 

Custer SD 57730-8214 

Tel. 605/673-9200 

FAX 605/673-9350

File Code: 1950 Date: August 2, 2011 

Subject: Authorized Hazardous Fuel Reduction Projects per HFRA 

To: Mountain Pine Beetle Response Project ID Team 

 

 

The following describes the conditions related to the Mountain Pine Beetle (MPB) Response Project 

which is proposed to implement qualified “Authorized Hazardous Fuel Reduction Projects” pursuant to 

the Healthy Forests Restoration Act of 2003, Title I. The Healthy Forests Initiative and Healthy Forests 

Restoration Act Interim Field Guide provides a Decision Diagram key to help evaluate proposals such as 

the MPB Response Project to determine whether a project can qualify under HFRA authority. 

The verbal ‘walk-through’ (below) of the decision diagram in the Interim Field Guide, may be easier to 

work through by following along with the flow diagram steps displayed in that document (see Interim 

Field Guide reference and decision diagram attachment). The MPB Response project qualifies as an 

“authorized” under HFRA. 

Decision Diagram 1: Using Healthy Forests Initiative CE and Healthy Forests Restoration Act 

Authorities to Evaluate Project Proposals. 

Is the proposed action: 

• Outside designated wilderness? Yes, there is no wilderness in MPB Response Project.
Appendix D Mountain Pine Beetle Response Project Insect and Disease Determination Letters D - 3 

• Collaborative as described in the Implementation Plan? Yes. The Implementation Plan (see 

Reference below) spells out a collaborative framework that has a three-tiered organization 

structure - Local Level; State/Regional and Tribal Level; and National Level. The MPB 

Response Project public involvement process represents a comprehensive participatory 

collaborative effort at the Local Level as set forth in the Implementation Plan. A description of 

this effort will be summarized in the MPB Response Project EIS, Chapter 1 Public Involvement 

and Collaboration Section and Appendix A. 

If Yes to both questions above, go to: 

Is the project’s objective to protect communities, watersheds, T& E species, or natural 

resources by treating hazardous fuels? No, the focus of the MPB Response Project is also to 

reduce the spread and impacts of the existing MPB epidemic, protect local communities and 

resources from large scale wildfire, and move towards achieving desired land and resource conditions 

as provided by the Forest Plan. 

If No to this question above, go to: 

Is the project on NFS or BLM land? Yes, 

If Yes to this question, go to: 

Consider using HFRA authorities. Go to decision diagram 2. 

Decision Diagram 2: Determining Whether a Project Meets the Definition of “Authorized” or 

“Covered” by the Healthy Forests Restoration Act. 

Insect and Disease Test 

Is the project in an area of blow down, wind throw, or damage by ice storms? No, see discussion 

above and the proposed action calls for reducing the threat of mountain pine beetle. 

If No to this question, go to: 

Is the project in an area with an insect or disease epidemic? Yes, Information presented by the 

Rapid City Service Center, ‘Aerial overview detection survey in 2010, Black Hills of South Dakota 

and Wyoming’, RMSC-03-11’ documents the existence of an expanding epidemic. 

If Yes to this question, go to: 

Is there a significant risk to ecosystem components or the forest or range resource? Yes, There 

are a number of significant consequences to a beetle epidemic of this magnitude. Large scale loss over 

an area this size will certainly have a negative effect on timber, wildlife, and people (see ‘Aerial 

overview detection survey in 2010, Black Hills of South Dakota and Wyoming’, RMSC-03-11). 

If Yes to this question, go to: 

Qualifies as an “authorized” hazardous-fuel reduction project under HFRA 
Appendix D Mountain Pine Beetle Response Project Insect and Disease Determination Letters D - 4 

Given the results evident from the decision diagram exercise presented above, information presented 

from RCSC, and having reviewed the HFRA statutory guidance and associated documentation, I have 

directed the MPB Response Project ID Team to proceed with development of proposed projects that are 

“authorized” project[s]. Furthermore, having reviewed the projects proposed and developed, I have 

concluded that these projects individually are “covered project(s)”. Thus the cumulative array of 

projects proposed, that make up the MPB Response Project, permit me to declare that this Project is an 

“authorized hazardous fuel reduction project” pursuant to the HFRA, Title I, Sec. 101(2) and 102(a)(4). 

If you have any questions, please contact MPB Response Project Team Leader Katie Van-Alstyne at 

(605) 716-2067. 

/s/ Craig Bobzien 

CRAIG BOBZIEN 

Forest Supervisor 

Attachments: 

• Decision Diagram from the Interim Field Guide

References: 

• A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the 

Environment: 10-Year Comprehensive Strategy Implementation Plan, May 2002. 

• Healthy Forests Restoration Act (HFRA) of 2003, (P.L. 108-148). 

• The Healthy Forests Initiative and Healthy Forests Restoration Act - Interim Field Guide, 

USDA FS, USDI BLM, FS-799, February 2004.