United States 

Department of 

Agriculture 

Forest 

Service 

July 2011 

Environmental 

Assessment 

Cold Springs Project 

Northern Hills Ranger District, Black Hills National Forest 

Lawrence County, South Dakota 
For More Information Contact: 

Jackie Groce 

Natural Resource Planner 

2014 North Main Street 

Spearfish, SD 57783 

Phone No. 605-642-4622 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the 

basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, 

parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part 

of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all 

programs.) Persons with disabilities who require alternative means for communication of program information 

(Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and 

TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 

Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 

(TDD). USDA is an equal opportunity provider and employer. 
Environmental Assessment 

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Figure 1. Cold Springs Project vicinity map 
Cold Springs Project 

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Environmental Assessment 

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Table of Contents 

Introduction ...................................................................................................................................................1

Document Structure ..................................................................................................................................1

Background ...............................................................................................................................................1

Management Direction ..........................................................................................................................1

Mountain Pine Beetles ...........................................................................................................................2

Healthy Forests Restoration Act ............................................................................................................2

Purpose and Need for Action ........................................................................................................................3

Modified Proposed Action ........................................................................................................................4

Decision Framework .................................................................................................................................4

Public Involvement and Scoping ..............................................................................................................4

Issues .........................................................................................................................................................5

Alternatives ...................................................................................................................................................9

Alternatives Considered in Detail .............................................................................................................9

Alternative A – No Action ....................................................................................................................9

Alternative B – Modified Proposed Action ...........................................................................................9

Alternatives Considered but Eliminated from Detailed Study ................................................................ 17

No Road Actions ................................................................................................................................. 17

Further Reduce Stocking Levels ......................................................................................................... 17

Expand the Project Boundary .............................................................................................................. 18

Reestablish Ponderosa Pine stands ...................................................................................................... 18

Project Design Criteria ............................................................................................................................ 18

Project Monitoring .................................................................................................................................. 29

Comparison of Alternatives .................................................................................................................... 29

Environmental Consequences ..................................................................................................................... 32

Introduction ............................................................................................................................................. 32

Cumulative Effects .............................................................................................................................. 32

Forest Resources ..................................................................................................................................... 32

Introduction ......................................................................................................................................... 32

No-Action Alternative ......................................................................................................................... 33

Modified Proposed Action Alternative ............................................................................................... 42

Summary and Comparison .................................................................................................................. 51

Fire and Fuels .......................................................................................................................................... 52

Introduction ......................................................................................................................................... 52

No-Action Alternative ......................................................................................................................... 54

Modified Proposed Action .................................................................................................................. 55

Summary and Comparison .................................................................................................................. 57

Wildlife ................................................................................................................................................... 58

Introduction ......................................................................................................................................... 58

Wildlife Habitat ................................................................................................................................... 59

Threatened and Endangered Species ................................................................................................... 64

Region 2 Sensitive Species .................................................................................................................. 64

Management Indicator Species ............................................................................................................ 67

Species of Local Concern .................................................................................................................... 69

Migratory Birds ................................................................................................................................... 71

Fisheries .................................................................................................................................................. 72

Introduction ......................................................................................................................................... 72

No-Action Alternative ......................................................................................................................... 72

Modified Proposed Action ................................................................................................................... 73
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Summary and Comparison .................................................................................................................. 73

Botany ..................................................................................................................................................... 73

Introduction ......................................................................................................................................... 73

No-Action Alternative ........................................................................................................................ 75

Modified Proposed Action .................................................................................................................. 75

Summary and Comparison .................................................................................................................. 80

Hydrology and Soils ............................................................................................................................... 82

Introduction ......................................................................................................................................... 82

No-Action Alternative ........................................................................................................................ 83

Modified Proposed Action .................................................................................................................. 84

Summary and Comparison .................................................................................................................. 91

Air Quality .............................................................................................................................................. 91

Introduction ......................................................................................................................................... 91

No-Action Alternative ........................................................................................................................ 91

Modified Proposed Action .................................................................................................................. 92

Summary and Comparison .................................................................................................................. 92

Recreation ............................................................................................................................................... 93

Introduction ......................................................................................................................................... 93

No-Action Alternative ........................................................................................................................ 93

Modified Proposed Action .................................................................................................................. 94

Summary and Comparison .................................................................................................................. 95

Scenery ................................................................................................................................................... 95

Introduction ......................................................................................................................................... 95

No-Action Alternative ........................................................................................................................ 98

Modified Proposed Action .................................................................................................................. 98

Summary and Comparison ................................................................................................................ 106

Heritage Resources ............................................................................................................................... 106

Introduction ....................................................................................................................................... 106

No-Action Alternative ....................................................................................................................... 107

Modified Proposed Action ................................................................................................................ 107

Summary and Comparison ................................................................................................................ 108

Consultation and Coordination ................................................................................................................. 110

Agencies and Persons Consulted .......................................................................................................... 110

Interdisciplinary Team Members: ..................................................................................................... 110

Federal, State, and Local Agencies: .................................................................................................. 110

Tribes: ............................................................................................................................................... 111

Others: ............................................................................................................................................... 112

References ............................................................................................................................................ 113

Introduction, Purpose and Need, Alternatives .................................................................................. 113

Forest Resources ............................................................................................................................... 114

Fire and Fuels .................................................................................................................................... 117

Wildlife ............................................................................................................................................. 118

Fisheries ............................................................................................................................................ 120

Botany ............................................................................................................................................... 120

Hydrology and Soils ......................................................................................................................... 122

Air Quality ........................................................................................................................................ 123

Recreation ......................................................................................................................................... 123

Scenery .............................................................................................................................................. 123

Heritage ............................................................................................................................................. 124
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List of Tables 

Table 1. Proposed vegetation and fuel treatments ....................................................................................... 11

Table 2. Proposed road management activities ........................................................................................... 12

Table 3. Project design criteria .................................................................................................................... 19

Table 4. Comparison of alternatives ............................................................................................................ 30

Table 5. Cold Springs pine structural stages existing condition for MA 4.1 ............................................... 34

Table 6. Cold Springs pine structural stages existing condition for MA 5.1 ............................................... 35

Table 7. Structural stage 4 with very large tree size .................................................................................... 35

Table 8. Example of overstocked stands under the no-action alternative ................................................... 36

Table 9. Structural stages for MA 4.1 across the cumulative effects area under the no-action alternative . 39

Table 10. Structural stages for MA 5.1 across the cumulative effects area under the no-action alternative

 ............................................................................................................................................................. 40

Table 11. Comparison of percentage of project area and cumulative effects area stocking levels in square 

feet of basal area .................................................................................................................................. 41

Table 12. Insect risk ratings for ponderosa pine (in acres) under the proposed action ............................... 43

Table 13. Cold Springs pine structural stages for MA 4.1 under the proposed action ................................ 45

Table 14. Cold Springs pine structural stages for MA 5.1 under the proposed action ................................ 45

Table 15. Structural stage 4 with very large tree size under the proposed action ....................................... 47

Table 16. Example of overstocked stands under the proposed action alternative (basal area) .................... 47

Table 17. Structural stages for MA 4.1 across the cumulative effects area under the proposed action 

alternative ............................................................................................................................................ 49

Table 18. Structural stages for MA 5.1 across the cumulative effects area under the proposed action 

alternative ............................................................................................................................................ 50

Table 19. Comparison of no-action and proposed action stocking levels across the cumulative effects area 

(in acres and percentages) ................................................................................................................... 51

Table 20. Insect risk ratings for ponderosa pine (in acres) under the proposed action ............................... 51

Table 21. Existing project area fire hazard rating on National Forest System lands ................................... 54

Table 22. Existing project area WUI fire hazard ratings on National Forest System lands ........................ 54

Table 23. Post-treatment fire hazard ratings for the project area ................................................................ 57

Table 24. Post-treatment fire hazard ratings for WUI ................................................................................. 57

Table 25. Comparison of project area National Forest System land hazard ratings by alternative ............. 58

Table 26. Comparison of project area National Forest System land hazard ratings by alternatives for WUI

 ............................................................................................................................................................. 58

Table 27. No-action alternative - direct and indirect effects to habitat ....................................................... 59

Table 28. Modified proposed action - direct and indirect effects to habitat (A: no action, B: modified 

proposed action) .................................................................................................................................. 61

Table 29. Summary of effects on region 2 sensitive wildlife and fish species by alternative (A: no action; 

B: modified proposed action) .............................................................................................................. 65

Table 30. Summary of effects on management indicator species by alternative (A: no action, B: modified 

proposed action) .................................................................................................................................. 68

Table 31. Summary of effects on wildlife species of local concern by alternative (A: no action, B: 

modified proposed action) ................................................................................................................... 69

Table 32. Summary of effect on migratory birds by alternative (A: no action, B: modified proposed 

action) .................................................................................................................................................. 72

Table 33. Habitat generalizations ................................................................................................................ 76

Table 34. Summary of effects – region 2 (R2) sensitive and Black Hills species of local concern (SOLC) 

plants (MII = May impact individuals, but not likely to result in a loss of viability on the planning 

area, nor cause a trend toward Federal listing.) ................................................................................... 81

Table 35. Cold Springs Project affected watersheds ................................................................................... 82

Table 36. Detrimental soil disturbance ratios for project area treatment types ........................................... 85
Cold Springs Project 

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Table 37.Estimated sediment delivery to road crossings by alternative ..................................................... 87

Table 38. Estimated volume and risk of sediment delivery through the WIZ as a result of implementing 

the modified proposed action. Erosion and sedimentation estimates are based on the WEPP FuME 

model (Elliot et al. 1999). ................................................................................................................... 87

Table 39. Equivalent clearcut by watershed. Note: the estimated threshold value for the affected 

subwatersheds is 15 percent equivalent clearcut area (ECA). ............................................................ 91

Table 40. Acres of proposed vegetation treatments in each scenic integrity objective for the modified 

proposed action ................................................................................................................................. 100

List of Figures 

Figure 1. Cold Springs Project vicinity map .................................................................................................. i

Figure 2. Cold Springs ponderosa pine age class distribution .................................................................... 36

Figure 3. Locations of mountain pine beetle infestations since 2008 within the cumulative effects area for 

Cold Springs........................................................................................................................................ 38

Figure 4. Cold Springs cumulative effects area age class distribution as compared to the project area ..... 41

Figure 5. Proposed action insect risk rating for Cold Springs pine stands as compared to the current 

condition ............................................................................................................................................. 43

Figure 6. Proposed action structural stages for Cold Springs as compared to the current condition and the 

forestwide objectives .......................................................................................................................... 46

Figure 7. Cold Springs Project proposed commercial treatments and scenic integrity objectives map ...... 97

List of Appendices 

Appendix A: Modified Proposed Action Unit Silviculture and Fuel Treatments 

Appendix B: Scoping Comments and Comment Disposition 

Appendix C: Past, Present and Reasonably Foreseeable Management Activities 

Appendix D: Silviculture Findings of Compliance with Laws, Regulations, and Policy 

Appendix E: Silvicultural Stand Diagnosis—No Treatment Rationale 

Appendix F: Maps
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Introduction 

Document Structure 

The Forest Service has prepared this Environmental Assessment in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This 

Environmental Assessment discloses the direct, indirect, and cumulative environmental impacts 

that would result from the modified proposed action and no-action alternatives. The document is 

organized into the following parts: 

 Purpose and Need: This section includes information on the history of the project, the 

purpose and need for the project, and the proposal for achieving that purpose and need. 

This section also details how the Forest Service informed the public of the proposal and 

how the public responded. 

 Alternatives, including the Modified Proposed Action: This section provides a more 

detailed description of the agency’s modified proposed action. This discussion also 

includes project design features developed to reduce impacts or insure project compliance 

with the Black Hills Forest Plan (forest plan) or laws and regulations. Finally, this section 

provides a summary table that compares the environmental consequences associated with 

the modified proposed action and no-action alternatives. 

 Environmental Consequences: This section describes the environmental effects of 

implementing the modified proposed action and no-action alternatives. The effects of the 

no-action alternative provide a baseline for evaluating and comparing the modified 

proposed action. 

 Agencies and Persons Consulted: This section provides a list of preparers and agencies 

consulted during the development of the Cold Springs Project Environmental 

Assessment. 

 Appendices: The appendices provide more detailed information to support the analyses 

presented in the environmental assessment. 

Additional documentation, including more detailed analyses of project-area resources, may be 

found in the project record located at the Northern Hills Ranger District in Spearfish, South 

Dakota. 

Background 

The Cold Springs project area in the Black Hills National Forest encompasses approximately 

12,300 acres of National Forest System lands and 1,700 acres of private lands on the 

southwestern corner of the Northern Hills Ranger District in the O’Neil Pass vicinity. The 12,300 

acres of National Forest System lands include approximately 11,800 acres with forest cover. 

Ponderosa pine forest covers approximately 83 percent of the area. 

Management Direction 

The Black Hills National Forest Land and Resource Management Plan, usually called the “forest 

plan,” provides guidance for all resource management activities on the Black Hills National 

Forest. It provides overall forest management goals and objectives, standards and guidelines, and 

management area-specific goals, objectives, standards, and guidelines. The forest plan, as 
Cold Springs Project 

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amended, supported by the final environmental impact statement (FEIS) for the revision and the 

Phase II Amendment (USDA Forest Service 2005a, 2005b, 2006), is the Forest programmatic 

document required by the rules implementing the Forest and Rangeland Renewable Resources 

Act of 1974 as amended by the National Forest Management Act of 1976 . 

Project area National Forest System lands include two forest plan management areas (MA): 4.1, 

Limited Motorized Use and Forest Products Emphasis; and 5.1, Resource Production Emphasis. 

Management area 4.1 is managed for non-motorized recreation, while providing for timber 

production, forage production, visual quality, and a diversity of wildlife. Management area 5.1 is 

managed for wood products, water yield, and forage production, while providing other 

commercial products, visual quality, diversity of wildlife, and a variety of goods and services. 

Mountain Pine Beetles 

Mountain pine beetles, Dendroctonus ponderosae, are infesting project area pine stands. The 

mountain pine beetle is the most aggressive and destructive insect affecting pines in western 

North America and ponderosa pine trees are a primary host (USDA Forest Service 2000, Allen 

2010). The beetle is a native insect that is always present in pine forests. At endemic levels, 

beetles survive in stressed or weakened trees. When favorable conditions exist, populations can 

quickly increase to epidemic proportions. At such times, apparently, healthy pines are attacked 

and frequently killed. Food availability, in the form of thick phloem often found in large trees, is 

most directly associated with the development of beetle epidemics. Beetle populations can build 

and spread relatively quickly. During an epidemic, large group killing often occurs over a 

widespread area of mature and younger overstocked stands. 

In general, the mountain pine beetle prefers stands of dense, large-diameter mature and 

overmature pine. Extensive areas of the preferred habitat are at greater risk of large-scale 

epidemic, given the presence of beetle population, than forested areas that include a mixture of 

age classes and tree species. 

Stands with the highest risk for mountain pine beetle-caused losses are generally single-storied 

with most (75 percent) of the stems in the 7- to 13-inch diameter at breast height (d.b.h.) range 

and stocking above 120 square feet of basal area (Allen 2010). Stands with the lowest risk are 

multi-storied with an average diameter less than 6 inches and less than 80 square feet of basal 

area (USDA Forest Service 2000). Recent research indicates the lower the residual stocking, the 

greater the reduction in mountain pine beetle-caused mortality, in even- and uneven-aged stands 

(Schmid et al. 2007, Negron et al. 2008). 

Healthy Forests Restoration Act 

The Cold Springs Project has been developed under the authority of the Healthy Forests 

Restoration Act. The Black Hills National Forest Supervisor, with the assistance of Rocky 

Mountain Region Forest Health Management staff, has determined that epidemic insect 

conditions exist in the Cold Springs project area and vicinity (Bobzien 2010). Forest conditions in 

the project area are susceptible to mountain pine beetle infestation and corresponding mortality. 

Mountain pine beetle-caused mortality poses a threat to management area goals for wood-fiber 

production, timber products, and wildlife habitat. The Cold Springs Project qualifies for 

expedited vegetation management under Section 102(a)(4) of the Healthy Forests Restoration 

Act. 
Environmental Assessment 

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Purpose and Need for Action 

The purpose of this project is to decrease the risk of mountain pine beetle infestation in ponderosa 

pine stands within an area managed for timber production and wood products. This action is 

needed, because mountain pine beetle infestation is increasing within the project area and 

vicinity. Aerial survey for mountain pine beetle-caused mortality in 2009 indicated approximately 

30 areas with mountain pine beetle-caused mortality. Field surveys in the autumn of 2010 indicate 

mountain pine beetle-caused mortality is spreading and most project area pine stands have some 

level of infestation, with stands averaging 11 percent overstory mortality (Allen 2010). The 

increase in infested trees, compared to those killed in 2009, indicates a growing infestation. A 

large portion of the project area ponderosa pine stands are susceptible to mountain pine beetlecaused losses and have conditions favorable to support an epidemic. Approximately 48 percent of 

project area ponderosa pine stands have a high risk of mountain pine beetle infestation, and 

another 19 percent are at moderate risk (USDA Forest Service 2010b). 

The forest plan includes direction to protect forest stands from insect and disease epidemics and 

minimize susceptibility to mountain pine beetle epidemics (USDA Forest Service 2006, p. II-46). 

Black Hills National Forest goals and objectives related to insects and disease: 

 Goal 10. Establish and maintain a mosaic of vegetation conditions to reduce occurrences 

of catastrophic fire, insect, and disease events, and facilitate insect and disease 

management and firefighting capability. 

 Objective 10-07. Where outbreaks of mountain pine beetle could present risks to 

management objectives for ponderosa pine, reduce acreage of ponderosa-pine stands that 

are in medium or high risk for infestation.

Forestwide standards and guidelines related to insects and disease: 

 Guideline 4201 a. Plan management activities with consideration for potential insect or 

disease outbreaks. Use integrated pest management strategies where insect or disease 

outbreaks may adversely affect management objectives. Utilize prevention vegetation 

management practices, including silvicultural treatments, to protect forest stands from 

insect and disease epidemics. 

 Standard 4201 b. During scheduled management activities, minimize susceptibility to 

mountain pine beetle epidemics by reducing average basal area to 70 or less in pine 

stands, except where denser stands are needed to meet other management objectives. 

 Standard 4201 c. Use the following insect-and-disease protection measures: Manage 

vegetation in and adjacent to high-use recreation areas to improve forest conditions, as 

needed to maintain or improve the desired recreation settings(s) or to conserve R2 

sensitive or species of local concern and snails. In and adjacent to developed recreation 

sites actively treat insect and diseases to reduce pest populations. 

 Standard 4201 d. Consider spatial array of stand conditions when planning harvests to 

reduce their potential for mountain pine beetle epidemics. For example, silvicultural 

treatments may be appropriate within or adjacent to dense mature stands. 

 Guideline 4205. Consider applying preventive silvicultural treatments or other integrated 

pest management strategies to National Forest System land adjoining other land 

ownerships to reduce the likelihood of insect and disease epidemics and spread. Plan 

suppression strategies to reduce mountain pine beetle populations in pine stands during 

epidemics. Prioritize according to values, risk and management objectives. Priority 

should be given to areas in which values to be protected exceed the cost of protection. 
Cold Springs Project 

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 Guideline 4206. Project plans should consider existing infestations of insects or disease 

within a project area. Activities should be designed to minimize the risks of spreading the 

infestation while still providing habitat for those wildlife species dependent upon the 

presence of insects and disease. 

Modified Proposed Action 

The modified proposed action includes vegetation treatments to reduce the risk of mountain pine 

beetle infestation, sanitation to reduce mountain pine beetle populations, road management 

activities associated with access for vegetation treatment and activity, and wildland fuel 

treatments. A variety of treatments and actions are proposed to reduce the risk of mountain pine 

beetle infestation in ponderosa pine stands. Treatments that reduce stocking and corresponding 

risk of attack are proposed across 4,904 acres. In addition to reduced stocking, proposed 

treatments would increase stand age class and species diversity, which reduces the amount of host 

material susceptible at any given time. 

Fuel treatments are proposed to reduce natural fuels and activity-generated slash. Proposed fuel 

treatments across 1,670 acres would break up continuous fuel concentrations and reduce fire 

hazard. 

Area roads would provide access for proposed vegetation management activities. Many of the 

roads needed for treatment access are already in place; however, some new National Forest 

System roads and temporary roads would be needed. Four miles of new system roads are 

proposed, approximately 8 miles of temporary road would be constructed, and 2 miles of nonsystem road would be converted to National Forest System road. Existing roads would require 

maintenance and reconstruction. Approximately 48 miles of road maintenance and reconstruction 

is proposed. All newly constructed roads and converted National Forest System roads would be 

closed to motorized vehicle traffic following completion of management activities. Reconstructed 

roads would remain a part of the National Forest System and their allowable use would be 

determined by the Black Hills National Forest Travel Management Plan. Road decommissioning 

would eliminate a 2-mile stretch of road located in a meadow bottom. A new system road, located 

on a forested, dry side-hill, would replace the existing road. 

The proposed action identified during scoping was updated to incorporate changes in response to 

an issue identified during scoping and to correct minor errors or interdisciplinary team concerns. 

More information regarding the modified proposed action, along with the modifications, and 

rationale for the changes, are discussed in the “Alternatives Considered in Detail” section of this 

document. 

Decision Framework 

The responsible official will decide whether to implement the modified proposed action or take 

no action after reviewing this environmental assessment and supporting documents, and 

considering all public input on this project. 

Public Involvement and Scoping 

Scoping is the process of obtaining public comments about proposed Federal actions to determine 

the range of issues to be addressed. We solicited comments on the proposed action from members 

of the public, other public agencies, tribal governments, adjacent property owners, interest 
Environmental Assessment 

5 

groups, and Forest Service specialists. We used various methods to request comments, including 

the following: 

 We mailed a scoping letter to over 220 interested parties, including property owners, 

tribal members, State and Federal agencies, and other organizations on January 18, 2011. 

This letter included a description of the project area, an overview of the planning process, 

a general explanation of the proposed actions, and an invitation to submit written 

comments. 

 We submitted a news release to the local news media on January 19, 2011. This release 

introduced the project to the public by providing a description of the project area and an 

explanation of the proposal. The release also solicited written public comment on the 

project. 

 The Rapid City Journal published a legal notice announcing the project on January 20, 

2011. 

 The Northern Hills Ranger District office held a public open house meeting on January 

26, 2011. Nine interested parties attended the meeting and met with Forest Service 

officials to view project area maps and discuss the proposed actions. Attendees were 

encouraged to submit comments or document their concerns associated with the proposed 

actions. 

 We posted the proposed action on the Forest’s web page. 

 We listed the project in the Black Hills National Forest, Northern Hills Ranger District 

Schedule of Proposed Actions in January 2011. 

Fourteen parties provided written feedback during the formal comment period. Many of the 

comments included statements of support for the project, observations about the data used to 

develop the proposed action, observations and thoughts about management approaches used on 

the Black Hills National Forest, and interpretations of management direction contained in the 

Black Hills National Forest Land and Resource Management Plan: 1997 Revision—Phase II 

Amendment (i.e., forest plan). The interdisciplinary team assigned to this project reviewed the 

comments and identified seven distinct issues, which are discussed in the next section. All 

comments received during the formal comment period and a discussion of how the 

interdisciplinary team used the comments can be found in Appendix B. 

Issues 

Per Forest Service Handbook 1909.15, chapter 10, issues “serve to highlight effects or unintended 

consequences that may occur from the proposed action” and are “best identified during scoping 

early in the process to help set the scope of the actions, alternatives, and effects to consider” 

(USDA Forest Service 2010c, p. 26). The interdisciplinary team and district ranger identified the 

following issues during project scoping. 

Issue 1—Habitat Fragmentation 

Issue Statement from Comments: The proposed action could cause habitat fragmentation. 

Strategic habitat corridors and habitat connectivity should be maintained while treating to reduce 

the risk of mountain pine beetle infestation. Trees infested with mountain pine beetle continue to 

provide habitat for many species even after they die and fall. Allow for some areas within the 

project area where endemic levels of mountain pine beetle can remain. 
Cold Springs Project 

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Discussion: The proposed action was designed to implement forest plan direction regarding 

management of plant and wildlife habitat. Project-level measures to conserve wildlife and plant 

habitat are evidenced in the design criteria applicable to the project and the stand-level treatment 

determinations that comprise the proposed action. Habitat for wildlife and plants, including 

habitat corridors for the pine marten (a region 2 sensitive species), would be retained under the 

modified proposed action. 

Even with implementation of the modified proposed action, endemic levels of mountain pine 

beetles would continue to persist in the project area; mountain pine beetles would not be 

eradicated. Pine stands within the project area have experienced approximately 11 percent 

mortality due to mountain pine beetles during the past 3 years. These dead trees would remain. 

Issue Disposition: This issue was dismissed from further consideration. The modified proposed 

action includes habitat conservation measures and follows forest plan direction regarding habitat 

management. Project analysis includes an assessment of the effects of proposed activities on plant 

and wildlife habitat. 

Issue 2—Efficacy of Thinning to Reduce Mountain Pine Beetle Risk 

Issue Statement from Comments: The proposed action relies on thinning activities to reduce the 

risk of mountain pine beetle infestation in the project area. There is no conclusive science that 

supports the notion that thinning reduces mountain pine beetle risk. 

Discussion: The Cold Springs Project tiers to the 1996 Revised Land and Resource Management 

Plan Final Environmental Impact Statement and the Black Hills National Forest Phase II 

Amendment: 1997 Land and Resource Management Plan Final Environmental Impact Statement. 

The analyses contained therein are grounded in science and conclude that management activities 

in ponderosa pine stands can affect the risk of attack by mountain pine beetle. Subsequent 

research that has taken place on the Black Hills National Forest indicates that partial cutting can 

minimize mountain pine beetle in ponderosa pine stands (Schmid, et al. 2007). Additional studies 

on the effectiveness of silviculture treatments are documented in The Effectiveness of Vegetation 

Management Practices for Prevention and Control of Bark Beetle Infestations in Coniferous 

Forests of the Western and Southern United States (Fettig et al. 2007). 

The Cold Springs proposed action is intended to implement direction contained in the forest plan. 

Forest plan goal 10 states that “the susceptibility of vegetation to stand-replacing fire and 

outbreaks of insect and disease pests will be reduced through vegetation management practices 

that promote vigorous, productive, resilient and diverse ecosystems” (forest plan, p. I-35). Forest 

plan objective 10-07 states that in areas where outbreaks of mountain pine beetle could present 

risks to management objectives for ponderosa pine, resource managers should reduce the acreage 

of ponderosa-pine stands that have a medium or high risk of infestation. 

Issue Disposition: This issue was dismissed from further consideration. The modified proposed 

action is based on forest plan direction and research. Project analysis includes an assessment of 

the effects of proposed activities on the risk of mountain pine beetle infestation within the project 

area. Furthermore, the analysis makes use of the best available science. 

Issue 3—Effects of the Road System 

Issue Statement from Comments: The proposed action contains too much road work (e.g., 

construction, conversion, reconstruction, and pre-use maintenance). There are too many roads in 
Environmental Assessment 

7 

the project area, and road use can lead to road damage, damage to riparian areas, the spread of 

noxious weeds, and soil erosion. 

Discussion: The road management activities in the modified proposed action are necessary to 

provide harvest access and to reduce or minimize resource damage. The use of roads for 

management activities is consistent with the goals and objectives outlined in the forest plan for 

management areas 4.1 and 5.1. The majority of the road work proposed is the reconstruction or 

maintenance of existing roads (48 miles). These activities would improve or reestablish drainage 

to reduce erosion. A transportation engineer and hydrologist have been involved in project 

development to assure roads are properly located, constructed, and maintained. The Cold Springs 

proposed action includes road decommissioning. A road currently located in a draw bottom would 

be relocated and moved out of the bottom to reduce road-related impacts. 

Issue Disposition: The project interdisciplinary team considered an alternative that did not 

include any of the road-related actions identified in the proposed action. See the “Alternatives 

Considered but Eliminated from Detailed Study” section for further discussion. 

Issue 4—Reducing Mountain Pine Beetle Risk 

Issue Statement from Comments: The scoping brochure indicates that the purpose of the Cold 

Springs Project is to decrease the risk of mountain pine beetle infestation in ponderosa pine 

stands within an area managed for timber production and wood products. The proposed action 

leaves a number of ponderosa pine stands untreated. The risk of infestation in these stands will 

not be reduced. Minimizing mountain pine beetle-caused mortality should be the primary 

objective in all stands. Stands lost to mountain pine beetle will not contribute to any management 

objective. 

Discussion: Based on this issue, the interdisciplinary team reviewed the ponderosa pine stands at 

medium or high risk of mountain pine beetle infestation that were not included for commercial 

treatment in the proposed action. The team identified six additional stands in which commercial 

treatment could be applied to reduce the risk of mountain pine beetle infestation. 

Issue Disposition: This issue was used to modify the proposed action. Discussion of the 

modifications is included in the “Alternatives” section. 

Issue 5—Optimal Stocking Levels 

Issue Statement from Comments: The proposed action will not maximize mountain pine beetle 

infestation risk reduction because it does not reduce residual stocking levels to 40 to 60 square 

feet of basal area. Stand stocking should be reduced to a residual stocking level of 40 to 60 square 

feet of basal area to provide maximum reduced risk of mountain pine beetle-caused losses. 

Discussion: Stand stocking at 40 to 60 square feet of basal area would result in the establishment 

of pine regeneration. Residual trees in this particular area would likely be subject to windthrow 

and breakage, and the stands would have considerably low stocking levels. Proposed treatments 

to 70 square feet of basal area (or less) would leave the stands stocked to provide suitable 

growing space for a healthy stand. The project area includes lands managed for forest wood-fiber 

production, and there will be periodic entries for timber harvest that can maintain stands stocked 

at levels suitable to maintain reduced risk of beetle infestation. 

The desired condition for long-term forest health includes a diversity of age classes across the 

project area. Thinning to low stocking levels across the landscape, compounded by the potential 
Cold Springs Project 

8 

for breakage and windthrow, would result in the establishment of pine regeneration across 31 

percent of the project area, which is not desired. 

Issue Disposition: The project interdisciplinary team considered an alternative that reduced 

stocking levels to 40 to 60 square feet of basal area. See the “Alternatives Considered but 

Eliminated from Detailed Study” section for further discussion. 

Issue 6—Project Area Boundary 

Issue Statement from Comments: Suitable habitat for mountain pine beetles and areas currently 

infested with mountain pine beetle exist just outside the project area to the south on the Hell 

Canyon Ranger District and to the north of State Highway 85. These areas are in need of 

treatment to reduce mountain pine beetle populations and to reduce the risk of additional 

infestation. The project area boundary should be expanded to include these areas. 

Discussion: The need for treatment in these areas is not disputed. However, expanding the project 

area boundary would require time for additional field work. In addition, it is likely that expanding 

the scope of the project in this way would require the interdisciplinary team to begin the NEPA 

planning process again. These activities would delay project implementation. Since mountain 

pine beetles reproduce and spread to new areas on an annual basis, it is important to keep the 

project on its current timeline so that implementation is not delayed. 

Issue Disposition: The project interdisciplinary team considered an alternative that increased the 

size of the project area. See the “Alternatives Considered but Eliminated from Detailed Study”

section for further discussion. 

Issue 7—Reestablishing Ponderosa Pine Stands 

Issue Statement from Comments: Seral ponderosa pine stands are in transition to spruce. There is 

abundant spruce regeneration within the understory of mature pines. Mountain pine beetles are 

now killing a large percentage of the remaining pine in these stands and converting them to 

spruce. Allowing pine stands to convert to spruce does not follow forest plan objective 200-01. To 

address this issue, all commercial-sized white spruce should be cut, masticated, and then burned 

to kill the submerchantable spruce. These treatments would reestablish pine as the dominant 

species. 

Discussion: The forest plan does not contain an objective numbered 200-01. An objective 

numbered 200-01 was included in the Phase II FEIS prepared in support of the forest plan (USDA 

Forest Service 2005a). This objective was adopted in the forest plan and numbered objective 239-

LVD. This objective indicates that land managers on the Forest should manage for 20,000 acres 

of spruce across the Forest using active management to achieve multiple-use objectives. 

As the discussion in the Phase II FEIS indicates, the objective is intended to favor hardwoods 

where spruce is encroaching upon hardwoods, but to favor spruce where spruce is encroaching 

into pine stands, “especially where it improves connectivity between spruce stands” (USDA 

Forest Service 2005a, p. III-25). In working to maintain at least 20,000 acres of spruce across the 

Forest, the Phase II FEIS recognized that there would be losses in spruce where hardwood 

conversion occurred or where spruce was removed to reduce fire hazard in close proximity to 

structures; however, that loss was expected to be balanced by gains due to succession in other 

areas (USDA Forest Service 2005a, p. III-27). 
Environmental Assessment 

9 

Stands that are white spruce, or mixed spruce and pine, have value for wildlife habitat and add to 

vegetative diversity in the project area. Treatments in selected seral ponderosa pine and white 

spruce stands were deferred to retain habitat for wildlife and plants. 

The project purpose and need is to decrease the risk of mountain pine beetle infestation in 

ponderosa pine stands within an area managed for timber production and wood products. 

Reestablishing pine as the dominant species in seral stands is not related to the purpose and need 

for the project and is not consistent with the intent of objective 239-LVD. 

Issue Disposition: The project interdisciplinary team considered an alternative to the proposed 

action that converts seral pine stands back to pine-dominated forest. See the “Alternatives 

Considered but Eliminated from Detailed Study” section for further discussion. 

Alternatives 

This section provides a detailed description of the no-action alternative (alternative A) and the 

modified proposed action (alternative B). This section also presents the alternatives in 

comparative form, providing a clear basis for choice among options by the decision maker and 

the public. Alternatives considered by the interdisciplinary team and the decision maker but 

eliminated from detailed study are also discussed. 

All figures are approximate and may vary due to irregular stand structure, small inclusions of 

inoperable ground, application of design criteria, or other factors. Actual figures may increase or 

decrease during on-the-ground preparation of the project. 

Alternatives Considered in Detail 

Alternative A – No Action 

Under the no-action alternative, none of the elements of the proposed action would take place in 

the Cold Springs project area. There would be no actions to respond to the purpose and need for 

action, or the issues brought forth during scoping. Vegetation management would not take place 

unless authorized by other decisions. Vegetation structure would change over time through 

natural growth, mortality, and events such as wildfires, storms, and insect outbreaks. The existing 

road network would persist until modified by future decisions. Activities authorized by previous 

decisions such as ongoing timber sales and post-sale projects would continue. Routine activities 

not tied to this project such as scheduled road maintenance, treatment of noxious weeds, livestock 

grazing, and fire suppression would also continue. 

Alternative B – Modified Proposed Action 

The proposed action identified during scoping was updated to incorporate changes in response to 

an issue identified during scoping and to correct minor errors or interdisciplinary team concerns. 

The interdisciplinary team reviewed the project to assess the potential to include additional 

treatments to further reduce the risk of mountain pine beetle infestation. The team focused its 

review on ponderosa pine stands with medium or high risk of mountain pine beetle infestation for 

which no commercial treatment was identified in the proposed action. In summary, nearly 1,900 

acres of ponderosa pine in the high or medium risk categories have less than 60 square feet of 

basal area of commercial pine. Applying a commercial treatment in these stands would not 

substantially reduce the risk of mountain pine beetle infestation and there is no need for change in 
Cold Springs Project 

10 

these stands. The project’s sanitation harvest provision could be applied in the event that 

mountain pine beetles are detected within the stands. This accounts for nearly 75 percent of the 

pine acreage that has a medium or high insect risk rating and that was not proposed for 

commercial treatment in the initial proposed action. 

The remaining 25 percent of the untreated pine was further reviewed. Nearly 15 percent of the 

acreage (approximately 350 acres) is steep or inoperable ground. About 4 percent of the acreage 

(approximately 112 acres) was not proposed for commercial treatment to comply with forest plan 

direction regarding goshawk nest management. Less than 1 percent (approximately 14 acres) was 

not proposed for commercial treatment because of the presence of habitat that might support 

region 2 sensitive plant species or because they are very small or isolated pine stands. 

Six additional stands (approximately 121 acres) in which commercial treatment could be applied 

to reduce the risk of mountain pine beetle infestation were identified. Treating these stands would 

not require any new road construction. Because these treatments would further address the 

purpose and need identified for the project, they were incorporated into the project. 

The sanitation harvest provision that was part of the proposed action was adjusted to apply to any 

stand within the project area rather than limiting the provision to stands with a pine cover type. 

This allows for the potential to remove additional infested trees if needed. 

Minor modifications were made to correct errors in the proposed action. Initial field review 

showed the trees in one stand (071301-31) were paint marked, indicating they were in an existing 

timber sale. Further investigation indicated the stand was not part of any sale. The treatment 

identified for this stand was changed from precommercial thinning to commercial thinning 

followed by precommercial thinning. 

An existing unclassified road could be decommissioned to reduce the potential for unauthorized 

access to National Forest System road 209.3DC, a system road proposed for decommissioning 

under the proposed action. The road is not currently part of the district transportation system. 

Decommissioning unclassified road U100072 has been incorporated into the project. 

The modified proposed action includes vegetation treatments to reduce the risk of mountain pine 

beetle infestation, sanitation to reduce mountain pine beetle populations, road-management 

activities associated with access for vegetation treatment and activity, and wildland fuel 

treatments. A variety of treatments and actions are proposed to reduce the risk of mountain pine 

beetle infestation in ponderosa pine stands. Treatments that reduce stocking and corresponding 

risk of attack are proposed across 4,904 acres. In addition to reduced stocking, proposed 

treatments would increase stand age-class and species diversity, which reduces the amount of host 

material susceptible at any given time. Treatments are also proposed to decrease mountain pine 

beetle populations. Treatments are summarized in Table 1 and descriptions of the treatments 

follow. A list of treatment units is included Appendix A. Maps of the modified proposed action 

vegetation and fuel treatments are included in Appendix F. 

Fuel treatments are proposed to reduce natural fuels and activity-generated slash. Proposed fuel 

treatments would break up continuous fuel concentrations and reduce fire hazard. 
Environmental Assessment 

11 

Table 1. Proposed vegetation and fuel treatments 

Commercial Vegetation Treatments Acres 

Aspen Release 83 

Commercial Thin 1,398 

Commercial Thin, 50 percent canopy cover 25 

Single-tree Selection 523 

Single-tree Selection, 50 percent canopy cover 108 

Shelterwood Preparation 531 

Shelterwood Preparation, 50 percent canopy cover 107 

Shelterwood Removal 357 

Shelterwood Establishment 1,290 

Total Commercial Treatment Area 4,424 

Noncommercial Vegetation Treatments Acres 

Aspen Release 242 

Aspen Release Following Commercial Treatment 247 

Precommercial Thin 155 

Precommercial Thin Following Commercial Treatment 1,060 

Precommercial Thin & Aspen Release Following Commercial Treatment 107 

Wildlife Timber Stand Improvement 83 

Wildlife Timber Stand Improvement Following Commercial Treatment 34 

Total Noncommercial Vegetation Treatment 1,9281

Fuel Treatments Acres 

Broadcast Burn 240 

Broadcast Burn Following Vegetation Treatment 657 

Pile and Burn Following Vegetation Treatment 279 

Slash, Pile and Burn Following Vegetation Treatment 494 

Total Fuel Treatment Area 1,6702

Sanitation 

Sanitation/Salvage and Noncommercial Sanitation Within Commercial Treatment Units3 4,424 

Sanitation/Salvage and Noncommercial Sanitation, Outside Treatment Units4 7,337 

Area roads would provide access for proposed vegetation management activities. Many of the 

roads needed for treatment access are already in place; however some new National Forest 

System roads and temporary roads would be needed. Existing roads would require maintenance 

and reconstruction. All newly constructed roads and converted National Forest System roads 

would be closed to motorized vehicle traffic following completion of management activities. 

Reconstructed roads would remain a part of the National Forest System and their allowable use 

would be determined by the Black Hills National Forest Travel Management Plan (USDA Forest 

Service 2010a). Temporary roads would be needed to provide log-truck access to suitable landing 

 

1

 Both commercial and noncommercial treatments are planned on 1,448 acres. 2

 Fuel treatments follow vegetation treatment on 1,430 acres. 

3

 The area of sanitation treatment would depend on the level of mountain pine beetle infestation; all 

treatment units (4,424 acres) have the potential for sanitation treatment. 4

 The area of sanitation treatment would depend on the level of mountain pine beetle infestation; all forest 

stands (11,761 acres) have the potential for sanitation treatment. 
Cold Springs Project 

12 

areas where trees are processed into logs. Proposed road management activities are summarized 

in Table 2. 

Table 2. Proposed road management activities 

Transportation Actions Miles 

New National Forest System Road Construction 4.0 

Non-system Road to System Road Conversion 2.4 

Temporary Road Construction 7.85

National Forest System Road Reconstruction/Pre-use Maintenance 48.1 

Forest System Road Decommissioning 2.3 

Total Miles of Transportation Activities 64.6 

Vegetation Treatments 

Sanitation and Salvage Harvest 

Sanitation treatments are considered to be preventative and are most effective before an epidemic 

starts. Populations of mountain pine beetles would be reduced by harvesting or treating infested 

trees. Infested trees of sawtimber size (9 inches diameter breast height (d.b.h.) and larger) could 

be salvaged. Salvage harvest of sawtimber-sized trees is preferred; infested trees would be cut and 

logs removed from the forest and processed at a sawmill. Processing the infested logs prior to 

adult mountain pine beetle emergence would kill the beetles. Infested trees, both sawtimber and 

less than sawtimber size, could also be treated in-place: felled, limbed, and bucked to short 

lengths, and part of the bark would be scarified or removed to dry out the wood, making it 

unsuitable habitat for the beetles. Infested trees of sawtimber size would be treated in-place where 

it is not practical to use salvage harvest. 

Sanitation and salvage treatments would occur within treatment units and throughout the project 

area at mountain pine beetle infestation locations. The most recent information available 

regarding beetle infestation (aerial survey, field reconnaissance) would be used to strategize and 

design sanitation and salvage treatments. 

Prior to implementation, resource specialists would review areas of sanitation and salvage 

treatment outside of harvest units to determine whether any special design criteria are needed to 

protect forest resources and ensure the proposals comply with forest plan direction. No new 

system roads would be constructed to access sanitation and salvage units. 

Commercial Thinning 

The stocking of pine-dominated stands would be reduced by cutting commercial-sized trees and 

removing the logs from the site. The best-formed, insect- and disease-free dominant overstory 

trees would be retained. Commercial thinning would reduce the stocking and decrease 

susceptibility to mountain pine beetle infestation. Reducing stand densities to 60 to 806

 square 

 

5

 Temporary road miles are approximate; the actual miles of temporary road would depend on the timber 

purchaser’s logging system. 

6

 Approximately 70 square feet of basal area would be about 90 12-inch-diameter trees on each acre, or 128 

10-inch-diameter trees. 
Environmental Assessment 

13 

feet of basal area7 generally provides the best compromise between maximizing growth rates, 

minimizing mountain pine beetle risk, and allowing sufficient time between harvest entries 

(USDA Forest Service 2000). 

Shelterwood Preparation 

Shelterwood preparation would decrease the stocking of dense, mature pine sawtimber stands. 

The intent of the harvest is to prepare the stand for a future shelterwood establishment cut. The 

preparation cut would open the overstory and allow the residual trees to establish windfirmness 

and cone baring crowns prior to an establishment cut. The best-formed, insect- and disease-free 

dominant overstory trees would be retained. After treatment, stand densities would be 60 to 80 

square feet of basal area, decreasing susceptibility to mountain pine beetle infestation. 

Shelterwood Establishment 

Shelterwood establishment cutting would initiate pine regeneration in mature stands. Stands 

would be cut to a relatively low stocking level (approximately 30 square feet of basal area8

), 

leaving the best overstory trees to serve as a seed source for a new stand. The low-stocked 

overstory would be at low risk to mountain pine beetle-caused mortality, and the new stand of 

trees would promote diversity across the project area. Increasing the mix of age classes reduces 

the amount of susceptible host forest. 

Shelterwood Removal 

Shelterwood removal would remove most overstory pine trees in stands that have been fully 

regenerated in the past with a shelterwood establishment cut. After most large overstory trees are 

removed, the stand that remains would generally be well stocked (300 or more stems per acre) 

with 6- to 20-foot conifers. This treatment completes the transition to a young stand, increasing 

the mix of age classes, and reduces the amount of susceptible host forest. 

Aspen Release 

Aspen release would maintain or encourage aspen growth by removing conifer competition. 

Maintaining or expanding aspen is desirable to provide a diversity of habitat. Increased diversity 

across the project area reduces the amount of host material for mountain pine beetles. Aspen 

exists in stands where it’s the predominant forest cover, and as a minor component of pine 

dominated stands. Where aspen is the predominant forest cover, all conifers would be removed. 

Where aspen occurs as a small group or inclusion within a pine stand, the conifers in close 

proximity to the aspen would be removed. Aspen release would be accomplished through 

commercial timber harvest and through post-sale, noncommercial cutting. 

Single-tree Selection 

Single-tree selection would decrease stocking in pine and mixed pine/spruce stands that have a 

multi-storied or uneven-aged structure. Trees would be cut in all diameter classes to achieve the 

desired stocking of approximately 70 square feet of basal area. Single-tree selection would 

maintain or promote an uneven-aged stand structure and diversity. 

Additional measures would be taken to increase stand diversity where management is primarily 

for wildlife habitat. There would be an increased focus on retaining mature trees approximately 

 

7

 Basal area: the cross-sectional area of a stand of trees measured at breast height. The area is generally 

expressed in terms of square feet per acre. 

8

 Approximately 30 square feet of basal area would be about 21 16-inch-diameter trees on each acre. 
Cold Springs Project 

14 

18 inches d.b.h. and larger. Mature overstory trees would be retained in irregularly spaced clumps 

featuring interlocking crowns. 

Precommercial Thinning 

Precommercial thinning would decrease stocking in stands composed of small-diameter stems, 

generally less than 9 inches d.b.h. Approximately 150 to 250 stems per acre of the best formed 

trees would remain. Cut trees would be lopped and scattered on site, or piled and burned. 

Wildlife Timber Stand Improvement 

The understory of stands with management emphasis on wildlife habitat would be thinned to a 

variable density. Understory trees exhibiting the best vigor and form would be retained and 

released from competition. Inferior and cull noncommercial pine less than 6 inches d.b.h. would 

be cut and slashed. 

Fuel Treatments 

Broadcast Prescribed Burning 

Forest stands and meadows would be burned with a low-intensity surface fire. The low-intensity 

burn would reduce natural and activity surface fuels, along with developing ladder fuels and 

conifer saplings. Broadcast burning of activity slash and natural fuels would enhance soil 

conditions by returning to the soil inorganic and organic chemicals found in the foliage and small 

woody material. Overstory tree mortality is not desired; however, some overstory trees may be 

killed due to the burn. Broadcast burns would require control lines, where forest litter is cleared 

down to mineral soil. Hand crews or small crawler tractors would construct control lines; or 

existing roads would serve as control lines. 

Pile and Burn 

Concentrations of surface and ladder fuels would be hand- or machine-piled and burned. This 

treatment would reduce and break up concentrations of activity and natural fuels. Piling and 

burning would also decrease fire hazard near structures. 

Fuel Slashing 

Small conifer trees in excess of those desired for a fully stocked stand and brush would be cut 

prior to piling and burning. This treatment would reduce ladder fuels. 

Road Management Activities 

New Road Construction 

Three new roads, approximately 4 miles, are proposed to be constructed where no route has 

previously been developed. The new roads are needed to provide harvest access, and there is a 

long-term, reoccurring need for the roads. New roads would be constructed to Forest Service 

specifications and would adhere to forest plan standards and guidelines, region 2 watershed 

conservation practices, and project-specific design criteria. 

Two new roads would be closed following the completion of management activities. The method 

of closure would be determined based on site conditions. The new road that replaces 209.3D 

would remain open to motorized vehicle use. 
Environmental Assessment 

15 

Non-system to System Road Conversion 

Approximately 2 miles of existing non-system roads would be added to the forest road system. 

The routes proposed for conversion are unclassified, user-created routes or routes that were 

National Forest System roads, but have since been decommissioned. The road template already 

exists. The route would be added to the National Forest System and improved as necessary to 

meet Forest Service specifications. These roads would also adhere to forest plan standards and 

guidelines, region 2 watershed conservation practices, and project-specific design criteria. These 

routes would be closed to motorized vehicle use following management activities. 

Reconstruction or Pre-use Maintenance of Existing Roads 

Reconstruction or pre-use maintenance is proposed for approximately 48 miles of existing 

National Forest System roads that need improvement prior to proposed vegetation and fuel 

management activities. Reconstruction is more intensive than pre-use maintenance and could 

include surface rock placement, improvement of drainage structures, and realignment. Pre-use 

maintenance involves blading the road surface to provide a smooth running surface, establishing 

proper drainage, reestablishing the road shoulder, and removing brush. 

Temporary Road Construction 

Temporary roads would be constructed to provide harvest access. Temporary roads are essentially 

a path cleared to allow logging equipment access. The temporary roads would be blocked and 

revegetated following use. 

Road Decommissioning 

A National Forest System road (road 209.3D) and an unclassified road (U100072) located in the 

upper portion of Clayton Draw would be decommissioned, and a new road would be constructed 

to replace road 209.3D. Road 209.3D is located in the bottom of a meadow, and proper drainage 

is not possible. Use of the road for log hauling could result in unacceptable erosion. The 

replacement road would be located to the east, outside of the meadow and in a location where 

proper drainage can be maintained. The new location would also allow timber harvest landings to 

be located in forest stands, outside of meadows. Motorized vehicle use of road 209.3D, 

authorized by the Black Hills National Forest Travel Management Plan Record of Decision 

(USDA Forest Service 2010a), would not change. 

Unclassified road U100072, which crosses National Forest System Road 209.3D, is not part of 

the forest transportation system and decommissioning would increase the effectiveness of road 

209.3D decommissioning. 

The existing roadbeds would be removed from the National Forest System and blocked to vehicle 

traffic, and vegetation would be reestablished. The intent of road decommissioning is to stop 

motorized vehicle traffic and return the roadbed to natural conditions to the extent practicable. 

Harvest System and Implementation 

Forest vegetation treatments would be accomplished primarily through commercial harvest and 

service contracts, including timber sale and stewardship contracts. Harvest operations would yield 

sawtimber and roundwood products. These products would contribute to Forest goals for wood 

products. Standard harvest operations in the Black Hills area include tree felling, removal, and 

processing with mechanized equipment. Harvested trees are usually transported from the stump to 

central landing areas adjacent to roads where they are limbed and processed into logs. Limbs and 

tops are usually piled for burning at the landing. Piled limbs and tops could also be hauled off site 
Cold Springs Project 

16 

if markets develop for biomass (chips). In some cases, limbs and tops could be lopped and 

scattered across the harvest unit. This is usually done where landing area is limited, or slash needs 

to be retained on site due to resource concerns. 

Most areas proposed for harvest could be accessed with conventional wheeled or tracked logging 

equipment; however, five units (approximately 130 acres) would require skyline yarding. Skyline 

yarding involves transporting cut trees from the stump to a central landing by a suspended cable 

system. 

Commercial-sized live trees fall into two classes: sawtimber and products other than sawtimber. 

Sawtimber-sized trees are 8 to 9 inches d.b.h. and greater; products other than sawtimber (POL) 

are trees 5 to 9 inches d.b.h. There is a ready market for sawtimber trees; however the market for 

POL is variable. Cutting trees in the 5- to 9-inch d.b.h. size class is important to reduce stocking 

to the desired level and decrease mountain pine beetle risk. The harvest of POL-sized trees could 

be accomplished through a variety of means, depending on market conditions: POL could be 

included in a timber sale contract and harvested along with the sawtimber trees; POL-sized trees 

could be offered for sale separate from the sawtimber; or POL could be cut and decked through a 

service contract. 

Commercial harvest units are scheduled for sale in fiscal year 2013, and the timber sale would 

take up to 3 years to complete; the sale could be sold as early as October 2012. Depending on 

mountain pine beetle populations in the project area, the timeframe for sale, or harvest unit 

completion, could be shortened. Noncommercial vegetation treatments and fuel treatments would 

follow the commercial harvest. Sanitation treatments could be implemented soon after a project 

decision, and are expected to continue over the timeframe of the commercial timber sale. 

A burn plan would be developed prior to any prescribed burning taking place on the ground. 

Forest resource specialists review the burn plan to ensure consistency with the forest plan and the 

line officer authorizes the plan. The plan identifies burn objectives, conditions under which a burn 

would be allowed, and methodologies for achieving the objectives of the burn. 

Post-sale Activities 

The Knutson-Vandenburg (KV) Act authorizes the Forest Service to collect money from timber 

sales for resource enhancement, protection, and improvement work in the timber sale area. 

Actions proposed as KV activities for the Cold Springs project area are listed below: 

 Regeneration surveys 3rd and 5th year post-harvest: Surveys would be conducted 

following shelterwood removal and establishment treatments to verify stocking standards 

have been met. 

 Vegetation monitoring: Post treatment vegetation data would be collected for use in 

monitoring and evaluation of activities. Standard stand exam protocol would be followed 

for complete condition evaluation. Vegetation monitoring could be implemented on any 

treatment type not covered by 3rd and 5th year post-harvest regeneration surveys. 

 Site preparation: Site preparation involves mechanical scarification to expose mineral 

soil for ponderosa pine establishment. This treatment would be identified for 

implementation if regeneration surveys indicate inadequate stocking. 

 Noxious weed treatment and monitoring: Noxious weeds will be monitored and sprayed 

(as necessary) following ground-disturbing activities pursuant to design measures 

identified for this project to control the establishment and spread of noxious weeds. 
Environmental Assessment 

17 

 Road closure: Two new roads and two non-system roads converted to system roads under 

the Cold Springs Project would be closed upon the completion of management activities. 

Closure methods would be determined at the time of closure depending on site 

conditions. Possible methods include locked gates, boulders, dirt berms, downed trees, 

fences, partial obliteration, and recontouring. 

Alternatives Considered but Eliminated from Detailed Study 

The project interdisciplinary team considered a wide range of alternatives. Following are brief 

descriptions of alternatives considered but eliminated from detailed analysis. 

No Road Actions 

One commentor requested an alternative with reduced road management activities. 

The project interdisciplinary team considered an alternative that did not include any of the roadrelated actions identified in the proposed action. This alternative was dismissed from detailed 

analysis because the road management activities in the proposed action are necessary to provide 

harvest access for treatments to meet the purpose and need for the project and to reduce or 

minimize resource damage. The use of roads for management activities is consistent with the 

goals and objectives outlined in the forest plan for management areas 4.1 and 5.1. 

Any impacts associated with road activities are likely to be minimal in intensity of effects. The 

few new roads included in the proposed action were located to minimize resource conflicts. The 

maintenance of existing roads would likely improve drainage conditions. All road work would 

comply with region 2 watershed conservation practices. These measures are intended to minimize 

resource damage. The analysis completed for this project includes an assessment of the effects of 

all road activities on riparian habitat, noxious weeds, and soils. It also describes the effects of no 

action. 

Further Reduce Stocking Levels 

One commentor requested an alternative that reduced stocking levels to 40 to 60 square feet of 

basal area to provide maximum reduced risk of mountain pine beetle-caused losses. 

The project interdisciplinary team considered an alternative that reduced stocking levels to 40 to 

60 square feet of basal area, but this reduction in stocking levels was not deemed necessary to 

meet the purpose and need of the project. Furthermore, such an alternative would not result in 

desired conditions. This alternative was dismissed from detailed analysis. 

Proposed treatments to 70 square feet of basal area (or less) would leave the stands stocked to 

provide suitable growing space for a healthy stand. The project area includes lands managed for 

forest wood-fiber production, and there will be periodic entries for timber harvest that can 

maintain stands stocked at levels suitable to maintain reduced risk of beetle infestation. 

Stand stocking at 40 to 60 square feet of basal area would result in the establishment of pine 

regeneration. Residual trees in this particular area would likely be subject to windthrow and 

breakage, and the stands would have considerably low stocking levels. Thinning to low stocking 

levels across the landscape, compounded by the potential for breakage and windthrow, would 

result in the establishment of pine regeneration across 31 percent of the project area, which is not 

desired. The desired condition for long-term forest health includes a diversity of age classes 

across the project area. 
Cold Springs Project 

18 

Expand the Project Boundary 

One commentor requested an alternative that expanded the project boundary to include additional 

areas in need of treatment to reduce mountain pine beetle populations and to reduce the risk of 

additional infestation. 

The project interdisciplinary team considered an alternative that increased the size of the project; 

however, this alternative was eliminated from detailed study because expanding the project area 

would cause unacceptable delay in project planning and implementation. The delay could allow 

mountain pine beetle populations to increase and spread to additional forest stands. 

Reestablish Ponderosa Pine stands 

Two commentors requested an alternative that reestablished pine as the dominant species in seral 

stands. One commentor stated that allowing pine stands to convert to spruce does not follow 

forest plan objective 200-01. 

The project interdisciplinary team considered an alternative that converts seral pine stands back to 

pine-dominated forest, however, this alternative was eliminated from detailed study because 

conversion of mixed spruce/pine stands back to pine is outside the scope of the project and does 

not relate to the purpose and need for the project. The project purpose and need is to decrease the 

risk of mountain pine beetle infestation in ponderosa pine stands within an area managed for 

timber production and wood products. 

The project area is and will continue to be dominated by ponderosa pine stands. Transition of 

some mixed spruce/pine stands to spruce-dominated stands may occur; however, the extent of this 

transition is expected to be limited. Furthermore, heterogeneity in stand structure and vegetation 

types across the project area contributes to the area’s resilience to mountain pine beetle attack. 

The forest plan does not contain an objective numbered 200-01. An objective numbered 200-01 

was included in the Phase II FEIS prepared in support of the forest plan (USDA Forest Service 

2005a). This objective was adopted in the forest plan and numbered objective 239-LVD. This 

objective indicates that land managers on the Forest should manage for 20,000 acres of spruce 

across the Forest using active management to achieve multiple-use objectives. 

As the discussion in the Phase II FEIS indicates, the objective is intended to favor hardwoods 

where spruce is encroaching upon hardwoods but to favor spruce where spruce is encroaching 

into pine stands, “especially where it improves connectivity between spruce stands” (USDA 

Forest Service 2005a, p. III-25). In working to maintain at least 20,000 acres of spruce across the 

Forest, the Phase II FEIS recognized that there would be losses in spruce where hardwood 

conversion occurred or where spruce was removed to reduce fire hazard in close proximity to 

structures; however, that loss was expected to be balanced by gains due to succession in other 

areas (USDA Forest Service 2005a, p. III-27). 

Project Design Criteria 

Project design criteria are listed in Table 3. These criteria were developed to reduce or eliminate 

adverse impacts from project activities, and are incorporated as an integrated part of the modified 

proposed action. Project design criteria are based upon standard practices and operating 

procedures that have been employed and proven effective in similar circumstances and 

conditions. Forest Service Manual and Handbook direction, Regional Watershed Conservation 

Practices (WCPs, Forest Service Handbook 2509.25), forest plan standards and guidelines, South 
Environmental Assessment 

19 

Dakota Best Management Practices, and other management requirements apply to the proposed 

activities. Management requirements such as applicable forest plan standards are repeated here 

only if clarification is required. 

Table 3. Project design criteria 

Applies To: Measure 

All Activities 

Brush Disposal: 

 Rehabilitation of slash pile sites would include site preparation and seeding to 

return the sites to productivity and control the spread of noxious weeds. 

All Activities 

Heritage Resources: 

 All culturally sensitive areas, Traditional Cultural Properties, graves, potential 

graves and sites eligible or considered unevaluated to the National Register of 

Historic Places should be avoided under proposed activities with a 100‐foot 

buffer. Further mitigations, if defined, would be identified in the project file for 

each property and would be required for project implementation; any properties 

with mitigations not identified in this proposed action would need heritage review 

and State Historic Preservation Office concurrence before project 

implementation. Heritage site locations and specific mitigations are outlined in 

Section 106 of the National Historic Preservation Act (1966, as amended) 

compliance reports, on file at the Northern Hills Ranger District. Heritage site 

locations are not identified in this proposed action to protect sensitive site 

information according to Section 304 of the National Historic Preservation Act 

and Section 9 of the Archaeological Resources Protection Act (1979). 

 In the event that culturally sensitive areas, Traditional Cultural Properties, 

graves, potential graves and sites eligible or considered unevaluated to the 

National Register of Historic Places cannot be avoided, or new heritage 

resources are found during implementation of the project, all activity must stop 

and a member of the district heritage staff must be notified to determine an 

appropriate course of action. Appropriate consultation with the State Historic 

Preservation Office, Tribal Historic Preservation Offices, and other applicable 

parties would take place as directed by 36 CFR 800. 

 Leaders of project activities described in this proposed action will review the 

heritage report and geospatial data for areas to protect and consult with district 

heritage staff on specific mitigations. Project leaders should contact district 

heritage staff for additional assistance in marking the sites for protection on the 

ground. 

All Activities 

Improvements: 

 Avoid or protect improvements such as fences; water developments; land 

boundary corners, posts and bearing trees; utility infrastructure; mining claim 

corner posts and developments. These will be shown as protected 

improvements on timber sale area maps. 

 Avoid or protect improvements under special use permit. 

 All recreation trails would be shown as protected improvements on timber sale 

maps. Project administrators would ensure protection of trails during project 

implementation. 

All Activities 

Meadows: 

 White spruce will not be removed from wet meadows unless they are considered 

a safety hazard. 

 Surface-disturbing activities (e.g., log skidding, location of landings, brush piling, 

temporary roads construction, etc.) will be avoided as much as possible in 

meadows. If, during implementation, activities such as these cannot be located 

outside of meadows, the district hydrologist, botanist, range management 

specialist, and wildlife biologist will be contacted prior to implementation to 

determine if special requirements are warranted to protect site integrity. 
Cold Springs Project 

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Table 3. Project design criteria 

Applies To: Measure

All Activities 

Noxious Weeds: 

 Contracts and permits issued as part of this project would include measures to 

limit spread of noxious weeds. Where proposed activities would occur in areas 

infested with noxious weeds and considered to be at high risk for spread, 

off‐road equipment associated with the activity will be washed before leaving the 

site to prevent spread of weeds to adjacent National Forest System and private 

lands. Known areas meeting these criteria will be identified by district staff before 

commencement of any timber sale contract associated with this project. Known 

weed infestations will be displayed on the timber sale map. 

 Where ground‐disturbing activities occur in areas infested with weeds, weeds 

would be treated prior to project implementation, where feasible, to reduce future 

spread and establishment of noxious weeds. Where pre-treatment is not 

feasible, noxious weeds may be treated following ground-disturbing activities.

 Review of the area for noxious weed infestations will continue during 

management activities. If new noxious weed infestations that could be spread by 

management activities are found during implementation, actions to minimize 

spread would be taken. 

All Activities 

Public Safety: 

 Appropriate signing or other cautionary measures would be implemented in 

conjunction with all management activities to ensure public safety. 

 Implementation of these measures would be the responsibility of the person 

initiating the action (e.g., timber purchaser, prescribed fire manager). 

All Activities 

Range: 

 Managers of vegetation treatment projects would consult with district range 

managers to ensure alteration of natural barriers does not allow livestock to 

circumvent fences. 

All Activities 

Region 2 Sensitive Plant Species: 

 Refer to the botany design criteria shapefile for identified plant habitat and to the 

Biological Evaluation/Specialist Report for a verbal description of plant habitat. 

 Any potential habitat for sensitive plant species outside of treatment units would 

be avoided. If that is not feasible, consult with a qualified botanist to determine 

whether other options exist. 

 Any region 2 sensitive plant or animal species or plant or animal species of local 

concern located after contract or permit issuance will be appropriately managed 

by active coordination between permittee, contractor or purchaser, Forest 

Service line officer, project administrator, and biologist and/or botanist. 

All Activities 

Revegetation: 

 Disturbed soil would be revegetated in a manner that optimizes plant 

establishment for that specific site. Revegetation may include topsoil 

replacement, planting, seeding, fertilization, liming, and placement of weed‐free 

mulch, as necessary. Revegetation would be initiated as soon as possible, 

generally not to exceed 6 months after termination of ground‐disturbing activities. 

All disturbed soils would be revegetated with native species when available, 

using seed mixtures free of noxious weeds. On areas needing the immediate 

establishment of vegetation, non‐native, non‐aggressive annuals, 

non‐aggressive perennials, or sterile perennials may be used until native 

perennials become established. These species can be used to prevent the 

spread of noxious weeds and prevent erosion. Only weed‐free mulch would be 

used. 

All Activities 

Scenery: 

 Activity slash would be reduced to natural levels within 300 feet of U.S. Highway 

85, unless not visible due to changes in topography. Slash would be treated 

within 1 year of harvest completion. 
Environmental Assessment 

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Table 3. Project design criteria 

Applies To: Measure

All Activities 

Snags and Down Logs: 

 Conifer snags over 20 inches d.b.h. and those with cavities would be cut only for 

safety reasons. Conifer snags under 20 inches d.b.h. would be cut only for safety 

reasons or when necessary for construction of roads, skid trails, firelines, and log 

landings – Standard 2301a. 

 Retain all hardwood snags except for those considered a safety hazard −

Standard 2301b. 

 Retain at least 50 linear feet per acre of coarse woody debris with a minimum 

diameter of 10 inches in ponderosa pine stands, and 100 linear feet per acre in 

white spruce stands to help retain moisture; trap soil movement; provide 

microsites for establishment of forbs, grasses, shrubs, and trees; and to provide 

habitat for wildlife – Standard 2308a. 

 In vegetation treatment units, one pile of woody material per 2 acres would be 

left to create near‐ground structure for small mammal species, except within 300 

feet of buildings – Standard 3117. 

 Any snag cut for safety reasons will be retained on site as coarse woody debris. 

All Activities 

Soil and Water: 

 Some proposed activities would take place on soils identified as having a 

potential for mass erosion. The following provisions, intended to minimize the 

amount of exposed bare soil, off‐site transport, and soil displacement, are to be 

implemented: (1) on slopes over 30 percent, harvesting and skidding methods 

that minimize the amount of soil displaced into piles or windrows would be used 

to leave soil intact and in place; and (2) prescribed burns on slopes over 30 

percent would be conducted when soil, duff, and large fuels are sufficiently moist 

to retain duff as ground cover for prevention of erosion. 

 Some proposed activities would take place on soils that are more susceptible to 

compaction. The following provision, intended to reduce the risk of detrimental 

compaction, would be implemented: Heavy equipment would avoid streams and 

swales (low‐lying or depressed and often wet stretches of land) except to cross 

at designated points, build crossings, or conduct restoration, unless protected by 

at least 1 foot of packed snow or 2 inches of frozen soil. 

 To reduce potential for compaction and/or rutting, the following measure applies 

on all soil map units: Heavy equipment will be operated for land treatments only 

when soil moisture is below the plastic limit (soil moisture exceeds the plastic 

limit if the soil can be rolled into 3‐mm threads without breaking or crumbling), 

the soil is protected by at least 1 foot of packed snow, or the top 2 inches of the 

soil are frozen (Watershed Conservation Practices Handbook management 

measure 13/design criteria (b)). 

 No wheeled or tracked equipment will be allowed within 100 feet of perennial or 

intermittent streams or springs. 

 No wheeled or tracked equipment will be allowed within 100 feet of wetlands. 

All Activities 

Wildlife: 

 Any newly discovered raptor nests, snail colonies, red‐bellied snake hibernacula, 

or bat roosts (i.e., snags or rock formations observed being used by bats, or 

newly discovered mines and caves) would be evaluated by a district wildlife 

biologist prior to implementation to determine if special requirements are 

warranted to protect site integrity. These resources would be protected in 

accordance with forest plan standards. 

 To minimize disturbance to nesting goshawks, a timing restriction will apply from 

April 1 through August 15 within 1⁄2 mile of active nests by minimizing 

human‐caused noise and disruption beyond that occurring at the time of nest 

initiation. The following activities would not occur during the timing restriction: 

fuel-reduction activities, cutting, skidding, yarding, decking, hauling, road 

construction, and other activities that may disturb nesting birds. An exception 

might be: hauling within 1⁄2 mile of active nest sites during the nesting season if it 
Cold Springs Project 

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Table 3. Project design criteria 

Applies To: Measure

is reasonable to assume that goshawks in the area are habituated to this type of 

disturbance or surveys indicate that goshawks are not nesting in the area 

(consult with a district wildlife biologist to determine an appropriate course of 

action). Specific site locations and GIS shapefile are documented in the project 

file – Standard 3111. 

 Tree marking will not occur from April 1 through August 15 within 1/8 mile of 

active goshawk nests to assure that goshawks do not abandon nests. From April 

1 through August 15, if crews are being aggressively watched or attacked by 

goshawks during marking activities, they will immediately abandon all marking 

efforts within 1⁄2 mile of the active goshawk nest. 

 Avoid creating barriers (e.g., new open roads) between red‐bellied snake 

hibernacula and riparian areas or wetlands. There are currently no known 

hibernacula in the planning area. This design criterion will apply to any newly 

discovered hibernacula – Standard 3116. 

 Avoid ground disturbance within 100 feet of an opening of a natural cave – 

Standard 1401. 

All Activities 

Travel Management: 

 While any projects resulting from this analysis are taking place, all gates that 

would normally be closed will remain closed except for administrative purposes. 

Timber Harvest 

Aspen: 

 Where hardwood enhancement sites are adjacent to commercial treatment units, 

cut all conifers within one tree length (approximately 75 feet) of aspen stand to 

maintain vegetative diversity within the stand. 

 Conserve all live aspen with wildlife cavities (Standard 3124 and Guideline 2204) 

and all snags (Standard 2301b and 2305), except for those that are considered a 

safety hazard. 

 Remove all live pine and spruce from hardwood enhancement stands. Where 

appropriate, use tree hinging or slash techniques to deter ungulates from 

browsing aspen suckers. 

 Whenever possible, skid trails (or other surface-disturbing activities) will be 

placed directly adjacent to aspen stands to promote expansion of aspen clones, 

which are likely to benefit from openings and ground disturbance. 

Timber Harvest 

Harvest: 

 Existing pine regeneration would generally be protected in stands proposed for 

overstory removal harvest. Provisions related to felling, bucking, and whole-tree 

yarding would be included in the timber sale contract. Log-length yarding is the 

preferred method of timber removal. Skid trails within these stands would be 

approved by the sale administrator before commencement of logging. Landing 

locations would, where feasible, take advantage of existing openings or areas 

with no regeneration. 

 To increase the likelihood of successful conifer regeneration, stands proposed 

for establishment cut would be logged in the summer or early fall, where 

feasible, to maximize the site scarification provided by the skidding operation, 

provided there are no concerns related to riparian areas, noxious weeds, or 

sensitive plants. 

 Where stand variation dictates an alternative treatment to the majority treatment, 

this variation shall be accommodated. For example, a 1⁄4-acre pocket of aspen 

within a commercial thin stand of ponderosa pine shall be cleared of conifers 

within and up to one tree length (approximately 75 feet) from the edge of the 

pocket in an effort to maintain vegetative diversity within stands. 

Timber Harvest 

Road Restrictions: 

 Timber sale units would be laid out to facilitate existing road restrictions (for 

example, trees around gates and other barriers would be left uncut to maintain 

obstructions and discourage driving around the gate or barrier). 
Environmental Assessment 

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Table 3. Project design criteria 

Applies To: Measure

Timber Harvest 

Scenery: 

 Layout and marking of timber sale units would comply with forestwide marking 

guides in effect at the time of implementation. Visual marking guidelines (FSH 

2409.12 Amendment No. r2_bh_2409.12-2008-1) would be followed for travel 

routes: U.S. Highway 85, National Forest System roads 231.5, 209.1, and 

134.1, and recreation sites: Holey Rock Trailhead and Bratwurst Trailhead. 

 Where possible, treatments would be designed to reduce the chance of wind 

damage to residual trees. This may include retaining higher density of mature 

trees on exposed ridges, lee slopes, and other areas prone to high winds and 

heavy snow accumulation. 

 To reduce effects of continuously even tree spacing on wildlife and scenery, 

commercial thin treatments would emphasize tree health and crown size over 

spacing. Residual trees in shelterwood removal and establishment cut units 

would be variably spaced. 

 Skyline logging corridors would be as narrow as possible to minimize visual 

effects of any soil displacement. 

 Where existing conditions allow, treatments in forested areas adjacent to other 

ownership would blend into adjacent tree density conditions rather than creating 

strong vegetation edges. A horizontal transition zone of 2 chains (132 feet) 

would achieve this transition in tree density. 

 Within 300 feet of U.S. Highway 85, the following design criteria will be in place: 

(1) Skid trails will be utilized during dry or frozen conditions to minimize soil 

disturbance, and will be re‐seeded with native grasses. These techniques have 

been effectively used to reduce soil displacement and speed up the 

re‐vegetation process along these skid trails, reducing highly visual evidence of 

skid trails. (2) All stumps should be cut low (less than 6 inches) within this zone 

in the following units: 070505 53, 071205 17, 071206 5, 071301 10, 071301 16, 

071302 4, 071302 11, 071302 12, 071302 69, 071205 60, 071301 6, 071301 9, 

071301 100, 071302 5, 070505 49, 070505 52, 070505 58, 070505 62, 070505 

72, 071205 39, 071205 84, 071206 9, 071301 20, and 071205 41. 

 No whole-tree harvest slash piles will be placed within 300 feet of U.S. Highway 

85, National Forest System roads 231.5, 209.1, and 134.1. 

 Use topography and vegetation to screen log landings from view of U.S. 

Highway 85, National Forest System roads 231.5, 209.1, and 134.1. Once 

management activities are complete, rehabilitate landings by returning to original 

contours, scarifying to eliminate compaction (as necessary), and planting with 

native grass seed. If vegetation clearing is needed for log landings, shape edges 

to mimic natural patterns and openings. 

 Within 300 feet of U.S. Highway 85, National Forest System roads 231.5, 209.1, 

and 134.1, and Eagle Cliff non-motorized recreation trails, the following design 

criteria will be in place: (1) Where possible along these routes, remaining 

vegetation should be in a variety of sizes and spacing to maintain a more natural 

appearance. This technique has been very effective in maintaining a natural 

appearance. Locations where it was not used resulted in a “tree‐farm” 

appearance (avoid leaving all trees same height and evenly spaced across the 

landscape). (2) Slash will be cleaned up to natural levels within 300 feet of these 

travel corridors. This can be accomplished by slash clean up (e.g., scattering 

and underburning, piling, and burning, or chipping) after logging. (3) Slash, once 

placed on the ground, needs to be treated in accordance with forest plan 

Guidelines 4112 and 5606. 

 To meet High scenic integrity objectives (SIO) in shelterwood establishment 

units 070505 50 and 071205 4, the following design criteria will be in place: 

leave a higher basal area ranging from 40-60 square feet of basal area in an 

irregular spacing and leave denser areas or islands of trees throughout the unit. 

 To meet Moderate SIO in shelterwood establishment unit 071305 5, the following 
Cold Springs Project 

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Table 3. Project design criteria 

Applies To: Measure

design criteria will be in place: in the northern half of the unit, leave a higher 

basal area ranging from 40-60 square feet of basal area with irregular tree 

spacing. 

Timber Harvest 

Range: 

 All pasture gates would be kept closed during the grazing season (June through 

October). 

 If log hauling or movement of heavy equipment related to the proposed timber 

harvest causes damage to cattle guards, the timber purchaser would be 

responsible for repair. 

Timber Harvest 

Region 2 Sensitive Plant Species and Species Of Local Concern: 

 Occurrences of region 2 sensitive plants and plant species of local concern 

would be avoided during all proposed timber harvest activities. Known areas are 

identified in the design criteria shapefile. 

 Potential plant habitat would be excluded from mechanical treatment areas. 

Known plant habitat is identified in the design criteria shapefile. 

 Skid trails, temporary roads, landings, or other disturbances associated with 

logging activities in plant habitat would be designated in consultation with a 

qualified botanist. These areas are included in the design criteria shapefile. 

 Plant habitat outside of treatment units would be avoided unless reviewed by a 

qualified botanist and approved by the Line Officer. These areas are included in 

the design criteria shapefile. 

Timber Harvest 

Recreation: 

 Snowmobile and non-motorized recreation trails would be shown as 

improvements on timber sale area maps and protected during harvest 

operations. An evaluation of the potential for conflicts between logging and trail 

use would take place at the time of timber sale appraisal and contract 

preparation. If conflicts appear likely between use of the trails and specific 

logging units or haul routes, logging would be restricted between December 1 

and March 31, unless a logical and desirable alternative trail route is identified. 

Only those units and/or roads in conflict would be restricted, so that logging 

operations could proceed in the remainder of the sale area. 

 Winter operations of timber sale units that necessitate skidding across a 

snowmobile or non-motorized recreation trail, but do not otherwise affect the 

trail, may be allowed. Determination would be made on a case‐by‐case basis, 

with crossings permitted only at locations approved by the sale administrator and 

with proper cautionary signing installed by the timber contractor. 

Timber Harvest 

Soil and Water: 

 In stands where slopes exceed 55 percent, ensure that a tree overstory 

component with at least an 80 basal area density remains following timber 

harvest and post-sale activities. If there is a need to reduce basal area density 

below this level, consult the district hydrologist for field verification of the site to 

determine further potential of slope stability impairment associated with 

additional levels of basal area reduction. 

 Skid trails and temporary roads: Place slash in a well‐distributed pattern across 

the skid trail surface and install water bars, where necessary, following harvest 

activities. 

 When logging in previously disturbed stands, use existing skid trails and landings 

whenever possible. 

 Avoid locating any temporary roads, skid trails, or log landings within 100 feet of 

perennial or intermittent streams, springs, or wetlands. 

 Avoid conducting vegetation treatments that remove overstory trees within 50 

feet of perennial or intermittent streams, springs, or wetlands. 

 Wheeled or tracked harvest equipment will not operate on slopes exceeding 40 

percent. 
Environmental Assessment 

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Table 3. Project design criteria 

Applies To: Measure

Timber Harvest 

Wildlife: 

 No treatments will be conducted within 500 feet of adit portal or shaft openings of 

mines or caves to maintain microclimate of bat hibernacula or nurseries, unless it 

is determined through bat surveys that the site is not bat roost habitat. Bat 

surveyors and bat survey protocols must be pre‐approved by the district wildlife 

biologist and surveys must be conducted prior to implementation. The 500-foot 

no treatment zone may be reduced depending upon survey results and 

topography, and will be reviewed by a district wildlife biologist and approved by 

the Line Officer. Known mine site locations are documented in the project file – 

Standard 3207. 

 Known snail sites with region 2 sensitive species or species of local concern will 

be avoided (i.e., no vegetation treatments, no heavy equipment use, and no skid 

trails, landings, temporary roads, or any other activity that may compact soils or 

alter ground cover, moisture regimes, or litter composition). Known site locations 

are documented in the project file – Standard 3103. 

 Disturbance of newly discovered colonies of land snails would be avoided until 

the colonies are evaluated by a district wildlife biologist to determine if region 2 

sensitive species or species of local concern are present. Appropriate buffer 

areas (no treatment zones) around newly discovered colonies would be 

recommended based on site‐specific conditions and approved by the Line 

Officer. Avoidance zones or mitigation measures would be determined on a 

case‐by‐case basis. 

 In the event that a bald eagle is documented in a stand, the wildlife biologist will 

be notified and harvest operations will be suspended until the eagle has vacated 

the stand – Standard 3101d. 

Timber Harvest 

Spruce Habitat: 

 Commercial and non‐commercial treatments of ponderosa pine in sprucedominated stands will not occur except within 200 feet of buildings or where 

spruce is encroaching into hardwoods, so long as other identified design criteria 

do not apply in these areas. 

Prescribed Fire 

Burn Plan: 

 Prescribed burning would be implemented only under conditions defined in a 

prescribed burn plan. 

 In stands that have been designated as part of the suitable timber base, at least 

90 percent of the trees greater than 9 inches in diameter will be retained. In other 

stands, at least 50 percent of the trees greater than 9 inches in diameter will be 

retained. 

 The district silviculturist will assist with the preparation of or review the final 

prescribed burn plan. 

Prescribed Fire 

Improvements: 

 Measures will be taken to protect utility lines and any other improvements within 

the burn unit during prescribed burns. 

Prescribed Fire 

Region 2 Sensitive Plant Species: 

 Control lines that disturb soil (i.e., hand lines or dozer lines) would not be located 

in plant habitat, unless needed to ensure safety. These areas are included in the 

design criteria shapefile. 
Cold Springs Project 

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Table 3. Project design criteria 

Applies To: Measure

Prescribed Fire 

Soil and Water: 

 Prescribed burns in some sites would take place all or partly on soils with severe 

erosion hazard. These burns would take place only when burn severity could be 

kept low. 

 Small wetlands located in or immediately adjacent to any burn units would be 

excluded from areas to be burned and protected from disturbance. No active 

ignition would occur within the water influence zone (WIZ); fire would be allowed 

to creep into this zone. 

 Prescribed burn plans will include monitoring measures to evaluate the 

breakdown of hydrophobic soils, where applicable, following burn 

implementation. 

Prescribed Fire 

Scenery: 

 Where possible, prescribed burns adjacent to U.S. Highway 85 would be burned 

so that overstory trees visible from the road show as little scorch as possible. 

Prescribed Fire 

Wildlife: 

 In any given year, conduct prescribed burns on no more than 60 percent of a 

contiguous meadow (that is greater than 20 acres in size) to minimize impacts of 

prescribed fire on butterflies and ground-nesting birds. Timing restriction would 

apply to meadows from May 15 to August 15, to minimize impacts to groundnesting birds. Fall burns are preferred – Standard 3125. 

 Prescribed burns within 1⁄2 mile of historic goshawk nests would be coordinated 

with the district wildlife biologist. Timing restriction would apply from April 1 

through August 15, if the nests are active. 

 All documented land snail colonies with region 2 sensitive species or species of 

local concern that are in prescribed burn units would be protected by burning 

when snails are hibernating (i.e., when average daytime temperatures are less 

than 50 degrees Fahrenheit), or these colonies will be avoided. Specific site 

locations are documented in the project file – Standard 3103. 

 No fire lines or direct ignition of fire will occur on known snail colonies any time of 

the year. Specific site locations are documented in the project file. 

 During prescribed burning, protect existing guzzlers. Use whatever technique the 

burn boss deems appropriate (e.g., foam, black lining, wrapping, etc.), based on 

site conditions. 

 If Atlantis fritillary or regal fritillary butterflies occur in meadows that are within 

burn units, redesign the project to conserve important habitat components of 

known sightings (survey for butterflies as appropriate). No known occurrences of 

either species exist in proposed burn blocks. Check with the district biologist 

prior to burning to determine if new information indicates their presence – 

Standard 3105. 

 Prescribed burning in areas with caves or mines would be coordinated with a 

district wildlife biologist. Impacts to bat hibernacula would be avoided with the 

use of timing restrictions and/or establishing buffer zones. Specific mitigations 

will be determined by a district wildlife biologist and fuels specialist during burn 

plan development. Specific site locations are documented in the project file. This 

design criterion will also apply to any newly discovered hibernacula – Standard 

3102. 

Prescribed Fire 

Range: 

 To avoid conflicts with grazing and to ensure that prescribed fire mitigation is 

implemented, prescribed fire projects will be coordinated in advance with the 

range management specialist. 
Environmental Assessment 

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Table 3. Project design criteria 

Applies To: Measure

Prescribed Fire 

Recreation: 

 Personnel from the South Dakota Department of Game, Fish and Parks will be 

notified prior to the initiation of prescribed burns if the burn unit includes or is 

adjacent to a designated snowmobile trail, so that trail markers may be removed 

or protected. 

 Generally, slash piles will be located away from designated snowmobile or 

cross‐country ski trails where possible. Where that is not possible and piles are 

located immediately adjacent to trails, piles will either not be burned between 

December 1 and March 31 (to prevent melting of the snow on the trail) or 

specific mitigation will be instituted to prevent snow melt on the trail. 

Prescribed Fire 

Heritage: 

 In the event that sites are within a prescribed burn boundary, both prehistoric 

and historic sites would be avoided by both hand line and dozer lines. Sites with 

consumables, such as wood, would either be wrapped with structure protection 

material, or have either a wet line or hand line placed around the resource. 

Transportation 

System 

Dust Control: 

 Dust control, if necessary, may be done with water, magnesium chloride, calcium 

chloride, or equivalent. 

Transportation 

System 

Noxious Weeds: 

 District staff responsible for the noxious weed program would, in coordination 

with the project engineer, inspect gravel pits for noxious weed infestation before 

transport and use of gravel and other material. Infestations would be treated to 

prevent spread. 

 District staff responsible for the noxious weed program would inspect stockpiled 

gravel annually for weed infestation, in coordination with the project engineer. 

Transportation 

System 

Revegetation: 

 Timber sale roads would be seeded after construction, but before timber harvest, 

if any part of the gap between construction and harvest would occur between 

April and October. This may be accomplished under the road contract. If 

necessary, seeding would again occur after use of the road is complete. Seeding 

may be delayed until after completion of harvest if the gap between construction 

and harvest would be of short duration and hydrology, soils, engineering, and 

noxious weed specialists determine after field review that a delay would be 

acceptable. 

Transportation 

System 

Soil and Water: 

 New road construction is to be designed to limit cut and fill slopes where 

possible, particularly when located above steep slopes. 

 Construction of landings, roads, and tractor and skid trails would be avoided 

within 100 feet (or a distance equal to the mean height of mature dominant late 

seral vegetation, whichever is more) of perennial seeps, springs, and wetlands. If 

this is not possible, crossings would be constructed and restored to prevent 

headcutting, gullying, erosion, and sediment transport to ephemeral or perennial 

channels. Creation of large water-collection points, such as road ditches or 

excessively large water bars, would be avoided, particularly up‐gradient of 

existing rotational site features, such as slumps and landslides. A greater 

frequency of water bars than that identified as the maximum spacing 

recommended in FSH 2509.25 for the Rocky Mountain Region is to be used. 

FSH 2509.25 direction disclosed that the listed spacings were maximum 

spacings and should be reduced if warranted by onsite factors, such as amount 

of road use, downslope stability, erosion, etc. Forestry Best Management 

Practices for South Dakota (2003) identifies suggested drainage feature 

spacings (p. 12) that have narrower spacings between drainage features as 

compared to FSH 2509.25. The 2009 Field Audit Report െ Implementation 

Monitoring of SD Forestry Best Management Practices further supports the 
Cold Springs Project 

28 

Table 3. Project design criteria 

Applies To: Measure

greater need for more frequent spacing of water bars. The audit identified some 

areas with insufficient numbers of water bars on native surface roads. 

Temporary road cuts exceeding 2 feet would be avoided. If this is infeasible 

because of steep slopes, temporary roads would be re‐contoured. 

 Where feasible, existing haul roads would be reconstructed with rolling grades 

instead of ditches and culverts. 

 Water bars and sediment barriers would be placed 10 to 20 feet below water bar 

outlets and culvert outlets on skid trails steeper than 15 percent. 

 Engineering staff would consult with a forest hydrologist and fisheries biologist 

on design of stream crossings. Fill slopes would be protected with riprap, 

gabions, prompt seeding, or other measures approved by the hydrologist, 

fisheries biologist, or soil scientist. 

 Placement of structures would comply with Federal and State laws regarding 

construction in and near waterways, including placement of fill and measures to 

control sedimentation. 

 Generally, do not locate any new system roads or temporary within 100 feet of 

streams (perennial, intermittent or ephemeral), springs, or wetlands. If a stream 

crossing is required, ensure that it is constructed to prevent headcutting, 

gullying, erosion, and sediment transport to stream channels by implementing 

Region 2 Watershed Conservation Practices. 

Transportation 

System 

Travel Management: 

 In general, all newly constructed roads would be closed following construction 

until needed for timber sale or related activities and closed again after use. 

Roads needed for timber sale or related activities, but normally closed to 

motorized vehicles, would also be closed when not in use. 

 All newly constructed roads that are to be closed following use will be closed 

with appropriate methods, which may include: locked gates, dirt berms, boulders, 

downed trees, fences, or re‐contouring. 

 Where new roads or access routes are constructed through allotment fences, 

temporary cattle guards or gates will be installed at the crossing point. If the road 

is identified for closure, immediately following completion of related timber sale 

activities, the fence will be returned to its original condition by the timber 

purchaser. Use of temporary gates or cattleguards will require adequate bracing 

(wood posts) placed sufficiently to support the gate and/or associated fence line. 

Wood posts will not be removed after timber sale activities are completed. In the 

event the new route is to remain open, a permanent cattleguard with bypass 

gate or a permanent gate, depending on site conditions, will remain in place. 

 Retain access routes as needed for utility line construction, reconstruction, and 

maintenance of existing right‐of‐way corridors. 

 Avoid or protect utility infrastructure during construction and decommissioning of 

roads. 

Transportation 

System 

Region 2 Sensitive Plant Species: 

 A botanist will work with the road engineer to determine the best placement of 

the proposed new road construction that will potentially cross plant habitat. 

These areas are included in the design criteria shapefile. 

Transportation 

System 

Wildlife:

 Maintenance of existing roads in areas that pass through known snail colonies 

will be limited to the clearing limits (i.e., roads may be maintained to standard). If 

needed improvements or realignment of those areas go beyond the existing 

clearing limits, review and input by the district wildlife biologist would be required 

to ensure that snail colonies would not be impacted – Standard 3103. 

 Avoid constructing new roads through snail colonies. Where data suggests an 

overlap between new roads and known snail colonies, a wildlife biologist and the 

engineer, together, will determine if there are any feasible alternate road 
Environmental Assessment 

29 

Table 3. Project design criteria 

Applies To: Measure

locations – Standard 3103. 

 The presence of snails in any area not previously identified will be brought to the 

attention of the district wildlife biologist before maintenance or construction 

continues. 

Transportation 

System 

Heritage: 

 Sites that currently have a native surface road running through them will have 

site-specific mitigations detailed in the heritage specialist report following a 

review by district heritage staff to determine if further consultation by the South 

Dakota State Historic Preservation Office, appropriate Tribal Historic 

Preservation Offices, and other applicable parties is necessary as directed by 

Section 106 of the National Historic Preservation Act 1966 (as amended). 

Project Monitoring 

The Northern Hills Ranger District would monitor project implementation. The timber sale 

administrator or other contract administrators would complete some of the project 

implementation monitoring. Other resource specialists would be involved in monitoring specific 

mitigation measures relating to their particular resource area. Specific monitoring requirements 

are listed below. 

 Project managers will monitor revegetation of disturbed and burned areas to determine 

the need for additional measures and noxious weed control. 

 Gravel pits and gravel stockpiles will be inspected for noxious weed infestation. 

 Engineering and hydrology or soils specialists will monitor effectiveness of erosion 

control measures (seeding, water bars, etc.) 1 and 3 years following installation. 

 Hydrology or soils staff will monitor soil compaction at a sample of timber sale landings 

and harvest units. 

 Timber sale administrators and hydrology or soils specialists will monitor application and 

effectiveness of water conservation practices and best management practices. 

 Reforestation surveys will be conducted in shelterwood establishment and removal 

harvest units to verify stocking standards have been met. 

 Fuel treatment areas will be monitored to evaluate post-treatment fuel loading. 

 Cultural sites will be monitored to ensure implementation of project design criteria. 

 Road closures will be monitored to evaluate closure effectiveness. 

Comparison of Alternatives 

Table 4 compares the effects of the alternatives in summary form. The alternatives are compared 

by project purpose and need, and resource effects. Information in Table 4 is focused on activities 

and effects where different levels of effects or outputs can be distinguished quantitatively or 

qualitatively among alternatives. The “Environmental Consequences” section of this document 

forms the scientific and analytical basis for this comparison and describes the effects in detail. 
Cold Springs Project 

30 

Table 4. Comparison of alternatives 

Comparison Value Alternative A – No Action Alternative B – Modified Proposed Action 

Project Purpose and Need 

Mountain Pine Beetle 

Risk in Ponderosa Pine 

stands 

High: 4,924 acres (48%) 

Medium: 1,938 acres (19%) 

Low: 3,342 acres (33%) 

High: 804 acres (8%) 

Medium: 3,009 acres (29%) 

Low: 6,392 acres (63%) 

Potential Sanitation & 

Salvage Treatment Area 

to Reduce Mountain 

Pine Beetle Populations 

0 acres 11,761 acres 

Forest Diversity: 

Age-class No change 

360 acres shifted to young age-class (3% of 

project area forest) 

1,290 acres in transition to young age-class 

(11% of project area forest) 

621 acres of uneven-aged management (5% 

of project area forest) 

Forest Diversity: 

Tree Species No change 570 acres of aspen released from pine competition (5% of project area forest) 

Resource Effects 

Project Area Fire 

Hazard Rating: percent 

of project area 

Very High: 17% 

High: 42% 

Medium: 28% 

Low: 13% 

Very High: 9% 

High: 18% 

Medium: 31% 

Low: 42% 

Project Area WUI Fire 

Hazard Rating: percent 

of WUI. 

Very High: 30% 

High: 30% 

Medium: 27% 

Low: 13% 

Very High: 15% 

High: 12% 

Medium: 36% 

Low: 37% 

Wildlife Habitat 

No change in forest 

structural stages; excess 

mature forest and shortage 

of grass-forb, shrubseedling and sapling pole 

structural stages. 

Change in structural stages initiated through 

harvest. Shelterwood removal and 

establishment treatments would increase 

young forest structural stages and move the 

project area toward desired structural stages. 

Fisheries No suitable, occupied 

habitat; no effects No suitable, occupied habitat; no effects 

Noxious Weeds 

Increase in noxious weeds 

due to decreases in forest 

canopy. 

Increase in noxious weeds due to project 

activities. 

Botanical Resources 

No direct effects; potential 

meadow and hardwood 

habitat loss. 

Potential loss if unknown, individual plants; no 

effects to viable populations. Hardwood and 

meadow habitat would improve. 

Hydrology No direct or indirect effects. 

Short-term limited effects at stream crossings 

due to sedimentation. No long-term watershed 

or aquatic impacts. 

Soils No direct or indirect effects. 

Short-term soil displacement and compaction 

on limited area. Mid-term (less than 10 years) 

soil effects on a limited area due to pile 

burning. No long-term direct or indirect effects 

to soil productivity. 
Environmental Assessment 

31 

Table 4. Comparison of alternatives 

Comparison Value Alternative A – No Action Alternative B – Modified Proposed Action 

Air Quality No direct effects Possible short-term (1-2 days) effects on a 

limited area (20-mile radius). 

Recreation 

Potential increase in hazard 

trees due to mountain pine 

beetle caused mortality 

Temporary displacement of dispersed 

recreation activities during harvest operations. 

Improved visitor safety due to road 

maintenance, reconstruction and reduced 

number of hazard trees. 

Scenery No direct effects 

Short-term effects to scenic resources. Effects 

could last up-to 3 years following the 

completion of activities. 

Heritage 

No direct effects 

Increased risk of cultural 

resource damage due to 

wildfire associated with high 

fire hazard 

No adverse or negative effects. 

Reduced risk of cultural resource damage due 

to wildfire, associated with reduced fire hazard. 
Cold Springs Project 

32 

Environmental Consequences 

Introduction 

This section summarizes the physical, biological, social and economic environments of the 

affected project area and the potential changes to those environments due to implementation of 

the alternatives. It also presents the scientific and analytical basis for comparison of alternatives 

presented in the chart above. Additional details regarding area conditions, analysis assumptions or 

methodology can be found in the individual resource reports located in the project record. 

Cumulative Effects 

According to the Council on Environmental Quality (NEPA) regulations “cumulative impact” is 

the impact on the environment which results for the incremental impact of the action when added 

to other past, present and reasonably foreseeable future actions regardless of what agency 

(Federal or non-Federal) or person undertakes such actions (40 CFR 1508.7). 

The relative boundaries, and past and planned activities assessed for cumulative effects vary by 

resource. Each resource cumulative effects area can be different and possibly larger or smaller. 

Relevant cumulative effects are discussed for each resource in this section. The cumulative effects 

analysis for each environmental component or resource area is guided by and consistent with the 

Council on Environmental Quality letter “Guidance on the Consideration of Past Actions in 

Cumulative Effects Analysis” as of June 24, 2005. A listing of relevant related past, present and 

future management activities within 1⁄2 mile of the project boundary is provided in Appendix C. 

Sources of information for cumulative effects analysis include, but are not limited to: Forest GIS 

files (project GIS geodatabase:coldsprings021411), Black Hills National Forest Schedule of 

Proposed Actions (2011) 

Forest Resources 

Introduction 

This section discusses the environmental consequences of the no action and modified proposed 

action on forest resources. It summarizes the Cold Springs Forest Vegetation Report (Orlemann 

2011), which is located in the Cold Springs project file. 

Spatial and Temporal Context for Effects Analysis 

The baseline year used for the forest resource analysis is 2010. In this analysis, all past activities 

and events are reflected in the existing condition. Activities that occurred more than about 20 

years prior to the baseline will not be specifically mentioned. Most long-term studies of forest 

vegetation condition agree that time periods from 15 to 20 years are sufficient for evaluating the 

long-term effect of silvicultural treatments (Hornbeck et al. 1993; Monleon et al. 1997; Zausen et 

al. 2005). 

Likewise, in the effects discussion below, the potential effects of the Cold Springs Project on the 

project area vegetation will not generally be forecast beyond about 15 to 20 years. The project is 

designed to improve growing conditions for residual trees. It is expected that these conditions will 

be improved and sustained over the next 20 years, decreasing insect risk and disease impacts, and 

growing larger trees faster. Speculating about effects beyond about the next two decades is 

unlikely to provide useful information to the decision maker. 
Environmental Assessment 

33 

The likely cumulative effects area (CEA) will be the affected watersheds or the areas of 

contiguous habitat. In this case, the project area lies in portions of just one watershed, Upper 

Spearfish Creek, which covers a total area of approximately 41,410 acres. This will be the areal 

extent of the CEA for the forest vegetation effects associated with the Cold Springs Project. 

No-Action Alternative 

Direct and Indirect Effects 

Forest Health 

Insect Damage 

Currently, approximately 6,800 acres (or 67 percent) of the project area pine stands have a high or 

moderate insect hazard rating. Coupled with the observed high beetle populations in the area, the 

likelihood of a continuous, widespread, epidemic-level infestation of mountain pine beetle is high 

(Allen 2010). If not treated, the hazard will remain high until stocking levels decrease due to 

mortality from mountain pine beetle activity or wildfire. In fact, studies have shown that up to 77 

percent of the ponderosa pine trees in unthinned stands may be attacked by mountain pine beetle 

in the Black Hills (Schmid and Mata 2005). Moreover, the no-action alternative would not allow 

for the mountain pine beetle population reductions associated with sanitation and salvage 

(Samman and Logan 2000). Thus, under a policy of no action, there would be no opportunity to 

improve tree vigor and resistance to insects, or to remove existing infestations from project area 

stands, and many currently forested areas could lose most of their mature pine overstory. 

Weather Damage 

Under the no-action alternative, dense pine stands may be more susceptible to snow and wind 

damage than those that have been thinned (Shepperd and Battaglia 2002; Schubert 1974; Wonn 

and O’Hara 2001). Because this was not extensively observed during stand reconnaissance, 

however, it is not expected to be a significant problem. Moreover, the potential risk of stand 

damage associated with timber treatments and prescribed fire would not occur under this 

alternative. As a result, damage will not be addressed further in this section. 

Forest Composition 

Ponderosa Pine 

Overall, ponderosa pine is well represented throughout the project area and its status as the 

dominant tree species would not be significantly impacted under the no-action alternative. It is 

likely, however, that, in the absence of treatment, specific sites would continue to transition from 

one cover type to another. Ponderosa pine would likely continue encroaching into hardwood and 

meadow areas, and filling in small openings in the forest canopy (Bock and Bock 1984; Fisher et 

al. 1987). In the densest stands, however, especially on north- and east-facing aspects, pine would 

slowly lose the regeneration battle to the more shade-tolerant white spruce (Shepperd and 

Battaglia 2002; Walker and Chapin 1986). 

White Spruce 

As noted above, white spruce would likely enjoy some competitive advantage under the no-action 

alternative. In the absence of disturbance, this may lead to some areas of pine, especially on the 

cooler and wetter sites, succeeding to spruce. This effect is unlikely to be significant.
Cold Springs Project 

34 

Hardwoods 

As the canopy closes and the conifer encroaches into other cover types under the no-action 

alternative, aspen and other hardwoods will diminish in numbers until natural disturbances once 

again open up the canopy. Within many sites, forbs and grasses in the understory will be shaded 

out, reducing quality of other resources such as wildlife habitat, forage, and visual aesthetics 

(Pase 1958).

Forest Structure 

Structural stage is an important forest attribute, categorizing stands based on tree size and density. 

Project area structural stages are displayed by project area management area in Table 5 and Table 

6. Structural stages are defined by the following conditions based on the forest plan, Phase II 

Amendment: 

 Structural Stage 1 (Grass/Forb): The grass/forb stage was historically a product of fires, 

windthrow, or similar disturbances. This stage is dominated by grasses and forbs lasting until 

tree seedlings become established. Under forest management, this stage can be created 

through harvesting. 

 Structural Stage 2 (Shrub/Seedling): The shrub/seedling stage consists of shrubs such as 

chokecherry, rose and serviceberry along with tree seedlings. A stand remains in stage 2 until 

tree seedlings reach 1 inch diameter at breast height (d.b.h.), which should take less than a 

decade. 

 Structural Stage 3 (Sapling/Pole): The sapling/pole stage consists of trees with stems 1 to 9 

inches d.b.h. This stage typically persists up to 30 years to age 70. This structural stage is 

divided further by percent of canopy closure. Canopy closure is less than 40 percent for 3A 

classifications; 3B classifications have canopy closure of 40 to less than 70 percent; and 3C is 

anything with greater than 70 percent canopy closure. 

 Structural Stage 4 (Mature): The mature stage begins when trees reach the 9-inch d.b.h. class. 

Trees remain in this stage until they are about 160 years old. As with Structural Stage 3, 

understory productivity depends upon the overstory canopy cover. Less than 40 percent 

canopy cover is 4A; 40 percent to less than 70 percent is 4B; and greater than 70 percent 

canopy closure is 4C. Tree size in this stage will vary depending upon growing-site potential 

and density of the stand. 

 Structural Stage 5 (Late Succession): This structural stage is characterized by very large trees 

(16 or more inches d.b.h.). Trees are at least 160 years old; ponderosa pine that reach this age 

are commonly referred to as “yellow barks.” Late seral ponderosa pine may occur in dense 

stands, but may also grow in the open or in “park-like” stands. 

Table 5. Cold Springs pine structural stages existing condition for MA 4.1 

Structural Stage Forestwide Objectives (percent) Percent of Existing Condition Project Area 

1 5 2.1 

2 5 6.9 

3A 10) 3.5 

3B 15 0.0 

3C 5 0.0 

4A 25 28.7 

4B 25 47.2 
Environmental Assessment 

35 

Table 5. Cold Springs pine structural stages existing condition for MA 4.1 

Structural Stage Forestwide Objectives (percent) Percent of Existing Condition Project Area 

4C 5 4.6 

5 5 7.0 

Table 6. Cold Springs pine structural stages existing condition for MA 5.1 

Structural Stage Forestwide Objectives (percent) Percent of Existing Condition Project Area 

1 5 2.0 

2 5 9.8 

3A 10 1.0 

3B 15 0.6 

3C 5 0.3 

4A 25 28.3 

4B 25 44.1 

4C 5 11.8 

5 5 2.2 

Under the no-action alternative, over-represented structural stages, such as 4A, 4B, and 4C could 

continue to develop, with the largest bulge, 4B, converting to 4C and 5 over time. On the other 

hand, the presence of outbreak levels of mountain pine beetle could cause significant mortality in 

the larger and older trees over a very short period of time (Negron et al. 2008). In this case, near 

complete mortality of the older trees will occur on up to 80 percent of structural stages 4B and 4C 

(dense stands with larger trees). Significant but lesser amounts of mortality would be expected in 

structural stage 4A due to its larger tree sizes. This high mortality will convert older stands to 

younger age structural stages. Adding younger structural stage stands helps to increase vegetative 

diversity in the area, which is currently dominated by mature pines. 

Structural Stage 4 with Very Large Tree Size 

The no-action alternative would not directly affect structural stage 4 stands that are rated as “very 

large” tree size. Indirectly, some of these stands may drop out of the classification as a result of 

high levels of mountain pine beetle-induced mortality. On the other hand, while the mountain 

pine beetle prefers larger trees (greater than 6 to 8 inches d.b.h.) over smaller trees, there is 

evidence that attacks on the largest trees are somewhat random and scattered, often leaving some 

of the larger trees unaffected (Olsen et al. 1996). Table 7 displays the percentage of structural 

stage 4, with very large trees size, in management areas 4.1 and 5.1. 

Table 7. Structural stage 4 with very large tree size 

Area MA 4.1 Existing Condition MA 5.1 Existing Condition 

Black Hills National Forest 18% (5,664 acres) 12% (45,688 acres) 

Cold Springs Project 27% (243 acres) 19% (1,447 acres) 
Cold Springs Project 

36 

Age Class Distribution 

Under the no-action alternative, there would be no change to the current age-class distribution in 

the project area (see Figure 2). In the event of a significant mountain pine beetle epidemic, 

however, most of the older and larger trees would be killed. This would shift the distribution in 

the project area toward the younger age classes. The effect is similar to the structural stage 

discussion, above. 

Figure 2. Cold Springs ponderosa pine age class distribution 

Stocking Levels 

The stocking of more than 6,000 acres of pine (or approximately 59 percent) within the project 

area currently exceeds the desired condition of 70 square feet of basal area. Under the no-action 

alternative, the effect of overstocking on project area stands would be exacerbated. These effects 

include reduced tree growth and vigor, as well as increased susceptibility to insect infestation and 

stand-replacing wildfire (Egan et al. 2010). Stands 1302-16 and 1305-5 provide good examples of 

the overstocked conditions, over 70 square feet of basal area, contemplated under the no-action 

alternative (Table 8). 

Table 8. Example of overstocked stands under the no-action alternative 

Stand Size Desired Stocking 

(basal area) 

Current Stocking 

(basal area) 

Stocking in 2030 

(basal area) 

1302-16 95 acres 70 feet or less 115 feet 157 feet 

1305-5 190 acres 70 feet or less 106 feet 136 feet 

Of course, as noted extensively in this section, these projections do not account for heavy 

mountain pine beetle mortality in the project area. In the case of an epidemic, the stands may 

achieve desired stocking rates through the work of the beetle. By modeling an outbreak in Forest 
Environmental Assessment 

37 

Vegetation Simulator9, the stocking in stand 1302-16 (by 2030) can be projected at 73 feet of 

basal area; in stand 1305-5, the number is 64. As a result, the desired condition may be attained 

by doing nothing. On the other, the forest plan directs managers to reduce stocking through 

silvicultural treatments that protect the stands from insect epidemics and provide forest products. 

Snags10

The snag population in the Cold Springs project area is currently meeting forest plan objectives. 

The most recent data indicates the conifer stands in the project area have, on average, seven to 

eight hard snags per acre. In addition, forest health surveys and field reconnaissance show that 

recent mountain pine beetle mortality affects at least 10 percent of the pines in the project area. 

These recently killed trees are adding to the snag population throughout the project area. The noaction alternative will not reduce snag densities or impact snag development. As a result, snags 

will not be addressed further in this section. 

Regeneration 

Natural regeneration in the Black Hills is generally reliable, and regeneration would not be 

directly affected by the no-action alternative. There may, however, be an indirect risk associated 

with doing nothing. In the case of a stand-replacing wildfire, regeneration may be set back in 

some areas by the absence of a nearby seed source (Bonnet et al. 2005). 

Cumulative Effects 

Forest Health 

Within the Cold Springs project area, at least 67 percent of the pine stands are currently rated at 

medium or high insect risk. Across the cumulative effects area (CEA), the figure is similar, at 67 

percent. In addition, mountain pine beetle infestations have recently been observed throughout the 

watershed (Figure 3). As a result, the likelihood of a continuous, widespread, epidemic-level 

infestation of mountain pine beetle within the cumulative effects area is high (Allen 2010). Under 

the Cold Springs proposed treatments, thinning would improve tree vigor and resistance to insects 

or disease, sanitation would remove infested trees, and hardwood enhancement treatments would 

reduce the number of mountain pine beetle host species. Under the Cold Springs no-action 

alternative, however, none of these forest health treatments would be implemented. As a result, 

the cumulative effect of no action on insect risk, is to forego the potentially beneficial effects of 

forest health treatment within the project area, and to contribute to the large acreage across the 

cumulative effects area that is highly susceptible to a mountain pine beetle outbreak. 

 

9

 Forest Vegetation Simulator (FVS) is a forest vegetation modeling program (Dixon 2002) 

10 A snag is a dead tree with no green needles. 
Cold Springs Project 

38 

Figure 3. Locations of mountain pine beetle infestations since 2008 within the cumulative effects area 

for Cold Springs 

Composition 

Ponderosa Pine 

Ponderosa pine is the dominant cover type throughout both the project area (83 percent) and the 

CEA (73 percent). While the long-term effect of no action might be a slight change in cover 

types, as noted in the discussion of direct and indirect effects, there have been sufficient 

treatments designed to maintain the health of pine throughout the CEA that the overall effect 

would be insignificant. Ponderosa pine is well represented throughout the CEA and its status as 

the dominant tree species would not be significantly impacted under the no-action alternative. As 

a result, there will be no cumulative effect to ponderosa pine composition associated with no 

action. 

White Spruce 

Across the CEA, white spruce likely enjoys a competitive advantage over ponderosa pine in the 

absence of treatment or other disturbance. This could lead to some areas of pine converting, over 
Environmental Assessment 

39 

time, to areas of spruce. In this case, however, the direct and indirect effects of no action on white 

spruce composition were found to be insignificant. Without direct effects, there can be no 

cumulative effects.

Hardwoods 

The hardwood regeneration and weeding treatments planned or implemented across the CEA are 

designed to shift species composition away from conifers and back toward hardwoods. For the 

41,410-acre Cold Springs CEA, these treatments have totaled approximately 780 acres. This is a 

tiny step intended to arrest the decline of hardwoods in the northern Black Hills. Under the noaction alternative for Cold Springs, this acreage total would remain unchanged. On the other 

hand, should the extent of the current mountain pine beetle infestation grow significantly across 

the CEA, the opportunities for canopy-opening disturbances that favor shade-intolerant hardwood 

species may increase. 

Forest Structure 

Across the CEA, structural stages 4B and 4C are over-represented (Table 9 and Table 10). Under 

the no-action alternative, these over-represented structural stages, could continue to develop, with 

the largest bulge, 4B, converting to 4C and 5 over time. On the other hand, as has been noted 

under the description of the current condition and the direct effects of no action, the presence of 

outbreak levels of mountain pine beetle could cause significant mortality in the larger and older 

trees (Figure 3).In this case, near complete mortality of the larger trees could occur on up to 80 

percent of structural stages 4B and 4C (dense stands with larger trees). Significant but lesser 

amounts of mortality would be expected in structural stage 4A due to its larger tree sizes. This 

high mortality will convert older stands to younger age structural stages. Adding younger 

structural stage stands helps to increase vegetative diversity across the CEA, which is currently 

dominated by mature pines. 

Table 9. Structural stages for MA 4.1 across the cumulative effects area under the no-action 

alternative 

Structural 

Stage 

Forestwide Objectives 

(percent) 

CEA Under No Action 

(percent) 

1 5 0.9 

2 5 6.1 

3A 10 3.2 

3B 15 3.5 

3C 5 3.3 

4A 25 23.4 

4B 25 42.5 

4C 5 12.0 

5 5 5.0 
Cold Springs Project 

40 

Table 10. Structural stages for MA 5.1 across the cumulative effects area under the no-action 

alternative 

Structural 

Stage 

Forestwide Objectives 

(percent) 

CEA Under No Action 

(percent) 

1 5 1.9 

2 5 7.6 

3A 10 2.3 

3B 15 1.2 

3C 5 1.1 

4A 25 27.0 

4B 25 42.5 

4C 5 14.9 

5 5 1.5 

Ultimately, the cumulative effect of no action for Cold Springs is to contribute additional acres to 

the large percentage of high-risk stands across the cumulative effects area. Currently, more than 

55 percent of the cumulative effects area is in structural stages 4B and 4C, which are 

characterized by dense stands of larger trees. These are the conditions that are most susceptible to 

large-scale disturbances such as insect epidemics and wildfires. 

Structural Stage 4 with Very Large Tree Size 

In MA 4.1, approximately 18 percent of the SS4 pine stands are rated as “very large;” for MA 5.1, 

the percentage is approximately 14 percent. Under the Cold Springs no-action alternative, these 

percentages will not be directly affected. Indirectly, some of these stands may drop out of the 

classification as a result of high levels of mountain pine beetle-induced mortality. 

Age Class Distribution 

Approximately 76 percent of the stands in the CEA for which stand age is available 

(approximately 34,000 acres) are 100 years of age or older. This is almost identical to the current 

condition within the Cold Springs project area. The distribution of age classes in the CEA ranges 

from 0 to 230 years, with the majority of stands in the 90- to 140-year age classes. The age class 

curve is a bell-shaped curve with the greatest acreage in the 100-year class (Figure 4). 
Environmental Assessment 

41 

Figure 4. Cold Springs cumulative effects area age class distribution as compared to the project area 

Under the no-action alternative, there would be no change to the current age class distribution 

throughout the CEA. In the event of a significant mountain pine beetle epidemic, however, most 

of the older and larger trees would be killed. This would shift the distribution in the CEA toward 

the younger age classes. The effect is similar to the structural stage discussion, above. 

Stocking and Stand Density 

Stocking Levels 

As noted in the description of existing condition, many of the Cold Springs project area stands are 

above the desired stocking level of 70 square feet of basal area; 60 percent of them exceed 80 

square feet of basal area. The situation across the CEA is similar, but slightly worse (Table 11). In 

fact, approximately 67 percent of stands within the CEA have stocking levels that exceed the 

forest plan desired condition of 70 square feet of basal area (as opposed to 59 percent of the 

project area). 

Table 11. Comparison of percentage of project area and cumulative effects area stocking levels in 

square feet of basal area 

Area 0 to 40 BA 40 to 80 BA 80 to 120 BA Greater than 120 

BA 

Project Area 25% 16% 47% 13% 

CEA 26% 10% 43% 21% 

Within the CEA, other timber management activities completed in the past 5 years have 

effectively reduced stocking. Stands 1304-61 and 1304-62, for example, were treated with 

shelterwood establishment cuts under the Pond timber sale. Those stands are currently stocked 

(with trees larger than 5 inches d.b.h.) at 26 and 34 square feet of basal area, respectively. Many 

of the CEA stands that are at or below 70 square feet of basal area were treated with an 

establishment or overstory removal cut fairly recently. Those that have been thinned, especially 
Cold Springs Project 

42 

where the thinning took place more than a decade ago, are quickly returning to levels exceeding 

the desired 70 square feet of basal area. This is because thinning creates opportunities for 

increased growth immediately post-thinning (Sala et al. 2005). Stands 304-16 and 304-28, for 

example, were commercially thinned during the mid-1990s under the Stageyard timber sale. 

These stands are currently stocked at 100 and 87 square feet of basal area, respectively. 

The cumulative effect of the no-action alternative under Cold Springs would be to leave project 

area stands above desired stocking levels (70 square feet of basal area), contributing to the 

overstocked condition of the entire watershed. Of course, as noted above, in the case of a 

mountain pine beetle epidemic, some of the CEA may achieve desired stocking rates through the 

work of the beetle. 

Regeneration 

As noted elsewhere in this report, natural regeneration in the Black Hills is generally reliable, and 

is not directly affected by the no-action alternative. While there may be an indirect risk regarding 

the effect of high-severity wildfire on regeneration associated with no action (Bonnet et al. 2005), 

the risk is likely to be very low (Lentile et al. 2005), and an attempt to quantify it would be highly 

speculative. As a result, there will be no further discussion of the cumulative effect of doing 

nothing on regeneration success within the CEA. 

Modified Proposed Action Alternative 

Direct and Indirect Effects 

Forest Health 

Insects and Disease 

Thinning of forest stands can improve individual tree vigor and growth, as well as resistance to 

insects and disease (Amman and Logan 1998; Fettig et al. 2007; Fettig et al. 2010; Wallin et al. 

2008). Thinning that opens the forest canopy may also reduce risk by altering the microclimate 

such that pheromone plumes are disrupted (Powell et al. 2000). As a result, forest entomologists 

and managers who have reviewed the Cold Springs stands, as well as those from other areas of 

the Black Hills have recommended silvicultural treatments to reduce insect risk (Allen 2010; 

Bobzien 2010). In fact, according to Schmid et al. (2007), the most important aspect of managing 

mature ponderosa pine stands in the Black Hills is minimizing mountain pine beetle-caused 

mortality through tree thinning. The approximately 4,400 acres of conifer thinning and 

shelterwood cuttings included in the modified proposed action would provide benefits associated 

with reduced competition on tree growth and vigor, while reducing the acres rated as high insect 

risk to fewer than 1,000 (Table 12). The resulting stands would be more resilient to future bark 

beetle outbreaks and would be moving toward the desired future condition (Figure 5). 

 
Environmental Assessment 

43 

Table 12. Insect risk ratings for ponderosa pine (in acres) under the proposed action 

Risk Rating Existing Condition Proposed Action 

Low 3,343 (33%) 6,392 (63%) 

Medium 1,937 (19%) 3,009 (29%) 

High 4,924 (48%) 804 (8%) 

Figure 5. Proposed action insect risk rating for Cold Springs pine stands as compared to the current 

condition 

The sanitation and salvage treatments would remove (and/or destroy) trees infested with 

mountain pine beetles, thereby reducing current insect populations. These techniques have been 

successfully used to suppress localized populations (Samman and Logan 2000). Allen and Ball 

(2010) concluded that removal of infested trees can help reduce local mountain pine beetle 

populations. 

Salvage treatments involve the removal of infested trees from the stand. Objectives of this 

treatment are to suppress bark beetle populations in local pockets of activity and utilize the timber 

resource in the short period before it deteriorates (Lowell and Cahill 1996). Salvage treatments 

would not affect mortality rates nor would they reduce the susceptibility of stands to subsequent 

bark beetle attacks (Amman et al. 1985). Likewise, the proposed precommercial thinning would 

not influence current spruce beetle mortality rates. 

Finally, the aspen release treatments would essentially eliminate any current risk from mountain 

pine beetle mortality with the removal of all the pine. In sum, management for aspen and 

structural conifer diversity would reduce the potential risk from bark beetle infestation, because 

dense stands of large-diameter conifers are those most susceptible to losses from beetle attacks. 

Weather and Mechanical Damage 

The proposed action is likely to help reduce the potential for snow and wind damage in overly 

dense stands by thinning to produce improved diameter growth (Wonn and O’Hara 2001). 
Cold Springs Project 

44 

Moreover, to ensure that treatments do not make some stands more susceptible to these damaging 

agents, some older, dense stands would be regenerated in two steps to give individual trees the 

opportunity to develop firmness. This includes the proposed 638 acres of shelterwood 

preparation, as well as the two-step shelterwood removals. These techniques are commonly used 

in the Black Hills (Boldt et al. 1983; Shepperd and Battaglia 2002). 

Logging damage is generally minimized in operations on the Black Hills by the use of 

mechanical fellers and by careful skidding (Hartsough 2003). The project design features provide 

that felling and skidding are managed under the timber sale contract and approved by the Forest 

Service timber sale administrator. Likewise, achieving prescribed fire objectives while 

maintaining the health of existing trees has been extensively studied and documented for the 

Black Hills (Battaglia et al. 2008; Battaglia et al. 2009; Hood 2010). Moreover, the project design 

features ensure that prescribed fire would only be implemented under conditions defined in a burn 

plan. As a result, the proposed action is unlikely to have significant direct or indirect effects on 

tree damage. 

Forest Composition 

Ponderosa Pine 

The modified proposed action calls for maintenance, thinning, shelterwood preparation, as well as 

regeneration establishment treatments in ponderosa pine. These treatments have been effective at 

providing for the continued presence of healthy stands of ponderosa pine in the Black Hills 

(Shepperd and Battaglia 2002). Implementation of the modified proposed action will not cause a 

significant change in the dominance of ponderosa pine cover types in the project area. 

White Spruce 

The inclusion of approximately 630 acres of single-tree selection in the modified proposed action 

is likely to favor the continued maintenance and expansion of spruce. Single-tree selection is an 

uneven-aged management system that promotes a variety of structural stages and compositional 

diversity. These treatments result in fewer canopy gaps and less mechanical disturbance than 

typical even-aged systems. As a result, shade-tolerant and mid-seral species such as white spruce 

enjoy a successional boost from these treatments (Graham and Jain 2005). On the other hand, the 

area proposed for these treatments is relatively small (approximately 5 percent of NFS lands 

within the project area), and selection cutting does provide some opportunity for ponderosa pine 

regeneration (Fiedler 1996). As a result, the effect of the proposed action on the areal extent of 

white spruce is unlikely to be significant.

Hardwoods 

The release of approximately 570 acres of hardwoods (aspen/birch) from pine competition by the 

commercial and noncommercial removal of conifers is proposed in this alternative. Though the 

actual acreage of aspen will increase, it is anticipated that the increase will be less than 5 percent 

of the commercially treated pine acres. Consequently, no change of cover type from pine to aspen 

is anticipated. When applied to stands with an aspen cover type, all commercial and noncommercial pine would be removed from the stand. This will move the area toward the forest 

plan goal of increasing the aspen component, but it will not reach the goal of doubling the extent 

of aspen across the forest. The effects of this treatment will be an increase in vegetative diversity 

and increased vigor of hardwood communities by release from the competition of pine (Jones et 

al. 2005). Moreover, the project design features, such as the plan to cut and hinge all conifers 

within these units, will serve to protect aspen regeneration from excessive ungulate browsing. 
Environmental Assessment 

45 

Forest Structure 

Under the modified proposed action, stand structure generally would change from a closedcanopy structure to an open-canopy structure. Approximately 3,400 acres would move from the 

more closed 4B and 4C structures to the open structures of 3A and 4A (Table 13 and Table 14). 

The 3A structure is generally created by shelterwood removal treatments, while commercial 

thinning and shelterwood preparation create 4A structures. These treatments are designed to 

reduce mountain pine beetle risk as well as fire hazard. This alternative is intermediate in its 

effect on moving the area toward the desired condition for structural stage; it is an improvement 

as compared to the no-action alternative, but it leaves a significant portion of the project area in 

structural stage 4A (Figure 6). 

Table 13. Cold Springs pine structural stages for MA 4.1 under the proposed action 

Structural Stage Forestwide Objectives (percent) Proposed Action (percent) 

1 5 2.1 

2 5 6.9 

3A 10 7.2 

3B 15 0.0 

3C 5 0.0 

4A 25 58.8 

4B 25 16.6 

4C 5 1.4 

5 5 7.0 

Table 14. Cold Springs pine structural stages for MA 5.1 under the proposed action 

Structural Stage Forestwide Objectives (percent) Proposed Action (percent) 

1 5 2.0 

2 5 9.8 

3A 10 3.6 

3B 15 0.8 

3C 5 0.3 

4A 25 58.1 

4B 25 20.1 

4C 5 3.1 

5 5 2.2 

Structural stage 4A is characterized by larger trees and a more open canopy (less than 40 percent 

canopy closure) as compared to the other structural stages. As a result, 4A stands are generally 

rated at medium and low insect risk and moderate and low fire hazard, which is a significant 

improvement over structural stages 4B and 4C. This meets the purpose and need for this project. 

In addition, it is worth noting that many of the treatments are simply the first step in moving the 

project area toward the desired future condition. For example, treatments such as “shelterwood 

preparation” are designed to prepare the stand for future shelterwood treatments, which will have 

the effect of regenerating the stands and moving them into structures 3A and 3B. In other words, 

the bulge in structural stage 4A associated with the proposed action is not a static condition, but is 
Cold Springs Project 

46 

preparatory to moving a further percentage of the project area toward the desired future condition. 

Finally, the forest plan objectives are to be applied on a forestwide basis. An abundance of 4A in 

one small project area has a very tiny and temporary effect on the forestwide condition, which is 

currently close to the desired condition. 

Figure 6. Proposed action structural stages for Cold Springs as compared to the current condition 

and the forestwide objectives 

Structural Stage 4 with Very Large Tree Size 

For MA 4.1 within Cold Springs, all of the stands that meet the structural stage 4 with very large 

tree size criteria are in structural stage 4A. As a result, these are relatively open stands of larger 

trees which have not been proposed for treatment under the Cold Springs Project. Because they 

will not be treated, the potential direct, indirect, and cumulative effects associated with MA 4.1 

for structural stage 4 with very large tree size is the same as that described under the no-action 

alternative. The large tree objective as it relates to MA 4.1 will not be discussed further in this 

document. 

Proposed actions in MA 5.1 structural stage 4 stands that meet the very large tree size 

requirement can generally be divided into two groups: First, even-aged regeneration treatments, 

such as shelterwood removals, and establishment cuts (especially where advanced regeneration is 

already present) are designed to remove the existing overstory and provide for growing space for 

seedlings and saplings. Where these are planned, the stands would likely no longer meet the 

structural stage 4 with very large tree size requirement. In addition, single-tree selection 

treatments, because they remove trees through all diameter ranges are likely to shift average tree 

diameters toward the lower size classes. The total acreage of structural stage 4 stands with very 

large tree sizes proposed for these treatments is 373. Second, stands that have been proposed for 

treatments designed to thin smaller trees and open the stand, either in preparation for shelterwood 

establishment or as an intermediate treatment, can be expected to retain the structural stage and 

large tree component required for this forest plan objective. 
Environmental Assessment 

47 

Finally, it should be noted that other structural stage 4 stands with “large” trees that do not 

currently qualify for the “very large” tree size objective might be moved into that group by 

treatments that thin from below and shift the composition of the stand toward trees that are 16 

inches or greater. For example, stand 70503-23 is currently stocked with pine that averages 8 

inches in diameter. It is proposed for treatments including a precommercial thin, as well as a 

commercial thinning from below. When modeled in FVS, the result is an average tree size of 15 

inches, not enough to qualify as “very large,” but close enough to demonstrate that there may be a 

few stands that shift into the category as a result of treatment. Thus, the proposed action would 

result in approximately 14 percent of MA 5.1 in structural stage 4 with very large tree size, and 

with time, through growth, additional stands will become structural stage 4 with very large tree 

size (see Table 15). 

Table 15. Structural stage 4 with very large tree size under the proposed action 

Area MA 5.1 Existing Condition MA 5.1 Proposed Action 

Black Hills National Forest 12% (45,688 acres) 12% (45,315 acres) 

Cold Springs Project 19% (1,447 acres) 14% (1,074 acres) 

Age-Class Distribution 

Age-class distribution would improve in this alternative by removing the overstory on 

approximately 360 acres. In addition, the shelterwood establishment cuts on 1,290 acres should 

establish regeneration under the reserve trees, providing future young stands. In this alternative, 

there will be an increase in the younger, early-successional stages to better align with forest plan 

objectives. There will also be an increase in the sapling and pole age classes due to removal of 

larger and older pine to move toward forest plan structural stage objectives. 

Stocking 

In general, the desired condition for stocking is to have stand basal areas at or below 70 square 

feet per acre or less in pine stands. It is well documented that highly stocked stands are at greater 

risk from forest pests than those at lower stocking levels (Negron et al. 2008; Sartwell and 

Stevens 1975; Schmid and Mata 2005; Negron et al. 2009). More than 6,000 acres of pine (or 

approximately 60 percent) within the project area currently have basal areas exceeding 70 square 

feet of basal area. Under the proposed action, approximately 4,300 acres of these overstocked 

stands would be treated to reduce stocking to 70 square feet of basal area or less—thus meeting 

the desired condition on approximately 80 percent of the area. As an example, stands 1302-16 and 

1305-5 were modeled using FVS to simulate stocking levels associated with the proposed action. 

For a comparison with the stocking conditions of these two stands under the no-action alternative, 

see Table 16. 

Table 16. Example of overstocked stands under the proposed action alternative (basal area) 

Stand Size Desired 

Stocking 

Current 

Stocking Proposed Action Stocking 2020 

Stocking 

2030 

1302-16 95 acres 70 feet or less 111 feet Commercial thin to 70 84 feet 98 feet 

1305-5 190 acres 70 feet or less 103 feet Establishment cut to 30 44 feet 81 feet 
Cold Springs Project 

48 

Regeneration 

Natural regeneration in the Black Hills is generally reliable and abundant (Boldt et al. 1983). 

Treatments that reduce canopy closure and disturb duff and litter layers are especially effective at 

providing for regeneration. Under the modified proposed action, thinning and regeneration 

treatments on approximately 4,400 acres would be expected to stimulate natural regeneration. 

This is especially true of the proposed establishment cuts (1,290 acres), which will substantially 

open the canopy (30 square feet of basal area) and will provide scarification to promote 

germination and seedling establishment. Moreover, project design features associated with the 

proposal specifically protect advanced regeneration and provide for site scarification through 

summer or early autumn logging. In addition, fuel treatments conducted after timber cutting, such 

as low-intensity prescribed fire, should have positive effects on natural regeneration in pine 

stands (Moghaddas et al. 2008; Peters and Sala 2008). Finally, monitoring of regeneration success 

will be completed under the Black Hills Monitoring Plan. 

Snags 

The modified proposed action includes sanitation and salvage of green mountain pine beetleinfested trees only. As a result, snags would not be directly affected by the proposal. Incidental 

removal may occur for safety purposes under the project design features, but this would not 

measurably reduce the current abundance of snags across the project area. Indirectly, taking 

actions to improve tree vigor and reduce mountain pine beetle susceptibility as proposed may 

reduce the future rate of snag recruitment. Because snags are, however, currently abundant at both 

the project and forest level, and because the mountain pine beetle epidemic is likely to continue 

killing trees across the forest, this potential indirect effect is not considered significant. 

Cumulative Effects 

Forest Health 

Insects and Disease 

Under the Cold Springs modified proposed action, thinning would improve tree vigor and 

resistance to insects or disease, sanitation and salvage would remove infested trees, and hardwood 

enhancement treatments would reduce the number of mountain pine beetle host species. As a 

result, the areal extent of stands rated as high insect risk would be reduced by approximately 

4,100 acres. These improvements would provide a modest benefit across the CEA, reducing the 

areas rated as medium to high insect risk from 89 percent to 79 percent. 

Forest Composition 

Ponderosa Pine 

Ponderosa pine dominates approximately 73 percent of the CEA. Many of the treatments under 

the modified proposed action are designed to improve the health of project area ponderosa pine 

stands. When added to several thousand acres of pine treatments across the CEA during the past 

10 or 15 years, these treatments should have the effect of maintaining the dominance of pine 

throughout the area. Because implementation of the Cold Springs proposed action will not cause 

a significant change in the dominance of ponderosa pine cover types in the project area, there will 

be no cumulative effect. 
Environmental Assessment 

49 

White Spruce 

There are approximately 5,590 acres of white spruce within the CEA, including about 850 acres 

in the project area. As noted in the discussion of direct and indirect effects, above, the effect of 

treating approximately 650 acres with single-tree selection is likely to favor white spruce slightly. 

The effect of the proposed action on white spruce composition has, however, been found to be 

insignificant. Without direct effects, there can be no cumulative effects. 

Hardwoods 

The hardwood regeneration and weeding treatments planned or implemented across the CEA total 

approximately 780 acres. Under the proposed action, Cold Springs would add approximately 630 

acres, for a cumulative total of about 1,400 acres. This will move the CEA toward the forest plan 

goal of restoring the hardwood component, though it will not reach the goal of doubling the 

extent of aspen across the forest. 

Forest Structure 

As a direct effect of the modified proposed action, stand structures will move toward forest 

objectives, with the exception of structural stage 4A, which becomes increasingly overrepresented in the project area. Likewise, across the CEA, the Cold Springs proposal has the 

effect of reducing the bulge of stands in structural stages 4B and 4C, closed-canopy stands, while 

increasing the proportion of 4A, open structured. As has been noted, this effect should reduce 

mountain pine beetle risk as well as fire hazard. It is also a temporary condition that is a step 

toward the desired future condition. Moreover, the effect across the CEA is essentially to provide 

a more balanced distribution of large tree conditions along with a modest reduction in the hazards 

associated with large areas of closed-canopy forests (see Table 17 and Table 18). 

Table 17. Structural stages for MA 4.1 across the cumulative effects area under the proposed action 

alternative 

Structural 

Stage 

Forestwide Objectives 

(percent) 

CEA Under the Proposed 

Action (percent) 

1 5 0.9 

2 5 6.1 

3A 10 4.1 

3B 15 3.5 

3C 5 3.3 

4A 25 30.3 

4B 25 35.5 

4C 5 11.3 

5 5 5.0 
Cold Springs Project 

50 

Table 18. Structural stages for MA 5.1 across the cumulative effects area under the proposed action 

alternative 

Structural 

Stage 

Forestwide Objectives 

(percent) 

CEA Under the Proposed 

Action (percent) 

1 5 1.9 

2 5 7.6 

3A 10 3.1 

3B 15 1.3 

3C 5 1.1 

4A 25 36.6 

4B 25 34.7 

4C 5 12.2 

5 5 1.5 

Structural Stage 4 with Very Large Tree Size 

As noted above, stands across the cumulative effects area are currently meeting the forest plan 

goal for structural stage 4 with very large tree size. In MA 5.1, the percentage is currently 

approximately 14 percent. Under the Cold Springs proposed action, approximately 373 acres are 

proposed for treatments that would eliminate them from consideration under this objective. That 

reduction in acreage would change the approximate percentage in MA 5.1 across the CEA to 12 

percent. As a result, it will continue to meet the forest plan objective. 

Age Class Distribution 

Age class distribution across the CEA will improve under the Cold Springs modified proposed 

action alternative by removing the overstory on approximately 360 acres within the project area. 

In addition, the shelterwood establishment cuts on 1,290 acres should establish regeneration 

under the reserve trees, providing future young stands. The cumulative effect of these changes 

will, however, be minor. For example, overstory removal will occur on just 1 percent of the CEA. 

This should be, generally, a beneficial effect in the CEA because there will be an increase in the 

younger, early successional stages to better align with forest plan objectives. The effect, however, 

will not be significant. 

Stocking 

As noted in the description of existing condition, many of the Cold Springs project area pine 

stands are in a fully stocked condition; 60 percent of them exceed 80 square feet of basal area. 

The situation across the CEA is similar but slightly worse; approximately 67 percent of pine 

stands within the CEA have stocking levels that exceed the forest plan desired condition. The 

cumulative effect of the proposed action alternative under Cold Springs would be to reduce the 

project area acreage that is stocked at levels beyond the desired condition of 70 square feet of 

basal area, contributing to a reduction in stocking across the CEA. This would have the effect of 

reducing the area of CEA pine stands that are stocked at over 70 square feet of basal area from 

around 64 percent of the watershed to approximately 48 percent of the watershed, moving the 

CEA toward the forest plan desired conditions (Table 19). 
Environmental Assessment 

51 

Table 19. Comparison of no-action and proposed action stocking levels across the cumulative effects 

area (in acres and percentages) 

Action 0 to 40 basal 

area 

40 to 80 basal 

area 

80 to 120 basal 

area 

Greater than 120 basal 

area 

No 7,786 (26%) 3,111 (10%) 12,980 (43%) 6,344 (21%) 

Proposed 10,191 (34%) 5,541 (18%) 9,198 (30%) 5,308 (18%) 

Regeneration 

Under the discussion of direct and indirect effects, above, it was noted that treatments that reduce 

canopy closure and disturb duff provide for abundant regeneration in the Black Hills. The 

cumulative effect of the Cold Springs Project would be to add approximately 4,400 treated acres 

to the treatment total for the CEA. While this is likely to provide some additional benefits in 

terms of regeneration success, the effect is relatively insignificant since natural regeneration is 

generally reliable and abundant throughout the Black Hills. 

Summary and Comparison 

The modified proposed action includes forest vegetation treatments that would reduce stocking 

and corresponding risk of mountain pine beetle attack across approximately 4,904 acres (40 

percent of forest stands on National Forest System lands within the project area). In addition to 

reduced stocking, proposed treatments would increase stand age-class and species diversity, 

which reduces the amount of host material that would be susceptible to mountain pine beetle 

attack at any given time. Sanitation and salvage treatments would also decrease mountain pine 

beetle populations. 

Insect risk for ponderosa pine stands would be reduced. Table 20 displays the existing (no-action 

alternative) insect risk and the insect risk following treatments under the modified proposed 

action. 

Table 20. Insect risk ratings for ponderosa pine (in acres) under the proposed action 

Risk Rating Existing Condition Proposed Action 

Low 3,343 (33%) 6,392 (63%) 

Medium 1,937 (19%) 3,009 (29%) 

High 4,924 (48%) 804 (8%) 

Treatments that reduce stocking would shift approximately 3,400 acres of forest from structural 

stages 4C and 4B to structural stage 4A or 3A. 

Age class distribution would improve by removing the overstory on approximately 360 acres. In 

addition, the shelterwood establishment cuts on 1,290 acres should establish regeneration under 

the reserve trees, providing future young stands. 

Approximately 570 acres of hardwoods would be released from pine competition and 630 acres 

of single-tree selection would favor the maintenance and expansion of white spruce. 

The sanitation and salvage treatments would remove (and/or destroy) trees infested with 

mountain pine beetles, thereby reducing current insect populations. Sanitation and salvage 

treatments could take place across all project area forest stands 
Cold Springs Project 

52 

The modified proposed action would not directly affect project area snag numbers, with the 

exception of incidental removal for safety purposes. 

Fire and Fuels 

Introduction 

This section discusses the environmental consequences of the no action and modified proposed 

action on project area fire hazard, fire regime and condition classes. It summarizes the Cold 

Springs Fire and Fuels report (Lewis 2011), which is located in the Cold Springs project file. 

Fire Regime and Condition Class 

A natural fire regime is a general classification of the role fire would play across a landscape in 

the absence of modern human mechanical intervention, but including the influence of aboriginal 

burning (Agee 1993). The five natural (historical) fire regimes are classified based on average 

number of years between fires (fire frequency) combined with the severity (amount of 

replacement) of the fire on the dominant overstory vegetation. These five regimes include: 

 I – 0 to 35-year frequency and low- (surface fires most common) to mixed-severity (less than 

75 percent of the dominant overstory vegetation replaced); 

 II – 0 to 35-year frequency and high (stand-replacement) severity (greater than 75 percent of 

the dominant overstory vegetation replaced); 

 III – 35- to 100+-year frequency and mixed-severity (less than 75 percent of the dominant 

overstory vegetation replaced); 

 IV – 35- to 100+-year frequency and high (stand replacement) severity (greater than 75 

percent of the dominant overstory vegetation replaced); 

 V – 200+-year frequency and high (stand-replacement) severity. 

Three Fire Condition Classes categorize and describe vegetation composition and structure 

conditions that currently exist inside the Fire Regime Groups. Based on the coarse-scale national 

data (Schmidt et al. 2002), they serve as generalized wildfire risk rankings. The risk of loss of key 

ecosystem components from unwanted wildland fire increases from Fire Condition Class 1 

(lowest risk) to Fire Condition Class 3 (highest risk). 

Condition classes are a way of categorizing how much key ecosystem components such as 

species composition, structural stage, and stocking level have changed in an area due to changing 

fire regimes. 

There are three condition classes: 

 Condition Class 1: Fire regimes are within an historical range and the risk of losing key 

ecosystem components is low. Vegetation attributes (species composition and structure) are 

intact and functioning within their historical range. 

 Condition Class 2: Fire regimes have been moderately altered from their historical range. The 

risk of losing key ecosystem components is moderate. Fire frequencies have departed from 

historical frequencies by one or more return intervals (either increased or decreased), 

resulting in moderate changes to one or more of the following: fire size, intensity and severity 

and landscape patterns. Vegetation attributes have been moderately altered from their historic 

range. 
Environmental Assessment 

53 

 Condition Class 3: Fire regimes have been significantly altered from their historical range. 

The risk of losing key ecosystem components is high. Fire frequencies have departed from 

historical frequencies by multiple return intervals. This results in dramatic changes to one or 

more of the following: fire size, intensity, severity, and landscape patterns. Vegetation 

attributes have been significantly altered from their historical range. 

Fire Regime Condition Class (FRCC) is a composite of fire regimes and condition classes stated 

above. As noted in the Interagency Fire Regime Condition Class (FRCC) Guidebook (2008), 

FRCCs are used to describe general fire regime and vegetation traits for the historical (reference) 

versus current periods to produce departure estimates. 

The Black Hills ponderosa pine forest is recognized as classic Fire Regime 1. There are ample 

historic examples of the relatively frequent, low-intensity fires and the resulting vegetative 

structure. Historically, a given acre of forest would have burned every 10 to 40 years. With the 

shortest return intervals on the dryer pine sites. The Cold Springs project area is dominated by 

ponderosa pine sites, although there are stands that are classified as aspen, grass, and white 

spruce. 

Fire Hazard 

Fire hazard generally refers to the difficulty of controlling potential wildfire. It is commonly 

determined by fire behavior characteristics such as rate of spread, intensity, torching, crowning, 

spotting, fire persistence and by resistance-to-control. 

Flame length and fire type are two important aspects of fire behavior because they determine 

what type of firefighting resources are needed, and what kind of resistance to control there will 

be. The Black Hills National Forest utilizes a matrix to designate fire hazard ratings based upon 

forested structural stage, species, and average tree size diameter. The forest utilizes a similar 

matrix to determine post-treatment fire hazard ratings based upon specific silvicultural treatments 

and whether additional fuel treatments such as prescribed burning follow. The rating system is a 

convenient way to express the overall hazard of fuels conditions in the area, taking into account 

the full fuels complex including surface, ladder, and canopy fuels. The nature of the rating system 

is such that flame length and anticipated fire type are incorporated into the rating. As such, a Low 

rating would mean that the anticipated fire type is surface and flame lengths are considered low. 

The Wildland-Urban Interface 

The wildland-urban interface (WUI) is the zone where human developments meet or intermingle 

with undeveloped wildlands. For the purposes of this analysis, the 1⁄2-mile buffer is regarded as 

lands within the designated WUI. There are 57 homes within or directly adjacent to the project 

area boundary. In addition, there are an additional 26 occupied structures within 2 miles of the 

project area. 

Spatial and Temporal Context for Effects Analysis 

The area considered for cumulative effects is the project boundary. This area was selected 

because collective activities within this area can modify fire behavior. Although the effects 

outside this boundary could notably influence fire behavior, the spatial magnitude (size) of this 

boundary was determined quite adequate from a fire management perspective. The existing 

condition reflects the effects of past activities, including fire suppression. Fuel models and stand 

conditions reflect the changes associated with activities affecting fire hazard, fire regime and 

condition class up to the present. 
Cold Springs Project 

54 

No-Action Alternative 

Direct/Indirect Effects 

Future fire activity and severity in the Cold Springs project area will depend on a number of 

interacting factors, including the amount of mortality, vegetation, environmental conditions, and 

the time from the mortality occurring to a fire’s occurrence. The likelihood of an ignition 

occurring (risk) is not likely to be affected to a measurable degree between either alternative in 

the Cold Springs Project. Because the level of insect-caused mortality in the future is not known, 

the exact changes to the future fuel loading and stand structure is not a precise measurement. 

Therefore, projecting fire hazard for no action is based upon current conditions. 

Under the no-action alternative, no activities would occur and no silvicultural or fuels reduction 

treatments would be implemented. There would be no treatment of surface, ladder, or canopy 

fuels in either the WUI or areas beyond the 1⁄2-mile designated WUI area. Based on current stand 

conditions, much of the area is rated as having a High or Very High fire hazard rating (see Table 

21). This hazard will increase over time, with growth, due to increasing levels of surface, ladder, 

and canopy fuels. 

Table 21. Existing project area fire hazard rating on National Forest System lands 

Existing Fire Hazard 

Rating Acres Percent of project area 

Low 1,493 13 

Medium 3,460 28 

High 5,222 42 

Very High 2,144 17 

Currently, approximately 59 percent of the project area pine stands have a High or Very High fire 

hazard rating (see Table 21). Under no action, there would be no opportunity to reduce the fire 

hazard rating as directed under forest plan objective 10-01, or in accordance with the national fire 

plan. There would be no removal or treatment of available fuels to reduce the fire hazard to meet 

this standard. 

WUI areas would continue to have excess amount of areas in High to Very High fire hazard 

ratings (see Table 22). As such, the forest would not be responsive to the Lawrence County 

Community Wildfire Protection Plan, nor would it meet the direction for WUI areas under forest 

plan objective 10-01. Currently 60 percent of the WUI area within the Cold Springs Project is 

rated as having a High or Very High fire hazard rating. 

Table 22. Existing project area WUI fire hazard ratings on National Forest System lands 

Existing WUI Fire Hazard 

Rating Acres Percent of WUI 

Low 154 13 

Medium 323 27 

High 359 30 

Very High 370 30 
Environmental Assessment 

55 

Fire regimes have been significantly altered from their historical range within the project area. 

The risk of losing key ecosystem components is high. Fire history for the project area shows that 

fire frequencies have departed from historical frequencies by multiple return intervals. This has 

the potential to result in dramatic changes to one or more of the following: fire size, intensity, 

severity, and landscape patterns. Vegetation attributes have been significantly altered from their 

historical range. With the exception of the more recent mechanical treatments, most of the project 

area would remain in Condition Class III. There would be no improvement in the amount of lands 

that are in a more resilient condition class. 

Cumulative Effects 

The cumulative effects area has been managed through activities such as logging, most notably 

from the 1990s and 2000s. Past activities include a variety of prescriptions associated with 

several projects such as commercial thinning and precommercial thinning. A variety of treatment 

methods have included mechanical piling, hand piling, and prescribed burning. 

The existing condition reflects the effects of past activities, including fire suppression. Fuel 

models and stand conditions modeled reflect the changes associated with activities affecting fire 

behavior and hazard up to present. 

Under the no-action alternative, the cumulative effects of past management actions and the 

continuation of fire suppression without management action, combined with vegetation growth 

and tree mortality, would result in the area trending toward increasing fire hazard. 

Modified Proposed Action 

Direct and Indirect Effects 

The modified proposed action would reduce stocking and fuels on approximately 5,144 acres. 

Proposed treatment activities would reduce surface fuels, remove ladder fuels, and decrease tree 

crown density. Trees of commercial size would be whole-tree yarded, pile and burned at central 

landings. Under this alternative, post treatment conditions would result in substantially reduced 

fire hazard ratings over a substantial portion of the project area. Generally speaking, the treated 

units would have reduced fire hazard, resulting in less fire intensity, torching, and severe crown 

fire. The most notable change is the reduction of acres from Very High to Low. 

Thinning from below would reduce the ladder fuels in ponderosa pine stands. The larger trees that 

remain on the site will be more resistant to fire due to decreased flame lengths from the removal 

of ladder fuels. The decreased density would be less likely to support running crown fires. 

Mechanical whole-tree harvest removes much of the activity fuels, depositing them at central 

processing landings for treatment. Stands that have had whole-tree harvesting treatments have a 

lower fuel hazard due to reduced 3-inch and less fuel, and reduced canopy density and ladder 

fuels. These cutting practices also create fuel conditions suitable for conducting low-intensity 

prescribed burning (USDA Forest Service1996). Commercial timber harvest utilizing whole-tree 

harvesting is common throughout the Black Hills and the predominant harvest method. 

Lop and Scatter − Lopping and scattering may be needed to facilitate prescribed burning. Felled 

trees and shrubs would be limbed, lopped, and bucked using chainsaws so that slash would lie 

close to the ground, then the slash would be spread more or less evenly over the ground. 
Cold Springs Project 

56 

Slashing − This method of thinning trees and shrubs would involve the use of chainsaws to create 

a prescribed spacing. Given site-specific treatment needs, slashing may be required where a close 

spacing of remaining plants is desired and specific species are retained or removed. In the WUI 

defense zone space (0 to 300 feet), shrubs (juniper) would be thinned to a minimum horizontal 

distance between individual or small clumps of shrubs, depending upon the slope. Horizontal 

spacing would vary, based on shrub density and slope. 

Prescribed Fire – Broadcast burn would be used to: 

 minimize the potential for unwanted wildfires by reducing surface and ladder fuels and 

breaking up contiguous vegetation, 

 help restore historic fire patterns and frequencies, and 

 help improve forest health, wildlife habitat, meadows, and aspen regeneration. 

Burning would be accomplished by applying low- to moderate-intensity fire using hand, 

mechanical, or aerial firing methods. Prescribed burning would be accomplished when conditions 

are favorable and risk of fire escape is low. All burning will take place under the guidelines set 

forth in a prescribed fire burn plan developed specifically for all burning activities within the 

project area. Prescribed burn plans will address parameters for weather, air quality, contingency 

resources, and potential escapes. 

There is a large body of literature that makes the case for treating the various strata of fuels. 

According to Graham et al. (2004), “Qualitative observations, limited empirical data, and 

modeling provide the scientific basis for identifying how forest structure can be modified to 

reduce fire hazard and modify fire behavior. Additionally, research shows that when activities 

reduce surface fuels (low vegetation, woody fuel, shrub layer), those activities decrease the 

chances that surface fires will be able to ignite ladder fuels and canopy fuels (Weaver 1955, 

Cooper 1960, Biswell 1960, Biswell et al. 1973, Martin et al. 1989, Pollet and Omi 2002). The 

most effective strategy for reducing crown fire occurrence and severity is to (1) reduce surface 

fuels, (2) increase height to live crown, (3) reduce canopy bulk density, and (4) reduce continuity 

of the forest canopy (Van Wagner 1977, Agee 1996, Graham et al. 2004, Scott and Reinhardt 

2001, Cruz et al. 2003).” 

Science-based literature indicates the most appropriate fuel treatment strategy is often thinning 

(removing ladder fuels and decreasing crown density) followed by prescribed fire, piling and 

burning fuels, and mechanical treatments. These treatments would provide maximum protection 

from severe fires in the future. 

The modified proposed action would result in a substantial reduction in the number of acres with 

a High or Very High fire hazard rating. Guidance under forest plan 10-01 would be met. Not only 

would a greater percentage of the area be moved out of the High and Very High rating category, 

but much of it would be moved into the Low rating. Fire hazard ratings for the project area are 

projected to have only 27 percent of the area in High or Very High rating, and 42 percent would 

be rated as Low (Table 23) The anticipated lower flame lengths and surface fire activity would 

mean that firefighters have a higher probability of successfully performing direct attack on the 

fire, thus minimizing fire size, cost, while increasing firefighter safety. 
Environmental Assessment 

57 

Table 23. Post-treatment fire hazard ratings for the project area 

Post-Treatment Project Area Fire Hazard 

Rating Acres Percent of project area 

Low 5,200 42 

Medium 3,879 31 

High 2,080 18 

Very High 1,159 9 

Treatment in WUI areas would meet forest plan guidance under 10-01 as well. A total of 1,205 

acres would be treated within the designated WUI area. This would move the area to only 27 

percent having a High to Very High rating (Table 24). This alternative reduces the number of 

acres in the High and Very High rating by more than half. 

Table 24. Post-treatment fire hazard ratings for WUI 

Post-Treatment WUI Fire Hazard 

Rating Acres Percent of WUI 

Low 449 37 

Medium 433 36 

high 146 12 

Very High 177 15 

The changes in stand structure, density and composition as well as the reduction in fuels under 

this alternative would move more lands within the project to a more resilient condition class 

according to the guidelines given in the Forest Plan Phase II final environmental impact statement 

(FEIS) (table B-5). The resulting changes mean that approximately 1,289 acres would be moved 

to a structural stage resembling Condition Class I, and approximately 3,466 acres would resemble 

the stand structure associated with Condition Class II. 

Cumulative Effects 

The existing condition reflects the effects of past activities, including fire suppression. Fuel 

models and stand conditions modeled reflect the changes associated with activities affecting fire 

behavior and hazard up to present. 

Modified proposed action treatments would reduce the effects of aggressive suppression and 

enhance past management effects by reducing the fuels available for burning. Previous and 

ongoing activities in the area have reduced the overstory fuels as well as much of the ladder fuels, 

thereby reducing the fire hazard rating. The reduction in crown fire potential means that a greater 

portion of the area would meet the Black Hills Land and Resource Management Plan objective 

10-01, as well as national and local direction contained within the Lawrence County Community 

Wildfire Protection Plan. 

Summary and Comparison 

The modified proposed action reduces the area with High and Very High hazard ratings 

substantially. There would be 32 percent less acres in the project area with these ratings (see 
Cold Springs Project 

58 

Table 25). Within the WUI, there would be 33 percent less acres in the High and Very high rating 

(see Table 26). 

The no-action alternative would not meet either national or forest direction for the treatment of 

fire hazard in either the WUI or for project area National Forest System lands. The modified 

proposed action would meet national direction as well as meeting forest direction. Not only 

would a substantial amount of the acres be moved out of the High and Very high category in both 

areas, but a large portion of that would be converted to stands that have a Low rating. The amount 

of acres in the low category would be increased by 29 percent in the project area (see Table 25), 

and by 24 percent within the WUI (see Table 26). 

Table 25. Comparison of project area National Forest System land hazard ratings by alternative 

Project Area acres 

 Fire hazard rating No action Modified proposed action 

Acres Percent Acres Percent

Low 1,493 13 5,200 42 

Medium 3,460 28 3,879 31 

High 5,222 42 2,080 18 

Very High 2,144 17 1,159 9 

Table 26. Comparison of project area National Forest System land hazard ratings by alternatives for 

WUI 

WUI acres 

 Fire hazard rating No action Modified proposed action 

Acres Percent Acres Percent 

Low 154 13 449 37 

Medium 323 27 433 36 

High 359 30 146 12 

Very High 370 30 177 15 

Wildlife 

Introduction 

This section discusses the environmental consequences of no action and the modified proposed 

action on wildlife resources. It summarizes the Cold Springs Project Wildlife Resource Report 

(Moser 2011b) and the Cold Springs Biological Evaluation for Wildlife and Fisheries (Moser 

2011a), which are located in the Cold Springs project file. 
Environmental Assessment 

59 

Wildlife Habitat 

No-Action Alternative 

Direct and Indirect Effects 

The direct effects of the no-action alternative would be minimal, as no new actions would occur. 

Long-term, indirect effects would vary depending on habitat type. Indirect effects would occur as 

a response to current conditions in the absence of active management, other than fire suppression 

efforts. In general, the no-action alternative would maintain existing habitat and protect 

biodiversity in the short term. Long term, the proportion of ponderosa pine and white spruce 

cover type in the Cold Springs project area would be expected to rise as these species continued 

to encroach into existing meadows and hardwood stands. Early-successional habitats would 

continue to decline as pine stands continue to progress toward later seral stages. Currently, latesuccessional habitat (structural stage 5) is below management objectives within the project area 

and forestwide. Over the next 10 to 20 years, some of the mature stands could further develop 

toward late-successional habitats. However, this alternative would not result in a variety of 

successional stages in ponderosa pine, which would reduce habitat and structural diversity and 

not comply with Forest objectives. Natural disturbances such as wildfire and beetle outbreak 

would continue to return portions of the forest in which they occur to early-successional stages. 

However, the no-action alternative would greatly increase the chances of high-intensity wildfire, 

insect, and disease events. These events could create more forest openings, favor hardwoods, and 

return ponderosa pine habitat to an early seral condition. Effects by project area habitat types are 

described in Table 27. 

Table 27. No-action alternative - direct and indirect effects to habitat 

Habitat Type 

Direct effects 

for the no-action 

alternative 

Indirect effects for the no action alternative 

Ponderosa 

Pine None 

In the absence of active management, additional dense, latesuccessional stands with closed canopy would develop. The 

amount of snags is likely to increase with forest succession. 

These stands would have an increased risk of mountain pine 

beetle infestation and high-intensity wildfire. These events could 

create more forest openings, favor hardwoods, and increase 

early seral ponderosa pine habitat. 

White Spruce None 

In the absence of active management, white spruce as a 

component of the ecosystem would likely continue to increase 

within its ecological limits. 

Hardwood 

Communities None 

In the absence of active management, conifer encroachment 

would continue to reduce areas dominated by aspen. However, 

insect-caused mortality could increase hardwoods. 

Grassland/ 

Meadows None In the absence of active management, conifer encroachment would continue to reduce meadow habitat. 

Riparian/ 

Aquatic None 

Stream fragmentation by existing dams and roads would 

continue to persist. 

Water quality would continue to be influenced by ongoing 

Federal/non-Federal activities. 
Cold Springs Project 

60 

Cumulative Effects 

A century of fire suppression has caused widespread alteration and degradation of wildlife habitat 

in the Black Hills (USDA Forest Service 2005a). Frequent recurring disturbances like wildfire 

and insects maintained a generally open, mature pine canopy with productive and diverse 

understory by thinning pine stands and creating open stands with abundant grasses, forbs, and 

shrubs in the understory (Sieg and Severson 1996). In the absence of frequent low-intensity fires, 

the increase in the density and canopy cover of pine stands has resulted in large, contiguous 

expanses of higher density trees with abundant pine regeneration and sparse understories (Parrish 

et al. 1996). Fire suppression has also resulted in the conversion of hardwood stands such as 

aspen and bur oak to pine, which has reduced diversity (Uresk and Severson 1998). 

No new activities would occur under the no-action alternative, and the conditions described above 

would continue in the absence of active management, into the foreseeable future. The cumulative 

effects of no action on wildlife habitat would be similar to the indirect effects described above. 

Modified Proposed Action 

Direct and Indirect Effects: 

The modified proposed action is designed to reduce the threatened mountain pine beetle epidemic 

by moving toward the Forest objectives for structural stage management. In general, there would 

be short-term impacts to wildlife habitat availability during treatments; however, over the long 

term, there would be improved diversity of habitats and improved quality of most habitats. As a 

result of the hardwood enhancement treatments, there would be an increase in the amount and 

quality of hardwood habitat (primarily aspen). Commercial and noncommercial hardwood 

enhancement treatments would occur on 572 acres. 

There would be an increase in the diversity of understory plants within many pine stands due to 

reduced forest canopy cover and disturbance caused by broadcast burning and logging. Nearly 28 

percent (3,541 acres) of the treatments on National Forest System (NFS) land within the project 

area would have a precommercial thinning and/or a broadcast burn component under this 

alternative. In addition, emergency sanitation and salvage harvest treatments may occur in sites 

with beetle infestation. Sanitation and salvage harvest would be implemented only where deemed 

necessary to control the spread of mountain pine beetles. These treatments would help to limit the 

spread of beetles and would open up these stands and result in more sunlight, moisture, and 

nutrients being available for understory plants including grasses, forbs, and shrubs. Inclusions of 

aspen, birch, and oak within these pine stands may also benefit from these treatments. 

Disturbance created by broadcast burning would also help stimulate the regeneration of the less 

shade-tolerant plant species within these stands. No new system roads would be constructed to 

access sanitation and salvage harvest units. 

Most of the proposed treatments within the project area ponderosa pine stands would have an 

effect on the stand structural stage. Table 13 and Table 14 display the proportion of each structural 

stage in MA 5.1 and 4.1 following the treatments proposed under the proposed action alternative. 

Additional discussion regarding treatment effects on project area structural stages can be found in 

the “Forest Resources” section of this document. The modified proposed action would include an 

estimated 4 miles of new NFS road construction, 2.4 miles of currently unclassified roads would 

be added to the system, 7.8 miles of temporary roads construction, and 48.1 miles of system road 

reconstruction. These system roads would need to be prepared for use. Preparation could range 

from minimal maintenance activities to reconstruction of the road template, depending on the 
Environmental Assessment 

61 

current condition of the road. The loss of habitat to road construction is unknown, but Rowland et 

al. (2004) using elk habitat, stated that it is often estimated at 5 acres per linear mile (Rowland et 

al. 2004). There would likely be some effects from disturbance during project implementation. 

System roads that undergo pre-use maintenance or reconstruction would remain on the system 

and allowable uses would be determined by the forestwide travel management plan. No indirect 

disturbance impacts from public use of newly constructed roads are expected after the project is 

finished because newly constructed or temporary roads would be closed following completion of 

management activities. The method of closure will depend on site conditions and be determined 

at the time of closure. In addition, 2.3 miles of existing NFS roads are proposed for 

decommissioning in an effort to improve watershed conditions. Closure methods for these roads 

would also depend on site conditions. 

Effects to riparian/aquatic habitat are summarized in Table 28. These effects are mitigated 

through the use of the forest plan standards and guidelines, Region 2 Watershed Conservation 

Practices Handbook (WCPH; Forest Service Handbook 2509.25) and South Dakota Forestry Best 

Management Practices (BMPs). The Handbook contains proven watershed conservation practices 

to protect soil, aquatic, and riparian systems. If used properly, the watershed conservation 

practices will meet applicable Federal and State laws and regulations, including State BMPs. A 

summary of the relevant WCPH direction is in the Cold Springs Project Soil and Hydrology 

Resource Report (Maloney 2011). 

Effects to habitats due to the treatments proposed in the modified proposed action are provided in 

Table 28. Relevant forest plan standards and objectives are met by the use of specific design 

criteria applied to mitigate the impacts in the project area. 

Table 28. Modified proposed action - direct and indirect effects to habitat (A: no action, B: 

modified proposed action) 

Habitat Type Direct Effects for Alternative B Indirect Effects for Alternative B 

Ponderosa 

Pine 

Commercial and noncommercial treatments 

to approximately 5,144 acres, which 

includes 1,698 acres of prescribed burning. 

Treatments include the removal of 831 

acres of mature, dense forest (4C). 

Reduction of pines in structural stage 

4A, and 4B and increase in structural 

stages 3A, 3B and 3C for both MAs, 

moving toward forestwide structural 

stage objectives. 

Long-term movement toward all 

structural stage objectives, including 

structural stage 5. 

White Spruce 

A small reduction of spruce in pine habitat 

as a result of pine and hardwood treatment 

activities. 

Very little active management in sprucedominated habitat. Some treatments will 

occur in pine/spruce ecotones. 

Overall change in acreage of spruce 

would be minimal. 

White spruce as a component of the 

ecosystem would likely continue to 

increase within its ecological limits. 

Hardwood 

Communities 

628 acres of primary and secondary 

treatments in aspen stands with commercial 

and noncommercial treatments (conifer 

removal) and prescribed burn. 

Increase in quantity and quality of 

hardwood habitat due to reduced conifer 

competition. 
Cold Springs Project 

62 

Table 28. Modified proposed action - direct and indirect effects to habitat (A: no action, B: 

modified proposed action) 

Habitat Type Direct Effects for Alternative B Indirect Effects for Alternative B 

Grassland/ 

Meadows 

Direct effects from prescribed burning: 

reduced conifers. Enhancement of meadow habitat. 

Riparian/ 

Aquatic 

Direct effects would be limited to those 

incurred by new road stream crossings. 

Effects would include habitat loss at the 

crossing and short-term habitat loss in the 

vicinity of the road crossing during 

construction. 

Bank stabilization may decrease and 

sedimentation may increase due to 

stream crossings (refer to Hydrology 

Report). 

There is also the potential for short-term 

impacts from sedimentation during 

treatment activities. 

Cumulative Effects 

Past and present actions are reflected in the existing condition. This analysis is bounded by the 

Northern Hills Ranger District boundary and the 15-year period required for project 

implementation. Relevant actions on Federal and non-Federal land assessed in the analysis are 

discussed below. A century of fire suppression has caused widespread alteration and degradation 

of wildlife habitat in the Black Hills (USDA Forest Service 2005a). Frequent recurring 

disturbances like fire and insects maintained a generally open, mature pine canopy with a 

productive and diverse understory by thinning pine stands and creating open stands with abundant 

grasses, forbs, and shrubs in the understory (Sieg and Severson 1996). In the absence of frequent 

low-intensity fires, the increase in the density and canopy cover of pine stands has resulted in 

large, contiguous expanses of higher density trees with abundant pine regeneration and sparse 

understories (Parrish et al. 1996). The action alternative is expected to offset some effects of fire 

suppression. The net cumulative effect is expected to offset the loss of open, mature pine habitat 

with a productive understory. 

Fire suppression has also resulted in the conversion of hardwood stands such as aspen and bur 

oak to pine, which has reduced diversity (Uresk and Severson 1998). The action alternative is 

expected to have a positive cumulative effect on hardwood habitat which may offset some 

conversion to pine that has occurred as a result of fire suppression. Encroachment of pine into 

meadows and riparian areas has reduced grass, forb, and shrub availability. The increased 

biomass of pine has changed hydrologic conditions and decreased available water within the 

watersheds. 

The project area has been logged intermittently for the last 130 years. Logging has had multiple 

effects on the project area. Logging has created single-story stands of mature trees and multi-level 

pine stands with both immature and mature pine. The Cold Springs Project would continue this 

condition, however, with an increase of individual tree selection treatments aimed at increasing 

multi-level pine stands on the District. Mixed pine-hardwood stands have also developed due to a 

proliferation of aspen in the understory as the mature pine canopy is removed. The Cold Springs 

Project is expected to reduce the incremental impacts of past sales by implementing hardwood 

enhancement treatments. 
Environmental Assessment 

63 

Invasive weeds have also spread as a result of past and ongoing harvest activities, recreational 

activities, and livestock grazing. Treatment of invasive weed infestations with herbicide has 

controlled the spread of weeds in many of these areas. The Cold Springs Project is expected to 

incrementally increase the spread of invasive plants, but most increases will be mitigated through 

post-harvest weed treatments. 

Several timber sales are planned or are ongoing on the Northern Hills District. They include sales 

associated with various planning areas, none of which overlap with the Cold Springs project area. 

Treatments in these areas will primarily affect the ponderosa pine cover type, and will result in 

the decrease of pine cover and density throughout these project areas. Pine habitat, both mature 

and immature, will be decreased, forested habitat will be fragmented, and hardwood stand 

development, as well as grass, forbs, and shrub habitat will be encouraged and increased. These 

effects should be long term (more than 30 years). The Cold Springs Project is expected to have 

similar impacts within the Cold Springs project area, which is expected to incrementally add to 

these affects across the district. 

Grazing has been a continuous activity in the project area for over 100 years, and is expected to 

continue into the foreseeable future. Historically, however, there were larger numbers of both 

cattle and sheep grazing in the project area. Pasture fences did not exist, so livestock were not 

rotated between pastures and use was season long. In some instances, livestock grazing converted 

native riparian plant species to bluegrass, spread noxious weeds, altered stream banks in sitespecific locations, consumed water, reduced fine fuels, and reduced the diversity of plant species. 

As grazing practices have improved, fences have controlled livestock distribution and altered the 

use of specific areas. Water developments at several springs have also changed grazing patterns. 

These improvements in practices have generally lessened the impacts across the project area. 

There would be no additional incremental impacts from the Cold Springs Project. 

Historic and ongoing mining, grazing, logging, recreational and road-related activities have 

influenced stream habitat conditions within the project area. The Cold Springs Project will not 

cause additional influence on stream habitat conditions. 

Direct mortality from wildlife/vehicle collisions could occur in the modified proposed action. 

Direct mortality is expected to affect individuals and is not expected to put populations at risk. In 

general, the more motorized routes and motorized use in wildlife habitat, the more potential there 

is for wildlife/vehicle collisions. The most effects on wildlife from motorized recreation are likely 

to come in the form of disturbance as a result of route or area use. The miles of motorized routes 

and the amount of area open to motorized travel were used to evaluate the level of effects to 

wildlife, in general, and were analyzed recently for the forestwide travel management plan. 

Motorized vehicles have damaged roads and riparian areas when conditions are wet or in cases 

where streams were crossed. The use of some open roads, particularly during wet periods, has 

also contributed to the establishment of noxious weeds, and the erosion and degradation of 

riparian areas due to increasing sedimentation and changes in stream morphology. Increased use 

by all-terrain vehicles (ATVs) can be expected, but would be focused on roads and trails 

designated by the forestwide travel management plan, and are likely to continue to degrade 

wildlife habitat both directly and due to habitat fragmentation. 

Snags have been reduced within harvest units due to safety concerns for loggers and development 

of roads, skid trails, and other activities. The Cold Springs Project would have additive impacts if 

some snags are removed for safety reasons. Fuelwood gathering has decreased the number of 

snags, particularly adjacent to roads where the wood can more easily be hauled out. Some 
Cold Springs Project 

64 

incremental additive impacts are to be expected from fuelwood gathering due to greater public 

access, however, this project does not authorize fuelwood gathering and most new roads would be 

closed after project completion. Wildfires, drought, and beetle activity have increased the overall 

number of snags in and around the project area. 

Snags can be classified as hard or soft depending on the state of decomposition. A hard snag is a 

dead or partially dead tree composed primarily of sound wood, particularly sound sapwood. A 

soft snag, usually created by mountain pine beetle infestation, is a snag composed primarily of 

wood in advanced stages of decay and deterioration, particularly in the sapwood (outer) portions 

(USDA Forest Service 1996). Lentile et al. (2000) reported that after 5 years, rapid deterioration 

left soft snags susceptible to high winds, with an average life expectancy of 10 years. Schmid et 

al. (2009) report the rate and height of breakage in mountain pine beetle-killed trees indicates that 

they are unlikely to persist as suitable snags for more than 5 to 10 years after infestation. 

Private lands within and adjacent to the Cold Springs project area contain habitat for wildlife and; 

therefore, their management can have impacts on wildlife. Resource management and 

conservation by private citizens and companies depends on a number of factors (e.g., desired 

goals, market prices, development potential), making it difficult to predict future trends in private 

forest structure and diversity. Landowners could treat forests for lumber, which could reduce 

habitat for some species. Fire hazard reduction activities are likely to increase on some of these 

lands over the next 15 years in an effort to prevent loss of homes from wildfire, which could 

result in additional loss of habitat. It is assumed that urban development and other activities 

would continue on private lands. This would likely increase the importance of habitat located on 

NFS land. 

Threatened and Endangered Species 

The U.S. Fish and Wildlife Service (USFWS) provides a list of Federally Threatened (T), 

Endangered (E), Proposed (P), Candidate (C) species and Nonessential/Experimental Population 

(XN) via their South Dakota Field Office Internet site (USFWS 2011, most recent update 21 

December 2010). Listed species that occur in Lawrence County are the whooping crane (Grus 

americana) (E) and Sprague’s pipet (anthus spragueii) (C). No known occurrences or suitable 

habitat for the whooping crane or Sprague’s pipet occur within the Cold Springs project area or 

the Northern Hills Ranger District. The Forest Service has also conducted additional consultation 

with the USFWS (Twiss 2003). Based on past consultation and the species list, it is determined 

that no currently listed species with T, E, P, C, or XN status have the potential to occur within the 

Northern Hills Ranger District on the Black Hills National Forest, nor has “critical habitat” been 

designated for any T or E species on the Forest. Sprague’s pipet, a grassland obligate species, is 

not likely to occur in the Black Hills. Therefore, no federally listed species are addressed further 

in this document, and there will be “no effect” to threatened and endangered species and no 

impact to critical habitat. 

Region 2 Sensitive Species 

Sensitive species (SS) are those plant and animal species identified by the Regional Forester for 

which population viability is a concern, as evidenced by “significant current or predicted 

downward trends in population numbers or density” or “ significant current or predicted 

downward trends in habitat capability that would reduce a species’ existing distribution” (FSM 

2670.5). 
Environmental Assessment 

65 

The most recent region 2 sensitive species wildlife list (FSM R-2 Supplement 2600-2009-1, 

effective June 9, 2009) was reviewed, and species that may occur in or near the Black Hills were 

identified. Table 6 in the Cold Springs Project Wildlife and Fisheries Biological Evaluation 

(Moser 2011a) describes the region 2 sensitive species likely to occur on the Black Hills National 

Forest. Although each of these species are known to or could potentially occur in or near the 

Black Hills, not all of them have potential to occur in the Cold Springs project area. A pre-field 

wildlife and fish review of the project area for all region 2 sensitive species was completed using 

Heritage database records, district data, literature reviews, communication with district personnel 

and the forest plan to identify which sensitive species should be analyzed. Table 29 summarizes 

effects on these species; full analysis for each species is found in the Cold Springs Project 

Wildlife and Fisheries Biologicial Evaluation, located in the Cold Springs project file. 

For further information about these species and generalized analysis of landscape-scale project 

affects, reference the 1997 Black Hills National Forest Management Plan as amended by the 

Phase II Amendment, and associated biological assessment/biological evaluation (USDA Forest 

Service 2005a, 2005c). 

Table 29. Summary of effects on region 2 sensitive wildlife and fish species by alternative (A: no 

action; B: modified proposed action) 

Species Direct Effects Indirect Effects Cumulative 

Effects Determination 

American Marten 

(Martes 

americana) 

A: None. 

B: Low 

potential for 

individual 

mortality. 

Potential den 

site 

disturbance. 

A: Increased denning 

and foraging habitat. 

Increased risk of habitat 

loss due to wildfire. 

B: Reduced habitat; 

reduced mature 

ponderosa pine, coarse 

woody debris, and 

ground cover. 

A: None 

B: Would add to 

reduced habitat 

due to 

management 

activities: reduced 

mature ponderosa 

pine, coarse woody 

debris, and ground 

cover. 

A: No impact 

B: May impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Bald Eagle 

(Haliaetus 

leucocephalus) 

A: None 

B: Short-term 

disturbance. 

A: Potential habitat 

increase. 

B: Enhanced habitat for 

primary food source. 

A: None. 

B: No measureable 

change in available 

habitat. Enhanced 

habitat for primary 

food source. 

A: No impact. 

B: May impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Black-backed 

Woodpecker 

(Picoides 

arcticus) 

A: None. 

B. Potential 

nest removal. 

A: Existing habitat would 

be maintained, and 

habitat may increase 

because of insectcaused tree mortality and 

high fire hazard. 

B: Sanitation treatments 

would reduce foraging 

habitat; potential habitat 

would be reduced due to 

reduced insect-caused 

A: Would contribute 

to potential habitat 

increase. 

B: Would contribute 

to reduced potential 

habitat. 

A and B: May 

impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 
Cold Springs Project 

66 

Table 29. Summary of effects on region 2 sensitive wildlife and fish species by alternative (A: no 

action; B: modified proposed action) 

Species Direct Effects Indirect Effects Cumulative 

Effects Determination 

tree mortality and fire 

hazard. 

Black Hills 

Redbelly Snake 

(Storeria 

occipitomaculata 

pahasapae) 

A: None 

B: Potential 

individual 

mortality due 

to 

management 

activities and 

vehicle traffic. 

A: Potential habitat 

impacts associated with 

high fire hazard and 

insect-caused tree 

mortality; positive and 

negative effects. 

B: Potential reduced prey 

availability. Increased 

hardwood habitat. Mesic 

habitat improved through 

road decommissioning. 

A: Would contribute 

to current trend of 

habitat loss. 

B: Would contribute 

to increased mesic 

habitat and 

hardwood habitat. 

A and B: May 

impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Cooper’s 

Mountain Snail 

(Oreohelix 

strigosa cooperi) 

A: None 

B: Mortality of 

unknown snail 

colonies. 

A: Habitat would 

increase. Potential 

habitat loss associated 

with high fire hazard. 

B: Reduced risk of 

habitat loss due to 

wildfire. Habitat loss due 

to management 

activities. 

A: Would add to the 

risk of habitat loss 

due to wildfire. 

B. Would add to a 

decrease in habitat. 

A and B: May 

impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Flammulated Owl 

(Otus 

flammeolus) 

A: None 

B: Low 

potential for 

individual 

mortality. 

A: Potential increase in 

late-successional habitat 

and snags. Risk of 

habitat loss due to 

mountain pine beetlecaused tree mortality. 

B: Reduced preferred 

habitat. Incidental loss of 

snags. Precommercial 

thinning and prescribed 

burning would benefit 

foraging habitat. 

A: Would add to the 

risk of habitat loss 

due to wildfire and 

forest insects. 

B: Would add to 

reductions of 

preferred habitat. 

A: No impact. 

B: May impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Lewis’s 

Woodpecker 

(Melanerpes 

lewis) 

A: None. 

B: Low 

potential for 

individual 

mortality. 

Potential nest 

removal. 

A: Reduced preferred 

habitat; open, mature 

pine habitat; however, 

Increased fire hazard 

and mountain pine beetle 

mortality could benefit 

habitat. 

B: Increased preferred 

habitat: open-canopied 

mature pine. 

A: Would contribute 

to trend of reduced 

habitat; however, 

natural 

disturbances could 

benefit habitat. 

B: Would contribute 

to increased 

preferred habitat. 

A and B: May 

impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Northern 

Goshawk 

(Accipiter gentilis) 

A: None. 

B: Low 

potential for 

individual 

mortality and 

A: Potential loss of 

foraging and nesting 

habitat as forest density 

increases. Potential loss 

of habitat due to wildfire 

A: Would contribute 

to potential loss of 

habitat due to 

natural disturbance: 

wildfire, insectA and B: May 

impact 

individuals, but 

not likely to 

result in a loss 
Environmental Assessment 

67 

Table 29. Summary of effects on region 2 sensitive wildlife and fish species by alternative (A: no 

action; B: modified proposed action) 

Species Direct Effects Indirect Effects Cumulative 

Effects Determination 

nest removal. and insect-caused tree 

mortality. 

B: Loss of potential 

nesting habitat. Nesting 

disturbance during 

project implementation. 

Known nest area habitat 

enhancement. 

caused tree 

mortality. 

B: Would contribute 

to decreased 

potential nesting 

habitat. 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Northern Leopard 

Frog (Rana 

pipiens) 

A: None. 

B: Low 

potential for 

individual 

mortality due 

to project 

activities. 

A: Potential habitat 

quality impacts 

associated with high fire 

hazard. Continued 

decline in hardwood and 

meadow habitat. 

B: Potential habitat 

disturbance or loss. 

Improved hardwood and 

meadow habitat. 

A: Would contribute 

to decline in 

hardwood and 

meadow habitat, 

and habitat threats 

associated with 

wildfire 

B: Contributes to 

potential habitat 

disturbance or loss. 

Contributes to 

improved habitat. 

A and B: May 

impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Regal Fritillary 

(Speyeria idalia) 

A: None 

B: Low 

potential for 

individual 

mortality due 

to 

management 

activities in 

meadows and 

adjacent 

riparian areas. 

A: Reduced habitat 

through pine 

encroachment on 

meadows. 

B: Broadcast burn would 

maintain meadow 

habitat. Noxious weed 

spread may impact host 

plants. 

A: Contributes to 

continued reduced 

habitat reduction. 

B: Contributes to 

maintenance and 

enhancement of 

meadow habitat. 

A and B: May 

impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

toward Federal 

listing. 

Fringed Myotis 

(Myotis 

thysandodes 

pahasapensis) 

Townsend’s Bigeared Bat 

(Pelcotus 

townsendii) 

Hoary bat 

(Lasiurus 

cinereus) 

A: None. 

B. Low 

potential for 

individual 

mortality due 

to tree felling 

and vehicle 

collisions. 

Potential snag 

and roost tree 

loss. 

A: Reduced foraging 

habitat through natural 

forest succession and 

growth. Increase in 

roosting snags. Potential 

habitat improvement 

associated with high fire 

hazard and beetlecaused tree mortality. 

B: Reduced roosting 

habitat. Potential habitat 

loss due to reduction of 

snags and roost trees. 

Foraging habitat would 

improve. 

A; Contributes to 

reduced foraging 

habitat. Contributes 

to increased 

roosting habitat. 

B: Contributes to 

reduced roosting 

habitat. Contributes 

to increased 

foraging habitat. 

A: No impact. 

B. May impact 

individuals, but 

not likely to 

result in a loss 

of viability in 

the planning 

area, nor 

cause a trend 

to federal 

listing. 

Management Indicator Species 

Management indicator species for the Black Hills National Forest are designated in the forest plan 

(USDA Forest Service 2006). Although each of these species is known to or could potentially 

occur in or near the Black Hills National Forest, not all of them have potential to occur in the 
Cold Springs Project 

68 

Cold Springs project area. Table 30 summarizes the effects on these species. Full analysis is 

found in the Cold Springs Project Wildlife Resource Report (Moser 2011b). If a management 

indicator species or its habitat were not found in the project area, it was not identified for further 

analysis. 

Table 30. Summary of effects on management indicator species by alternative (A: no action, B: 

modified proposed action) 

Species Direct Effects Indirect Effects Cumulative Effects 

Black-backed 

Woodpecker 

(Picoides 

arcticus) 

A: None. 

B. Potential nest 

removal. 

A: Existing habitat would be 

maintained, and habitat may 

increase because of insect-caused 

tree mortality and high fire hazard. 

B: Habitat would be reduced through 

sanitation and salvage of insect 

infested trees; potential habitat would 

be reduced due to reduced insectcaused tree mortality and fire hazard. 

A: Would contribute to 

potential habitat 

increase. 

B: Would contribute to 

reduced habitat. 

Brown Creeper 

(Certhia 

americana) 

A: None 

B: Potential nest 

removal. 

A: Existing habitat would remain. 

Potential for habitat loss due to fire 

or insect-caused tree mortality. 

B: Habitat would be reduced through 

timber harvest in dense mature pine 

stands. Broadcast burning may 

increase snag habitat. 

A: Would contribute to 

an increase in habitat; 

however, the risk of 

habitat loss due to 

wildfire would increase. 

B: Would contribute to 

reduced habitat. 

Golden-crowned 

Kinglet (Regulus 

satrapa) 

A: None. 

B: Low potential 

for individual 

mortality. 

A: Existing preferred (sprucedominated) habitat would remain. 

B: Existing preferred habitat would 

remain. Reduction of potential 

spruce habitat through broadcast 

burning. 

A and B: No cumulative 

effect because existing 

white spruce habitat 

would remain. 

Ruffed Grouse 

(Bonasa 

umbellus) 

A: None. 

B: Potential 

individual bird 

mortality and nest 

destruction. 

A: Reduced aspen habitat through 

succession to pine. Habitat may 

increase due to release of aspen 

through wildfire or insect-caused 

disturbance. 

B: Aspen habitat maintained and 

increased through pine removal. 

A: Would contribute to 

continued aspen habitat 

decline; however, habitat 

may increase. 

B: Would contribute to 

maintaining and 

increasing aspen habitat. 

Song Sparrow 

(Melospiza 

melodia) 

A: None. 

B: Low potential 

for individual 

mortality. 

A: Reduced riparian habitat through 

conifer encroachment. 

B: Riparian aspen habitat would be 

maintained. 

A: Would contribute to 

continued trend of 

habitat loss due to 

conifer encroachment. 

B: Would contribute to 

maintaining and 

increasing riparian aspen 

habitat. 

White-tailed 

Deer 

(Odocoileus 

virginianus) 

A: None. 

B: Low potential 

for individual 

mortality from 

vehicle collisions. 

A: Early-seral habitat would decline; 

however, early-seral habitat could 

increase and cover habitat could 

decrease due to wildfire or insectcaused tree mortality. 

B: Increased diversity of forest 

structure and associated habitat: 

increased forage and browse 

production. Decreased cover habitat. 

A: Would contribute to 

increases in cover 

habitat at the expense of 

early-seral habitat. 

B: Would contribute to 

diversity of forest 

structure and associated 

habitat. 
Environmental Assessment 

69 

Species of Local Concern 

Species of local concern are plant, fish, and wildlife species (including subspecies or varieties) 

that do not meet the criteria for sensitive status. These could include species with declining trends 

in only a portion of region 2, or those that are important components of diversity in a local area. 

The local area is defined as NFS lands within the Black Hills National Forest (FSM 2620.5 Black 

Hills Supplement 2600-2005-1). 

Analysis of project impacts on species of local concern was completed for those species that 

occur in the project area, or have habitat that occurs in the project area. Table 31 summarizes 

effects on these species. Full analysis can be found in the Cold Springs Project Wildlife Resource 

Report (Moser 2011b). 

Table 31. Summary of effects on wildlife species of local concern by alternative (A: no action, B: 

modified proposed action) 

Species Direct Effects Indirect Effects Cumulative Effects 

Birds 

Black-and-White 

Warbler 

(Mniotilta varia) 

A: None. 

B: Low potential for 

individual mortality. 

A: Habitat could decrease due to 

pine encroachment into aspen and 

riparian areas. 

B: Low potential for disturbance 

during project activities. Beneficial 

habitat impacts due to aspen 

release. Broadcast burning would 

have short-term negative habitat 

impacts, however, foraging habitat 

would have a long-term 

improvement. 

A: Would contribute to 

decreases in habitat. 

B: Would contribute to 

increased aspen 

habitat. 

Broad-winged 

Hawk 

(Buteo 

platypterus) 

A: None. 

B: Low potential for 

individual mortality 

and loss of unknown 

nests. 

A: Nesting habitat would increase. 

Foraging habitat would decrease. 

Risk of habitat loss due to high fire 

hazard and insect-caused tree 

mortality. 

B: Nesting habitat reduced by 36 

percent. Foraging habitat would 

remain stable or increase. Future 

nesting habitat would develop 

through thinning and burning. 

A: Would contribute to 

potential habitat loss 

due to wildfire and 

forest insects. 

B: Would contribute to 

reduced nesting 

habitat. 

Cooper’s Hawk 

(Accipiter 

cooperii) 

A: None. 

B: Low potential for 

individual mortality 

and loss of unknown 

nests. 

A: Nesting habitat would increase. 

Foraging habitat would decrease. 

Risk of habitat loss due to high fire 

hazard and insect caused tree 

mortality. 

B: Nesting habitat reduced by 36 

percent. Foraging habitat would 

remain stable or increase. Future 

nesting habitat would be developed 

through thinning and burning. 

A: Would contribute to 

potential habitat loss 

due to wildfire and 

forest insects. 

B: Would contribute to 

reduced nesting 

habitat. 
Cold Springs Project 

70 

Table 31. Summary of effects on wildlife species of local concern by alternative (A: no action, B: 

modified proposed action) 

Species Direct Effects Indirect Effects Cumulative Effects 

Northern Sawwhet Owl 

(Aegolius 

acadicus) 

A: None. 

B: Low potential for 

individual mortality. 

A: Nesting habitat would increase. 

Roosting habitat may decline. Risk 

of habitat loss due to high fire 

hazard and insect-caused tree 

mortality. 

B: Reduced preferred nesting and 

breeding habitat: dense mature 

stands. Structural stage 5 would be 

maintained. 

A: Would contribute to 

potential habitat loss 

due to wildfire and 

forest insects. 

B: Would contribute to 

reduction of preferred 

habitat. Would 

contribute to reduced 

risk of habitat loss due 

to wildfire and forest 

insects. 

Pygmy Nuthatch 

(Sitta pygmaea) 

A; None 

B: Low potential for 

individual mortality. 

A: Risk of habitat loss due to high 

fire hazard and insect-caused tree 

mortality. 

B: Mature, dense forest nesting 

and foraging habitat would 

decrease. Mature, open forest 

nesting and foraging habitat would 

increase. Reduced number of 

large-diameter trees available for 

future snags. 

A: Would contribute to 

potential habitat loss 

due to wildfire and 

forest insects. 

B: Would contribute to 

a balance of habitat 

structural stages. 

Contributes to a 

reduced number of 

large-diameter trees 

available for future 

snags. 

Sharp-shinned 

Hawk 

(Accipter 

striatus) 

A: None. 

B: Low potential for 

individual mortality 

and loss of unknown 

nests. 

A: Preferred nesting habitat (dense 

young forest) would likely increase; 

foraging habitat would decrease. 

Risk of habitat loss due to high fire 

hazard and insect-caused tree 

mortality. 

B: Preferred nesting habitat would 

increase over time; foraging habitat 

would remain stable. 

A: Would contribute to 

potential habitat loss 

due to wildfire and 

forest insects. 

B: Would contribute to 

reduced nesting habitat 

and enhanced foraging 

habitat. 

Mammals 

Long-eared 

Myotis (Myotis 

evotis) 

Long-legged 

Myotis 

(Myotis volans) 

Northern Myotis 

(Myotis 

septentrionalis) 

Small-footed 

Myotis 

(Myotis 

ciliolabrum) 

A: None. 

B. Low potential for 

individual mortality, 

A: Roost trees would increase due 

to insect-caused tree mortality. 

Foraging habitat may decrease, 

B: Potential loss of roost trees and 

snags through timber harvest and 

broadcast burning. Foraging 

habitat would improve. 

A: Would contribute to 

increased roosting 

habitat, a decrease in 

foraging habitat. Would 

contribute to potential 

habitat loss due to 

wildfire. 

B: Would contribute to 

loss of roost trees and 

snags; would 

contribute to improved 

foraging habitat. 

Meadow 

Jumping Mouse 

(Zapus 

hudsonius)

A: None. 

B: Low potential for 

individual mortality 

due to minimal 

project activity in 

riparian habitat. 

A: Potential increase in insectcaused tree mortality and wildfire 

would have short-term negative 

impacts, but long-term benefits to 

habitat. 

B: Potential habitat loss. Timber 

harvest and broadcast burning 

A: Would contribute to 

long-term habitat 

benefits. 

B. Would contribute to 

maintaining or 

enhancing habitat. 
Environmental Assessment 

71 

Table 31. Summary of effects on wildlife species of local concern by alternative (A: no action, B: 

modified proposed action) 

Species Direct Effects Indirect Effects Cumulative Effects 

would have short-term habitat 

impacts, however, long-term 

impacts would benefit habitat. 

Northern Flying 

Squirrel 

(Glaucomys 

sabrinus) 

A: None. 

B: Risk of individual 

mortality and next 

destruction due to 

timber harvest 

A: Dense mature forest and latesuccessional forest habitat may 

increase; however, there is a risk 

of habitat loss due to insect-caused 

tree mortality and increased fire 

hazard. 

B: Dense mature forest habitat 

would decrease. 

A: Would contribute to 

potential habitat loss 

due to wildfire and 

forest insects. 

B: Would contribute to 

decreased dense, 

mature forest habitat. 

Invertebrates 

Atlantis Fritillary 

Butterfly 

(Speyeria 

Atlantis 

pahasapa) 

Tawny Crescent 

Butterfly 

(Phyciodes 

batessi) 

A: None. 

B: Risk of individual 

mortality due to 

broadcast burning. 

A: Meadow and hardwood habitat 

would continue to decline due to 

pine encroachment. 

B: Benefits to habitat include 

broadcast burning meadows, road 

decommissioning in meadow, and 

hardwood release. 

A: Would contribute to 

decline in habitat. 

B: Would contribute to 

maintenance of habitat: 

meadows and 

hardwoods. 

Callused Vertigo 

Snail 

(Vertigo arthuri) 

Frigid 

Ambersnail 

(Catinella 

gelida) 

Mystery Vertigo 

Snail 

(Vertigo 

paradoxa) 

Striate Disc 

Snail 

(Discus 

shimekii) 

A: None. 

B: Risk of individual 

mortality to unknown 

snail colonies due to 

timber harvest, road 

construction and 

broadcast burning. 

A: Habitat would continue to 

increase due to increased forest 

cover, however, there is a risk of 

habitat loss due to insect-caused 

tree mortality and increased fire 

hazard. 

B: Decreased shaded forest habitat 

due to timber harvest and 

broadcast burning. 

A: Would contribute to 

potential habitat loss 

due to wildfire. 

B: Would contribute to 

decreased habitat. 

Migratory Birds 

Many species of migratory birds are of international concern because of naturally small ranges, 

loss of habitat, population declines, and other factors. Species of concern applicable to projectlevel conservation are identified by many sources, including: Endangered Species Act, Region 2 

sensitive species list, Forest management indicator species list, United States Fish and Wildlife 

Service Birds of Conservation Concern (BCC) 2008 publication, (USDI Fish and Wildlife Service 

2008, and the Wyoming Partners In Flight (PIF) Plan11 (Nicholoff 2003). All of these sources and 

 

11 Note: South Dakota does not have a PIF plan. 
Cold Springs Project 

72 

their respective species of concern, except BCC and Wyoming PIF, have been examined in the 

Cold Springs Project Wildlife Resource Report (Moser 2011b) or the Cold Springs Project 

Biological Evaluation for Wildlife and Fisheries (Moser 2011a). Effects of species not addressed 

elsewhere are summarized in Table 32 and addressed in detail in the Cold Springs Project 

Wildlife Resource Report (Moser 2011b). 

Table 32. Summary of effect on migratory birds by alternative (A: no action, B: modified proposed 

action) 

Species Direct Effects Indirect Effects Cumulative Effects 

Golden Eagle 

(Aquila chrysaetos) 

A: None. 

B: Potential for nest 

disturbance. 

A: None. 

B: Enhanced 

prey/hunting habitat. 

A: None. 

B: Would contribute to 

enhanced prey/hunting 

habitat. 

Red-headed Woodpecker 

(Melanerpes 

erythrocephalus) 

A: None. 

B: Potential for nest 

disturbance. 

A: None. 

B: Project area 

preferred habitat 

would increase by 

31 percent. 

A: None. 

B: Would contribute to 

increased preferred 

habitat. 

Black-billed Cuckoo 

(Coccyzus erythropthalmus) 

A: None. 

B: Potential for nest 

disturbance. 

A: None. 

B: Increased habitat 

diversity. 

A: None. 

B: Would contribute to 

increased habitat 

diversity. 

Fisheries 

Introduction 

This section discusses the environmental consequences of the no action and modified proposed 

action on fisheries resources. It summarizes the Cold Springs Fisheries Report (Hirtzel 2011), 

which is located in the Cold Springs project file. 

There are no fish-bearing streams or lakes in the Cold Springs project area (Stewart and Thilenius 

1964; Ford 1988; Isaak et al. 2003; South Dakota Department of Game, Fish and Parks 2009). 

The headwaters of Spearfish Creek occur to the northeast and in close proximity to the project 

boundary. It flows intermittently across limestone outcrops south of U.S. Highway 85. A 

recreational fishery comprised of non-native brook trout exists in Spearfish Creek approximately 

0.75 mile downstream of the Cold Springs project area where Spearfish Creek perennial surface 

flow emerges from a spring. Clayton Pond is a small impoundment for livestock watering that has 

never been stocked with fish. 

There are no federally listed, proposed, or candidate species or critical habitat designated in the 

Cold Springs project area (USFWS 2010). 

No-Action Alternative 

Direct, Indirect and Cumulative Effects 

There would be no direct, indirect, or cumulative effects to fisheries under this alternative 

because there is no suitable, occupied habitat in the project area. 
Environmental Assessment 

73 

Modified Proposed Action 

Direct and Indirect Effects 

There would be no direct effects to fisheries because no fish occur in the Cold Springs project 

area. There would be no short- or long-term negative indirect effects to fisheries downstream in 

Spearfish Creek from vegetation management activities or road construction/maintenance/use 

because no changes in water quality, flow regimes, sediment input, bank stability, etc., are 

anticipated to occur. See the hydrology analysis for additional details. Downstream recreational 

fishing opportunities will be maintained. 

The modified proposed action would have no impact on any of the three regionally designated 

sensitive fish species: the finescale dace (Phoxinus neogaeus), the lake chub (Couesius 

plumbeous) or the mountain sucker (Catostomus platyrhynchus). These species are known to 

occur on the Black Hills National Forest; however, neither these species nor their habitats are 

present in the Cold Springs project area. 

The mountain sucker is also designated a management indicator species on the Black Hills 

National Forest. This project would have no effect on the forestwide population trend of the 

mountain sucker because of the lack of habitat in the project area. 

Cumulative Effects 

Given the lack of direct or indirect effects, alternative B would not have an additive incremental 

impact in relation to past, present, or reasonably foreseeable actions. Subsequently, there will be 

no cumulative effects. 

Summary and Comparison 

The no-action alternative and modified proposed action would have no direct, indirect, or 

cumulative effects on fisheries. There are no fisheries in the project area and no effects to 

downstream fisheries are expected. 

Botany 

Introduction 

This section discusses the environmental consequences of the alternatives on botanical resources 

and noxious weeds. It summarizes the Cold Springs Project Botany Report (Englebert 2011a), 

which is located in the Cold Springs project file. Specific botanical resources discussed include 

rare plants and their habitats (region 2 sensitive species, Black Hills plant species of local 

concern, and other South Dakota State-listed species) and Black Hills montane grasslands. 

Region 2 sensitive species are species identified by the regional forester for which population 

viability is currently of concern, as evidenced by significant current or predicted downward trends 

in population numbers or density, or by significant current or predicted downward trends in 

habitat capability that would reduce a species’ existing distribution (USDA Forest Service 2011). 

A biological evaluation was prepared to disclose the determination of effects on region 2 sensitive 

plant species (Englebert 2011b). That document can be found in the project record. A summary is 

included in this section. 
Cold Springs Project 

74 

Species of local concern are species that do not meet the criteria for sensitive status. These could 

include species with declining trends in only a portion of region 2, or those that are important 

components of diversity in a local area. 

South Dakota State-listed species are plant species that are considered rare in the State of South 

Dakota. The State has identified these plants for tracking by the South Dakota Natural Heritage 

Program. Most of the region 2 sensitive and species of local concern are also State-listed species. 

Black Hills montane grassland is a plant community type endemic to the Black Hills. It is 

categorized as G1 (critically imperiled) by NatureServe (NatureServe 2010). Besides being 

unique plant communities, Black Hills montane grasslands are often habitat for sensitive, species 

of local concern, and State-listed plant species. 

Methodology 

Region 2 Sensitive Species and Black Hills Species of Local Concern 

Impacts to the sensitive plant species and plant species of local concern may be direct, such as 

trampling, defoliation, and mechanical damage; or more indirect such as a change in the 

microclimate or species composition, both of which may result in a loss of habitat. In general, 

direct impacts are short-term impacts, occurring immediately, while indirect impacts such as 

changes to the habitat occur over a longer timeframe. 

A determination of effects to sensitive species has been made following the direction of Forest 

Service Manual 2672.4. The environmental analysis completed for the Phase II Amendment of 

the Black Hills National Forest Plan (USDA Forest Service 2005a) determined that the Black 

Hills plant species of local concern are likely to persist on the forest under the alternative that was 

selected for implementation. For this project, consistency with Phase II direction will determine 

species of local concern persistence. 

Noxious Weeds 

To analyze the effects of the Cold Springs Project on noxious weeds, we will consider the 

projected change in the rate of infestation for the proposed action. The design criteria listed in 

Table 3 would allow for effective management of noxious weeds throughout project 

implementation. These criteria meet forest plan objectives 230 and 231 as they relate to 

eradication, control, and prevention of noxious weeds. The effects analysis presented below 

assumes that relevant weed prevention practices are implemented. 

Spatial and Temporal Context for Effects Analysis 

The cumulative effects analysis area for the botanical resources will be the areas of potential plant 

habitat within the Cold Springs project area (as identified in the shapefile that can be found in the 

project record). For noxious weeds, the analysis area is the project area (including private 

inholdings). Effects outside of these areas are either minimal or cannot be tracked and defined. 

This analysis is bounded in time as the next 50 years, as described in the 2005 Phase II Final 

Environmental Impact Statement (FEIS) associated with the amendment to the Revised Forest 

Plan. This temporal scale is based on: (a) the biology of the species (e.g., generation time, 

response time to changed conditions, recolonization capability); and (b) the time needed for the 

overall ecosystem to respond to proposed management (USDA 2005a). 
Environmental Assessment 

75 

No-Action Alternative 

Direct and Indirect Effects 

Botanical Resources 

There would be no direct effects to any botanical resources under the no-action alternative, since 

no management activities would occur. Ongoing activities such as recreation, fire suppression, 

and road maintenance would continue. Management activities analyzed under other 

environmental documents would continue to occur. 

There is the potential for indirect effects over time as potential habitat is altered by changes in 

species composition. Orelmann (2011) noted that under the no-action alternative the hardwood 

communities and the open meadows are likely to diminish in number. This could result in a 

reduction in potential habitat for the region 2 sensitive and species of local concern plants that 

prefer these moist forested habitats and for those that prefer open grassy areas. 

Noxious Weeds 

Allen (2010) states that pine stands throughout the project area are susceptible to continued beetle 

mortality and expansion. Canopy gaps created by the death of beetle-killed trees allow light to 

reach the forest floor, creating opportunities for many herbaceous species, including noxious 

weed (Samman and Logan 2000). In areas of the project where weed species are currently 

present, the no-action alternative would likely result in an increase in weed populations as the 

canopy thins and the weeds out-compete the native vegetation. Determining the extent of increase 

in weed populations due to beetle infestation is difficult, but it is expected to be less than what 

would likely occur due to timber management activities. 

Roads are a known major conduit for noxious weeds. Under the no-action alternative, closed 

roads in the project area would remain closed and no new construction would occur. By 

maintaining the current non-use of roads in the project area, noxious weed infestations are less 

likely to increase. 

Modified Proposed Action 

Direct and Indirect Effects – Botanical Resources 

We have generalized the preferred habitats and grouped together the region 2 sensitive and Black 

Hills species of local concern plants (as shown in Table 33) to form habitat categories for analysis 

because effects are similar. 

 
Cold Springs Project 

76 

Table 33. Habitat generalizations 

Common name 

Riparian areas and moist forest 

(includes white spruce and 

hardwood sites) 

Meadows and grasslands 

(includes montane grasslands) 

Arrowleaf sweet coltsfoot X 

Broadlipped twayblade X 

Foxtail sedge X 

Groudcedar X 

Highbush cranberry X 

Iowa grapefern X 

Large round leaf orchid X 

Leathery grapefern X 

Narrowleaf grapefern X 

Northern hollyfern X 

Pleated gentian X X 

Shining willow X 

Stiff clubmoss X 

Yellow lady’s slipper X 

The proposed action can be deconstructed into the following management actions: mechanical 

removal of thinned trees (including non-commercial vegetation treatments), removal of infested 

trees (sanitation), removal of conifers from stands of hardwoods (hardwood enhancement), 

prescribed burning, prescribed burning following mechanical removal of thinned trees, and road 

management activities. 

Effects common to all treatments and all species or habitats 

The project area has been surveyed and no region 2 sensitive or species of local concern plants 

are known to be present, but any time there is habitat for a plant in an area, there is a chance that 

unknown individuals may be present. Therefore, risk cannot be completely eliminated due to the 

possibility of unknown individuals as well as possible mistakes from mapping inaccuracies and 

human error. But, with the design criteria in place, there is minimal risk of effects to rare plants 

and their habitat because potential plant habitat has been identified and would be avoided during 

mechanical treatments. There is a possibility that these treatments may have direct impacts on 

unknown individuals, but the risk is very low. 

A potential indirect effect common to all treatments and all species is the possible change in soil 

moisture and hydrologic function of the area resulting from reduced vegetation via silvicultural 

treatments and broadcast burns. This effect is difficult to predict and quantify and could be 

negative or positive, depending on the magnitude and location. It is possible that an increase in 

available moisture could occur and that increase would improve and/or expand potential plant 

habitat. 

Whenever the ground is disturbed, habitat degradation is possible by invasion or spread of 

noxious weeds resulting from adjacent or immediate disturbances (mechanical vegetation 

treatments and/or prescribed burning). After habitat loss, the spread of invasive species is 

considered the greatest threat to imperiled species in the United States (Sieg et al. 2003). Design 
Environmental Assessment 

77 

features incorporated into the proposed action, standards and guidelines present in Phase II of the 

Black Hills National Forest Land and Resource Management Plan, as amended and the Black 

Hills National Forest Noxious Weed Management Plan (USDA Forest Service 2003) would help 

reduce these indirect effects. Noxious weeds may out-compete desired plant species, and spray 

from herbicides used to help control weeds can also have negative effects. 

Effects from mechanical treatments, all species and habitats 

Any time mechanical treatment is involved, there’s potential for direct impacts to unknown 

individual plants from machinery running through habitats and over individuals. Ground 

disturbance and soil compaction are also possibilities with mechanical treatments and can lead to 

indirect effects by altering habitat components. Effects from ground disturbance would be as 

discussed in the “Effects common to all treatments and all species or habitats” section (i.e., 

potential habitat degradation from invasive species). 

Effects from sanitation and salvage treatments, all species and habitats 

Sanitation and salvage treatments (removal of beetle-infested trees) have the potential to occur 

throughout the Cold Springs project area. Prior to implementation, resource specialists would 

review areas of sanitation and salvage treatment outside of harvest units to determine whether any 

special mitigation is needed to protect forest resources and ensure the proposals comply with 

forest plan direction. With such input, effects to botanical resources would be reduced or 

eliminated. 

Any ground disturbance associated with sanitation and salvage treatments would have the same 

effects as those discussed in the “Effects common to all treatments and all species or habitats” 

section (i.e., potential habitat degradation from invasive species). 

Effects from hardwood enhancement treatment, moist forest habitats 

In general, hardwood communities are considered to be potential habitat for many of the region 2 

sensitive and species of local concern plants (identified as moist forest habitat in Table 33). Areas 

within the hardwood communities with the greatest potential to harbor these plants are identified 

in the potential plant habitat shapefile, and thus, would be protected by design criteria. There is 

however, the slight risk that areas within these hardwood communities have not been identified 

and that unknown individuals would be directly impacted. However, in the long term, 

enhancement of these hardwood communities would enhance habitat for those species. 

Any ground disturbance associated with hardwood enhancement treatments would have the same 

effects as those discussed in the “Effects common to all treatments and all species or habitats” 

section (i.e., potential habitat degradation from invasive species). 

Effects from broadcast burning, moist forest and riparian habitats 

The moist forests and riparian areas identified as potential habitat are unlikely to carry a fire 

during broadcast burning. The broadcast burning proposed in the Cold Springs Project would be 

conducted in the spring (May) and autumn (mid-September to January) to take advantage of 

moderate daytime temperatures and low night time temperatures, higher relative humidity, 

increased chance of precipitation, lower fuel temperatures, and higher fuel moisture content. 

Therefore, no negative impacts to the potential plant habitat are expected. 
Cold Springs Project 

78 

Effects from broadcast burning, meadow and grassland habitats 

The potential habitat identified in site 071303-50 is a mesic meadow that is unlikely to carry a 

fire when burned within prescription. Therefore, no negative impacts to the potential plant habitat 

are expected. The uplands surrounding the mesic meadow may be potential habitat for grapeferns 

and moonworts (Botrychium species). Broadcast burning has the potential for a positive indirect 

effect of maintaining the open conditions these Botrychium species seem to prefer, with the 

possibility of a negative direct impact if an unknown occurrence is in the area to be treated. Dr. 

Donald Farrar (2004) stated that when the above-ground growth of these diminutive plants is 

present, a fast-moving fire may remove above-ground stem portions, but would not be expected 

to affect below-ground individuals or parts. In fact, the burning may release more nutrients to the 

soil to benefit the mycorrhizae associated with these plants, as there is often a flush of growth 

following fires. 

Two State-listed grasses are known to occur at this site; tufted hairgrass and California oatgrass. 

Tufted hairgrass generally survives all but the most severe fires (Walsh 1995). It usually sprouts 

from the root crown after the aerial portions are burned. This area would be burned under 

prescription in the autumn or spring, so burning is not expected to be severe, and thus would not 

be detrimental to the tufted hairgrass. California oatgrass has a high fire tolerance and does not 

decrease in cover after burning (Lambert 2003), so prescribed burning is not expected to be 

detrimental to it either. 

There is the risk that broadcast burning may behave differently than anticipated or result in 

patchy areas of higher severity burning. The possibility of escape of a broadcast burn, while 

greatly minimized by the precautions taken, could negatively impact potential plant habitat in a 

manner similar to wildfire. Small patches of higher severity burning may also occur, and could 

adversely impact potential plant habitat, including removal of shading overstory, disruption of 

soil micro-organisms, invasion of noxious weeds and/or non-native plant species, and destruction 

of the seed bank due to consumption or high soil temperatures. 

Activities associated with broadcast burning may result in direct impacts to habitat or individuals, 

such as crushing or burning, but no detrimental effects are expected. In the long term, the habitat 

would likely be enhanced. 

Effects of road management activities, all habitats or species 

None of the ground-disturbing transportation actions would occur in areas identified as potential 

plant habitat; therefore, no direct effects are expected. Indirect effects to potential habitat include 

the potential for an increase in invasive species as discussed in the “Effects common to all 

treatments and all species/habitats” section. Another indirect effect that may occur is related to 

accessibility. New roads may make areas that were previously inaccessible to people and grazing 

animals more readily accessible, which could lead to trampling, grazing, or collection of rare 

plants, as well as acting as a vector for noxious weed spread. 

Direct and Indirect Effects – Noxious Weeds 

Noxious weed infestations are expected to increase under the modified proposed action. Skid 

trails, landings, burn piles, temporary roads and areas where machinery would be working all 

create a seedbed for noxious weeds. The potential for noxious weed establishment is even greater 

in disturbed areas adjacent to existing weed populations. Under this alternative, 4,904 acres have 

the potential for being disturbed as trees are dropped and skidded to landing decks and understory 
Environmental Assessment 

79 

fuels are treated. Proposed treatment would result in an estimated 147 additional acres of noxious 

weeds, and the transportation actions could result in an additional 17 acres of noxious weeds. 

Areas proposed for broadcast burn activities could result in additional acres of infestation. Dozer 

line, hand lines, staging areas, and areas with mineral soil exposed are all susceptible to weed 

infestation. Again, these areas are even more susceptible when existing weed populations are 

nearby. Pre-treatment of weed infestations before broadcast burn activities reduces the risk of 

spread. 

Equipment moving in and out of treatment and/or broadcast burn areas facilitates the 

establishment and spread of noxious weeds. When equipment moves into the project area from 

another area (especially out of state) it has high potential for carrying noxious weed seed (or plant 

parts) into the project area. Many new invaders, noxious weeds that are not previously known to 

an area, become established this way. Moving from an infested area to a weed-free area within the 

project area can have the same effect—spread of noxious weeds. Applying the design criteria 

would help reduce these risks. 

A potential indirect effect of the proposed treatments is an increase in off-road motorized travel 

due to the expanded road system and increased accessibility resulting from the removal of trees 

and fuels. As off-road use increases, noxious weed spread and infestation increases. 

Cumulative Effects – Botanical Resources, Noxious Weeds, Both Alternatives 

Past, present, and reasonably foreseeable future activities within the project area include livestock 

grazing, timber harvest and thinning, motorized and non-motorized recreational use, road and 

trail building and maintenance, insect and disease outbreaks, fire suppression, prescribed fire, 

road construction, urban development (sub-dividing and development of private land), and 

noxious weed infestation and treatment. A list documenting past and planned future activities for 

the project area is included in Appendix C. 

The effects of these types of activities on region 2 sensitive and species of local concern plants 

and their habitats and noxious weeds are as follows: 

 Livestock grazing leads to biomass removal and trampling. It can lead to changes in species 

composition, compaction of soils, changes in fuel loading and the fire regime, downcutting of 

riparian areas with subsequent drying of adjacent meadows, and noxious weed invasion. 

Grazing animals can spread noxious weeds and transport weed seeds into new areas. Grazing 

impacts likely occurred within the project area in the past at intensities and frequencies 

greater than current or future levels. Through allotment management plans, potential future 

impacts to region 2 sensitive and species of local concern plant species by livestock trampling 

or grazing can be reduced. 

 Timber harvest and thinning has led to a more open canopy with additional light reaching the 

forest floor (which may be beneficial or detrimental, depending on the species), soil 

disturbance and compaction, development of skid roads, and noxious weed invasion. Changes 

in forest composition, structure, and fire frequency have also occurred. Timber harvest and 

thinning also increase impacts from recreational activities by allowing improved access. 

 Motorized and non-motorized recreational use has led to the development of non-system 

roads and trails, development of dispersed campsites, erosion, and the vectoring of noxious 

weeds in previously uninfested areas. These activities can lead to physical damage to plants 

and their habitats (biomass removal, vegetation compaction, and ground disturbance). 
Cold Springs Project 

80 

Vehicles and people help spread noxious weeds by carrying weed seeds into new areas. These 

impacts are controllable through area closures and travel management. 

 Road and trail construction and maintenance causes soil disturbance and erosion, 

fragmentation and destruction of habitat, and noxious weed invasion. It also increases the 

impacts from recreational activities by allowing improved access. 

 Insect and disease outbreaks are natural events that occur periodically, although current levels 

are more intense than in recent memory. Such outbreaks lead to tree mortality, creation of 

forest-gap habitats, opening of meadow habitats, increase of weed spread and potentially to 

stand-replacing fires. 

 Fire suppression has led to increased fuel loading, canopy closure, and higher intensity 

wildfire. Fire is a natural disturbance in the ecosystem. In some areas, habitat succession and 

fire could possibly create or improve habitat for select plant species by opening up meadows 

or reducing the litter accumulation and competition from other plants. In other areas, 

wildfires or controlled fires would create high ground temperatures that could sterilize the 

soil and eliminate fungal species that are necessary for the survival of others. Fire also tends 

to favor post-fire germination of non-native species in environments where non-natives are 

abundant and/or native species are stressed. 

 Urban development destroys plant habitat, fragments populations, and increases the risk of 

weed invasion and fire. 

The actions and effects described above can be both additive and interactive to each other and to 

the direct and indirect effects described earlier. Current management direction is designed to 

eliminate or reduce negative cumulative impacts by protecting region 2 sensitive and species of 

local concern plants from direct and indirect impacts and to allow for the treatment of noxious 

weeds under the current weed management plan for the Black Hills National Forest. Because 

there are policies, standards, and guidelines that limit effects, the cumulative effects are not 

expected to contribute to any change in status or viability of region 2 sensitive and species of 

local concern plants. Also, the cumulative effects are not expected to contribute to an increase in 

any current or predicted downward trend in population numbers or density or to current or 

predicted downward trends in habitat capability that would reduce the existing distribution of any 

of the region 2 sensitive and species of local concern plant species discussed in this analysis, 

under either of the alternatives. 

Summary and Comparison 

Region 2 Sensitive Plants and Black Hills Species of Local Concern 

The effects to Black Hills species of local concern and region 2 sensitive species can be 

summarized as: 

 Under the no-action alternative, no activities would occur, thus there would be no direct 

effects. 

 There is a potential indirect effect to both the hardwood and meadow habitats if proposed 

treatments do not occur. This could lead to a loss of habitat for the species that prefer 

hardwood and meadow habitats 

 There may be habitat in the project area for all species addressed in this analysis. When 

habitat is present in a project area, there is always the possibility that unknown 

individuals are present, which management activities may directly affect. 
Environmental Assessment 

81 

 None of the known occurrences of arrowleaf sweet coltsfoot, broadlipped twayblade, 

leathery grapefern, northern hollyfern, pleated gentian, shining willow, stiff clubmoss, 

foxtail sedge, groundcedar, highbush cranberry, Iowa moonwort, lesser roundleaved 

orchid, lesser yellow lady’s slipper, and narrowleaf grapefern on the Black Hills National 

Forest are located within this project area and none would be disturbed by activities 

associated with this project. Therefore, while loss of unknown individuals may occur in 

this project area, the viable populations at the known occurrences would not be affected. 

 Treatments within the moist forested sites and meadow areas are expected to enhance the 

habitat long term. 

 Design criteria are in place to reduce the risk to individuals and potential habitat. 

 With ground-disturbance activities, there is a chance of noxious weed infestation which 

can degrade habitat. 

The FEIS accompanying the Phase II Amendment to the Black Hills National Forest Plan 

determined that the species of local concern plant species addressed in this analysis are all likely 

to persist on the forest under the management outlined in the forest plan (USDA Forest Service 

2005a). Because this project has been determined to be consistent with the forest plan for these 

species, it can be determined that they would be likely to persist, relative to this project. 

A biological evaluation was completed for this project and it can be found in the project record. It 

details the determination of effects made for all region 2 sensitive species that may have habitat in 

the project area (see summary of effects in Table 34). Please see the biological evaluation for 

details. 

Table 34. Summary of effects – region 2 (R2) sensitive and Black Hills species of local concern 

(SOLC) plants (MII = May impact individuals, but not likely to result in a loss of viability on the 

planning area, nor cause a trend toward Federal listing.) 

Common name Scientific name Status 

Determination of effects 

(R2 sensitive) or Persistence (SOLC) 

No-action 

Alternative 

Proposed Action 

Alternative 

Arrowleaf sweet 

coltsfoot 

Petasites frigidus var. 

sagittatus SOLC Likely to persist Likely to persist 

Broadlipped 

twayblade Listera convallarioides SOLC Likely to persist Likely to persist 

Foxtail sedge Carex alopecoidea R2 sensitive MII MII 

Groundcedar Lycopodium 

complanatum R2 sensitive MII MII 

Highbush 

cranberry 

Viburnum opulus var. 

americanum) R2 sensitive MII MII 

Iowa grapefern Botrychium campestre R2 sensitive MII MII 

Leathery grapefern Botrychium multifidum SOLC Likely to persist Likely to persist 

Lesser 

roundleaved orchid Platanthera orbiculata R2 sensitive MII MII 
Cold Springs Project 

82 

Table 34. Summary of effects – region 2 (R2) sensitive and Black Hills species of local concern 

(SOLC) plants (MII = May impact individuals, but not likely to result in a loss of viability on the 

planning area, nor cause a trend toward Federal listing.) 

Common name Scientific name Status 

Determination of effects 

(R2 sensitive) or Persistence (SOLC) 

No-action 

Alternative 

Proposed Action 

Alternative 

Lesser yellow 

lady’s slipper 

Cypripedium 

parviflorum R2 sensitive MII MII 

Narrowleaf 

grapefern Botrychium lineare R2 sensitive MII MII 

Northern hollyfern Polystichum lonchitis SOLC Likely to persist Likely to persist 

Pleated gentian Gentiana affinis SOLC Likely to persist Likely to persist 

Shining willow Salix lasiandra var.

caudata SOLC Likely to persist Likely to persist 

Stiff clubmoss Lycopodium 

annotinum SOLC Likely to persist Likely to persist 

Noxious Weeds 

There would be an increase of approximately 150 acres of noxious weed infestation in the project 

area due to management activities associated with the proposed action. Weeds are also expected 

to increase as a result of the beetle infestation that is expected to occur under the no-action 

alternative. While it is difficult to quantify, it is expected that the increase in infestation under the 

no-action alternative would be less than that expected under the modified proposed action. 

Treatment of noxious weeds is expected to continue in the area as described in the Black Hills 

National Forest Noxious Weed Management Plan. 

Hydrology and Soils 

Introduction 

This analysis discloses the potential effects of the alternatives on soil and water resources. It 

summarizes the Cold Springs Soil and Hydrology Report (Maloney 2011), which is located in the 

Cold Springs project file. 

The majority of the project area is located within one 6th code subwatershed (6th Code HUC) −

Upper Spearfish Creek (see Table 35). 

Table 35. Cold Springs Project affected watersheds 

HUC 6 Name HUC 7 Code Total Watershed Acres 

Upper Spearfish Creek 10120203030101 8,672 

Upper Spearfish Creek 10120203030102 8,476 

The subwatersheds all have terrain that has relatively gentle slopes. Slopes are gently to 

occasionally moderately steep, rolling prairie grassland stringer meadows bounded by ponderosa 
Environmental Assessment 

83 

pine forests. Slopes in the project area mostly range between 0 to 20 percent (nearly 80 percent of 

the project area). Stream dissection is generally low with some moderate stream dissection 

occurring within the Upper Spearfish Creek and Clayton Draw. 

Soils in the project area are dominated by the soil map unit 184E (Stovho-Lail-Trebor complex, 2 

to 12 percent slopes) and 75E (Lail-Trebor complex, 10 to 40 percent slopes). Both of these soil 

map units are fairly productive and resilient. All soil units except for 187G are well suited for 

forestland harvesting equipment. However, soil rutting hazards are rated severe for all map units. 

This indicates that although soils are well suited for withstanding the impacts of forest harvesting 

equipment, when the soils get wet or saturated, soil rutting will occur quickly, on both harvest 

units and on unsurfaced roads. 

The only major stream in the project area is Spearfish Creek, and all of its length within the 

project area is considered to be intermittent. Most of the streams in the project area are grassland 

swales to irregularly continuous intermittent streams with bed and bank scour. Streams tend to be 

grass-lined and, in many cases, are bounded by dense grass. There are 21 miles of intermittent 

streams and 18 miles of ephemeral streams. 

There are no streams listed by the State of South Dakota as not meeting beneficial uses (fish and 

wildlife propagation, recreation, stock watering, and irrigation) the project area. 

Spatial and Temporal Context for Effects Analysis 

Analysis for effects on soils will be limited to the actual proposed vegetation, transportation and 

fuel treatment activity area locations. 

Analysis for direct and indirect hydrology effects concentrates on the affected subwatersheds 

(Table 35). Cumulative effects are assessed at the scale including all affected sixth field 

watersheds. For the purpose of this analysis, short-term effects are considered to last no more 

than 3 to 5 years. Medium-term effects are those which last beyond 5 years, but less than 15 

years. Any effect which has an impact on water quality, water yield, or riparian habitat that lasts 

longer than 15 years is considered a long-term effect. 

No-Action Alternative 

Direct Effects 

There would be no change from the soil or water resources current condition resulting from the 

no-action alternative. There would be no additional impacts to soil and water resources as a result 

of not implementing the proposed action. 

Indirect Effects 

Under the no-action alternative, current management plans would continue to guide management 

of the project area. No fuels management activities would be implemented to accomplish project 

goals. Road maintenance and repair, and trail maintenance and repair would continue. This 

alternative would allow the project area to continue on its current trend without the proposed 

management actions. There would be no additional indirect effects to water, riparian, or aquatic 

resources. 
Cold Springs Project 

84 

Cumulative Effects 

There would be no change from the soil or water resources current condition resulting from the 

no-action alternative. There would be no additional impacts to soil and water resources as a result 

of not implementing the proposed action. Therefore, there would be no additional cumulative 

effects to soil or water resources. 

Modified Proposed Action 

Design Features and Mitigation Measures 

The project would implement project design criteria and best management practices in order to 

comply with forest plan requirements and other laws and regulations. Water influence zones 

(WIZ) are delineated for those stream reaches that have been determined perennial or intermittent 

under most conditions of climate or intermittent with prolonged dry season base flow sustained 

by groundwater storage (USDA Forest Service 2006). They have also been delineated around 

wetlands and springs. TheWIZ for this project is a 100-foot buffer along streams, seeps, lakes, 

and ponds (USDA Forest Service 2006). 

The modified proposed action alternative, through project design criteria, incorporates Forest 

Service Soil and Water Conservation Practices and Best Management Practices (WCPs/BMPs) 

(USDA Forest Service 2006) that are designed to protect and restore watershed resources. All of 

these measures included in the action alternative have evolved through extensive research and 

development (Burroughs and King 1989) and have been monitored and modified over several 

decades, with the express purpose of improving measures and making them more effective. 

Federal and State site evaluations of BMP control measures (Seyedbagheri 1996; USDA Forest 

Service 2010) have found the practices to be effective in protecting beneficial uses. 

Soils - Direct and Indirect Effects 

Soil Disturbance 

The effects of the modified proposed action on soils are direct effects and would be limited to the 

vegetation and fuel treatment activity area locations. The impacts from the project activities are 

expected to occur from the use of ground-based mechanical equipment used for felling and 

yarding. Concerns regarding effects to soils are (1) surface soil displacement from log and brush 

skidding and the turning action of tracked ground-based equipment, and (2) the potential for the 

compaction of soils due to the weight and vibration of the ground-based equipment. Soil 

disturbance surveys were conducted to analyze and address soil displacement concerns. Soil 

compaction concerns were analyzed through a field (Cold Springs Soil Health Surveys 2008) and 

GIS review of the soil units proposed for ground-based treatment. The risk for compaction was 

evaluated based on the inherent physical properties of the affected soil map units and their 

potential for compaction (see Table 36). The expected detrimental disturbance ratio increase and 

post-project detrimental disturbance ratio were based on ongoing and recent past project 

disturbance rations. 
Environmental Assessment 

85 

Table 36. Detrimental soil disturbance ratios for project area treatment types 

Treatment Type 

Activity Area Acres 

Current Avg. 

Detrimental 

Disturbance 

Ratio12

Expected 

increase in 

Detrimental 

Disturbance 

Ratio13

Expected Total 

Post-Project 

Detrimental 

Disturbance Ratio 

Aspen Release 572 <3% ≤1 to 5% ≤8% 

Thinning, Selection and 

Shelterwood 3,852 <5% ≤5% ≤10% 

Wildlife Timber Stand 

Improvement 117 <3% ≤4% ≤7% 

Broadcast Burn 897 <3% ≤3 – 5% ≤5% 

Pile and Burn 279 <5% ≤3% ≤11% 

Slash, Pile, and Burn 494 <3% ≤1% ≤4% 

Sanitation and Salvage 11,761 <3% ≤5% <8% 

The inherent resilience of the soils within the project area allow for the relatively frequent 

silvicultural treatment cycles. Recent monitoring of past harvest areas within the project area 

shows relatively minimal detrimental soil-disturbance impacts. This is mainly due to the 

productivity of the soils and their dry bearing strength. Grass and pine needle duff mats quickly 

reclaim disturbed soil areas and prevent any long-term soil resource damage. Detrimental soildisturbance ratios exceeding 15 percent are typically considered to not be meeting standards and 

guidelines for the maintenance of long-term soil productivity (FSH 2509.18). None of the 

proposed vegetation treatments are expected to exceed the 15-percent threshold. 

The new roads, temporary roads, skid trails and landings to be utilized for vegetation treatment 

activities were considered in conjunction with the treatment units. Temporary roads, skid trails, 

and landings generally produce short- to mid-term detrimental soil-disturbance impacts if they are 

not treated and rehabilitated. Temporary roads and landings can take up to 5 years to be 

rehabilitated due to access needs for post-harvest treatments. None of the proposed temporary 

roads cross an existing stream channel. They do cross the edges of some meadows, but in all 

cases are well away from WIZ. Landings would be located outside of meadows or on the margin 

(within the transition zone) between the grassland and forested area. However, according to soildisturbance monitoring in the project area, the rehabilitation rates post activities are relatively 

rapid. Recent soil-disturbance monitoring indicates that these features are readily rehabilitated 

due to the local soil productivity and resilience of basal vegetation. This is most likely due to the 

implementation of WCPs/BMPs and the natural aggressive revegetation of ground vegetation. 

Therefore, the project-induced soil disturbance is assumed to be reclaimed and restored to a nondetrimental soil-disturbance condition within 5 to 10 years, as long as project design criteria and 

WCPs/BMPs are applied. 

The impacts to soils from the current road system are primarily associated with the public using 

roads that are not part of the transportation system and user-defined off-highway vehicle roads 

and trails. The 209.3D road in Clayton Draw is currently a site where road use is creating 

detrimental soil disturbance conditions, as vehicles are creating ruts and small gullies in the 

meadow. The decommissioning of that road segment would be a net benefit in terms of the 

overall percentage of detrimental soil disturbance within the subwatershed. The road segment 

 

12 Current detrimental disturbance ratios are based on project area field data. 

13 Expected detrimental disturbance rations are based on monitoring of similar projects. 
Cold Springs Project 

86 

(FSR 232.1) that passes by Yellow Jacket Spring has problems associated with wet season travel 

and road surface rutting. This would be improved by maintaining the road to Forest road 

standards during the project. 

Therefore, the direct effects are expected to be some short-term soil displacement and some slight 

compaction associated with skid trails. Landings and pile burning would also create isolated 

disturbance areas with high burn severity locations (generally between 1/10th and a quarter acre 

in size). These effects are expected to last short- to mid-term (less than 10 years), and are not 

expected to contribute to the overall long-term detrimental soil-disturbance ratio. 

There would be no indirect effects from or to the soil resource. All of the effects to the soil 

resource are considered to be direct effects. 

Long-Term Soil Productivity 

There would be no direct or indirect effects to long-term soil productivity. The local soils are 

resilient as long as they are not impacted with ground-based equipment during wet or saturated 

soil conditions. Long-term soil productivity would be maintained through the implementation of 

project design criteria and WCPs/BMPs. Recent monitoring has shown that soil disturbance, and 

therefore, long-term soil productivity, are maintained within forest plan standards for disturbance. 

Mass Movement 

None of the soils identified in the forest plan for slope stability issues are found in the project 

area. There are some areas of steep slopes which are may have slope instability (Slope Stability, 

2008, Northern Hills District) but those areas are typically short sections of steep slopes (over 30 

percent slopes). Road construction is proposed in one of those concern areas; however the road 

route avoids the steep sections and would not require impacting the areas of steep slope. Further, 

vegetation treatment units would retain a forest stocking of at least 80 square feet of basal feet on 

slopes greater than 55 percent. Therefore, soil stability would be maintained through the 

avoidance of road construction and heavy cutting on steep slopes where treatment areas have 

been identified as a concern for slope stability. 

Hydrology- Direct and Indirect Effects 

The direct effects to water quality would be limited to a very few locations and situations where 

roads with drivable fords cross streams. There are no proposed temporary roads or landings to be 

constructed within WIZ areas. The impact of the road crossings would be negligible (and more 

likely beneficial over time) as most of the current crossings would be maintained or upgraded to 

conform to WCPs/BMPs. Stream crossings for log yarding activities would be required to meet 

WCP/BMPs for log skidding activities. The storm-proofing of these road crossings and 

implementation of WCPs/BMPs are expected to minimize sediment input or disturbance to 

stream channels (Burroughs and King 1989). Any disturbance to a stream that might occur would 

be identified and rehabilitated following BMP and timber contract processes. 

The Water Erosion Prediction Project (WEPP) road modeling indicates that there would not be a 

substantial difference in sediment delivery at road crossings from the current condition due to 

implementation of the modified proposed action. There are currently 70 stream crossings and the 

modified proposed action would not add crossings through temporary or new system road 

construction. Road traffic is expected to increase for limited periods of time during 

implementation, and potentially could increase sediment delivery; however, sediment delivery at 

crossings should actually stay the same or slightly decrease due to upgrades at the stream channel 

approaches to meet BMP guidelines (Table 37). 
Environmental Assessment 

87 

Table 37.Estimated sediment delivery to road crossings by alternative 

Treatment Level Tons Sediment per Year per Crossing 

Alternative 1- No Action 0.1 

Alternative 2- Proposed Action 0.1 

There would be no direct effects to steamflow, wetlands or WIZ areas. The implementation of 

WIZ buffers precludes any direct effects. All effects to streamflow, wetlands, and WIZ areas are 

indirect effects that happen at a different time or place from the implementation of the modified 

proposed action. 

Indirect effects to water resources and riparian areas are those effects which occur off-site (not 

directly on the waterbody) and do not immediately affect water quality, riparian health, or stream 

channels (such as is the case with the local area of a road crossing). The effects usually occur at a 

later time or place as a result of precipitation events and runoff (erosion from an activity unit or 

landing to a stream after a storm event for example). 

Treatments adjacent to the WIZ usually pose the most risks for impacts to water quality, riparian 

health, and stream channels. Therefore, for the purposes of this project, treatment activities were 

delineated for locations outside of the WIZ. Effects to the WIZ would be controlled through the 

combined implementation of project design features and WCPs/BMPs. 

As noted in the direct effects section, road crossings are the most likely locations for effects to 

water, riparian, and aquatic resources. There are no new or temporary roads or landings proposed 

in streams, wetlands or within the WIZ area. Therefore, the existing stream crossings are the 

locations where there is potential for an effect to stream channels or water quality. The other 

potential for effects to water, riparian, and aquatic resources would be from activities outside of 

the WIZ that could be transported downslope through the WIZ to a stream channel. Sediment 

delivery from upslope activities could potentially be transported through the WIZ to downslope 

intermittent streams. Table 38 displays the analysis of the potential for sediment delivery through 

the intermittent WIZ stream buffers. 

Table 38. Estimated volume and risk of sediment delivery through the WIZ as a result of 

implementing the modified proposed action. Erosion and sedimentation estimates are based on the 

WEPP FuME model (Elliot et al. 1999). 

Treatment Type 

Tons per square 

mile in first year 

of disturbance 

“Average” Annual 

Hillslope 

Sedimentation 

(tons per square mile 

per year) 

Wildfire (Slopes up to 10%) 1,497.6 37.4 

Wildfire (Slopes up to 20%) 2,835.0 70.9 

Wildfire (Slopes up to 40%) 4,748.8 118.7 

Prescribed Fire (Low Intensity- Slopes up to 10%) 76.8 0.3 

Prescribed Fire (Low Intensity- Slopes up to 20%) 172.8 8.6 

Prescribed Fire (Low Intensity- Slopes up to 40%) 313.6 15.7 

Thinning, Selection and Shelterwood (Slopes up to 10%) 12.8 0.6 

Thinning, Selection and Shelterwood (Slopes up to 20%) 25.6 1.3 

Thinning, Selection and Shelterwood (Slopes up to 40%) 44.8 2.2 
Cold Springs Project 

88 

Table 38. Estimated volume and risk of sediment delivery through the WIZ as a result of 

implementing the modified proposed action. Erosion and sedimentation estimates are based on the 

WEPP FuME model (Elliot et al. 1999). 

Treatment Type 

Tons per square 

mile in first year 

of disturbance 

“Average” Annual 

Hillslope 

Sedimentation 

(tons per square mile 

per year) 

Access Roads (Low Traffic) 1.2 to 15 1.2 to 15 

Access Roads (High Traffic) 3.2 to 15 3.2 to 15 

The WEPP model was run using the WIZ buffer width (100 feet) and the road densities that are 

on the upper end of the range for the affected watersheds (3.6 miles per square mile vs. using 2.5 

miles per square mile). By utilizing the more conservative values, the model outputs present a 

reasonable upper bound for impacts and sediment delivery to streams. The WEPP results for 

prescribed fire indicate that there is an initial potential for a slight input of sediment from the 

burning activities, which drops to nearly background levels within the first year. Thinning, 

selection and shelterwood activities and road use are not expected to deliver substantial amounts 

of sediment to stream channels. For example, the prescribed fire on 20-percent slopes would 

equate to approximately 0.25 ton per acre of sediment delivery for treated stands adjacent to 

streams (172.8 tons per 640 acres = 0.27 ton per acre). Thinning on 20-percent slopes would 

equate to approximately 0.04 ton per acre. 

Stream Flow 

Road drainage systems may alter a stream’s water yield. These changes occur when subsurface 

and surface flow is captured at road cuts and in ditches, and redirected into a channel (USDA 

Forest Service 1996). Roads can also direct water away from a stream (USDA Forest Service 

1996). The effects of road drainage can include an increase in peak discharge, changes in the 

shape and timing of the hydrograph, increases in the total discharge, and potentially a decrease in 

water quality (USDA Forest Service 1996). However, flow regimes do not appear to be adversely 

affected by the dense road networks in the Black Hills. During field reviews by Forest personnel, 

peak flows of streams were not shown to increase due to road density (USDA Forest Service 

1996). Roads are occupying areas where trees or biomass would be. This creates an opening in 

the forest floor and reduces the evapotranspiration rates on these areas making more water 

available for groundwater recharge or streamflow. Normally roads tend to change flow regimes 

by delivering water more quickly to streams making their peak flows higher. 

Recent research indicates that effects from peak flows, although of concern, should be confined to 

a relatively discrete portion of the network where channel gradients are less than approximately 

0.02 percent and streambeds are composed of gravel and finer material. Furthermore, data support 

the interpretation that if peak flow increases do occur, they can only be detected in flows of 

moderate frequency and magnitude. Beyond that, they are likely not detectable (Grant et al. 

2008). Therefore, it is unlikely that there would be any detectable changes from the current 

condition resulting from either the new road construction or the vegetation treatments. 

Riparian Areas and Wetlands 

Those riparian areas that do exist within the project area are associated with springs and wetlands 

where there is enough water for riparian vegetation to thrive. These areas are scheduled to receive 
Environmental Assessment 

89 

a WIZ buffer of 100 feet. There would be no treatments that effect riparian vegetation with the 

possible exception of broadcast burning. Since broadcast burning would only be allowed to creep 

into wetland and spring WIZ areas, it is not foreseen that fire intensity or organic material 

consumption would be high. The season and timing of burning activities are designed to be 

implemented at a time of the year when wetland and spring areas would be moist and resistant to 

high-severity, high-intensity fire. Broadcast burn control lines could occur within the WIZ buffer, 

however they would be narrow lines (approximately 1 foot wide) constructed with hand tools. 

Therefore, it is not expected that there would be any measurable effect to riparian areas or 

wetlands, and there would be no substantial change from the current condition. 

Water Influence Zones 

Water influence zones would be delineated and implemented for all perennial and intermittent 

streams, wetlands, and springs within the project area that are adjacent to treatment activities. 

These WIZ areas are exclusive of ground-based treatment activities and direct lighting of 

broadcast burns. However, end lining, hand thinning, and broadcast fire backing into WIZ areas 

may occur. The instances where these exceptions would occur are expected to be few due to the 

lack of woody vegetation in WIZ areas and the proposed broadcast burn prescription for cool, 

low-severity, low-intensity burns. With the exception of some potentially slight reductions to 

sediment delivery resulting from road maintenance activities, it is not expected that the WIZ areas 

would be substantially impacted or altered from the implementation of the proposed project. 

The project is affecting a very small portion of the available WIZ area within the project 

boundary, but of those acres, there would be a neutral effect due to the limitations on cutting 

riparian vegetation, ground cover maintenance standards, and road maintenance at stream 

crossings. 

Further, improvements in road drainage and implementation of WCPs/BMPs associated with 

project-related road use and maintenance should decrease the overall long-term impact of 

sedimentation on stream channels. 

Cumulative Effects 

The cumulative effects area was delineated based on affected 7th Code Hydrologic Unit 

subwatersheds. The affected subwatersheds and their acreages are listed in Table 39. 

A degree of activity within a watershed, beyond which an adverse effect might be expected, is 

termed a threshold of concern. Thresholds of concern for affected subwatersheds are usually 

developed based on a sensitivity index which includes slope, vegetative cover, geology/erosion 

hazard rating, and critical watershed elements (public drinking water sources, and other 

waterbodies highly susceptible to water quality degradation). A numeric range is supported by 

research and guidelines for soil disturbance, beyond which significant adverse effects in study 

watersheds were reported (Reid 1993). Thresholds of concern are expressed as a percentage of a 

watershed that is in equivalent clearcut area (ECA) (USDA Forest Service 1974, USDA Forest 

Service 2005) and, in this case, is 15 percent ECA within any of the affected subwatersheds. A 

Fifteen-percent threshold was utilized in this case as the majority of the affected watersheds are 

well vegetated, and underlain by geology and geomorphic processes which are relatively resilient 

to forest management practices. Downstream water sources in Spearfish Creek were considered 

and therefore the threshold was ultimately adjusted to the middle of the 14 to 18 percent range. 

Cumulative watershed effects were analyzed using the equivalent clearcut area (ECA) method. 

The ECA model analysis is described in PNW-GTR-637 (USDA Forest Service 2005). 
Cold Springs Project 

90 

Cumulative watershed effects are measured using the ECA model, which generates an index of 

cumulative disturbance (for both soil and water resources) by considering disturbance type, 

extent, and recovery over time. Although the model has many limitations, it provides an index of 

vegetative disturbance that can be used to compare the existing condition of different watersheds, 

and the potential impacts among land management alternatives. It uses a clearcut acre as the basis 

for comparing effects of various resource management treatment activities and features. A road 

surface, in the context of the method, is considered to be a native surface forest road (total 

clearcut), bare of vegetation, severely compacted and practically impervious, that sheds water and 

possibly conveys some distance to all water precipitated upon it. Thinning and prescribed fire 

vegetation treatments are considered to be a percentage of a totally clearcut acre with some 

portion of the acre left in a vegetated condition but reduced in hydrologic function. Judgment of 

the effect of proposed actions is made in consideration of current conditions, as determined by 

field observations, and those environmental parameters that are deemed relevant to the response 

of watershed hill slopes and channels in the project area. 

For the purposes of this analysis, it was assumed that all of the proposed treatment acreage would 

be implemented. This approach will most likely overstate the actual effects as not all acres would 

ultimately be treated. However, since it is essentially unknown which areas will be canceled for 

treatment activities, the more “conservative” approach is necessary to encompass all possible 

effects. 

The percent ECA (Table 39) shows the relative disturbance level attributed to each watershed by 

resource management activities and existing conditions prior to and after the implementation of 

an action alternative, which is estimated here as 2011. 

Implementation of the proposed action would initially increase the ECA values over the current 

condition beyond the threshold of concern in the short term. However, the thinning and fuel 

treatment generally raise the ECA values due to their broad-scale coverage. The intensity and 

impact of the treatments is of such a nature that they don’t present a long-term impact. The 

resilience of the local soils and the implementation of project design criteria and BMPs will 

assure that ECA values and impacts to the affected subwatersheds will be within threshold of 

concern values within 3 to 5 years. The broadcast burning effects are, however, expected to be 

relatively light to moderate from a hydrologic standpoint. The broadcast burns are expected to be 

low-intensity over most of the proposed burn areas and hydrologic soil conditions are expected to 

recover to pre-fire levels relatively rapidly (within 1 to 3 years). 

ECA modeling is an index of overall watershed disturbance and does not account for spatial 

location or mitigation factors which reduce erosion and ground disturbance. Therefore, it is not 

expected that the project will have a substantial impact at the watershed scale due to the relatively 

small additions in ECA attributable to the project activities. Although the ECA values indicate 

some increases over current values, the actual impacts associated with the project should be 

benign or slightly beneficial when considered in context of reintroducing fire into the ecosystem 

and the implementation of project design features and WCPs/BMPs. 
Environmental Assessment 

91 

Table 39. Equivalent clearcut by watershed. Note: the estimated threshold value for the affected 

subwatersheds is 15 percent equivalent clearcut area (ECA). 

7 Code HUC 

Subwatershed Acres 

Threshold of 

concern 

(percent of 

equivalent 

clearcut area) 

Current 

Condition 

ECA 

Immediate 

post project 

ECA 

3 to 5 years post 

project, percent 

2011 2013 2016 to 2018 

10120203030101 8,672 15% 3% 17% 2% 

10120203030102 8,476 15% 5% 32% 12% 

Summary and Comparison 

Direct effects to project area soils from implementation of the modified proposed action are 

expected to be short-term: soil displacement and slight compaction associated with skid trails. 

Pile burning would also create isolated high burn severity locations (generally less than 1/10th of 

an acre each). These effects are expected to last short- to mid-term (less than 10 years), and are 

not expected to contribute to the overall long-term detrimental soil disturbance ratio. There would 

be no direct or indirect effects to long-term soil productivity; long-term soil productivity would 

be maintained through the implementation of project design criteria and WCPs/BMPs. Soil 

stability would be maintained through the avoidance of road construction and heavy cutting on 

steep slopes where treatment areas have been identified as a concern for slope stability. The 

wetlands would have a WIZ buffer (100 feet) that excludes most activities. Through project 

activity avoidance of wetlands, the potential impacts to wetlands would be minor. 

The project watersheds’ existing conditions are all functioning well within their thresholds of 

concern, but they are not in a natural pristine condition; they are functioning in a managed 

system, and are therefore, functioning at risk in terms of hydrologic condition and aquatic 

resources. The affected watersheds are currently listed as Class 2 in the forest plan. Nevertheless, 

the modified proposed action itself does not increase the overall impact to watersheds and aquatic 

resources over the long term. Total equivalent clearcut area in both affected watersheds is under 

15 percent. Based on this analysis, it is not expected that the modified proposed action would 

negatively impact the affected subwatersheds from their current condition. 

Air Quality 

Introduction 

Air quality in the Black Hills area is generally excellent (USDA Forest Service 2005). The nearest 

area listed by the Environmental Protection Agency for non-attainment of particulate matter less 

than 10 microns in size (PM10) is Sheridan, Wyoming, approximately 200 miles west (i.e., 

upwind) of the project area (EPA 2011). South Dakota does not have any identified PM10 nonattainment areas nor are any PM2.5 non-attainment areas identified in Wyoming or South Dakota 

(EPA 2011). 

No-Action Alternative 

Direct, Indirect, and Cumulative Effects 

The no-action alternative would have no immediate effects on air quality. Fire hazard would 

remain high across much of the project area. These conditions increase the potential for a large, 
Cold Springs Project 

92 

stand-replacing fire, which would be expected to generate more smoke, possibly when smoke 

dispersal conditions are poor, and greater negative effects on air quality than a prescribed burn. 

Modified Proposed Action 

Direct and Indirect Effects 

The modified proposed action includes pile and broadcast burning. Smoke from burning 

associated with this alternative could affect air quality and human health. Effects would not be 

expected to extend more than about 20 miles from the burn site, based on experience with 

previous prescribed burns in the area. Although pile and broadcast burning would increase 

emissions for a few days at a time, proposed treatments are expected to decrease the potential for 

large, uncontrolled fires for up to 20 years. Burning would be conducted when smoke dispersal 

conditions are favorable to minimize negative effects on the immediate area. 

Pile and broadcast burning would release carbon dioxide and other compounds into the 

atmosphere. Emissions of greenhouse gases, including carbon dioxide, are the main 

anthropogenic cause of current climate change (Seppälä et al. 2009). Forest management can 

enhance the capacity of forests to act as a carbon sink, but can also contribute carbon to the 

atmosphere (Hurteau et al. 2008). The scale of individual project contributions and effects may be 

negligible and impossible to measure. Changing climate could affect resources in the project area 

over time, especially at lower-elevation sites along the edge of the prairie. Current forest plan 

direction generally would provide increased resilience to such changes. 

Cumulative Effects 

The spatial boundary for analysis of cumulative effects on air quality is all lands in the project 

area. There are no large population centers within 5 miles of the proposed burn blocks, where 

experience shows direct and indirect effects of smoke are generally discernible. The temporal 

boundary extends from the initiation of each burn to the end of active burning, usually from a day 

to a week. 

Other actions and events relevant to air quality include burning of slash at log landings (including 

large piles resulting from whole-tree yarding) in timber sales near the project area and on nonNFS lands, and broadcast burning elsewhere on the national forest or lands of other ownership. 

Burning of slash piles usually occurs in winter; in dry winters with little snow, burning may occur 

in many areas at once during the limited time when snow cover is available. Under these 

conditions, the modified proposed action could add to smoke effects of burning in adjacent areas. 

If burning conditions remain favorable for an extended period of time, it would be possible for 

proposed burns to occur around the same time as burns elsewhere on the Forest, which could 

result in the presence of smoke for a longer than usual period. Favorable conditions, however, 

generally last only a few weeks each season. 

Summary and Comparison 

The no-action alternative would have no immediate effects on air quality; however project area 

fire hazard would remain high or very high across much of the project area, increasing the risk of 

a large wildfire and associated smoke. 

The modified proposed action includes broadcast burning and pile burning. Smoke from burning 

could affect air quality and human health; however, burning would be conducted when smoke 

dispersal conditions are favorable to minimize negative effects on the immediate area. The 
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93 

timeframe for potential negative effects would be limited to the days burning is initiated and the 

following 1 or 2 days. Proposed treatments would decrease the potential for large, uncontrolled 

fires and the smoke associated with a wildfire. 

Recreation 

Introduction 

This analysis discloses the potential effects of the alternatives on recreation resources. It 

summarizes the Cold Springs Recreation Resource Report (Jones 2011), which is located in the 

Cold Springs project file. 

The project area includes a portion of the non-motorized Eagle Cliff Trail system, including two 

developed trail heads. Popular activities on this system include cross-country skiing and 

snowshoeing. 

The project area is located near the heart of the Black Hills snowmobile trail system. There are 

approximately 16 miles of groomed snowmobile trails within the project area. A major 

snowmobile trail head, Trailshead Lodge, is located just outside the project boundary and the 

grooming hub of the trail system is based at Hardy Guard Station, just west of the project 

boundary. 

Spatial and Temporal Context for Effects Analysis 

The cumulative effects analysis area is the project area plus a 2-mile buffer around the project 

area. This extent is chosen because recreational uses in the project area are connected to adjacent 

areas (trails extend beyond the project area boundary), and events within the project area may 

displace use to adjacent, but reasonably nearby areas. The time period used for analysis is 10 

years prior until 10 years into the future. This period of time accounts for recent impacts that have 

occurred along with future impacts that can reasonably be foreseen. 

No-Action Alternative 

Although the no-action alternative would not change current management or propose any new 

activities, changes would still occur through natural biological processes and human use of the 

area. Visitors will continue to recreate on the Forest, and access to private land would be 

requested. 

Direct and Indirect Effects 

No changes would be made to developed, dispersed recreation or travel management. The same 

recreational activities that are currently available in the Cold Springs project area would continue 

to be available under this alternative. 

The number of pine trees infested and killed by mountain pine beetles is likely to continue to 

increase while climatic conditions and population dynamics are favorable. This would lead to 

increasingly unsafe conditions in recreation areas because of increased potential for falling trees. 

Many visitors consider beetle-killed trees unsightly, and increasing numbers of beetle-killed trees 

may encourage visitors to recreate in more scenic areas. 

Travel management would remain the same. No new closures or openings of new areas would 

occur. The changes to the travel management system were made with the Travel Management 

Record of Decision dated March 22, 2010, and would be implemented as such. 
Cold Springs Project 

94 

Cumulative Effects 

Hardy Guard Station, Eagle Cliff Trails, various snowmobile trails, Trailshead Lodge, and 

Thunderhead Episcopal Church Camp are all either Forest Service or private facilities adjacent to 

the project area. Cumulative effects from activities within the project area could conceivably 

impact these facilities. Under the no-action alternative, no thinning of ponderosa pine would 

occur, allowing likelihood of mountain pine beetle infestation to continue to increase. Beetlekilled trees are less aesthetically pleasing than healthy trees because they display red needles the 

year after mortality. The presence of mountain pine beetles in the Cold Springs project area would 

also increase the risk of infestation of trees outside the area, including trees around and within the 

listed facilities. Loss of trees immediately adjacent to or within these facilities would decrease 

their attractiveness to users. 

As the local population increases, use of forest roads and trails will probably continue to increase. 

This increased use may result in increased dust, ruts, damage and vandalism if the roads and trails 

are not maintained at adequate levels. No improvements or closures would take place under the 

no-action alternative, compounding the effects of increased use. 

The no-action alternative would not change the existing recreation or travel management 

direction for the project area, and therefore, would not contribute to cumulative effects. 

Modified Proposed Action 

Direct and Indirect Effects 

Proposed treatments to promote healthy forests would be a benefit to the recreation program. 

Healthier forests are safer and provide a visually more appealing appearance for the visitor to 

enjoy. 

All developed sites, non-motorized trails, and snowmobile trails would be protected during 

harvest activities. There will be no direct effects to the trail systems. 

The Eagle Cliff Trails would be minimally affected. Several proposed treatment areas are 

adjacent to the trail. The recreation staff would work with other Forest Service timber sale 

administrators to provide for safety near the trail during harvesting operations. Removal of hazard 

trees and general maintenance along designated trails and developed recreation sites would 

continue. Timing restrictions would be included to have no harvesting activities adjacent to the 

groomed cross-country ski trails from December 1 to March 31. 

Road reconstruction and maintenance activities would improve safety conditions for all users. 

National Forest System Road 209.3D is a road open to highway-legal vehicles according to the 

motor vehicle use map, and is slated for decommissioning. A new road is proposed to be 

constructed east of this road. Having the road in a more sustainable location would benefit the 

travel system. 

The Forest Service will continue to repair and maintain National Forest System roads and trails 

under its jurisdiction. New and existing user-created routes that are causing resource damage will 

be rehabilitated or removed, as funding allows. Emergency restrictions will continue to be 

implemented as needed, such as temporarily closing roads during wet conditions to prevent 

rutting and erosion or during periods of extreme fire danger. The Forest Service will continue to 

patrol and enforce regulations to protect road and trail surface resource, vegetation, and other 
Environmental Assessment 

95 

resources. This alternative will not affect State, county, or private management. Current 

management would continue unless changed through the travel management program. 

Any effects to dispersed recreation would be temporary in nature. As the name implies, dispersed 

recreation can occur anywhere throughout the project area. Campers, hunters, snowmobilers, 

people gathering forest products, or driving for pleasure, for example, can choose to recreate in 

another location if management activities are currently taking place in the area they like to 

frequent. Recreation would be disrupted in areas of harvest activity, but would be expected to 

return to normal when harvesting is complete. 

No changes in special use permits for outfitters or guides are anticipated under the action 

alternative. 

Cumulative Effects 

The recreation experience in Hardy Guard Station, Eagle Cliff Trails, various snowmobile trails, 

Trailshead Lodge, and Thunderhead Episcopal Church Camp immediately adjacent to the Cold 

Springs project area may benefit from proposed management activities. Thinning of ponderosa 

pine stands in the project area would decrease their susceptibility to mountain pine beetle 

infestation and the likelihood that beetles would spread to the areas. 

The road improvements proposed under the Cold Springs Project, in combination with the 

direction contained within the travel management decision, would result in a more clearly 

defined, safer motorized recreation experience in the project area. Road reconstruction and 

maintenance would make the existing road network safer for public travel. In addition, the travel 

management decision would define which routes are open to travel and what types of vehicles are 

allowed on them. This combination of effects could also have a positive effect on non-motorized 

recreation in that access to recreation areas is improved and it would be clear which routes are 

open to motorized vehicles and which are not. 

Summary and Comparison 

Although visitors may be temporarily displaced during proposed harvest activities, in the long 

run, a healthier forest would provide a safer and more aesthetically pleasing visitor experience in 

comparison to the no-action alternative. The decommissioning of road 209.3D and addition of the 

new road would create a more sustainable route for the travel system in comparison to the noaction alternative. 

Scenery 

Introduction 

This analysis discloses the potential effects of the alternatives on scenic resources. It summarizes 

the Cold Springs Project Scenery Management Resource Report (Hill 2011), which is located in 

the Cold Springs project file. 

The project’s effects on scenic integrity are addressed in this analysis. The measurement 

indicators for this analysis are the proposed activities’ compliance with forest plan established 

scenic integrity objectives (SIOs) for the project area and area of treatment type in each SIO. 

SIOs are management objectives adopted from the scenic class values. Scenic integrity is a 

measure of the degree to which a landscape is visually perceived to be “complete.” The highest 

scenic integrity ratings are given to those landscapes that have little or no deviation from the 
Cold Springs Project 

96 

character valued by constituents for their aesthetic appeal (USDA Forest Service 1995, 2-1). 

Within the Cold Springs project area, about 12 percent of the landscape is allocated as high SIO, 

about 35 percent is moderate SIO, and about 41 percent is low SIO. Figure 7 displays the project 

area SIOs in relation to the commercial treatment units. The SIOs found in the project area 

include: 

High SIO – A scenic integrity level meaning human activities are not visually evident. 

Activities may only repeat attributes of form, line, color, and texture found in the existing 

landscape character (USDA Forest Service 2006). The valued landscape character “appears” 

intact or unaltered. Deviations may be present but must repeat the form, line, color, texture, 

and pattern common to the landscape character so completely and at such scale that they are 

not evident (USDA Forest Service 1995). 

Moderate SIO – A scenic integrity level that refers to landscapes where the valued landscape 

character “appears slightly altered.” Noticeable deviations must remain visually subordinate 

to the landscape character being viewed (USDA Forest Service 1995, 2006). 

Low SIO – A scenic integrity level referring to the landscapes where the valued landscape 

character “appears moderately altered.” Deviations begin to dominate the valued landscape 

character being viewed, but they borrow valued attributes such as size, shape, edge effect, 

and pattern of natural openings, vegetative type changes, or architectural styles within or 

outside the landscape being viewed. They should not only appear as valued character outside 

the landscape being viewed but compatible or complimentary to the character within (USDA 

Forest Service 1995, 2006). 

The effects analysis will consider how each alternative meets the allocated SIOs. Effects caused 

by the no-action and modified proposed action alternatives were also considered in relation to the 

desired landscape character. 

Spatial and Temporal Context for Effects Analysis 

Short-term scenic effects of timber harvest and vegetation management are often the most 

noticeable until the growth of grasses, shrubs, and remaining trees begin to soften the effects of 

harvest operations. Short-term for this analysis refers to a 3- to 5-year period after all vegetation 

treatment and fuels reduction activities in an area are complete. Short-term effects are especially 

noticeable when the viewer has an up-close view of the treatment site usually in the foreground 

viewing distance. Long-term effects, which for this analysis is considered beyond 5 years, vary 

by the treatment and the logging method used. The scenic resource analysis considered the area 

within the project area boundary, unless otherwise noted. 

Past harvest of timbered slopes is generally noticeable for 15 to 30 years, depending on treatment 

prescriptions, soils, aspect, and vegetative species composition. At the end of this time period, the 

regrowth of vegetation begins to develop characteristics of a closed canopy and the area no longer 

appears altered. A complete list of potential cumulative actions can be found in Appendix C. The 

cumulative effects analysis area is the Cold Springs project area and viewshed of U.S. Highway 

85 adjacent to the project area, including lands in other ownership. 
Environmental Assessment 

97 

Figure 7. Cold Springs Project proposed commercial treatments and scenic integrity objectives map 
Cold Springs Project 

98 

No-Action Alternative 

Direct and Indirect Effects 

There would be no human-caused changes to the scenic quality within the project area. The noaction alternative would meet the adopted high, moderate, and low SIOs throughout the project 

area, as it does not create any unnaturally appearing elements of form, line, color, or texture. 

Vegetation structure would change over time through natural growth, mortality and events such as 

wildfires, storms, and insect outbreaks. High amounts of fuels, if established, do not create 

visually preferred open stands with high visual access and a clear forest floor. The potential for 

wildfire and insect outbreaks in this alternative would be an additional risk to the stability of the 

scenic resources in the future. Under the no-action alternative, the natural evolution of the 

vegetative component of the landscape would continue to change the scenic qualities of the area 

over time. For example, wind storms or snow and ice storms may cause portions of the project 

area, particularly beetle mortality areas, to blow down or contain areas of broken-topped trees. 

If the vegetation in the project area was consumed by fire, the existing landscape character would 

be lost until trees and understory vegetation reestablishes. If killed by wildfire, scorched timber 

and shrubs would alter the forested setting, changing the sense of place for visitors in the area. “In 

general, natural forest disturbances that result in extensive areas of dead or dying trees (Haider 

and Hunt 2002, Ribe 1990) such as the destruction of the forest by fire or flooding are perceived 

negatively (Daniel 2001; Fanariotu and Skuras 2004; Gobster 1994, 1995)” (cited in Ryan 2005, 

17). 

If many trees were killed by an insect outbreak at epidemic levels, the existing landscape 

character could also be lost until trees reestablish. Trees killed by an insect outbreak would be 

very noticeable in the first two years of mortality, as long as red needles persist. After needles fall 

to the ground, standing, dead trees appear gray in color. In most cases groups of dead trees, once 

needles have fallen, would remain subordinate to a surrounding landscape of green trees. 

However, an epidemic outbreak that kills entire stands of trees, or groups of trees larger than an 

acre, may start to dominate the landscape being viewed. Beetle mortality would especially 

dominate when a viewer has a direct view of an affected hillside for longer durations. Tops of the 

standing, dead trees eventually break out or entire dead trees fall to the ground. Areas with a lot of 

mortality often create a “jack-straw” appearance of downed logs across the forest floor as these 

trees fall to the ground. Large amounts of downed material, even if the cause is natural, is not a 

preferred visual setting (Ryan 2005). 

Cumulative Effects 

Because this alternative does not directly affect scenic resources, and because it does not have an 

additive effect to the impacts from past, present, and reasonably foreseeable activities, there are 

no cumulative effects for the no-action alternative. 

Modified Proposed Action 

Direct and Indirect Effects 

Vegetation Treatments 

The visual effects of tree removal, such as commercial thinning or shelterwood treatments, can 

vary depending on the intensity of the treatment. Stumps, slash, and edge effects of newly logged 
Environmental Assessment 

99 

areas or units, depending on the intensity of the treatment, can result in a forest that appears 

moderately altered in the short term. The contrast between harvested and unharvested areas in the 

short term is often quite noticeable. Reducing the amount of slash and woody debris after timber 

harvesting is beneficial for scenic resources, as numerous studies have found that “the public 

responds negatively to downed wood, slash, and other debris from timber harvesting and thinning 

(Arthur 1977, Echelberger 1979, Ruddell et al. 1989)” (cited in Ryan 2005, 45). 

Sanitation treatments would occur within treatment units and throughout the project area at 

mountain pine beetle infestation locations. If many trees need to be removed either within 

treatment units or other parts of the project area, other management activities may become more 

evident. Additionally, if many trees need to be removed, areas of sanitation removal may be quite 

noticeable due to the textural change in the forest canopy. However, if sanitation and salvage 

reduces the potential of large amounts of dead trees, a more preferred scenic setting is anticipated 

in the long term. Prior to implementation, resource specialists would review areas of sanitation 

treatment outside of harvest units to determine whether any special design criteria are needed. 

Commercial thinning, shelterwood preparation, and single-tree selection treatments would have 

similar effects on scenic resources as these treatments would achieve a stocking ranging from 60 

to 80 square feet of basal area. In most areas, trees would be whole-tree logged and hauled to a 

landing for processing, reducing the amount of slash seen in the proposed units after harvesting. 

These treatment types would result in a more open appearing forest. In foreground views, this 

type of harvest would change the visual access into the forested stand by reducing the number of 

tree boles. The forest, from this viewing distance would appear more open with greater visual 

access into the forested stand. The reduced number of trees would allow visitors to view greater 

distances across the otherwise forested area and more light would reach the forest floor. In 

middleground views, with the thinning described above, this type of timber harvest may be 

noticeable as a slight change in the texture of the tree canopy. Whole-tree yarding would reduce 

the amount of woody debris and slash seen from concern level viewpoints. The transition zone of 

unit edges in the scenery project design criteria would reduce any noticeable edges between 

treated and non-treated areas when viewed from the middleground distance. 

Shelterwood establishment cutting and shelterwood removal are the most intensive treatments in 

regards to scenery. These treatments would change the texture of the tree canopy dramatically, 

allowing more of the forest floor to be seen in these areas from both foreground and 

middleground views. The shape and edges of these treatment units would be more noticeable than 

other treatment types because more trees would be removed. These areas would appear quite open 

compared to the existing condition, allowing one to view much greater distances across the area. 

The transition zone of unit edges in the scenery project design criteria would reduce noticeable 

edges between treated and non-treated areas when viewed from the middleground distance. A 

shelterwood removal type consisting of the first step of two-step removal would resemble a 

shelterwood preparation cut described above. 

Precommercial thinning and wildlife timber stand improvement treatments would open the tree 

canopy slightly changing the texture of the tree canopy as viewed from U.S. Highway 85. The 

effects of these thinning treatments would be naturally appearing, creating more visual access in 

these forested stands and allowing the viewer to view greater distances into the forested stand. 

Thinning that would increase tree health and vigor would move these areas toward the desired 

landscape character. Once slash removal is complete, it is anticipated that these activities would 

not be evident. 
Cold Springs Project 

100 

Aspen release would increase visual variety and scenic attractiveness, especially during autumn 

color changes. 

Tree stumps have impacts to scenic resources in the short term and would be most noticeable in 

the immediate foreground view of the identified concern level viewpoints. Visible tree stumps 

from timber harvesting are generally disliked by viewers (Daniel and Boster 1976 and Ryan 

2005). Project design criteria are in place to reduce the visibility of stumps and minimize their 

impacts. Stumps would become less visible within one to two growing seasons as grasses, forbs, 

and shrubs sprout new growth. Table 40 summarizes the acres of vegetation treatment by SIO. 

Table 40. Acres of proposed vegetation treatments in each scenic integrity objective for the 

modified proposed action 

Proposed vegetation treatments 

Acres 

High 

SIO 

Moderate 

SIO 

Low 

SIO 

Total for 

treatment 

Commercial vegetation treatments 

Aspen release 42 36 6 83 

Commercial thin 212 656 530 1,398 

Commercial thin, 50 percent canopy cover 9 12 5 25 

Single-tree selection 101 123 299 523 

Single-tree selection, 50 percent canopy cover 25 11 72 108 

Shelterwood preparation 197 130 204 531 

Shelterwood preparation, 50 percent canopy 

cover 

0 39 68 107 

Shelterwood removal <1 127 174 301 

Shelterwood removal (1st step of 2 step) 23 33 0 56 

Shelterwood establishment 44 333 913 1,290 

Total commercial treatment area 4,424 

Noncommercial vegetation treatments 

Aspen release (247 acres following vegetation 

treatment) 135 183 170 489 

Precommercial thin(1,060 acres following 

vegetation treatment) 199 532 485 1,215 

Precommercial thin and aspen release following 

commercial treatment 0 98 9 107 

Wildlife timber stand improvement (34 acres 

following vegetation treatment) 6 35 76 83 

Total noncommercial vegetation treatment 1,928 

Note: Any slight discrepancies in totaling acreages are from rounding values in GIS. 

Views from U.S. Highway 85, including Bratwurst and Holey Rock Trailheads 

The foreground viewshed of U.S. Highway 85 is mostly allocated as high SIO, while most of the 

middleground viewshed is allocated moderate SIO. Views from the highway in the eastern 

portions of the project area, including the Bratwurst and Holey Rock Trailheads, are mostly 

limited to the highway corridor due to steep slopes and densely forested areas. Traveling farther 
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101 

west, meadow openings and gentler slopes adjacent to the highway allow for longer views of the 

proposed treatments. 

Proposed treatments occurring in the immediate foreground and foreground of U.S. Highway 85 

in high SIO include: shelterwood preparation cutting, commercial thinning, single tree selection, 

aspen release and pre-commercial thinning. Aspen release would increase visual variety and 

scenic attractiveness viewed from U.S. Highway 85. The forest, as viewed from U.S. Highway 

85, would appear more open with greater visual access into the forest. Where treatments are right 

next to the highway, visitors would be able to view greater distances across the otherwise forested 

area and more light would reach the forest floor. These treatments would create visually preferred 

settings having attributes of large trees; smooth, herbaceous ground cover; and an open midstory 

canopy with high visual penetration. Once all project activities are complete and with the scenery 

project design criteria applied, it is anticipated that project activities would not be visually evident 

to the visitor as viewed from U.S. Highway 85. 

The first step of a two-step shelterwood removal is also proposed above Holey Rock Trailhead. A 

higher basal area (about 60 square feet basal area) would be retained so that this area has forested 

appearance although the area may appear more open and have a slightly more open canopy 

texture. These treatments are also located above steep slopes north of the highway and trailhead, 

and would not be visually evident for long durations of view. 

Two treatment units of shelterwood establishment cutting are proposed in high SIO. Although 

these treatment units are mostly screened by topography, it is anticipated they may be seen for 

short durations of view. Project design criteria specific to these units include leaving more trees 

ranging from 40 to 60 square feet of basal area in an irregular spacing and leaving denser areas or 

islands of trees throughout the unit. This project design feature ensures the use of form, line, color 

and texture of the characteristic landscape so that deviations are not evident. 

Middleground views of the proposed treatments would continue to have a forested canopy 

character with vegetation treatments providing a slightly more open texture to the forest canopy 

when viewed from U.S. Highway 85. With the scenery project design criteria applied, it is 

anticipated that these vegetation treatments would not be visually evident in the characteristic 

landscape being viewed from U.S. Highway 85. 

Views from Tinton Road (NFS Road 134.1) 

The foreground and middleground viewsheds of Tinton Road are mostly allocated as moderate 

SIO. Proposed treatments occurring in the immediate foreground and foreground of Tinton Road 

include: shelterwood preparation cutting, commercial thinning, single-tree selection, aspen 

release, and precommercial thinning. Aspen release would increase visual variety viewed from 

Tinton Road. Where treatments are adjacent to Tinton Road, visitors would be able to view 

greater distances across the otherwise forested area, and more light would reach the forest floor. 

These treatments would create visually preferred settings having attributes of large trees and an 

open midstory canopy with high visual penetration. Once all project activities are complete and 

with the scenery project design criteria applied, it is anticipated that project activities would not 

be visually evident or any noticeable deviations would remain visually subordinate to the 

landscape character being viewed from Tinton Road. 

Views from South Rapid Road (NFS Road 231.5) 

The majority of the foreground viewshed of South Rapid Road is allocated as moderate SIO with 

some foreground areas and most of the middleground viewshed allocated as low SIO. Most of the 
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102 

views from South Rapid Road are of the foreground viewshed with limited views of the 

middleground viewing distance. 

Proposed treatments occurring in the immediate foreground and foreground of South Rapid Road 

in moderate SIO include: commercial thinning, single-tree selection, wildlife timber stand 

improvement, aspen release, and precommercial thinning. Aspen release would increase visual 

variety and scenic attractiveness viewed from South Rapid Road. The forest, as viewed from 

South Rapid Road, would appear more open with greater visual access into the forest. Where 

treatments are adjacent to the road, visitors would be able to view greater distances across the 

otherwise forested area, and more light would reach the forest floor. These treatments would 

create visually preferred settings having attributes of large trees; smooth, herbaceous ground 

cover, and an open midstory canopy with high visual penetration. Once all project activities are 

complete and with the scenery project design criteria applied, it is anticipated that project 

activities would not be visually evident to the visitor as viewed from South Rapid Road. 

Several treatment units of shelterwood removal and shelterwood establishment cutting are 

proposed in moderate SIO. These treatment types would open the forested setting quite noticeably 

when next to South Rapid Road, and would dominate the landscape if the viewer had longduration views or was standing within the treatment unit. These treatments, when next to the road, 

are spaced occasionally along South Rapid Road. The spacing and scale of these treatments next 

to the road would limit long duration views of these treatments. The change in texture of the tree 

canopy would be noticeable, but with the scenery project design criteria applied and with the 

spacing of proposed treatments along the road, it is anticipated these activities would remain 

subordinate to the landscape being viewed from South Rapid Road. 

Several shelterwood establishment treatments (units 071305-5, 071305-17, and 071305-4) are 

concentrated south of South Rapid Road and partially located in an area of moderate SIO. The 

change in canopy texture and scale of these units may begin to dominate the characteristic 

landscape if viewed. However, it is anticipated that topography south of the road would screen 

enough of these treatments from view that they would remain subordinate to the landscape being 

viewed from South Rapid Road. In any case, the project design criterion specific to unit 071305-5 

includes leaving more trees in the northern half of the unit, ranging from 40 to 60 square feet of 

basal area with irregular tree spacing. This project design feature ensures the use of form, line, 

color, and texture of the characteristic landscape so that deviations in moderate SIO remain 

subordinate to the landscape being viewed. 

Views from Long Draw Road (NFS Road 209.1) 

Long Draw Road passes through the southeastern portion of the project area with foreground 

viewsheds allocated as moderate and low SIO. Proposed treatments occurring in the immediate 

foreground and foreground of Long Draw Road in moderate SIO include: commercial thinning, 

single-tree selection, shelterwood removal, and precommercial thinning. The forest, as viewed 

from Long Draw Road, would appear more open with greater visual access into the forest. Where 

treatments are right next to the road, visitors would be able to view greater distances across the 

otherwise forested area, and more light would reach the forest floor. These treatments, along with 

proposed broadcast burning in these units, would create visually preferred settings having 

attributes of large trees; smooth, herbaceous ground cover; and an open midstory canopy with 

high visual penetration. Once all project activities are complete and with the scenery project 

design criteria applied, it is anticipated that project activities would either not be evident or if 

noticeable, would remain visually subordinate to the landscape being viewed from Long Draw 

Road. 
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103 

Cross-country ski trails in the area near Bratwurst and Holey Rock Trailheads 

Cross-country ski trails have immediate foreground and foreground viewsheds allocated as high 

and moderate SIO. Views of proposed treatments from the trails would be for longer durations. 

Proposed treatments next to cross-country ski trails include: shelterwood establishment cutting, 

shelterwood removal (first step of two-step process), commercial thinning, single-tree selection, 

and precommercial thinning. Effects to scenery from these treatments would be similar to those 

described for other concern level viewpoints above, but with longer duration views. 

Fuel Treatments 

All proposed burning activities would have short-term effects of burned, blackened vegetation, 

and charred ground surfaces. Grasses and shrubs would resprout within one growing season after 

the burn, no longer being visually evident at that time. The proposed control line may be 

noticeable within the immediate foreground viewing distance from identified U.S. Highway 85, 

South Rapid Road, and Long Draw Road, but it is anticipated this activity would also not be 

visually evident after one growing season. In the long-term, burning would increase the diversity 

of texture, color, vegetative size classes, and distribution across the landscape. In the short and 

long terms, underburning often creates a smooth, herbaceous ground cover, a preferred visual 

setting. Less severe natural disturbances, such as low burn severity areas where understory burns 

but most mature trees are not killed, result in preferred forests over time (Taylor and Daniel 

1984). 

Concentrations of surface and ladder fuels would be hand- or machine-piled and burned. 

Handpiling and burning, when debris is fully consumed, is a preferred hazardous fuels treatment 

in visually sensitive areas such as next to private property (Ryan 2005). Scenery effects of burned 

ground surfaces would be limited to the pile location rather than spread throughout the unit. 

Handpiles would be noticeable until burned, and the burned areas may be noticeable until grasses 

resprout. It is anticipated the handpile burned areas would not be evident after about one growing 

season as these areas revegetate and the surrounding shrubs, grasses, and forbs would screen most 

of the burned areas from view. This activity may be seen from U.S. Highway 85, South Rapid 

Road, Tinton Road, and Long Draw Road. Slashing treatments are proposed in units scattered 

throughout the project area. The cutting of understory vegetation component would open up the 

stands to a more park-like vegetative mosaic and provide more visual access into forested stands, 

a preferred visual setting. Understory slashing would mostly be noticeable in foreground views as 

people would be able to view greater distances across the forested stand. This activity may be 

seen from U.S. Highway 85, South Rapid Road, and Tinton Road. Table 40 shows proposed fuels 

treatments by SIO. 

Logging Removal Methods and Associated Facilities 

Removal methods for vegetation treatments include ground-based and skyline systems throughout 

the project area. 

Skyline Removal Methods 

Skyline corridors have the potential to create straight lines through a normally continuous canopy 

of forest. Effects of skyline logging removal to scenic resources include the potential to view into 

the skyline corridor from nearby roads. Skyline logging removal is located in the eastern portion 

of the project area and would not be visible from concern level viewpoints. Up to about 14 acres 

could be removed by skyline systems in moderate SIO and 119 acres in low SIO. 
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104 

Ground-based Removal Methods 

Ground-based removal methods would take place throughout the project area. Where groundbased logging would be used to remove trees, evidence of logging would be apparent primarily in 

foreground views. Possible effects include skid trails, which often create lines of exposed soils 

across the forest floor. These effects would last for about 3 years until grasses and shrubs in the 

understory reestablish and lessen the effects of ground-based equipment. Some effects by groundbased harvest operations would also be softened by the proposed prescribed burning. Groundbased removal, which is proposed on about 653 acres of high SIO, about 1,660 acres of moderate 

SIO, and about 1,978 acres of low SIO, would not be noticeable once all project activities are 

complete. It is anticipated that high, moderate, and low SIOs would be met from the identified 

concern level viewpoints within three growing seasons of all project activities being complete. 

Hauling Routes and Landings 

The log hauling routes for the majority of the timber removal includes roads throughout the 

project area. Approximately 48 miles of roads under Forest Service jurisdiction would be used as 

haul routes for timber and would have pre-use maintenance or reconstruction. Road reshaping and 

new road surfacing would be noticeable due to the fresh, lighter colored soils which would be 

added or exposed. After about one to two growing seasons, these road improvements would not 

be visually evident. 

Landings are most evident during project implementation before large piles of logs and slash are 

removed and immediately after project implementation until the landing is revegetated. The 

majority of landings would be away from view of concern level viewpoints such as U.S. Highway 

85. With the scenery project design criteria applied, it is anticipated that landings would not be 

evident from the identified concern level viewpoints. 

Temporary Road Construction 

Construction of temporary roads can affect scenery by exposing light-colored soils and creating 

noticeable color contrasts which may be seen in foreground and middleground views. Generally 

temporary roads, once rehabilitated, revegetate quickly and would visually recover in the short 

term once rehabilitation activities are complete. Temporary roads would be located throughout the 

project area and not visible or readily evident from the identified concern level viewpoints. 

Other Road Management Activities 

Road Decommissioning 

Road decommissioning activities generally have short-term effects to scenery by exposing lightcolored soils which create noticeable color contrasts in foreground and middleground views. 

These short-term effects would visually recover quickly as the areas revegetate. The long-term 

effects of road decommissioning are beneficial to scenic resources by recontouring slopes to 

mimic natural landforms and rehabilitating and revegetating exposed soils generally visible on cut 

and fill slopes created during road construction. Road decommissioning would be located in the 

Clayton Draw area and may be noticeable from South Rapid Road for up to five growing seasons 

until the area revegetates. 

New Road Construction 

The replacement for road 209.3D would be located to the east, outside of the meadow passing 

through forested vegetation and in a location where proper drainage can be maintained. The new 

location would also allow timber harvest landings to be located in forest stands, outside of 
Environmental Assessment 

105 

meadows. New road construction will be noticeable by exposing light-colored soils on the new 

road surface and cut and fill slopes, and by potentially creating a break in the tree canopy. The 

new road construction near Clayton Draw is located in moderate and low SIO and has the 

potential to be seen by South Rapid Road. However, the new road location follows hillside 

contours borrowing design from the characteristic landscape. It is anticipated that once newly 

exposed soils fade, the road would remain subordinate to the landscape being viewed from South 

Rapid Road. About 1 mile of new road construction is located south of South Rapid Road and is 

not anticipated to be evident from this route once constructed due to topography screening from 

the road. 

About 0.8 mile of new road construction is located in the foreground viewing distance of U.S. 

Highway 85. However, the new road construction is located in a forested area with higher 

proposed basal area and mostly screened from view by steep, roadside slopes in the eastern 

portion of U.S. Highway 85. A slight break in the tree canopy may be noticeable for short 

durations when traveling along U.S. Highway 85 by this new road construction. 

Non-system to System Road Conversion 

About 2.4 miles of non-system road would also be converted to system road. The routes proposed 

for conversion are unclassified, user-created routes or routes that were National Forest System 

roads, but have since been decommissioned. The road template already exists. The route would be 

added to the National Forest System and improved as necessary to meet Forest Service 

specifications. Effects to scenery would be similar to those described for road maintenance or 

reconstruction activities. These routes would be closed to motorized vehicle use following 

management activities. One route proposed for conversion can be seen in the foreground viewing 

distance of U.S. Highway 85 for short duration. This route does not dominate the landscape, but 

is noticeable as a native surface route intersecting with the highway. Since the route already exists 

on the ground and would be closed to motorized use following management activities, it is 

anticipated that the location and conversion of this road borrows from the form, line, and texture 

common to the existing landscape character so completely and at such a scale that conversion of 

this road would not be evident from U.S. Highway 85. Other routes proposed for conversion are 

not visible from concern level viewpoints due to topographic screening. 

Cumulative Effects 

Past activities have formed the current recreation opportunities and settings and most often form 

the viewing platform and opportunities for viewing scenery. 

Cumulative effects to scenic resources in the Cold Springs project area are expected to meet the 

SIOs of the forest plan in the short term. In the long term, the scenic resources would have more 

open canopy vegetation conditions characteristic of the Mountainous/Mixed Forest Landscape 

Character Unit of the Laccolith Mountains. In high SIO areas, it is expected that any human 

activities would not be visually evident and would repeat naturally established form, line, color, 

and texture. In moderate SIO, it is expected that any noticeable deviations would remain visually 

subordinate to the landscape being viewed. In low SIO areas, any deviations present, although 

they may dominate the valued landscape character, would borrow valued landscape attributes of 

the characteristic landscape. 

The proposed vegetation treatment and fuels reduction activities along with the past, present, and 

reasonably foreseeable future activities would result in some short-term effects to scenic 

resources, but would meet the designated SIOs of high, moderate, and low either at project 

completion or up to three growing seasons after all project activities are complete. Project design 
Cold Springs Project 

106 

features are in place to minimize the effects of the project on scenic resources. These short-term 

effects are expected until grasses, forbs, and shrubs sprout new growth after fuels reduction 

activities and soften the effects of the broadcast burning so that activities would either not be 

visually evident or, if they are evident, would be visually subordinate to the surrounding 

landscape. The project has been designed to meet the SIOs assigned to the project area by the 

Black Hills Forest Plan in the short term by applying the scenery project design criteria. In the 

long term, it is anticipated the stability of scenic resources would be improved by reducing the 

risk of mountain pine infestation and natural fuels and activity-generated slash and leads the 

landscape toward the desired landscape character. In the long term, the project area would be 

naturally appearing with visually preferred settings. 

Vegetation treatments, fuels treatments, and road management treatments associated with this 

project, along with the past, present, and reasonably foreseeable future activities, would have no 

cumulative effects to scenic resources. 

Summary and Comparison 

Under the no-action alternative there would be no changes to scenic quality. Changes to scenery 

would be initiated by natural processes. If vegetation were consumed by a fire or killed by an 

insect outbreak, views of the area may be dominated by large amounts of dead trees, which is not 

part of the desired landscape character. This alternative likely results in conditions and trends that 

put valued scenery attributes at risk with potential indirect effects that reduce the stability of 

scenic resources. 

The modified proposed action would create short-term effects to scenic resources while project 

activities are taking place and, depending on the treatments proposed in an area, for up to three 

growing seasons after all project activities are complete. The stability of scenic resources would 

be improved by reducing fuel loads and leads the landscape toward the desired landscape 

character. In the long term, the project area would be naturally appearing with attributes of 

visually preferred settings: smooth, herbaceous ground cover; an open midstory canopy with high 

visual penetration; and large tree promotion. 

Heritage Resources 

Introduction 

This analysis discloses the potential effects of the alternatives on cultural resources. It 

summarizes the Cold Springs Project Heritage Report (Scrivner 2011), which is located in the 

Cold Springs project file. 

Effects to cultural resources are analyzed based on potential damage or adverse effects to all 

cultural sites within the project boundary. All sites were assessed for possible adverse effects or 

damages. 

Spatial and Temporal Context for Effects Analysis 

The spatial context for analysis is the project area. The temporal context for effects analysis is 

two-fold. The immediate temporal context is essentially the direct effects that the current 

proposed project would have on cultural resources; that is, immediate changes to site condition or 

integrity, or even National Register status, as a direct result of project actions. The long-term 

temporal context is essentially the indirect effects that the current proposed project would have on 
Environmental Assessment 

107 

cultural resources, that is, long-term changes to site condition, integrity, or National Register 

status resulting from changes instigated by the project actions. 

No-Action Alternative 

Direct Effects and Indirect Effects 

Under the no-action alternative no new direct effects would occur. Cultural resources would 

continue to be susceptible to the effects of fuel loading, increasing the risk of wildfire. Cultural 

resources would continue to naturally deteriorate over time. Cultural resources would continue to 

be threatened by natural processes (wildfire, erosion) and minimally from recreational activities 

that bring modern people in contact with cultural sites. 

Currently, approximately 59 percent of the project area pine stands have a High or Very High fire 

hazard rating, and wildfire has a negative effect on cultural resources due to extreme 

temperatures, an inability to control the effects, and because resource inventories cannot be 

conducted in advance. Fire suppression activities such as bulldozer-created control lines, hand 

lines, and fire retardant drops all have the potential to destroy or damage cultural resources. In 

addition, wildfires cause erosion through vegetation-cover loss resulting in resource deterioration. 

Vegetation-cover loss may also inadvertently lead to increases in vandalism and looting of 

cultural sites as well. The high temperatures of wildfires cause rapid surface weathering of 

features and artifacts, accelerating loss. 

Cumulative Effects 

Cumulative effects to cultural resources are potential impacts on cultural sites from past, present, 

and foreseeable activities. Previous activities would have been mitigated via cultural resources 

inventory and documentation, and subsequent mitigation of adverse effects. Future activities will 

require cultural resource inventory prior to implementation and appropriate mitigation measures 

to be implemented to avoid or minimize adverse effects to National Register eligible sites. 

Modified Proposed Action 

The modified proposed action has the potential to adversely affect cultural resources if heritage 

design criteria are not implemented. Positive effects of the proposed action to heritage resources 

include an opportunity for the Forest to monitor eligible cultural sites, a reduction in fuel load, 

and the management of control lines to reduce the risk of wildfire. These actions all benefit the 

long-term heritage management goals of the Black Hills National Forest. 

Design Criteria 

Project design criteria to protect cultural resources are incorporated as an integrated part of the 

modified proposed action. To mitigate the potential of ground disturbance from vegetation 

treatments and road-related activities, all cultural resource sites will be flagged per South Dakota 

standards with a 30-meter buffer and avoided. Mechanical thinning and log and tree skidding will 

not be permitted within site boundaries. In addition, trees near the boundary of cultural resources 

will be felled away from sites, so that sensitive features and artifacts are not damaged by falling 

trees or the activity required removing them. Cultural resources that occur within planned lowintensity broadcast burn units will be similarly flagged, and avoided and buffered with a hand 

control line as necessary to prevent fire from spreading onto cultural sites and inadvertently 

causing thermal damage to artifacts or complete destruction of any wooden features or artifacts 
Cold Springs Project 

108 

associated with those sites. Cultural resources that occur within pile and burn units will be 

flagged and avoided. No pile burning will occur within site boundaries. 

If these design criteria are followed, then no adverse effects are expected. However, if the scope 

of work changes or if any additional cultural resources are encountered during implementation of 

this project, then work would cease in the area and the district or forest archaeologist would be 

contacted. Work in that area would only resume if, and when, mitigation measures can be 

determined and/or re-evaluated if found to be necessary. 

Direct and Indirect Effects 

No adverse effects are expected due to the implementation of design criteria to project cultural 

resources; however direct effects could occur without design criteria. Direct effects to cultural 

resources are those that physically alter, damage, or destroy all or part of a resource; alter 

characteristics of the surrounding environment that contribute to the resource’s significance; 

introduce visual or audible elements out of character with the property or that alters its setting; or 

resource neglect to the extent that it deteriorates or is destroyed (USDA Forest Service 2005: III411). The modified proposed action has the potential to directly affect the cultural resources 

within the project area. Several potential impacts to cultural resources were identified including: 

timber harvest, the construction of new roads, and burn treatments. Direct effects of timber 

harvest and road construction activities are primarily through ground disturbance caused by 

ground machinery surface disturbance, road grading, felling trees, and skidding logs or trees. 

Felled trees can also damage or destroy above-ground features and historic structures. In addition, 

oil and fuel spills from heavy machinery can damage archaeological deposits. Burn treatments 

have the potential to adversely affect cultural resources by burning historic structures and 

damaging or destroying artifacts and features within archaeological sites. 

Indirect effects under the current proposal are related primarily to reducing the risk of 

catastrophic wildfires in the project area. Adverse effects to cultural resources tend to be greater 

in wildfire situations because of extreme temperatures, an inability to control the effects, and 

because resource inventories cannot be conducted in advance (USDA Forest Service 2005: III413). In addition, wildfires cause erosion through vegetation-cover loss, resulting in resource 

deterioration. Vegetation-cover loss may also inadvertently lead to increases in vandalism and 

looting of cultural sites as well. The high temperatures of wildfires cause rapid surface 

weathering of features and artifacts, accelerating loss. 

Cumulative Effects 

Cumulative effects to cultural resources are potential impacts on cultural sites from past, present, 

and foreseeable actions. Previous activities would have been mitigated via cultural resources 

inventory and documentation, and subsequent mitigation of adverse effects. Future activities will 

require cultural resource inventory prior to implementation and appropriate heritage design 

criteria to be implemented to avoid or minimize adverse effects to resources. 

Summary and Comparison 

In summary, the no-action alternative would have an undesired effect on cultural resources. Most 

significant of these is the increased risk of damage to cultural resources from wildfires resulting 

in artifact damage, wooden structure and feature loss, and loss of site integrity through erosion. 

The modified proposed action could have both negative and positive impacts on cultural 

resources within the project area. However, there will be no adverse or negative effects to cultural 
Environmental Assessment 

109 

resources through the implementation of design criteria. The heritage project design criteria will 

mitigate adverse effects to cultural resources within the project area. Positive effects include 

reduced potential for a catastrophic wildfire that could result in thermal-damaged cultural 

resources, damage from suppression efforts, and increased erosion of archaeological sites. 
Cold Springs Project 

110 

Consultation and Coordination 

Agencies and Persons Consulted 

The Forest Service contacted or consulted the following individuals, Federal, State, tribes, and 

local agencies during the development of this environmental assessment: 

Interdisciplinary Team Members: 

Paul Bosworth Black Hills National Forest, North Zone Transportation Engineer 

Brenda Bowen Black Hills National Forest, District GIS Specialist 

Amanda Campbell Forest Service TEAMS Enterprise, Archaeologist 

Cissie Engelbert Forest Service TEAMS Enterprise, Botanist 

Patricia Goude Forest Service TEAMS Enterprise, Writer-Editor 

Jackie Groce Black Hills National Forest, District Environmental Coordinator 

Nicole Hill Forest Service TEAMS Enterprise, Landscape Architect 

Steve Hirtzel Black Hills National Forest, District Fisheries Biologist 

Bonnie Jones Black Hills National Forest, District Recreation Specialist 

Glen Lewis Forest Service TEAMS Enterprise, Fire and Fuel Specialist 

Caven Maloney Forest Service TEAMS Enterprise, Hydrologist, Soil Scientist 

Janet Moser Forest Service TEAMS Enterprise, Wildlife Biologist 

John Natvig Forest Service TEAMS Enterprise, Team Leader 

Andrew Orlemann Forest Service TEAMS Enterprise, Silviculturist 

Tom Smith Black Hills National Forest, District Range Staff 

Federal, State, and Local Agencies: 

Butte County Board of Commissioners 

Governor Dennis Daugard, State of South Dakota 

Honorable John Thune, U.S. Senate 

Honorable Kirsti Noem, U.S. House of Representatives 

Honorable Tim Johnson, U.S. Senate 

Lawrence County Board of Commissioners 

Meade County Board of Commissioners 
Environmental Assessment 

111 

South Dakota Department of Agriculture, Division of Resource Conservation and Forestry 

South Dakota Department of Environment and Natural Resources 

South Dakota Department of Game, Fish and Parks 

South Dakota Department of Game, Fish and Parks; Division of Parks and Recreation 

South Dakota Department of Transportation 

United States Department of Agriculture, Natural Resource Conservation Service 

United States Department of Interior, Bureau of Land Management 

United States Department of Interior, Fish and Wildlife Service, South Dakota Field Office 

Wyoming Game and Fish Department 

Wyoming State Historical Preservation Office 

Tribes: 

Cheyenne River Sioux Tribe 

Cheyenne/Arapaho Tribes of Oklahoma 

Crow Creek Sioux Tribe 

Eastern Shoshone Tribe 

Flandreau Santee Sioux Tribe 

Kiowa Ethnographic Endeavor for Preservation 

Lower Brule Sioux Tribe 

Mandan, Hidatsa and Arikara Nation 

Northern Arapaho Tribe 

Northern Cheyenne Tribe 

Oglala Sioux Tribe 

Rosebud Sioux Tribe 

Santee Sioux Nation 

Sicangu Treaty Council 

Sisseton-Wahpeton Sioux Tribe 

Spirit Lake Sioux Tribe 
Cold Springs Project 

112 

Standing Rock Sioux Tribe 

Yankton Sioux Tribe 

Others: 

Over 170 individuals, businesses, and organizations were notified of this proposal. A complete list 

is located in the project file. 
Environmental Assessment 

113 

References 

Introduction, Purpose and Need, Alternatives 

Allen, K. 2010. Mountain Pine Beetle Activity in the Cold Springs Project Area. Unpublished 

paper on file at: United States Department of Agriculture, Forest Service, Black Hills 

National Forest, Northern Hills Ranger District, Spearfish, South Dakota. 5 p. 

Bobzien, Craig. 2010. [letter to R. O’Byrne]. December 21, 2010. On file at: U.S. Department of 

Agriculture, Forest Service, Northern Hills Ranger District, Spearfish, South Dakota. 

Fettig, Christopher J., Kier D. Klepzig, Ronald F. Billings, Steven A. Munson, T. Evan Nebeker, 

Jose F. Negron, and John T. Nowak. 2007. “The effectiveness of vegetation management 

practices for prevention and control of bark beetle infestations in coniferous forests of the 

western and southern United States.” Forest Ecology and Management. 238: 24-53. 

Available online at http://www.sciencedirect.com

Negron, J.F., K. Allen, B. Cook, and J.R. Withrow, Jr. 2008. “Susceptibility of ponderosa pine, 

Pinus Ponderosa (Dougl. Ex Laws.) to mountain pine beetle, Dendroctonus ponderosae

Hopkins, attack in uneven-aged stands in the Black Hills of South Dakota and Wyoming 

USA.” Forest Ecology and Management. 254: 327-334. 

Schmid, J.M., S.A. Matta, R.R. Kessler, and J.B. Popp. 2007. The influence of partial cutting on 

mountain pine beetle-caused tree mortality in Black Hills ponderosa pine stands.

Research Paper RMRS-RP-68. Fort Collins, CO: USDA Forest Service, Rocky Mountain 

Range and Experiment Station. 11 p. 

USDA Forest Service 2000. Mountain Pine Beetle Management Guide, Silviculture Handbook, 

Forest Heath Management Region II. Fort Collins, Colorado. January 1, 2000. 

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risk reduction: toward a full accounting of forest carbon offsets.” Frontiers in Ecology 

and the Environment 6(9): 493-498. 

Seppälä, Risto, Alexander Buck, and Pia Katila, eds. 2009. “Adaptation of forests and people to 

climate change—a global assessment report.” IUFRO World Series Vol. 22. International 

Union of Forest Research Organizations. Helsinki. 224 p. 

South Dakota Department of Environment and Natural Resources (SDDENR). 2003. Forestry 

best management practices for South Dakota. Pierre, South Dakota. 

U.S. Department of Agriculture Forest Service. 2005. Appendix C—biological 

assessment/biological evaluation. Final environmental impact statement for the Phase 2 

Amendment to the 1997 revised Land and Resource Management Plan for the Black Hills 

National Forest. USDA Forest Service, Black Hills National Forest. Custer, South 

Dakota. October 2005. Available online: 

http://www.fs.usda.gov/wps/portal/fsinternet/!ut/p/c4/04_SB8K8xLLM9MSSzPy8xBz9C

P0os3gjAwhwtDDw9_AI8zPyhQoY6BdkOyoCAGixyPg!/?ss=110203&navtype=BROW

SEBYSUBJECT&cid=fsm9_012673&navid=130100000000000&pnavid=130000000000

000&position=Not Yet Determined.Html&ttype=detail&pname=Black Hills National 

Forest- Planning

Recreation 

Jones, Bonnie. 2011. Cold Springs Vegetation Management Project Recreation Report. 

Unpublished report on file at: U.S. Department of Agriculture, Forest Service, Black Hills 

National Northern Hills Ranger District Office, Spearfish, South Dakota. 10 p. 

Scenery 

Daniel, Terry C., and Ron S.Boster. 1976. Measuring landscape esthetics: the scenic beauty 

estimation method. Res. Pap. RM-167. Fort Collins, Colorado: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Forest and Range Experiment Station. 66 p. 
Cold Springs Project 

124 

Gobster, Paul H. 1994. “The aesthetic experience of sustainable forest ecosystems.” In: 

Covington, W. Wallace, and Leonard F. Debano, tech. coord., Sustainable Ecological 

Systems: Implementing an Ecological Approach to Land Management, 1993 July 12−15; 

Flagstaff, AZ. Gen. Tech. Rep. RM-247, pp. 246−255. Fort Collins, Colorado: U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Forest and Range 

Experiment Station. 

Hill, Nicole. 2011. Scenery Management resource report for Cold Springs vegetation 

management project. Unpublished report. U.S. Department of Agriculture, Forest 

Service, Black Hills National Forest, Spearfish, South Dakota. 

Ribe, Robert G. 1989. “The Aesthetic of Forestry: What Has Empirical Preference Research 

Taught Us?” Environmental Management, Volume 13, Number 1. Available online at: 

http://www.springerlink.com/content/v4x5132735646770/fulltext.pdf. 

Ryan, Robert L. 2005. Social Science to improve fuels management: a synthesis of research on 

aesthetics and fuels management. Gen. Tech. Rep. NC-261. St. Paul, Minnesota: U.S. 

Department of Agriculture, Forest Service, North Central Research Station. 58 p. 

Taylor, Jonathan G., and Terry C. Daniel. 1984. “Prescribed fire: public education and 

perception.” Journal of Forestry. 82: 361−365. 

U.S. Department of Agriculture, Forest Service. 1995. Landscape Aesthetics: A handbook for 

scenery management. Agriculture Handbook 701. 

U.S. Department of Agriculture, Forest Service. 1996. Final Environmental Impact Statement for 

the Revised Land and Resource Management Plan for the Black Hills National Forest. 

Custer, South Dakota: U.S. Department of Agriculture, Forest Service, Black Hills 

National Forest. December 1996. 

U.S. Department of Agriculture, Forest Service. 2006. 1997 Revised Land and Resource 

Management Plan for the Black Hills National Forest, As Amended by the Phase II 

Amendment. Custer, South Dakota: U.S. Department of Agriculture-Forest Service, Black 

Hills National Forest. March 2006. Available online at 

http://www.fs.fed.us/r2/blackhills/projects/planning/index.shtml

U.S. Department of Agriculture, Forest Service. 2011. National Visitor Use Monitoring Data. 

Custer, South Dakota: Black Hills National Forest. 

Heritage 

Scrivner, Julie. 2011. Heritage report for Cold Springs vegetation management project. 

Unpublished report. U.S. Department of Agriculture, Forest Service, Black Hills National 

Forest, Spearfish, South Dakota. 13 p. 

U.S. Department of Agriculture Forest Service. 2005. Final Environmental Impact Statement for 

the Phase II Amendment to the 1997 Revised Land and Resource Management Plan for 

the Black Hills National Forest. U.S. Department of Agriculture-Forest Service, Black 

Hills National Forest. Custer, South Dakota. October 2005. Available online at 

http://www.fs.fed.us/r2/blackhills/projects/planning/index.shtml
Environmental Assessment 

Appendix A: Modified Proposed Action Unit 

Silviculture and Fuel Treatments 
Cold Springs Project 

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Appendix A. Modified Proposed Action Unit Silviculture and FueTreatments Table 1 lists all treatment units included in the modified proposed action. Maps displaying the treatment units are located in 

Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

070309 96 5 5.1 NT Rx Burn070309 97 2 5.1 NT Rx Burn070309 99 1 5.1 NT Rx Burn070503 23 55 5.1 CT PCT Tractor070503 26 11 5.1 CT Tractor070503 117

6 5.1 CT PCT Tractor

070503 142 13 5.1 SWEC Tractor070505 13 33 5.1 SWR PCT Dec. 1 ‐ Mar. 31 Tractor 070505 17 53 5.1 SWP Tractor 070505 19 21 5.1 AR AR Tractor 070505 20 32 5.1 SWP Tractor070505 21 30 5.1 STS PCT Tractor070505 22 37 5.1 SWP Tractor 

1 SWR: shelterwood removal; SWEC: shelterwood establishment cut; SWP: shelterwood preparation cut; AR: aspen release; CT: comm

treatment; STS: single-tree selection; WL STS: single-tree selection with wildlife habitat design features; 50%CC: 50 percent canopy c

2 Rx Burn: broadcast prescribed burn; Slash: fuel slashing; P&B: pile and burn 3 PCT: precommercial thin; AR: aspen release; WL TSI: wildlife timber stand improvement 4 The December 1 through March 31 restriction provides for snowmobile trail use on project area roads. Log hauling and road use woul

December 1 and March 31, unless a logical and desirable alternative snowmobile route is identified. The April 1 through August 15 resSensitive Species wildlife habitat. 

5 Acres by Scenic Integrity Objective (SIO); H: High SIO; M: Moderate SIO; L: Low SIO. Any slight discrepancies in totaling acreage

in GIS. 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

070505 48 6 5.1 SWEC AR Tractor 070505 49 24 5.1 SWP Tractor 070505 50 13 5.1 SWEC Tractor 070505 52 11 5.1 SWP Tractor 070505 53 17 5.1 AR AR Tractor 070505 58 30 5.1 SWP Tractor 070505 62 27 5.1 SWP Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 070505 63 20 5.1 CT Slash, P&B AR Dec. 1 ‐ Mar. 31 Tractor 070505 72 5 5.1 SWP Tractor 070505 74 6 5.1 SWP Tractor 070505 78 5 5.1 SWEC AR Tractor 070505 79 31 5.1 SWP AR Tractor 070505 92 7 5.1 CT Tractor 070505 94 11 5.1 SWP Tractor 070505 98 14 5.1 AR AR Tractor 071203 10 5 4.1 SWR PCT Tractor 071203 67 3 4.1 SWR PCT Tractor 071203 83 4 4.1 SWR PCT Tractor 071205 4 25 4.1 SWEC Tractor 071205 8 33 4.1 CT PCT Tractor 071205 14 24 4.1 SWEC Tractor 071205 15 33 4.1 SWR PCT Tractor 071205 17 47 4.1 CT PCT Tractor 071205 23 40 4.1 CT PCT Tractor 071205 39 18 4.1 SWP Tractor 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

071205 41 14 4.1 SWR PCT Tractor 071205 43 9 4.1 SWR PCT Tractor 071205 47 4 4.1 SWR PCT Tractor 071205 49 10 4.1 STS AR Tractor 071205 60 25 4.1 CT_50%CC Tractor 071205 61 24 4.1 SWR PCT Tractor 071205 64 9 4.1 STS PCT, AR Tractor 071205 84 11 4.1 SWP Tractor 071206 4 17 4.1 SWP AR Tractor 071206 5 71 4.1 CT Slash, P&B Tractor 071206 9 26 5.1 SWP Slash, P&B AR Tractor 071206 10 105 4.1 STS Slash, P&B Tractor 071301 5 10 5.1 CT P&B PCT, AR Tractor 071301 6 4 5.1 STS PCT Tractor 071301 9 25 5.1 STS Tractor 071301 10 6 5.1 CT Tractor 071301 16 10 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071301 20 10 5.1 SWP Slash, P&B AR Tractor 071301 25 13 5.1 NT Rx Burn 071301 28 16 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071301 29 91 5.1 SWEC Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 071301 31 47 5.1 CT PCT Dec. 1 ‐ Mar. 31 Tractor 071301 38 48 5.1 CT Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 071301 40 21 5.1 CT P&B PCT Dec. 1 ‐ Mar. 31 Tractor 071301 46 16 5.1 STS P&B PCT Tractor 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

071301 49 12 5.1 SWEC Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 071301 55 5 5.1 CT Slash, P&B Tractor 071301 77 39 5.1 SWR P&B PCT Tractor 071301 79 47 5.1 NT AR 071301 86 11 5.1 STS PCT Tractor 071301 87 20 5.1 AR P&B PCT, AR Tractor 071301 88 14 5.1 STS P&B PCT, AR Tractor 071301 92 54 5.1 STS P&B PCT, AR Tractor 071301 95 3 5.1 SWP Tractor 071301 97 7 5.1 STS PCT Tractor 071301 98 33 5.1 SWEC Tractor 071301 99 9 5.1 AR Slash, P&B Tractor 071301 100 20 5.1 STS PCT Tractor 071301 102 28 5.1 NT PCT 071301 164 23 5.1 CT Slash, P&B AR Tractor 071301 168 3 5.1 AR Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 071302 4 122 5.1 CT PCT Dec. 1 ‐ Mar. 31 Tractor 071302 5 35 5.1 STS P&B PCT Dec. 1 ‐ Mar. 31 Tractor 071302 6 34 5.1 STS P&B PCT Dec. 1 ‐ Mar. 31 Tractor 071302 7 31 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071302 10 37 5.1 STS_50%CC P&B PCT Dec. 1 ‐ Mar. 31 Tractor 071302 11 17 5.1 CT Slash, P&B AR Tractor 071302 12 13 5.1 CT AR Tractor 071302 15 41 5.1 SWEC Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071302 16 95 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

071302 17 16 5.1 STS Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 071302 18 38 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071302 19 88 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071302 21 6 5.1 SWEC Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071302 22 28 5.1 NT Rx Burn 071302 26 17 5.1 NT Rx Burn 071302 30 25 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071302 31 106 5.1 NT AR 071302 36 49 5.1 STS Dec. 1 ‐ Mar. 31 Tractor 071302 40 50 5.1 SWP_50%CC Dec. 1 ‐ Mar. 31 Tractor 071302 42 25 5.1 NT Rx Burn 071302 43 25 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071302 46 9 5.1 NT Rx Burn 071302 47 26 5.1 STS PCT Dec. 1 ‐ Mar. 31 Tractor 071302 48 17 5.1 STS_50%CC PCT Dec. 1 ‐ Mar. 31 Tractor 071302 52 16 5.1 STS Dec. 1 ‐ Mar. 31 Tractor 071302 53 16 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071302 52 3 5.1 AR Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 071302 69 37 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071303 2 9 5.1 NT WL TSI Apr. 1 ‐ Aug. 15 071303 6 10 5.1 WL STS WL TSI Dec. 1 ‐ Aug. 15 Tractor 071303 10 35 5.1 STS_50%CC PCT Dec. 1 ‐ Mar. 31 Tractor 071303 11 20 5.1 STS_50%CC PCT Dec. 1 ‐ Mar. 31 Tractor 071303 12 13 5.1 SWP_50%CC Dec. 1 ‐ Mar. 31 Tractor 071303 14 115 5.1 SWR Rx Burn PCT Dec. 1 ‐ Mar. 31 Tractor 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

071303 19 30 5.1 NT WL TSI Apr. 1 ‐ Aug. 15 071303 21 29 5.1 NT WL TSI Apr. 1 ‐ Aug. 15 071303 26 33 5.1 SWP PCT Dec. 1 ‐ Mar. 31 Tractor 071303 28 21 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071303 32 12 5.1 CT Slash, P&B Dec. 1 ‐ Mar. 31 Tractor 071303 33 14 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071303 36 15 5.1 NT WL TSI Apr. 1 ‐ Aug. 15 071303 38 3 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071303 46 10 5.1 WL STS WL TSI Dec. 1 ‐ Aug. 15 Tractor 071303 50 43 5.1 NT Rx Burn 071303 57 9 5.1 WL STS WL TSI Dec. 1 ‐ Aug. 15 Tractor 071303 78 31 5.1 CT Dec. 1 ‐ Mar. 31 Skyline 071303 79 5 5.1 WL STS WL TSI Dec. 1 ‐ Aug. 15 Tractor 071304 14 16 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071304 28 47 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 29 37 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 30 56 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 33 6 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071304 34 23 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 35 61 5.1 SWP Dec. 1 ‐ Mar. 31 skyline 071304 37 43 5.1 NT Rx Burn 071304 39 41 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 40 50 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 42 8 5.1 STS PCT Dec. 1 ‐ Mar. 31 Tractor 071304 43 17 5.1 SWR PCT Dec. 1 ‐ Mar. 31 Tractor 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

071304 44 15 5.1 SWR Rx Burn PCT Dec. 1 ‐ Mar. 31 Tractor 071304 46 21 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 47 16 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 48 33 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 50 15 5.1 NT Rx Burn 071304 52 14 5.1 SWR PCT Dec. 1 ‐ Mar. 31 Tractor 071304 53 15 5.1 SWR PCT Dec. 1 ‐ Mar. 31 Tractor 071304 54 32 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071304 56 5 5.1 SWR PCT Dec. 1 ‐ Mar. 31 Tractor 071304 57 12 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071304 59 11 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071304 60 17 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071304 64 4 5.1 SWR PCT Dec. 1 ‐ Mar. 31 Tractor 071304 65 47 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071304 68 33 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071304 70 10 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071304 73 26 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071304 89 3 5.1 NT Rx Burn 071304 90 17 5.1 NT Rx Burn 071304 91 4 5.1 NT Rx Burn 071304 92 34 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071304 94 13 5.1 NT Rx Burn 071304 95 1 5.1 SWP_50%CC Dec. 1 ‐ Mar. 31 Tractor 071304 97 10 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071304 98 10 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

071304 100 13 5.1 CT Rx Burn Dec. 1 ‐ Mar. 31 Tractor 071305 4 70 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 5 190 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 7 9 5.1 NT AR 071305 9 147 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 12 46 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 15 52 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 17 62 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 19 14 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 24 88 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071305 25 4 5.1 NT AR 071306 18 8 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071306 42 127 5.1 NT PCT 071306 47 4 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071306 48 4 5.1 SWP_50%CC Dec. 1 ‐ Mar. 31 Tractor 071306 55 5 5.1 SWP_50%CC Dec. 1 ‐ Mar. 31 Tractor 071306 57 31 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071306 72 57 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071306 77 7 5.1 SWP Dec. 1 ‐ Mar. 31 Tractor 071306 79 9 5.1 SWEC Dec. 1 ‐ Mar. 31 Tractor 071306 82 35 5.1 SWP_50%CC Dec. 1 ‐ Mar. 31 Tractor 071308 8 9 5.1 CT Dec. 1 ‐ Mar. 31 Tractor 071308 43 19 5.1 SWEC AR Dec. 1 ‐ Mar. 31 Tractor 071308 45 15 5.1 NT AR 071308 60 7 5.1 SWEC Rx Burn Dec. 1 ‐ Mar. 31 Tractor 
Table 1. Cold Springs modified proposed action treatment units 

Treatment Unit Acres Management Area Commercial1 Treatment Fuel Treatment2

Noncommercial 

Vegetation 

Treatment3

Restriction4 Logging System 

071308 63 5 5.1 SWR PCT Dec. 1 ‐ Mar. 31 Tractor 
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Environmental Assessment 

Appendix B: Scoping Comments and Comment 

Disposition 
Cold Springs Project 

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Appendix B. Cold Springs Scoping Comments 

Table 1. Letter number and scoping respondent 

List of Respondents to Comment Period 

Letter # Agency, Organization, Business, or Individual 

1 Alan Michalewicz, Black Hills Electrical Coop 2 Mark Young, Black Hills Power 3 Tina Canova 4 Philip and Louise Poehlman 5 Richard Sorensen 6 Elizabeth and Jerry Strong 7 Dennis Bucher 8 John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan B. Ratner

Project; Wendy Roth; Dick Artley 

9 Carson Engelskirger, Black Hills Forest Resource Association 

10 Dennis Daugaard, Governor, State of South Dakota 11 Daryl D. Johnson, Lawrence County Commissioners 12 James R. Nelson, Spearfish Canyon Homeowners Association 13 Paul Pierson, Neiman Timber Company 14 Douglas Hofer, Director, Parks and Recreation Division, South Dakota Department of Game, Fish and Parks 
Table 2. Grouped comments, comment source, and response 

Comments by subject Source Code 

Analysis request 8.4, 8.20, 8.22, 8.23, 13.8 Hydrology 8.21 Project management 12.7, 12.8 Project management; alternatives 8.2, 8.3 Project management; follow-up 3.3, 6.2, 9.14, 11.16, 13.15 Project management; implementation 1.1 Project management; implementation date 3.2, 6.1, 12.6, 12.10, 13.13 Project management; silviculture 9.4, 9.5 Project management; silviculture and wildlife 10.4 Proposed action; additional treatments within the project area 9.2, 9.6, 9.9, 9.10, 9.11, 10.1, 11.2, 11.3, 11.5, 11.6, 11.11

13.7, 13.9, 13.10, 13.11, 13.12 

Proposed action; additional treatment area, outside the project area 11.7, 11.8 Proposed action; botany 11.4 Proposed action; efficacy of treatments 8.5, 8.6, 8.7, 8.8, 8.9, 8.10, 8.11, 8.12 Proposed action; fuel treatments 2.2, 6.1, 9.13, 11.9, 11.13, 11.14 Proposed action; purpose and need 12.3 Proposed action; roads 8.19 Proposed action, sanitation 12.5 Proposed action; silviculture 9.8, 9.12, 10.2, 11.10, 13.8 Proposed action, silviculture and wildlife 10.4 Proposed action; snowmobile trails 13.14 14.1, 14.2 Silviculture; beetle risk rating 9.3, 9.7, 11.2, 13.4, 13.5 Statement of support 2.1, 3.1, 4.1, 5.1, 7.1, 9.1, 11.1, 12.2, 12.9, 13.2, 14.3 Wildlife 8.4, 8.15, 8.16 Wildlife; goshawk 8.17 Wildlife; late-successional habitat 8.18 Wildlife; population viability 8.13, 8.14 
Table 3. Scoping comments listed by respondent 

Respondent #1, Alan Michalewicz, Black Hills Electrical Coop 

# Comment Comment Analysis a

1.1 

After reviewing the Cold Springs Project in detail, it appears that Black Hills Electric Cooperative has existing distribution electric lines located within a few of the ‘Pile and Burn’ areas of this project. We would prefer to work with your marking crews prior to removal as we may prefer to have additional trees removed for safety reasons along our right of way. I can make our employees available on very short notice to meet on site and evaluate these areas. Additionally BHEC will participate in cutting down any trees adjacent to our lines that your crews or your contracted crews don’t feel comfortable falling. Please contact me if you have any questions. Thank you 

Northern Hills Ranger District project would contact the BlacCooperative to coordinate treproximity to electric lines. 

Respondent #2, Mark Young, Black Hills Power 

# Comment Comment Analysis a

2.1 

I believe the proposed action in the Cold Springs Project area is necessary to address the Mtn Pine beetle problem. The proposed action plan & vegetation treatments seem to meet industry 

accepted actions to address the problem. 

Statement of support 

2.2 

My only objection is in regards to the “Proposed Fuel Treatments.” Broadcast Prescribed Burning is a well accepted method for Ponderosa pine forests & perfectly acceptable. However, I am opposed to “pile and burn” methods. This creates excessive air pollution, extra man hours, damage to surrounding trees & soil, & unnecessary time delays. To me the immediate solution is to have the debris chipped & scattered on-site while the gathering of debris is taking place. The use of “self-propelled tracked chippers” that have low ground pressure & easy access into wooded area even with difficult terrain is the better option. This puts the bio material back into the soil, reduces erosion potential, & is visually appealing. I hope you consider this methodology in your planning. Even if you do not, I fully support the need for action as proposed. 

Fuel treatment options, includconsidered during developmeaction. Piling and burning is lmastication or chipping, and treatment objectives. 
Respondent #3, Tina Canova

# Comment Comment Analysis a

3.1 

Thank you for sending the Cold Springs Project proposal paper. I've seen the devastation caused by the Mountain Pine Beetles in land near Custer State Park and I applaud your efforts 

to stop the epidemic. 

Statement of support 

3.2 Just two questions: 1- Is there a proposed time line? I saw the start could be Fall 2011. 

Timber sales are scheduled fcould be sold as early as Octpreparation (unit layout and tbegin in 2011. Sanitation/salvbegin after a final decision is 

3.3 

2- As a private land owner in the area, should I take similar actions? For example, I have mixed stands of Aspen on my property and I would be interested in the vegetation treatments 

such as Aspen release. My property is in the southern portion of the project area (SE1/4 NE1/4 lying S of South Rapid Creek Road and East of Boles Canyon Road). Only about 20 acres, but every little bit helps! Thanks again for your efforts to eradicate the devastation caused by the Mountain Pine Beetle. 

District staff contacted Ms. Cainformation regarding forest m

 Respondent #4, Philip and Louise Poehlman 

# Comment Comment Analysis a

4.1 

I would like to comment positively to the proposed Cold Springs Project. I encourage you to take aggressive, rapid and unrelenting action to control the infestation of the mountain pine 

beetle. Although we don't own property within the proposed Cold Spring Project area we do own adjacent property. We have seen a dramatic increase in affected trees on our property and have taken actions similar to those proposed in your Cold Springs Project with encouraging results. We strongly support any and all preventive measures on the adjacent national forest. 

Statement of support 

Respondent #5: Richard Sorensen 

# Comment Comment Analysis a

5.1 Go ahead, thin and cut some trees. Statement of support 
Respondent #6: Elizabeth and Jerry Strong 

# Comment Comment Analysis 

6.1 

We are reacting to the Cold Springs Project. It is a good idea to actively attend to the beetle project 

in the area designated by the project outline we received. We certainly hope that the project will be 

initiated early this spring as it is what we would call a day late and a dollar short. As property owners, we cut 30 of our infested green standing trees, but it is disheartening to know that a few short feet away our neighbor (United States National Forest) has not cut any infested trees nor removed any of the obviously dead trees which are numerous. We further hope that the project will not only thin the trees, but make a concerted effort to remove the brown dead trees and the green infested trees that will be brown dead trees by the summer of 2012. 

Timber sales are scheduand could be sold as earlpreparation (unit layout abegin in 2011. Sanitation/begin after a final decisioThe proposed action inclusalvage. These treatmenor cut and treat trees that with mountain pine beetleFuel treatments are plannlands within the project b

6.2 

We know that piling and burning the trees is imperative in disposing of the pine beetles, but it has 

been difficult to get burn permits through the current system. We do not live on our property full time and only have a telephone not the internet. The permits are readily available on-line, but it is very difficult to talk to anyone about getting a permit. It would be beneficial if the permits in the 

wintertime when there is plenty of snow were good for a week instead of a few days. We stopped 

in the Spearfish district office to see what we could do, but we were sent out the door with unanswered questions. We are trying our best to be a part of the solution; it would be nice if the government agencies, yours and Weed and Pest would be more expedient in helping with the problem. 

Permits for burning on prscope of this project. PerState of South Dakota. District staff contacted the information regarding foreassistance. 

Respondent #7: Dennis Bucher 

# Comment Comment Analysis 

7.1 I fully support the proposed project as the owner of private land located within the boundaries of the project area. The Mountain Pine Beetle epidemic urgently needs to be addressed. Statement of support 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

8.1 

I. The U.S. Forest Service (USFS) must complete an environmental impact statement analyzing the effects the Cold Springs Project will have on the area in question. Under NEPA, USFS must complete an environmental impact statement (EIS) for all major federal actions significantly affecting the human environment. The BHNF webpage indicates USFS only intends to complete an environmental assessment (EA) for the Cold Springs Project. An EA, rather than an EIS, is only appropriate if USFS is unsure whether the impacts of an action will be significant or not. 

Here, where the agency has proposed actions across 12,300 acres of National Forest System lands and 1,700 acres of private lands, the impacts of vegetation treatments, sanitation, road management activities, and activity and wildland fuel treatments will undoubtedly be significant to the acres within the project area, as well as the acres surrounding the project area, and the cumulative impacts to the Forest as a whole in terms of habitat corridors, connectivity, and fragmentation will be significant as well. An EA will not provide the appropriate level of analysis for such a large affected area. A probing, in-depth EIS is the proper mechanism by which the agency should consider the effects of this proposed project on species, recreation, and forest health. Other units of the National Forest System in the Rocky Mountain Region have completed environmental impact statements for much smaller project areas with fewer proposed management activities, rendering USFS’ choice here to only complete an EA immediately suspect. The agency ventures into arbitrary and capricious territory if it opts not to complete an EIS for such a large area, especially given the high number of miles on which proposed road management activities will occur across the project area. 

The purpose of an EA is tosufficient evidence and anwhether to prepare an EIS significant impact. (FSH 1may be prepared if a FONbecause the proposed actsignificant effect on the en

8.2 

II. USFS should consider a reasonable range of alternatives. 

Under NEPA, federal agencies must consider a reasonable range of alternatives that meet the 

purpose of and need for actions when analyzing environmental impacts associated with proposed projects. Colorado Envtl. Coal. v. Dombeck, 185 F.3d 1162, 1174 (10th Cir. 1999). Federal 

agencies cannot “defin[e] the objectives of their actions in terms so unreasonably narrow that they can be accomplished by only one alternative (i.e., the applicant’s proposed project).” Id. USFS proposes the Cold Springs Project under the authority of the Healthy Forests Restoration 

Act (HFRA). Although the agency has avoided considering more than the proposed action alternative and a “no action” alternative for HFRA projects in the past, there is no justification for this other than that the statute in question apparently allows such minimal consideration of alternatives. Furthermore, HFRA stipulates that one additional action alternative shall be developed and evaluated if it is proposed during scoping, and if it meets the purpose and need for the project. Here, USFS very narrowly defined the purpose of this project as solely aimed at “decreas[ing] the risk of mountain pine beetle infestation in ponderosa pine stands within an area managed for timber production and wood products.” Further, USFS asserted the project is necessary “because mountain pine beetle infestation is increasing within the project area and vicinity.” 

The EA includes a modifieno-action alternatives. Fouconsidered but dismissed These are discussed in thof alternatives is required (36CFR220.7(b)(2)). 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

8.3 

We propose that the agency consider an alternative that, while still reducing the risk of further 

mountain pine beetle infestation, aims to avoid further habitat fragmentation and strategically maintains and develops areas of habitat corridors and connectivity. Trees infested with mountain pine beetles continue to provide habitat for many species even after they die and fall, and USFS should consider an alternative that embraces this reality and allows for some areas to not be so heavily treated and continue to allow an endemic level of mountain pine beetle infestation. Just 

because the area is “managed for timber production and wood products” does not mean USFS does not have the discretion or authority to allow some trees or stands of trees in the area to not be ultimately harvested and instead remain as habitat in a variety of forms, living or dead. Of course, we recognize that any action alternative we propose during this scoping period will undoubtedly be dismissed by USFS as not meeting the very narrowly defined purpose and need crafted by the agency. Although USFS asserts this is acceptable under HFRA’s NEPA avoidance provisions, we contend this violates the spirit and intent of NEPA, allows the agency to avoid considering methods and measures that might promote habitat conservation, and ultimately amounts to a loss of public credibility on the part of the agency. Consideration of only one action alternative strongly indicates the agency’s predisposition toward that alternative, and provides no points of contrast or comparison from which USFS can make its ultimate decision whether to authorize the project as proposed. Instead, the agency will only have one set of impacts before it in terms of acres treated, board feet harvested, roads constructed and reconstructed, habitat destroyed, watersheds degraded, noxious weeds introduced, etc. In order to provide the agency with a better picture of the ultimate impacts of its proposed actions, we ask that USFS consider at least one other action alternative that integrates habitat conservation measures into the 

management activities aimed at reducing mountain pine beetle infestation. 

The proposed action was for wildlife and plants. The action includes habitat conpine marten and goshawkmeasures have been incoproposed action to minimiwildlife, Region 2 sensitive local concern. The proposwith no harvest to retain hwildlife. Treatments have aretain habitat and project dincluded to provide habitaThe modified proposed acconsideration of high-valuhabitat corridors would remlevels of canopy cover woEndemic levels of mountacontinue to persist in the ppine beetles would not be Pine stands within the proexperienced approximateldue to mountain pine beetThese dead trees (snags) unless removed due to sadesign features include mretain snags. Project sanittrees infested with mountaThe impacts of the modifiealternatives on wildlife and in the EA analysis. 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

8.4 

USFS must also acknowledge that impacts to wildlife and plant species and their habitats and viability will be a significant issue that warrants detailed consideration in light of the proposed activities and adverse effects. Wildlife and plant habitat and viability are never irrelevant to or beyond the scope of proposed actions within the National Forest System, as the “diversity” 

mandate from NFMA is applicable to every project. 

The impacts of the modifiealternatives on wildlife and the EA analysis. The Forest Service has esForest Service Manual to management for proposedthreatened, and sensitive ensures that these specieconsideration in the decisiBiological evaluations havdisclose the determination sensitive species. The Blahas also identified species are species that do not mesensitive status, yet are imdiversity within the Black H(FSM 2620.5 Black Hills S1). Forest Service Manual consider species of local cdesign and to evaluate the from alternatives considerEnvironmental Policy Act addition, the botany speciaany effects to South Dako(plants considered to be raare known to occur in the 

8.5 

III. The Cold Springs Project “Purpose and Need” is premised on questionable theories about 

combating mountain pine beetle infestation through logging. USFS proposes the Cold Springs Project under the authority of the Healthy Forests Restoration Act, legislation enacted to “expedite 

the approval of hazardous fuel reduction and forest health restoration projects.” HFRA itself is inherently flawed and based on public fear of insects and fire stoked by timber industry lobbyists. USFS justifies the Cold Springs Project by asserting that logging will reduce the spread of mountain pine beetles. This premise is not supported by conclusive science. 

The modified proposed acPlan direction. Forest Plan susceptibility of vegetation and outbreaks of insect anreduced through vegetatiothat promote vigorous, prodiverse ecosystems (ForePlan objective 10-07: Whepine beetle could present objectives for ponderosa pponderosa-pine stands tharisk for infestion.
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

Silviculture treatments in taction are consistent with Research that has taken pNational Forest indicates tmiminize mountain pine bestands (Schmid et al. 2007Additional studies on the esilviculture treatments are effectiveness of vegetation for prevention and control infestations in coniferous fsouthern United States (FThe project silvicultural repeffectiveness of proposed mountain pine beetle-causpopulations. The report increferences. 

8.6 

In testimony before U.S. House of Representative Subcommittees on the current mountain pine beetle outbreak just a year ago, Rocky Mountain Regional Forester Rick Cables stated, “It is clear that we can’t stop this current infestation. Thinning stands has proved ineffective.” Statement of 

Rick Cables, Regional Forester, Rocky Mountain Region, available at http://www.nwc.cog.co.us/docs/cbbc/rick_cables_USFS_testimony_061609.pdf. By premising yet 

another project on combating beetle infestation, USFS apparently deems its own Regional Forester’s testimony to be inaccurate, but provides no conclusive evidence logging will stop beetles’ spread. In fact, the more large trees are removed, the more smaller trees will likely be infested. USFS owes the public an explanation why, in the face of such clear statements from the Regional Forester, it continues to proceed with projects based on an assumption that cutting down trees will actually reduce the beetle infestation. In the face of a plethora of science questioning the efficacy of logging to stop the beetles’ spread, USFS owes the public and is required under NEPA and NFMA to demonstrate a science-based rationale for such projects, explaining why opposing science does not apply to the facts at hand. See Black et al., Insects and Roadless Forests: A Scientific Review of Causes, Consequences and Management Alternatives, available at http://www.xerces.org/wp-content/uploads/2010/03/insects-and-roadless-forests1.pdf

(the report is based on years of field research and a comprehensive scientific literature review). Although USFS has previously dismissed the Black report as inapplicable to the Black Hills because it focused on roadless forests in Colorado, the agency must clarify why the report is completely inapplicable or if any of it has some applicability to the Black Hills at all. Is it because 

the report discussed lodgepole pine? Because the elevation is different in the Black Hills? 

Rocky Mountain Regional statement is in reference tnorthern Colorado and Sois in regard to lodgepole p6). The Cold Springs ProjeHills National Forest, locatnortheastern Wyoming. Stproject area currently infesbeetle are comprised of prThe modified proposed acimplemented due to projecthe existing infrastructure harvest and log processinarea can be logged with cbased harvest equipment, moved from area to area. forest roads across much would allow for harvest accontractors are readily avaarea, and local mills have 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

Because the beetles are somehow different there? What other factors does the agency used to dismiss this report? Again, is there absolutely no portion of the report that has any applicability to the Black Hills? 

the infested logs and kill thSee the response to 8.5 The paper by Black and o“specifically” about lodgep“roadless areas” in “Coloraothers feel that large areatreatments in lodgepole piRoadless Areas in Coloradnot constitute science oppproposed for managed staSouth Dakota. The Black a“[s]everal studies across th

thinning reduces the amoumountain pine beetle in postands...”(page 14). The idmanaged ponderosa pine vigor and reduces stand spine beetle is not disputed practitioners or researche

8.7 

Regional Forester Rick Cables asserts USFS has changed its “focus from prevention to reducing risks to public safety and infrastructure.” Statement of Rick Cables. The authors of Insects and Roadless Forests similarly suggest USFS funds would be better used by mitigating risks around buildings and communities, not needlessly logging far from such infrastructure. “Overall,” the authors conclude, “it is going to be much less expensive, more effective and less damaging to focus fire-hazard reduction efforts [in response to beetle outbreaks] around 5 communities and homes than it would be to try to make a wholesale modification of forest structure over large landscapes.” See Black et al. page 22. 

The modified proposed acPlan direction. The Forest for all resource managemeHills National Forest (USDRegional Forester Rick Careference to “the outbreak and southern Wyoming...” lodgepole pine forests (paThe primary purpose of thto decrease the risk of moinfestation in ponderosa phazard reduction. 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

8.8 

USFS must take a complete hard look at the efficacy of logging to combat mountain pine beetle infestation, and must consider and respond to the best available science and responsible opposing science regarding the efficacy of logging to combat mountain pine beetle infestation in a manner available to the entire public (i.e., in the final statement itself). USFS cannot authorize a project based on such a questionable purpose and need, unless it adjusts the project to legitimately protect public safety and infrastructure solely within the wildland-urban interface. 

Please see the response t

8.9 

IV. Scientific literature does not conclusively demonstrate logging will effectively decrease the spread of mountain pine beetles in the project area. In objecting to a different HFRA project in the Northern Hills Ranger District, BCA commented on the DEIS that Rick Cables, Regional Forester for Region 2 of the U.S. Forest Service, testified before U.S. House of Representatives Subcommittees that “[t]hinning stands has proved ineffective” to stop the current infestation of mountain pine beetles. Nautilus FEIS, Appendix E, page E-8. USFS responded to BCA’s comments by asserting we took the Regional Forester’s testimony out of context, and that it only applies to Colorado. Id, page E-9. USFS has previously asserted this to BCA, arguing the situation is different in the Black Hills, despite the pine beetles already having reached “epidemic levels.” Id. If the beetles are at epidemic levels in the Nautilus Project area, are the beetles at 

epidemic levels in the Cold Springs Project area? What constitutes an epidemic level? If the beetles are already at epidemic levels, they have logically already infested the trees. But USFS goes on to claim “the evidence is clear that thinning ponderosa pine, which is dominant in the Black Hills, ahead of beetle infestation is effective.” Id. If there are already epidemic levels of mountain pine beetles in the Northern Hills, USFS is not authorizing thinning “ahead of beetle infestation” so as to be effective. The Cold Springs Project scoping notice indicates that “field surveys in the fall of 2010 indicate mountain pine beetle-caused mortality is spreading and most project area pine stands have some level of infestation....” If there is already some level of infestation, is not USFS contradicting previous statements about the efficacy of combating 

mountain pine beetle infestation through logging? 

Please see the response tThe mountain pine beetle area is growing (Allen 201of 2010 indicated approximproject area pine trees havpast 3 years. Green trees become infested. The Cold Springs modified includes direct methods to beetle populations (sanitatreatments that reduce stohealthy population of trees

8.10 

Plus, the scientific literature USFS refers to in its response to our Nautilus Project comments, Shepperd and Battaglia 2002, does not provide “evidence” that makes it “clear that thinning ponderosa pine” will be effective if there is in fact an epidemic of mountain pine beetles in the Black Hills. Instead, Shepperd and Battaglia say that “[s]everal silvicultural activities can be used to minimize the chance that endemic mountain pine beetle populations may become epidemic.” Shepperd and Battaglia, Ecology, Silviculture, and Management of Black Hills Ponderosa Pine, page 22 (USFS 2002) (emphasis added). The authors further state, “[o]ne key to inhibiting epidemic mountain pine beetle populations is to maintain a healthy population of trees that can resist mountain pine beetle attack.” Id. (emphasis added). 

Research that has taken pNational Forest indicates tmiminize mountain pine bestands (Schmid et al 2007Additional studies on the esilviculture treatments are 

effectiveness of vegetation for prevention and control infestations in coniferous fsouthern United States (FThe Cold Springs modified includes direct methods to 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

beetle populations (sanitatreatments that reduce stohealthy population of trees

8.11 

According to USFS itself in its response to our Nautilus Project comments, the conditions in the Black Hills have passed the point to “epidemic.” Nautilus FEIS, Appendix E, page E-9. Shepperd and Battaglia describe “endemic” mountain pine beetle populations as those that kill less than one 

tree per acre per year. Shepperd and Battaglia, page 17. The authors do not expressly define “epidemic” populations, but describe various thresholds that could be considered. Id., page 22. Regardless, the suggestions in the authors’ paper are aimed at inhibiting epidemic levels, which USFS concedes have already been reached in the nearby Nautilus Project area. Thus, the burden is again on USFS to show why the Regional Forester’s testimony is completely inapplicable to the Black Hills and the Cold Springs Project area. Mere geography does not definitively make science inapplicable to another area. Further, if ponderosa pine is so vastly different in how it responds to mountain pine beetles and can be managed to reduce infestation, USFS has not publicly provided science to show this. USFS later contended in its response that BCA’s cited science, Insects and Roadless Forests, supports the purpose and need for the Nautilus Project. Nautilus FEIS, Appendix E, page E-9. At one point the authors of that paper state that “if a bark beetle infestation is relatively small and 

concentrated in a limited area, it may be feasible to reduce the population growth by removing infested trees from a forest stand or thinning a stand to reduce stress on trees.” Id. However, the Cold Springs Project will result in the treatment of at least 5,000 acres of vegetation. How can 

5,000 acres be considered relatively small and concentrated to a limited area? Relative to what, the entire Forest? 5,000 acres is over eight square miles. The entire project area is 14,000 acres, 

over 23 square miles. By USFS’ admission, the infestation is at epidemic levels Forest-wide. See Nautilus FEIS, Appendix E, page E-9. Neither eight square miles nor 23 square miles is a “relatively small” or “limited area” without a comparison against some other applicable size figure, which cannot be the entire Forest if an epidemic exists across it. Any broader size figure would clearly encompass scales beyond the Black et al. paper’s scope. 

Please see the response tMountain pine beetle infesis growing (Allen 2010). F2010 indicated approximaproject area pine trees havpast 3 years. 

8.12 

Further, available science shows that “once bark beetles reach epidemic levels and cause extensive tree mortality,” which USFS has conceded is occurring in the Black Hills, “treatments aimed at reducing densities of the beetles are futile.” Black, S.H., Logging to Control Insects: The 

Science and Myths Behind Managing Forest Insect “Pests”: A Synthesis of Independently 

Reviewed Research, page 6 (quoting Wood et al. (1985)), available at http://www.xerces.org/wpcontent/uploads/2008/10/logging_to_control_insects.pdf (last visited Feb. 7, 2011). 

Field surveys were conducassess the forest insect coepidemic, and beetle popuSanitation treatments woupopulation. Sanitation can be an effecproject area due to project existing infrastructure asso

harvest and log processinarea can be logged with c
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

based harvest equipment, moved from area to area. forest roads across much would allow for harvest accontractors are readily avaarea, and local mills have the infested logs and kill thThe information provided oet al.) discusses the effectas a stand alone treatmenproposed action includes methods (sanitation) to redand treatments to reduce Black’s document was revand Celaya 1998, who conpreventive strategies are mtree losses. Unacceptable most cases by maintaining Thinning dense stands of crowns are no longer touccompetitive stress among making them less susceptInformation cited in Black’project proposed action. 

8.13 

V. The Cold Springs Project must ensure viable populations of wildlife on the Black Hills National Forest. NFMA requires the Secretary of Agriculture to promulgate forest planning regulations that “specif[y] guidelines for land management plans . . . [to] provide for diversity of plant and animal communities based on the suitability and capability of the specific land area.” 16 U.S.C. § 1604(g)(3)(B) (2010). To meet this statutory requirement, the 1982 planning regulations under which the 1997 Revised Black Hills National Forest Plan and Phase II Amendment were developed direct USFS to manage habitat “to maintain viable populations of existing native and desired non-native vertebrate species in the planning area.” 36 C.F.R. § 219.19 (1999). The 

provision goes on to define a “viable population . . . as one which has the estimated numbers and distribution of reproductive individuals to insure its continued existence is well distributed in the 

planning area.” Id. To accomplish this, USFS must provide habitat “to support, at least, a minimum number of reproductive individuals and that habitat must be well distributed so that 

The transition language in and interpretive rules explnot in effect. Projects sucdeveloped considering the and must be consistent wiFR 67073). The Forest Pmanaging for wildlife habitpopulation levels. The Colproposed action implemenForest Plan. 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

those individuals can interact with others in the planning area.” Id. Furthermore, § 219.19(a)(1) requires USFS to identify and select as management indicator species (MIS) “certain vertebrate and/or invertebrate species present in the area” in order to monitor the “effects of management activities.” Following such selection based on appropriate criteria, USFS must monitor population trends of MIS and determine relationships to habitat changes. 36 C.F.R. § 219.19(a)(6). Also, “[p]lanning alternatives shall be stated and evaluated in terms of both amount and quality of habitat and of animal population trends of [MIS].” 36 C.F.R. § 219.19(a)(2) (emphasis added). The 1982 planning regulations have never been overturned by a federal court, a notable indication they legally satisfy Congress’ intent in enacting NFMA. The 1982 planning regulations require that “[p]opulation trends of the management indicator species . . . be monitored and relationships to habitat changes determined” in order to satisfy NFMA. 36 C.F.R. § 219.19(a)(6) (1999). USFS must conduct “inventories” that “include quantitative data making possible the evaluation of diversity in terms of its prior and present conditions.” Id. § 219.26. USFS “must evaluate planning alternatives for projects that affect the selected management indicator species ‘in terms of both amount and quality of habitat and of animal population trends of the management indicator species.’” Forest Guardians v. U.S. Forest Serv., Civ. No. 00-714 JP/KPM-ACE (D. N.M. 2001) (quoting 36 C.F.R. § 219.19(a)(2) (1999). This stems from the prescription that forest plans must contain “[m]onitoring and evaluation requirements that will provide a basis for periodic determination and evaluation of the effects of management practices.” 36 C.F.R. § 219.11(d) (1999). USFS has also previously asserted against BCA that the 1982 NFMA planning regulations do not apply to projects implemented under the 1997 BHNF Plan, despite precedent to the contrary from the Tenth Circuit Court of Appeals, the District Court for the District of Colorado, and other federal jurisdictions. In Utah Environmental Congress v. Bosworth, the Tenth Circuit noted preliminarily 

that “[i]ndividual projects must comply the NFMA’s enacting regulations.” Utah Environmental Congress v. Bosworth, 372 F.3d 1219, 1221 (10th Cir. 2004) (citing 16 U.S.C. 1604(i)). The Tenth 

Circuit further held that 36 C.F.R. § 219.19 (1999), which governs USFS actions relating to wildlife viability and MIS, applies to the authorization of site-specific projects. Utah Environmental Congress, 372 F.3d at 1224-25. Site-specific projects must comply with forest plans, which must comply with planning regulations, which must comply with NFMA, the Tenth Circuit reasoned. Id. Following this logic, each tier of national forest management must comply with every higher tier, and the Tenth Circuit applied § 219.19 to a site-specific project. Under Tenth Circuit precedent, § 219.19 applies to the Cold Springs Project. 

8.14 

Similarly, the District Court for the District of Colorado held “that unless it is technically infeasible and not cost-effective, the Forest Service has an obligation to collect and analyze quantitative population data, both actual and trend, for MIS.” Colorado Wild v. U.S. Forest Serv., Civ. No. 03-Z-2592 (PAC) (D. Colo. 2004). The court reiterated “this requirement applies at both the forestplan level and the project level.” Id. Other district courts agree “[t]he unambiguous language of the 

Please see the response t
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

MIS regulations requires collection of population data.” Sierra Club v. Glickman, 974 F. Supp. 905, 936 (E.D. Tex. 1997). Under both binding and persuasive precedent, § 219.19 applies to the Cold Springs Project. USFS must provide any exact figures collected regarding wildlife in the Cold Springs Project area, so the general public cannot determine population levels absent perhaps a Freedom of Information Act request. Wildlife populations are subject to fluctuations and some data may quickly become obsolete. Relying on data collected over half a decade ago fails to satisfy the purpose of having MIS. MIS essentially serve as proxies for other species that occupy similar habitat ecosystems. Without actual, current population data or viability calculations, this proxy purpose offers no way to confirm compliance with NFMA’s diversity mandate. Some courts prohibit using a habitat-as-proxy (“proxy-on-proxy approach”) except “where both the Forest Service’s knowledge of what quality and quantity of habitat is necessary to support the 

species and the Forest Service’s method for measuring the existing amount of that habitat are reasonably reliable and accurate.” Native Ecosystems Council v. Tidwell, Civ. No. 06-35890 3718-

19 (D. D.C. 2010) (citing Native Ecosystems Council v. U.S. Forest Serv., 428 F.3d 1233, 1250 

(9th Cir. 2005)). In order for the proxy-on-proxy approach to pass judicial muster, it must “reasonably ensure[] that the proxy results mirror reality.” Native Ecosystems Council, Civ. No. 06-35890, 3719 (citing Gifford Pinchot Task Force v. U.S. Fish & Wildlife Serv., 378 F.3d 1059, 1066 

(9th Cir. 2004)). Other courts (notably in the Tenth Circuit) prohibit the use of “habitat trend data” as a proxy for population inventories outright, based on the plain language of the 1982 regulations. Forest Guardians v. U.S. Forest Serv., Civ. No. 00-714 JP/KPM-ACE (D. N.M. 2001); 

Sierra Club v. Martin, 168 F.3d 1, 6 (11th Cir. 1999). Without baseline data and non-obsolete onthe-ground monitoring, USFS cannot show compliance with NFMA’s diversity mandate or implementing regulations, let alone NEPA’s “hard look” requirement. Neither will USFS have honored its own policies. In the context of the Cold Springs Project, USFS must demonstrate how this site-specific project actually contributes to the maintenance of viable populations, through both localized population monitoring and habitat connectivity emphasis beyond the arbitrary boundaries of a project’s scale. According to the study by Traill et al., Pragmatic population viability targets in a rapidly changing world, Biol. Conserv. (2009), “conservationists often manage below a biologically reasonable extinction threshold.” “[M]ost populations presently exist as fragmented sub-populations within a larger meta-population,” the authors acknowledge, and this reality rings especially true for the BHNF. Id. Thus, “successful conservation depend[s] on genetic exchange among units to maintain high genetic diversity.” Id. A separate study defined “a minimum viable population size as one with a 99% probability of persistence for 40 generations.” Reed, D.H., et al., Estimates of minimum viable population sizes for vertebrates and factors influencing those estimates, Biol. Conserv. 113 (2003) 23-34. The authors of this study “estimate[d] that in order to ensure long-term persistence of vertebrate 
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

populations, sufficient habitat must be conserved to allow for approximately 7000 breeding age adults.” Id. at 30. The authors acknowledge the problems with managing for such large populations, as “continuous blocks of land capable of supporting populations of 7000 large vertebrates, especially carnivores, is not available.” Id. at 31. “Thus,” the authors recognize, “the 

need to coordinate networks of smaller populations to ensure viable populations through the use of corridors, or managed immigration, should be a high priority.”Id. USFS must clarify how the agency, through the Cold Springs Project, intends to provide corridors or allow for managed migration to accommodate viability on the larger temporal and spatial scale. Population viability analysis may not be an exact science, but it “is the method that most capably 

brings all the factors considered important to population persistence under one umbrella.” Id. Merely tiering back to the flawed Phase II Amendment blatantly avoids assessing the current situation and planning accordingly to account for all factors involved in wildlife viability. No matter how USFS tries to avoid the viability and MIS standards of the 1982 regulations, the 

terminology and purpose of these concepts pervades throughout each tier of resource management for the National Forest System, and USFS has not satisfactorily addressed how it intends to comply with its obligations to viability in general and MIS for the Cold Springs Project. USFS must respond to and correct its inadequacies based on the above-mentioned case law, statutory and regulatory provisions, and scientific studies. The public demands and the law requires (via NFMA, NEPA, the Administrative Procedure Act, etc.) intellectual honesty and 

transparency from USFS, not mere lip service to wildlife viability and MIS that avoids making reasoned decisions supported by and directly citing evidence fully disclosed in the environmental impact statement. 

8.15 

VI. USFS must provide adequate protections to MIS, Region 2 Sensitive Species, and Species of Local Concern. If USFS authorizes the Cold Springs Project, adequate measures must be included in the Record of Decision that protect MIS, Region 2 Sensitive Species, and Species of Local Concern. Maintenance, conservation and/or enhancement of habitat for these species must be quantified 

for the public in the EIS so that it is clear the agency is actually managing the project area in order to maintain viable populations of these native species. 

The impacts of the modifiewildlife and plants are disc
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

8.16 

Mountain pine beetle-infested and killed trees provide valuable habitat for many of these species, so the retention of snags and coarse woody debris should be prioritized. If snags will be cut for safety reasons, explanation of such safety reasons should be provided. In some instances, USFS has asserted that the enhancement of foraging habitat somehow counteracts a loss of nesting 

habitat for certain species. USFS should provide quantifiable data showing how that all balances 

out, because it is not at all clear how the agency is weighing the relative value of foraging habitat against nesting habitat. In other words, how does USFS compare acres or square or cubic footage of foraging habitat against the number of trees or acres providing nesting habitat in reaching its decision that habitat for northern goshawk will be conserved or enhanced? 

The Cold Springs modified designed to meet Forest Pdirection regarding snags. of project activities on spehabitat is included in the E

8.17 

If there are active or inactive northern goshawk or other raptor nests in the project area, they should be thoroughly documented and avoided so as not to further diminish those species’ nesting opportunities. 

The modified proposed accomply with forest plan stagoshawks. The EA includeof the modified proposed a

8.18 

Further, old growth forest and snags should be retained, as these habitat types are already incredibly rare across the Forest and provide critically important features for a number of at-risk species. USFS should provide the public with a map showing where it considers old growth forest to be present in the project area and surrounding vicinity. 

The modified proposed acgrowth forest. Structural stidentified in the project vegof structural stage 5 standSnag retention measures design. The proposed actiforest plan direction for sn

8.19 

VII. USFS must decrease the number of miles of road management activities associated with the 

Cold Springs Project. Despite the over-abundance of roads in the project area, and the BHNF’s mindbogglingly higher actual route density than any other National Forest System unit in Region 2, USFS proposes an incredible 63.9 miles of road work through the Cold Springs Project. In analyzing other projects, USFS has acknowledged that “[m]otorized vehicles have damaged roads and riparian areas when conditions are wet or in cases where streams were crossed,” and further seems to resign itself to the fact that “[i]ncreased use by all-terrain vehicles (ATVs) can be expected . . . and are likely to continue to degrade wildlife habitat both directly and due to habitat fragmentation.” Nautilus DEIS, page 103. “The use of some open roads . . . has also contributed to the establishment of noxious weeds, and the erosion and degradation of riparian areas due to increasing sedimentation and changes in stream morphology.” Id. Still, the Cold Springs Project actually proposes to convert 2.4 miles of “non-system” roads (i.e., most likely illegal ATV user-made) into system roads, without any assurances the 10 roads have any sort of ecologically-sound engineering qualities that support such conversion. Instead of eliminating these destructive routes, USFS instead basically 

pats unlawful Forest users on the back and thanks them for providing environmentally degrading routes. Although “newly constructed roads and converted National Forest System roads would be 

The road management acproposed action are necesaccess, and reduce or minThe majority of the road wor pre-use maintainance (and pre-use maintenance establish drainage to reduThe total miles of transpor2.3 miles of decommissionexisting system road woulexisting system would be bottom. A transportation engineer involved in project developlocations. The impacts of proposed r
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

closed to motorized vehicle traffic following completion of management activities,” USFS has previously implied that ATV damage “can be expected” to continue indefinitely, despite such “closures.” Nautilus DEIS, page 103. 

included in project analysi

8.20 

USFS must show how these newly constructed, reconstructed, and converted roads relate to the recently issued Travel Management Plan and corresponding questions about total route miles, route density, soundscape impacts, enforcement and monitoring concerns, habitat fragmentation, 

and wildlife disturbance and mortality concerns (in particular to SOLC snail species and meadow jumping mouse). 

Proposed road actions are March 2010 Black Hills NaManagement Plan (TMP). decision does not preclude proposed construction, remof system roads and trailsImpacts of the proposed roin the EA analysis. 

8.21 

Furthermore, USFS must show how many miles of roads it will construct, reconstruct, or convert in the water influence zone, and demonstrate compliance with Standard 1301 of the Forest Plan, which “allow[s] only those actions that maintain or improve long-term stream health and riparian ecosystem condition” in the WIZ. USFS must clarify how many stream crossings are associated with these road management activities. A stream crossing, by definition, implicates the water influence zone (i.e., within 100 feet of a perennial or intermittent stream, lake, or wetland), and by agency admission, will “destroy the riparian area in the immediate area.” Nautilus DEIS, page 159. 

Impacts of the modified prresources are disclosed in section in the EA includes activities within the Water Specifically, the analysis tdecrease in road miles witactivity (construction, recodecommission). The EA aassessment of the potentiwater quality based on thoWIZ areas. 

8.22 

USFS must take a true hard look at the impacts these roads will have on quiet recreation, illegal route use, habitat fragmentation, erosion and water quality, wildlife disturbance and direct mortality (especially local science regarding elk susceptibility to vehicle collisions and avoidance of roads), relation to and compliance with the TMP, achievement of route density goals, and the 

agency should include a comparison of local route density to that regionally and nationally across the National Forest System. USFS must thoughtfully address compliance concerns with Standard 1301 and remove routes that do not “maintain or improve long-term stream health and riparian ecosystem condition.” USFS should also provide a fen inventory, maps showing the location of wetlands, and maps showing perennial, intermittent, and ephemeral stream locations so the public can effectively comment on the proposed project. 

The EA includes analysis modified proposed action resources including vegetaresources, wildlife, fire and resources, recreation, ranresources. 

8.23 

VIII. USFS should provide the names of and maps showing other authorized, proposed, and indevelopment projects adjacent to and in the vicinity of the Cold Springs Project area from the last 15 years. The cumulative effects of a project such as this warrant serious consideration in the NEPA analysis. USFS should provide the public with maps showing the names and locations of other timber harvest and forest management activities authorized in the last 15 years that overlap, 

The cumulative effects of considered in the effects aproposed action. The EA imaps and tables of past a
Respondent #8: John S. Persell, Biodiversity Conservation Alliance; Nancy Hilding, Prairie Hills Audubon Society; Jonathan 

Watersheds Project; Wendy Roth; Dick Artley 

# Comment Comment Analysis 

lie adjacent to, or within a two-mile vicinity of the outer boundaries of the Cold Springs Project area. Such maps should include any projects authorized under categorical exclusions. This will help both the agency and the public get a better idea of the cumulative effects of management activities over the recent past on the surrounding landscape. If USFS refuses to provide the maps requested in this paragraph or any preceding paragraph, despite having access to GIS data and tools and project files that the public does not have, the agency must clearly state why it declines 

to do so. 

Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

9.1 

We would like to applaud the US Forest Service for utilizing HFRA Authorities on this project. This type of use is both appropriate and necessary and the Cold Springs Project falls well within the HFRA guidelines. Also of note, the potential for this project to be effective in combating the current 

epidemic appears to be closer in line with the purpose and need for than other projects in the past. While not perfect, we feel it is a good start, and with some modifications, the project has the potential to positively impact the landscape and those who have a vested interest in mitigating this 

epidemic. 

Statement of support 
Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

9.2 

The purpose and need for this project highlight the single largest concern for the Black Hills –mountain pine beetles. The Black Hills National Forest has proclaimed many times over the past year, that the mountain pine beetles are the number one priority for the forest. Ironically, we tend to agree and support this statement, much the same as all the user groups, interested parties, and general public that live, work and recreate in this forest. We would like to see this priority carried out and followed throughout the Cold Springs Project. In his paper entitled “The Influence of Partial Cutting on Mountain Pine Beetle-caused Tree Mortality in Black Hills Ponderosa Pine Stands”, Schmid outlines exactly this strategy as he writes: “The most important aspect of managing mature PP stands on the BHNF is minimizing MPBcaused mortality. If forest managers are to achieve long-term multiple objectives, managers need to assume that minimization of MPB-caused mortality is the primary objective in stands where incipient epidemic MPB populations arise and should temporarily relegate other objectives to secondary status until the immediate threat from epidemic MPB populations has been eliminated. 

While this approach may be contrary to the principle of multiple use and many objectives within the 

BHNF Plan, it is essential to achieving many of the Plan’s long-term multiple objectives. Allowing MPB populations to expand beyond the incipient stage will prevent achievement of most other 

management objectives.” It should be easy to rationalize this type of approach throughout the Cold Springs project. We already know what will happen to these stands if we leave them untreated. Most of the concerns such as goshawk, martens, and sensitive plants will be negatively impacted in a beetle ravaged forest. We do not have the luxury of disposable habitat for these concerns. 

The project interdisciplinaponderosa pine stands at mountain pine beetle infeincluded for commercial tproposed action. The teastands in which commercapplied to reduce the risk infestation. The proposed include treatment of these 

9.3 

Assigning Insect Risk Ratings An initial observation that we have is that the current extent of mountain pine beetles within the 

project is understated. The 2010 Aerial Insect and Disease Surveys were used and we acknowledge this. However, this survey is a crude gauge to point out where the insect activity is. Through observation on the ground and from the aerial photos, there are a number of stands that 

have advanced stages of infestation that have been omitted and deferred from treatment or that have not been assigned a high risk rating. •One example of this, stands 071205_25, 071205_23, and 071205_60 are all 4B stands and have all been identified as “high risk” to insects, yet directly across the road, stands 071303_55, 071303_56, and 071303_81 are all 4B stands yet have not received a “high risk” insect rating. Why were these stands not identified as such? •This lack of consistency, while evident throughout the project, can be highlighted in the southern 

portion of the project. Here there are numerous 4B & 4C stands, some of which have been identified as “high risk” and but many that have not. Why are these inconsistencies observed? Is a 4B structural stage the threshold for a stand to have high insect risk rating assigned? We would recommend the Cold Springs team go back through and reanalyze the current insect 

Forest stands were field r2010. In some cases stanafter stand exam was commountain pine beetle risk current stand structure, abreast height (DBH), and The risk rating is based odocumented in R2 Forest Rocky Mountain Region, Management Guide. The also be viewed in the BlaPhase II FEIS table 3-56. The risk rating of the units consistent with table 3-56have a forest cover type o23, 25, and 60 have a forponderosa pine. 
Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

risk ratings that were assigned to the stands. We would also like clarification on the above mentioned questions. 

The risk rating system is diameter, stand density astoried pine stands with athan 10 inches DBH rate stands with less than 120 (BA) are medium risk and high risk. A 30 BA pondeaverage diameter of 12 inrisk. Hazard ratings give an inthat are most likely to havinfestations. The risk ratinindication of current beetl2010). Stand treatments are devand based on more factoTreatments are proposed and 071205-60. No treatm071205-25 due to ground permit the operation of ha

9.4 

Current Structural Stages Upon further analysis of many of the stands within the project boundary, it appears that many of them are typed for structural stages incorrectly. Largely, many of the stands are typed 4A, which consist of trees greater than 9” with 0-40% canopy cover. The aerial photos clearly show the canopy cover in these stands of question are nearly closed and interconnected. To highlight this please look at stands 071206_8, 07505_60, 071205_42, 071303_13, 071302_44, and 071303_41 as examples. All of these stands are typed SS 4A yet appear to be more in line with a 4B or 4C stands. The crowns are closed and and interconnected. Furthermore, many of these stands are experiencing infestation and have numerous redtops throughout. While a 4A stand is not exempt from becoming infested, the amount and number of dead/dying trees leads us 

to believe these stands are denser than your inventory. We would strongly urge the US Forest Service to go back and review many of the stands that are typed incorrectly and consider commercial treatments in them to align with the Purpose and Need for the Cold Springs Project. 

The project-level vegetatareviewed for accuracy. Prfield reviewed in the fall owere based on field reviesince the 2008 stand exaInformation on the noted field notes and project-lev071206-08: This is a stanof ponderosa pine sawtimregeneration and the pine stocked. (The structural s071206-27: Recent sheltewith aspen release. (The correct.) 071205-42: 48 BA PP>9 35 percent average maxi
Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

structural stage is correct071303-13: even-aged pothinned; 15 percent AMDstage is correct.) The comment does not inphotos were taken. 

9.5 

Commercial Treatments We feel that using the current data at hand, the NHRD did a good job of assigning commercial treatments to high risk stands. However, given what appears to be incorrectly typed structural stages for stands and the inaccuracy of insect “risk ratings” that were assigned to other stands, we feel there are more stands to conduct commercial treatments in. We would hope the Cold Springs team would go through and take a second look at some of these concerns and apply the necessary commercial treatments to effectively reduce the risk of further infestation. 

Project area forest stands the fall of 2010. Treatmenreview and stand data. The project-level vegetatareviewed for accuracy anrepresent existing conditiThe proposed action has stands were reviewed anapproximately 166 acres, modified proposed action

9.6 

Another concern we have is the inconsistent use of commercial treatments on high risk stands. Some identified high risk stands have treatments and other identified high risk stands don’t have treatments. We realize there are some rare occasions where stands are deferred from treatment, but unless there is a specific reason for these “untreated” high risk stands, we would strongly urge you to reconsider treating these high risk stands. Again, we reemphasize the Forest’s commitment to making pine beetles the number one priority. In the DEIS we would like to see a list of all stands that will not receive treatment and the reason for each stand. 

The project interdisciplinaponderosa pine stands at mountain pine beetle infeincluded for commercial tproposed action. The teastands in which commercapplied to reduce the risk infestation. The proposed include treatment of these The project record includeinformation as well as a lirationale for no-treatment
Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

9.7 

After looking at the attribute tables provided, it appears that several of the stands have been assigned new insect risk ratings. How were these new risk ratings derived? We are assuming that stands that had some type of prior treatment in them were candidates for this update – evident by the slash piles and landings in these stands. Is this assumption correct? While we agree that this is a logical step in keeping the information as current as possible, we are concerned that some of these stands were assigned a low risk rating even though the current risk appears to be higher than that. A few stands that higlight this potential error include 170505-73, 071301015, 071303_85 & 071301-31. Most of these stands have visual indications of being infested, yet they were assigned a low risk rating. We would ask the Cold Springs team to go through and reaffirm all stands that originally were “high”risk and are now “low’ risk are accurately represented and also consider assigning commercial treatments to mitigate infestation where necessary. Could you please report the results of this in the DEIS (29 stands)? 

Forest stands were field r2010. In some cases, staafter the stand exam was mountain pine beetle risk current stand structure, astand density. The reviseon a rating system documHealth Management , RoMountain Pine Beetle Marisk rating system can alsHills National Forest PhaThe risk rating system is diameter, stand density astoried pine stands with athan 10 inches DBH rate stands with less than 120 120 BA and greater are hponderosa pine stand wit12 inches would rate medStand treatments are devand based on more factoRevising the insect risk rathe scope of this project. 

9.8 

In the Cold Springs scoping documents there is a description of 386 acres of shelterwood removal acres. We would recommend that these units be dropped from treatment in this project. Generally 

speaking, these stands are at low risk of infestation because of the spacing of these ‘seed trees.’ 

We need to focus our resources and efforts on addressing at-risk stands. Again, the purpose and need focuses on reducing mountain pine beetles, the BHNF is setting this as their primary goal, and we feel that to fully address this priority, these stands should be omitted from treatment in this planning project. 

The proposed action, as ddocument, includes sheltecomplete the transition of forest. This would increasand reduce the amount oIncreasing the diversity oimprove long-term forest 
Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

9.9 

We feel many of the other commercial treatments are adequate and much needed. We would like to see these be implemented on the ground, along with additional commercial treatments in at-risk stands. Currently only 1/3 of the project is slated for commercial treatments, which we feel, does not go far enough in addressing the current pine beetle epidemic. 

The project interdisciplinaponderosa pine stands at mountain pine beetle infe

included for commercial tproposed action. The teastands in which commercapplied to reduce the risk infestation. The proposed include treatment of these 

9.10 

Goshawks While there are no active goshawk nests within the project boundary, there are two just outside the eastern edge of the project. Again, we are offering the same comments in regards to Goshawks that we have submitted many times before. Why are there no commercial treatments that reduce insect infestation risk? Nearly every stand around the nests are 4B & 4C, which in other parts of the project, seem to have been assigned treatments, yet when they are overlapped by the ‘halfmile buffers’ associated with goshawk nesting sites, treatments are omitted. Why is this? Rich Reynolds and Russ Graham, the two prominent goshawk researchers in the country, have outlined numerous reasons as to why these stands need treated, yet the NHRD has ignored these. Why is the research outlined by these two researchers ignored and what is the rationale in doing so? The Black Hills National Forest have distributed a memo dated June 25, 2010 and a white paper clarifying management direction in regards to goshawks dated October 5, 2006, yet the NHRD is ignoring the direction indicated in both of these documents. Why is the district ignoring these and 

what is the rationale behind this? We recognize that wildlife treatments have been assigned to four stands in the vicinity. All of these 

stands are 4C and the treatments are precommercial in nature. How is this going to reduce stocking levels and susceptibility of further infestation? We strongly urge you to reconsider doing commercial treatments to save these stands and ensure these nests are able to persist beyond the current epidemic. This would be consistent with the purpose and need for the Cold Springs project. We would appreciate a thorough and adequate response to these questions. 

The project interdisciplinaponderosa pine stands at mountain pine beetle infe

included for commercial tproposed action. The teastands in which commercapplied to reduce the risk infestation. The proposed include treatment of these The project record includeinformation as well as a lirationale for no-treatmentcontains about 118 acres nesting habitat. Twenty afor commercial treatment goshawk nesting habitat, identified for non-commeto enhance goshawk nesIn addition, the modified psanitation and salvage trepopulation of mountain pi

9.11 

Late Succession While not mentioned in the scoping comments, we would not support omitting stands from treatment for the purpose of attaining SS 5. The level of infestation is too great throughout the project and these stands would most likely have a poor chance of avoiding infestation. 

The Cold Springs project movement toward forest structure stage as part of for action. No stands wertreatment because they astructure stage. 
Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

9.12 

Sanitation We support the NHRD in mentioning a sanitation provision. We feel this is very important and much needed given the current epidemic. We would suggest that the term “salvage harvest” be removed in the DEIS and replaced with “sanitation treatments.” Salvage is not interchangeable with sanitation and may create issues down the road in implementing sanitation efforts. 

Please see Forest Plan Gdefinitions of salvage and treatment terms included are consistent with the foharvest would provide an sanitation treatment and tthe infested logs would be 

9.13 

Prescribed Burning We support the 1,698 acres of prescribed burning proposed in the Cold Springs project. We appreciate that 85% of the proposed burning would happen following vegetation treatments. Whenever possible, we would like to see even more prescribed burning follow mechanical treatments. We would also offer the following recommendations to be incorporated in future direction of the Cold Springs project. 

1) Map of where the 1,698 acres is likely to be proposed. 

2) Mortality limits of 10% or less in stands. 3) Salvage clause allowing for the option of quick and efficient salvage of saleable timber in 

areas exceeding the set mortality limits, or if the prescribed burn does get away. 

4) Burn objectives. 5) We strongly urge prescribed burning to be done in stands that have had mechanical 

treatments prior to burning. 

6) We caution the US Forest Service in burning following precommercial thinnings where the 

slash is left on the forest floor. We would recommend burning in this scenario only in cases where the slash is minimal or the stand densities are low enough that the residual stand will not be damaged and the prescribed burn will be of low intensity. 

7) We do not support the use of prescribed burning to reduce pine beetle risk of infestation 

in stands. 

Maps of the modified protreatments are available iProject design features hinto the modified proposeburning would be implemconditions defined in a prburn plan will include burthat have been designatetimber base, at least 90 pgreater than 9 inches in dIn other stands, at least 5greater than 9 inches in dPrescribed burning under objectives to miminize ovpreclude the need for posPrescribed burning and pproposed in 2 units, 0713Burn plan objectives will itrees to meet forest plan This project does not inclreduce pine beetle risk of 
Respondent #9: Carson Engelskirger, Black Hills Forest Resource Association 

# Comment Comment Analysis 

9.14 

We would like to thank the NHRD for the opportunity to comment on the Cold Springs project and look forward to working with them throughout the life of the project. We would also like to be contacted by the NHRD to discuss our scoping comments and discuss our concerns in creating an effective DEIS. Would you please contact us once you have reviewed our comments? 

The District provided a scThis comment period proor affected by this proposmake their concerns knowthe Responsible Official. delivered, and electronic this action were accepted following publication of th

City Journal. Those who comments will be eligible decision pursuant to regu
Respondent #10: Dennis Daugaard, Governor, State of South Dakota 

# Comment Comment Analysi

10.1 

1. You have indicated that the primary purpose of the project is to decrease the risk of mountain 

pine beetle infestations in ponderosa pine stands within the project area. You indicate that 48 percent of the pine stands in the project area have a high risk of mountain pine beetle infestation, 

and another 18 percent have a moderate level of risk. Since the project area is approximately 

12,300 acres in size and 11,800 acres are covered with ponderosa pine forests, it is reasonable to assume that 66 percent (48 + 18) of the forested acreage, 7,788 acres, is very susceptible to mountain pine beetle infestation.Your plan indicates that you will treat or “reduce stocking and 

corresponding risk” on 4,458 forested acres. This only treats 57 pecent of susceptible forest stands 

in the project area. We do not believe that this will provide adequate protection against the mountain 

pine beetle; and, it will allow mountain pine beetle to spread into the area even if all the actions you propose are carried out. Therefore, we recommend treating a larger percentage of susceptible forest stands in the project area. 

The effectiveness of the susceptibility to mountailosses is discussed in thThe project interdisciplinponderosa pine stands amountain pine beetle infincluded for commercial proposed action. The teadditional stands in whiccould be applied to redupine beetle infestation. Tmodified to include treatThe project record containformation and includes brief rationale for no-treaThe modified proposed and salvage treatments of mountain pine beetles

10.2 

2. You indicate that, “post treatment stands densities would be 60-80 square feet of basal area ... ” 

However, you also indicate that, “recent research indicates the lower the residual stocking, the greater the reduction in mountain pine beetle-caused mortality ... "We believe that the current 

research is correct. Consequently, we believe your residual forest stand stocking levels will not adequately protect those forest stands against heavy mountain pine beetle infestations. Therefore, 

we recommend that these forest stands be reduced to a residual stocking level of 40-60 square feet of basal to provide maximum protection. 

An alternative to the proreduced stocking levels eliminated from detailed Post-treatment stand deor less, except where himaintain canopy closure Post-treatment thinning BA are not included in thaction. Stocking at 70 Bpercent AMD and well boccupancy (approximateTrees should not be in cnutrients. Thinning to 60 BA or lowestablishment of pine remanagement goals to remountain pine beetle risdiversity of age classes The modified proposed 
Respondent #10: Dennis Daugaard, Governor, State of South Dakota 

# Comment Comment Analysi

acres of shelterwood estreatment would initiate approximately 10 perceforest stands. These trepast shelterwood removdiversity of age classes Thinning and shelterwoolow basal area (60 BA oshelterwood establishmregeneration establishm31 percent of the pondewould not provide a balaproject area’s current minfestation is exacerbateponderosa pine sawtimbclass. Thinning a stand with hi(approximately 120 BA ostocking (40 to 60 BA) csusceptibility to breakagstands typically have higdue to competition, and bole and root systems to when opened up, and mare likely to be uprooted(Shepperd and Battaglia is located high in the Blaand trees are subject to snow loads. The project area is withimanagement areas 4.1 managed for forest prodthings. Periodic re-entry expected in these areas periodic basis can mainwhere trees are not in cis not necessary to thin area to maintain the stamountain pine beetle ris
Respondent #10: Dennis Daugaard, Governor, State of South Dakota 

# Comment Comment Analysi

time. Sawtimber stands at 40 than 20 percent AMD. A occupied when the stocapproximately 40 perce

10.3 

3. We recommend you work closely with state and county mountain pine beetle suppression efforts 

that may overlap the project area. And, it is imperative that you work closely with private landowners 

within the project area to assure them that mountain pine beetle infested trees close to their lands are cut and treated in an aggressive and timely manner. This will go a long way to sooth concerned private landowners adjacent to Forest Service lands. 

Members of the project Northern Hills Ranger Dthe Lawrence County CLawrence County Timbescoping documents havland owners within and area; and they were invon January 26, 2011, to Sanitation treatments arproposed action. 

10.4 

4. Your proposed plan indicates that you intend to retain "irregularly shaped clumps of largediameter trees" in some areas to create an uneven-age stand structure. We are concerned that 

these clumps of large diameter trees would be ideal places for mountain pine beetle infestations 

within treated forest stands. Therefore, we recommend that the residual basal area within these clumps of large trees be reduced. We recommend no greater than 40 square feet of basal area. 

The modified proposed and salvage treatments beetle populations. The monitored for mountain and proposed treatmentthe beetle-infested treesA treatment that reducefeet of basal area would establishment of regenedesired treatment in stagoshawk habitat. 
Respondent #11: Daryl D. Johnson, Lawrence County Commissioners 

# Comment Comment Analysis 

11.1 

First, we would like to thank you, Glenn and Jackie for meeting with the Lawrence County Timber Committee on Feb. 8. It was very informative. The discussion and comments were very helpful to 

both parties in being able to understand each others concerns and issues. In addition we also appreciate your team's cooperation and timeliness in responding to our requests for information. We applaud the USFS' use of the Healthy Forest Restoration Act to plan this project. This will help expedite the NEPA process in areas where treatments need to be applied as soon as possible. We hope the timber sales that come out of this project are destined to be sold at the start of your fiscal year 2012. 

Statement of support 

11.2 

We agree with the USFS that the primary purpose and need for this project is to decrease the risk 

of mountain pine beetle. The BHNF, Forest Supervisor has repeatedly stated that taking care of the current mountain pine beetle infestation is the number one forest' management priority. We 

heartily agree and think it is important the USFS' removal of all of the mountain pine beetle 

infested trees be a high priority within this project. Overall, we believe your team has done a good job in reducing the mountain pine risk in this project area by treating over 80% of the mpb high risk stands. This should help reduce the risk to most of the project area. There is a great opportunity to improve on your proposal. This can be accomplished by treating the rest of the high risk stands to the extent that they can feasibly be accessed. Some of these untreated stands were initially proposed for treatment but then dropped due to goshawk, pine marten and potential plant habitat concerns. Many of these stands have significant incipient bug populations. Schmid and others in RMRS-RP-68 “The Influence of Partial Cutting on Mountain Pine Beetle-caused Tree Mortality in Black Hills Ponderosa Pine Stands” state that “The most important aspect of managing mature PP stands on the BHNF is minimizing MPB-caused mortality. If forest managers are to achieve longterm multiple objectives, managers need to assume that minimization of MPB-caused mortality is the primary objective in stands where incipient epidemic MPB populations arise and should temporarily relegate other objectives to secondary status until the immediate threat from epidemic 

MPB populations has been eliminated.” We have listed some of the stands that we believe need to be commercially treated during this 

management entry. 0713030021 0713030019 0713060021 0712050006 0713050015 0713060074 0713060079 0713050011 0712050016 0712050025 0712050081 0713050002 0705050051 0713010028 0713060016 0713040084 0713060039 0713030044 0713030004 0713010012 0705050055 0713020069 0713010034 0713040099 0713020065 0713010095 0712050044 0713080042 0713030038 0713060010 0705050009 0713030074 0713050020 0713050018 0713050006 

The project interdisciplinaponderosa pine stands amountain pine beetle infeincluded for commercial proposed action. The teastands in which commercapplied to reduce the risk infestation. The proposed include treatment of thesThe EA appendix E inclua brief rationale for no-trediagnosis information is lrecord. The modified proposed aand salvage treatments tof mountain pine beetles
Respondent #11: Daryl D. Johnson, Lawrence County Commissioners 

# Comment Comment Analysis 

0713050001 0713030045 0713030022 0713030021 

11.3 

We are especially concerned about the high risk stands that have been dropped from being 

commercially treated due to goshawk concerns. After discussions with Richard Reynolds and in reviewing the recommendations of RM-17 and the recommendations of the BHNF wildlife biologist, we believe that the goshawk management approach to this area is too conservative especially in light of the amount of no treatment proposed in the adjoining West Rim project and the amount of mpb infestation in the area. We urge to you to reconsider treating those stands that 

were dropped from treatment. 

Please see the response 

11.4 

During our discussion, it was mentioned that the plant biologist is not concerned about having 

infested trees in areas set aside for sensitive plants or potential plant habitat. We fervently disagree with this management approach. While the infested trees may not threaten the plant habitat, which could be questionable, allowing these infested trees to infest other areas does not adhere to the purpose and need of the project and also to the Forest Supervisor's direction. 

The modified proposed ato treat or remove mounttrees. Prior to implementation, would review areas of saoutside of harvest units tspecial design criteria are forest resources and enscomply with forest plan dThe project botanist assiof the proposed action to plants and plant habitat iIn general, sensitive planarea include moist paper stands, moist spruce stariparian areas, and other water is present. These ausually infested by mouninfestations are found in potential plant habitat, thremoved with the sanitatin the proposed action....treatment outside of harvreviewed by resource spimplementation to determdesign criteria are neederesources and ensure the Forest Plan direction.” 
Respondent #11: Daryl D. Johnson, Lawrence County Commissioners 

# Comment Comment Analysis 

11.5 We would also like to have your team review some of the low risk stands that have significant mpb infestation that should have a higher risk that are not being treated. 0713050006 0713080040 Please see the response 11.6 

As we evaluate this project it is very important to understand the impact mountain pine beetle is 

causing on other areas of the BHNF, like the adjacent Rifle Pit area. Most of the highly stocked 

stands that have been left untreated where there are incipient mountain pine beetle populations 

end up being deforested from mountain pine beetle. Rifle Pit project is prime example. The bottom line is when there are epidemic levels of mountain pine beetle you cannot leave high risk stands untreated especially if there are already mountain pine infestations occurring within those stands. 

Please see the response 

11.7 

Lawrence County is also very concerned about the amount of deforestation that is occurring north 

of Highway 85 in the Rifle Pit country. This mountain pine beetle infestation has been going: on for at least 5 years and has killed thousands of trees. Unless the USFS has other plans, we would encourage the USFS to enlarge this project to encompass this area. Many of the areas that are being severely impacted are areas that were left out of the Rifle Pit timber sale. 

An alternative to the propexpands the project area alternative was eliminatebecause expanding the punacceptable delay in primplementation. The delapine beetle populations tadditional forest stands. 

11.8 

We are also concerned about the area just across the district line that is between the McInerny 

Timber Sale and the Cold Springs project. This area has a significant number of mountain pine beetles and is not scheduled for treatment by the BHNF in the next 5 years. For some reason it 

was not included in the Norwood project and is now isolated and untreated. We would recommend the Northern Hills District and Hell Canyon District join together and enlarge the Cold Springs project to include this area. 

Please see the response 

11.9 

We would also ask that you increase the amount of fuel treatments near any private land and 

structures. There are several stands (07130600 21, 07130600 39, 07130100 31) with high wildfire intensity/severity risk ratings next to private land that are not being treated. In addition to being rated as very high for fire hazard, these stands presently contain incipient mountain pine beetle infestations and have high mountain pine beetle risk. 

The modified proposed atreatment of 071301-31. is commercial thinning to precommercial thinning tprescription. Stands 0713reviewed. Commercial timstands would be difficult the location of private lanbe needed). The stands plant habitat. The forest concern or enhance habspecies and species of loThe proposed action was this comment. 

11.10 We recommend the USFS completely disclose to the public the peril of leaving high risk stands Rocky Mountain Region 
Respondent #11: Daryl D. Johnson, Lawrence County Commissioners 

# Comment Comment Analysis 

not treated. These risks have been understated repeatedly in past projects. There are plenty of 

examples that show what happens to highly stocked stands with incipient mountain pine beetle infestations that are left untreated. We urge the ID Team to use Rocky Mountain entomologist to evaluate and make recommendations for managing this project's ponderosa pine stands. 

Management staff have bconjunction with the prepKurt Allen’s project reporrecommendations are avThe effects of the no-actdiscussed in the EA. 

11.11 

We applaud the USFS for proposing a sanitation provision in this project, but we are concerned 

with how the sanitation provision is implemented. As evidenced in other projects, there are limitations to implementing the sanitation provision. The purchaser has limited ability to identify infested trees and the USFS has limited personnel to identify and mark infested trees. With looming budget cuts, it makes more sense to propose some types of treatments through most of the medium and high risk stands which will then require the purchaser to actually cover more of the project area. The ultimate goal is to rid the project of epidemic levels of mountain pine beetle and to reduce the risk of future outbreaks. 

Please see the response 

11.12 

From reviewing R2 veg. layer, it appears that much of the stand information does not reflect the 

actual vegetative conditions. We appreciate your efforts to reclassify the mountain pine beetle risk in stands that were previously treated under the Power Timber Sale but we are concerned that there are many stands currently listed with medium risk actually having low risk. We understand that the current risk rating system causes this problem but it makes a mockery of the risk classification when there are stands with 30 basal area of large trees that are mixed with aspen rated the same as highly stocked stands of POL and some small saw timber. We understand that this is outside of the scope of Cold Springs project to change this rating system but we encourage you to talk with the appropriate experts to consider modifying this rating system. Medium risk stands that have low risk that should be reclassified: 0705050068 0705030127 0712060001 0712060012 0705030115 0705030112 0705050096 0705050010 0705050016 0705050076 0705050070 0713010012 0713010034 0713010044 0713010032 0713010095 0713010082 0713010080 0713020070 0713020035 0713060038 0713060046 0713080025 0713050014 0713060013 0713040087 

Forest stands were field 2010. In some cases, staafter stand exam was comountain pine beetle risk current stand structure, astand density. The reviseon a rating system documHealth Management , RoMountain Pine Beetle Marisk rating system can alsHills National Forest PhaThe risk rating system is diameter, stand density astoried pine stands with athan 10 inches DBH rate stands with less than 120 and 120 BA and greater ponderosa pine stand wiof 12 inches would rate mPlease see the response additional discussion regsystem. Stand treatments are dev
Respondent #11: Daryl D. Johnson, Lawrence County Commissioners 

# Comment Comment Analysis 

and based on more factoRevising the insect risk rthe scope of this project. 

11.13 

We recommend the USFS propose prescribe burning to reduce the common juniper. The common 

juniper in these stands has a very high fuel risk that needs to be recognized. Reducing this fuel type near private lands would significantly decrease the susceptibility of fast moving and intense 

ground fire. 

The modified proposed aburning across 897 acresconsiderable recent past within the project area; s3,008 acres have been bburning (District FACTS The proposed action was slashing, or slashing, pilicommon juniper where nin close proximity to priva

11.14 

We would also like to see the Northern Hills District to not only reduce the conifer competition in 

aspen stands but also treat these stands to stimulate aspen regeneration. Prescribe burning could 

be an excellent tool along with patch clear cutting. 

The modified proposed aburning across 897 acresaspen within these burn stimulate aspen regeneraTreatments in the proposrelease, to maintain aspespecies on sites and as istands. These actions woarea tree species diversiTreatment to regenerate project purpose and nee

11.15 

In our discussions, you mentioned that spruce climaxing of seral pine stands was becoming a 

problem. We agree. Past treatments of seral pine stands that did not include removing the abundant young spruce in the understory has contributed greatly to this phenomenon. Now mountain pine beetle infestation in these mixed stands is taking care of most of the remaining pine. Allowing these pine stands to convert to spruce does not follow Forest Plan Objective 200-01. When treating these pine stands we encourage the USFS to cut all commercial sized spruce and then follow up the commercial treatments by masticating the larger sub' merchantable spruce and then prescribe burning to kill all of the small spruce. 

The project interdisciplinaalternative that converts pine-dominated forest, hwas eliminated from detaconversion of mixed sprupine is outside the scope not relate to the purpose The project purpose and risk of mountain pine beeponderosa pine stands wfor timber production and The project area is and w
Respondent #11: Daryl D. Johnson, Lawrence County Commissioners 

# Comment Comment Analysis 

dominated by ponderosa of some mixed spruce/pidominated stands may oof this transition is expecFurthermore, heterogenevegetation types across tcontributes to the area’s pine beetle attack. The forest plan does not numbered 200-01. An obwas included in the Phassupport of the forest plan 2005). This objective was plan and numbered objecobjective indicates that laForest should manage foacross the Forest using aachieve multiple-use objeAs the discussion in the the objective is intended where spruce is encroacto favor spruce where sppine stands, “especially wconnectivity between sprForest Service 2005, p. Imaintain at least 20,000 the Forest, the Phase II Fthere would be losses in conversion occurred or wremoved to reduce fire hto structures; however, thbe balanced by gains duareas (USDA Forest Ser
Respondent #11: Daryl D. Johnson, Lawrence County Commissioners 

# Comment Comment Analysis 

11.16 

We appreciate your teams efforts in making this a well thought out and effective project that will 

meet the purpose and need. Lawrence County believes we can help the USFS to achieve this and would like to meet with you in a couple of weeks to review our recommendations. 

The District provided a sThis comment period proor affected by this proposmake their concerns knothe Responsible Official. delivered, and electronic this action were accepted following publication of thCity Journal. Those who comments will be eligible decision pursuant to regu
Respondent #12: James R. Nelson, Spearfish Canyon Homeowners Association 

# Comment Comment Analysi

12.1 

The following comments are submitted in behalf of the Spearfish Canyon Homeowners 

Association(SCOA) for which I serve as President, Board of Directors, SCOA. These comments are a result of SCOA' s past and continuing participation in reviewing and commenting on BHNF projects of the past few years for improving the health of the BHNF. The comments also result from continuing coordination with the Lawrence County Timber Committee, and thus leave some of the more specific comments on the Proposed Vegetation Treatments, pages 5 through 7 of the project plan. to the Timber Committee response. As a general comment, SCOA has been supportive of BHNF plans and projects to improve/maintain the health of the forest here, and we are mindful of the many constraints that affect the timing, scope and locations of your successive efforts. 

Introduction paragraph. 

12.2 

With respect to the Cold Springs Project, let me first say that we were pleasantly surprised and highly supportive of the fact that this is the first project plan we have seen for the Northern Hills 

where it clearly states the first priority and focus of this plan is on the pine beetle infestation. We believe this is appropriate and, while fuels reduction and related overall goals for the Black Hills Forest need continued, long term activities to attain those goals. current first priority emphasis must be on controlling and reducing the spread of the beetle infestations. 

Statement of support. 

12.3 

With this priority in mind, we would recommend the project plan make this even more clear by restating both the Introduction and Purpose ad Need for Action paragraphs, the latter stating that 

"the project qualifies for expedited vegetation management under Section 102(1)(4) of the Healthy Forest Restoration Act", as stated on page 3. We believe the purpose should be ... "The purpose of this project is to accelerate the arrest of the current mountain pine beetle infestation in ponderosa pine stands, and to reduce the risk of spreading infestations within this project area and to/from those adjacent to the area." This statement should then be justified by the quoted statement referencing the Healthy Forest Act, Section 102(1)(4). 

The Northern Hills Districproposed change to the and need. The project pube changed. 

12.4 

In the recent years and in past comments of SCOA and the Lawrence County Timber Committee 

on projects such as Telegraph, Steamboat, etc., we have consistently emphasized this need for focus on beetle control and reducing the risk of spreading infestations as of first priority versus the more general, fundamental goal of fuels reduction at this time. Words and statements do matter to BHNF personnel as well as to us. It takes time and consistent emphasis to make this point to all concerned. Although fuels reduction, forest diversity, etc., remain important, until this current major infestation of the beetle in the Black Hills is arrested, controlled, “runs its course”, etc., we believe 

“battling the beetle” should be the clearly stated first priority. This priority would then provide a basis for addressing some of the constraints we know you have. For instance, the Goshawk nests that are near the Cold Springs project (I understand they are also along the common boundary with the adjacent West Rim project area), the constraints on treating areas that are potential Pine Marten habitats, etc., are constraints that should be examined from the aspect of whether that habitat will survive the beetle infestations if not treated. 

We believe some of the current constraints should be examined with this current environment in 

The project interdisciplinponderosa pine stands amountain pine beetle infeincluded for commercial proposed action. The teaadditional stands in whiccould be applied to redupine beetle infestation. Tmodified to include treatmThe EA appendix E inclua brief rationale for no-trdiagnosis information is record. The modified proposed a
Respondent #12: James R. Nelson, Spearfish Canyon Homeowners Association 

# Comment Comment Analysi

mind, rather than just from the Black Hills Forest Plan and USFS or other agency directives which may be restrictive to what needs to be done on an accelerated basis. Relief from some constraints may be possible which could significantly reduce beetle damage and spread. 

and salvage treatments tof mountain pine beetles

12.5 

SCOA was happy to learn that the proposed treatments in this project area includes the ability to 

use sanitation harvesting widely within the area, with the further flexibility to apply this treatment to all pine stands in the project, including those over and above the proposed treatment areas 

(potentially all 5947 acres of pine stands in the project area, rather than just to the 4924 acres 

planned for treatment). We hope this flexibility is used to aggressively go after beetle-infested pines which are not now identified, but may be existent, may appear as new infestations before the project activity begins in 2012, or may appear later in the life of the program. 

Sanitation treatment coudecision notice. 

12.6 

We are hopeful that the timeline for this project, done under an EA approach will allow accelerated 

review, approval and activities as early as 2012. The project plan as described notes most project area pine stands have some level of infestation, with stands averaging 11% beetle-caused overstory mortality, which indicates a growing infestation versus that mortality seen in 2009. My own personal flights over this area in December, 2010, indicated to me that 11% overstory mortality is conservative, and my subjective estimate would be closer to 20-25%. In any case, this project needs to get underway with treatment activities beginning as soon as possible, because areas of infestation are large and expanding. 

Timber sales are scheduand could be sold as earpreparation (unit layout abegin in 2011. Sanitationcould begin after a final d

12.7 

We believe it would be helpful to include as part of this and subsequent plans, a description, 

where applicable, of the status of adjacent BHNF projects with evidence that the planning for this project is well integrated with the plans/treatments/constraints of adjacent projects such that the overall strategy and tactics of each have been considered for most effective integration of activities and resources. For instance, in this Cold Springs project, what are/might be the interrelated goals and treatments for West Rim(power?) that were considered in developing this project plan?, and did those considerations lead to changes/alterations/refinements of the planning for this project?, 

or for West Rim? It would help understand the BHNF overall strategy/tactics, which are most likely dynamic as challenges like the pine beetle infestation appears and thus to understand how the BHNF is responding. 

Appendix C of the EA incpast, ongoing, and reasoactions within the project The cumulative effects oreasonably foreseeable vicinity were considered Projects on the Black Hildeveloped to achieve goin the Black Hills NationaResource Management 

12.8 

As noted earlier in this letter, SCOA has coordinated with the Lawrence County Timber Committee and agrees to that Committee's comments to this plan, especially with respect to specific 

comments on the vegetation treatments. 

The comments from the the corresponding communder Respondent #11. 

12.9 

We thank you for the opportunity to comment on this plan. We are in general agreement with the 

plan and would urge its initiation on an accelerated basis, since the beetle infestation will expand even further in this area (and probably adjacent areas) until arrested and controlled by aggressive treatments. 

Statement of support 
Respondent #12: James R. Nelson, Spearfish Canyon Homeowners Association 

# Comment Comment Analysi

12.10 

As a final comment, SCOA would recommend this project be initiated in priority ahead of the Steamboat Project, for which we recently provided comment. We believe Steamboat is a worthwhile project, but again, in the current environment of beetle infestations in the BHNF, the 

situation is much more severe in the Cold Springs Project area than that existing in the Steamboat Project area. Accelerated activities to control the spread of the beetles where they are, while 

reducing the risk of spread to adjacent areas should be the priority in 2011 and in the next few years, with more typical fuels reduction and forest diversity a lesser priority until this infestation "runs its course" or noticeably eases. 

Timber sales are scheduand could be sold as earpreparation (unit layout abegin in 2011. Sanitationcould begin after a final d
Respondent #13: Paul Pierson, Neiman Timber Company 

# Comment Comment Analysi

13.1 

Neiman Timber Company would like to thank you for the opportunity to comment on the project. We 

would also like to thank you for your timeliness in providing the requested information for us to analyze the project. 

Introduction 

13.2 

SUPPORT: Neiman Timber Company supports the following aspects of the project: 

• The purpose and need for the Cold Springs project. • The use of the Healthy Forest Restoration Act (HFRA) to achieve the purpose and need for 

this project. 

 Although we were unable to review all silvicultural prescriptions, the ID team has done a very 

good job prescribing the appropriate treatment for the stand conditions. 

 Treating approximately 80% of the high insect risk stands is a step in the right direction for 

controlling the MPB epidemic. 

 Identifying 3 suitable Goshawk nest areas and 3 replacement nest areas as described in RM217. 

• Assessing a new insect risk level for the project area. • Utilizing skyline yarding equipment to access difficult terrain.  Using a combination of commercial, pre-commercial, and RX burning to achieve desired forest 

conditions. 

• Sanitation Provision 

o We support the whole project being open for sanitation harvests. 

Statement of support 

13.3 

IMPROVEMENTS AND RECOMMENDATIONS: We agree with the statement made by Black Hills National Forest Supervisor that controlling the 

MPBs is the top priority for the forest. Although this project takes large strides towards this goal we are concerned that its short failings indicate that it is still not the top priority for the NHRD. In the research paper by Schmid, “The Influence of Partial Cutting on Mountain Pine Beetle-caused Tree Mortality in Black Hills Ponderosa Pine Stands” a strategy is provided for achieving this goal as it relates to other objectives: “The most important aspect of managing mature PP stands on the BHNF is minimizing MPB-caused mortality. If forest managers are to achieve long-term multiple objectives, managers need to assume that minimization of MPB-caused mortality is the primary objective in stands where incipient epidemic MPB populations arise and should temporarily relegate other objectives to secondary status until the immediate threat from epidemic MPB populations has been eliminated. While this approach may be contrary to the principle of multiple use and many objectives within the BHNF Plan, it is essential to achieving many of the Plan's long-term multiple objectives. Allowing MPB populations to expand beyond the incipient stage will prevent 

The project interdiscipliponderosa pine stands mountain pine beetle in

included for commerciaproposed action. The teadditional stands in whicould be applied to redupine beetle infestation. modified to include treaThe project record continformation and a list of rationale for no-treatmeThe modified proposed sanitation and salvage 
Respondent #13: Paul Pierson, Neiman Timber Company 

# Comment Comment Analysi

achievement of most other management objectives.” Given that the purpose and need of this project is to decrease the risk of MPB infestation and this is also the top priority of the BHNF, we provide the following recommendations to fully achieve this goal: 

population of mountain 

13.4 

• Insect Risk Rating 

o We support the NHRD assessing new insect risk ratings; we question how these new 

ratings are assigned. Is it based on past management activities or field verifications or both? We ask that this process be described. 

o Revamp the insect rating system. 

• We see the medium risk rating includes stands that range in TPP _BA 5" and larger from 104 

BA/a down to 0 BA/a. This makes it difficult to analyze what treatments are necessary. 

Forest stands were field 2010. In some cases, safter stand exam was cmountain pine beetle riscurrent stand structure, stand density. The revison a rating system docuHealth Management , RMountain Pine Beetle Mrisk rating system can aBlack Hills National For3-56. The risk rating system idiameter, stand density storied pine stands with than 10 inches DBH ratstands with less than 12and 120 BA and greateponderosa pine stand wof 12 inches would rate Please see the responsadditional discussion resystem. Stand risk rating, and a rating is included in the report. Stand treatments are desilviculturist and based insect risk. Revising the insect risk the scope of this projec

13.5 

• We are also concerned that stands currently dominated by white spruce generally receive a 

lower insect risk due to the lower densities of ponderosa pine and are deferred from treatment. It is critical to realize that the mature pine in these stands is at high risk to MPB and treatments 

The hazard rating systeprimarily for ponderosa al. 1994). Single-storied 
Respondent #13: Paul Pierson, Neiman Timber Company 

# Comment Comment Analysi

are needed to reclaim these stands as pine stands before the MPB kills all the pine (Le. veg. link: 0713050006). 

risk rating than two-storService 2000). The modified proposed sanitation and salvage population of mountain 

13.6 

• Climaxing White Spruce Stands 

o We encourage using commercial, pre-commercial, and RX burning as tools to 

eliminate climaxing white spruce from seral ponderosa pine stands. 

See response to comm

13.7 

• Landscape level treatments 

o Treating 80% of the identified high risk stands is commendable when compared to past 

projects. We recommend the FS treat 100% of the high MPB risk stands and all medium and low risk stands that have MPB infestation. With the MPB populations at epidemic levels within and surrounding the project, choosing to not treat a high insect risk stand will likely result in the loss of the stand. It is crucial to remember that the MPB does not just attack a single stand and then stop; they move out and infest other stands. Untreated, high insect risk stands create conditions for the MPB populations to grow to levels such that they will infest nearby medium and low risk stands. 

Please see the respons

13.8 

o When looking at the impacts that the proposed actions will have on various resources, the FS 

must disclose and analyze the reasons and effects that no treatment will have on the resources given the MPB population. 

The EA includes analysalternative. 

13.9 

We again disagree with the decision to use potential suitable plant habitat, goshawk habitat, and 

intermittent stream courses as reasons to not access the high insect risk stands. There is nothing in the Forest Plan, SD BMPs, or state regulations that restrict all operations in these areas. We urge the FS to reconsider high insect risk stands for treatment that were dropped due to these various resource concerns. We are not asking for everything to be thinned to a 60 BA/acre, but rather to commercially treat all these stands to meet an acceptable desired condition while reducing the insect risk and sanitizing the stand. Timber harvesting should not be viewed as a threat to these resources, but as a tool to maintain, protect, and enhance these resources. 

Please see the respons

13.10 

As stated earlier, we approve of the nest area designations made for the goshawk. In order to 

protect the two habitats for nesting areas, active management is needed. There is no sense in designating suitable and replacement nest sites only to walk away from them and leave them to the MPB. I have attached two maps for your consideration. Map 1 shows the proposed commercial treatments in the Goshawk area. Map 2 shows our proposed commercial treatments in the Goshawk area. 

Please see the respons
Respondent #13: Paul Pierson, Neiman Timber Company 

# Comment Comment Analysi

13.11 

Medium Risk stands need to be treated. According to the information in your attribute files, 

approximately 80% of medium insect risk stands that have not had past treatments will not receive treatments under this project. Many of these stands have MPB present or are likely to become infested if not treated. 

Please see the respons

13.12 

Sanitation is a great tool to have when reacting to MPB infestations. It is, however, limited by either 

a purchaser's ability to identify and treat stands that are in close proximity to their operations at any 

given time, and/or by the FS personnel's availability to identify and mark the infested area. Due to these limitations, we again recommend proposing commercial treatments in as many high and medium insect risk stands as possible so they are guaranteed to be treated. 

Please see the respons

13.13 We encourage the NHRD to advertise the sales as early as possible to allow treatments to begin before winter restrictions apply. 

Timber sales are schedand could be sold as eaSale preparation (unit lamarking) could begin in treatments could begin made. 

13.14 We encourage the NHRD to work with the state to reroute or close snowmobile and ski trails prior to sale advertisement. 

Staff on the Northern H

work with the State regaski trails. Snowmobile trails would improvements on timbeprotected during harvesevaluation of the potentlogging and trail use wotime of timber sale apprpreparation. If conflicts use of the snowmobile units or haul routes, logbetween December 1 alogical and desirable altroute is identified. Only in conflict would be restoperations could proceesale area. Winter operations of timnecessitate skidding acbut do not otherwise affallowed. Determination case‐by‐case basis, wit
Respondent #13: Paul Pierson, Neiman Timber Company 

# Comment Comment Analysi

only at locations approvadministrator and with pinstalled by the timber c

13.15 

We would again like to thank you for the opportunity to provide comments on the Cold Spring project. You have put together a very good project for addressing the MPB and we hope our 

comments will aid you in developing the best possible project to meet the purpose and need. Please contact us to schedule a meeting to discuss our comments and recommendations once you have had time to review them. 

The District provided a This comment period pin or affected by this promake their concerns knby the Responsible Offihand-delivered, and eleconcerning this action wcalendar days following in the Rapid City Journa

timely written commentformally object to the deregulations at 36 CFR 2
Respondent #14: Douglas Hofer, Director, Parks and Recreation Division, South Dakota Department of Game, Fish and Parks 

# Comment Comment Analysi

14.1 

This letter represents our comments in reply to the Cold Springs Project Area, in the Northern Hills 

Ranger District of the Black Hills National Forest. This project encompasses the Hardy Guard Station, which is the headquarters for the Black Hills snowmobile program, and is very important in maintaining the high traffic from snowmobiles and grooomers in and out of this area. Due to private land in many meadows, topography, and conflict with existing roads, moving snowmobile trails can be expensive, time consuming, and complicated. We understand removing trees infested with mountain pine beetles is a high piority and without these logging efforts the health of the forest would continue to decline. We strongly encourage the Northern Hills Ranger District, our Division of Parks & Recreation, and the logging industry to work together throughout planning process of this project. Working together, the goals of this project can 

be accomplished' while minimizing the number of miles of snowmobile trails impacted. 

Please see the respons

14.2 

The following specific actions would be most helpful in the implementation of the Cold Springs 

Project in regards to maintaining the snowmobile trail system in this area: A defined and complete map of logging activity occuring during winter months should be submitted to the SD Black Hills Trails office by August 15th annually. This would allow adequate time for new 

trail markers and changes to the publication of the SD Snowmobile Trails Map. Trail signs and markers need to be protected during harvest activities. Coordination between the SD Trails office and the US Forest Service Snowmobile Trails Coordinator needs to occur prior to August 15th to plan accordingly. 

Signing of harvest activities should be placed at trailheads, bulletin boards, and trail intersections to ensure public safety. 

The timber purchaser wsubmit a winter operatinDistrict staff would meet snowmobile trail staff to activity. Logging units orestricted between Deceunless a logical and dessnowmobile route is ideSnowmobile trails would improvements on timbeprotected during harvesSigning for public safety proposed action. 

14.3 

Thank you for the opportunity to comment and please feel free to contact the Black Hills Trails 

Office anytime at 584-3896, and thank you for the strong initiative to protect the health of the Black Hills National Forest. 

Statement of support 
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Environmental Assessment 

Appendix C: Past, Present and Reasonably 

Foreseeable Management Activities 
Cold Springs Project 

This page intentionally left blank. 
Appendix C. Past, Present and Reasonably Foreseeable ManageActivities The Cold Springs Project Area contains portions of five different grazing allotments and approximately 1,575 acres of primallotments are summarized in Table 1, and additional details follow. The project area contains 23 spring developments, 1 gu

reservoirs used in the management of livestock grazing. 

Table 1. Grazing allotments within the Cold Springs project area 

Allotment Name Total Size (Acres) Acres within the Project Area Proportion of Allotment within the Project Area 

Deadman 2,679 1,871 70% Griffith 5,705 4,953 87% Little Spearfish 9,180 1,340 15% Wildcat 17,099 895 5% Wolff 22,230 2,563 12% 

Deadman Allotment The Deadman Allotment is 2,679 acres in size. There are 1,871 acres of this allotment within the project area. Portions of 2 associated with the Deadman Allotment overlap the Cold Springs project area: the East Pasture and the West Pasture. There 

permittees that graze 159 cow/calf pairs from June 16 through October 1 in a 2-pasture deferred-rotation grazing system. Griffith Allotment The Griffith Allotment is 5,705 acres in size. There are 4,953 acres of the allotment within the project area. Portions of 5 se

associated with the Griffith Allotment overlap the project area: the East Yearling, West Yearling, Moses, Arnold, and Yellow Currently there is one permittee that grazes 140 cow/calf pairs and 60 yearlings from June 16 through October 15 in a 5-pa

grazing system. 
Little Spearfish Allotment The Little Spearfish Allotment is 9,180 acres in size. There are 1,340 acres of the allotment within the project area. Portion

associated with the Little Spearfish Allotment overlap the project area: the O’neil, Dry Gulch, Tornado, Valley, Shirley, and 

Currently there is one permittee that grazes 330 cow/calf pairs and 14 bulls from June 11 through September 30 in an 8-pas

grazing system. Wildcat Allotment The Wildcat Allotment is 17,100 acres in size. There are 895 acres of the allotment within the project area. The Clayton Pa

in this allotment that overlaps the Cold Springs project area. Currently there is one permittee that grazes 184 cow/calf pairs 

October 15 in a 3-pasture deferred-rotation grazing system. Wolff Allotment The Wolff Allotment consists of 22,230 acres. About 2,563 acres fall within the Cold Springs Project Area boundary. The C

the only pasture in this allotment that overlaps the Cold Springs project area. Currently there are two permittees that graze 

June 1 through October 15 in a 7-pasture deferred-rotation grazing system. Additional past, present and reasonably foreseeable activities within the project area and within a one-half-mile vicinity inc

 Powerline right-of-way maintenance  Travel management and road maintenance  Gravel extraction  Firewood cutting  Non-motorized recreation associated with the Eagle Cliff trail system  Motorized recreation including snowmobiles and ATVs  Dispersed recreation  Special use recreation: fly fishing, snowmobile trail use, Eagle Cliff trail use  Fire suppression  Noxious weed control: monitoring of noxious weeds, prevention and control measures.  Private land vegetation and fuel management 
Table 2 summarizes the area of past, planned, and on-going vegetation and fuel management activities within 1⁄2 mile of the 

Summarized treatments include: fuel treatments, commercial harvest, and non-commercial vegetation treatments. Treatmenthe year of accomplishment. The information was derived from the district FACTS (GIS) database. Table 2 includes the following commercial timber sales (contract award year): Beaver (1993), Big Mac (2001), Brahma (19

Elk Mountain, Geranium (2007), Hellsgate (1994), Hip (2011), Keough (1997), McInerny (2007), Mellow (1991), Merow 

Pond (1996), Power (1995, 2005), Power Pole (2006), Raddick (2010), Revell, Rifle (1992), Rifle Pit (2006), Short Draw, (1984), Yellow (1989), June, Deadman. 

Table 2. Summarized timber harvest, non-commercial vegetation treatments, and fuel treatments within one-half mile of the pr

Year 

Accomplished 

Fuel Treatments 

(Acres) Commercial Timber Treatments (Acres) Non-commercial Ve

Burn Pile Burn Misc Fuel Meadow Enhance Thin 

S W 

Estab 

& Seed 

Cut 

S W 

Removal Selection 

Hardwood 

Release 

San & 

Salv Special Tree Plant Site Prep TSI H

w

Re

FACTS 

Activity 

Codes 

1111, 1112, 

1113 

1130 

1152,1

153, 

1154, 1160, 

1180 

2400 4220, 4121 4131, 4194 4141, 4142, 4143 4151, 4152 4211 4230 4240 4441 4490, 4494 4511, 4521 6

1969 0 0 0 0 0 0 0 32 0 0 1977 0 0 0 0 0 0 0 19 0 0 1980 0 0 0 0 0 0 0 0 0 1981 0 0 0 0 0 0 0 0 0 1982 0 0 0 0 0 0 0 0 787 1983 0 0 0 0 0 0 0 0 824 1984 0 0 0 510 0 0 0 0 1,112 1985 38 0 0 106 0 0 0 30 0 100 1986 0 0 0 1,669 194 12 0 23 0 0 1987 0 0 0 212 0 0 0 25 0 0 1988 0 535 37 0 14 0 0 0 0 467 1989 0 0 56 1,335 267 25 115 295 0 224 1990 0 19 42 28 428 71 0 0 140 31 519 1991 0 201 0 0 0 363 0 0 161 317 
Year 

Accomplished 

Fuel Treatments 

(Acres) Commercial Timber Treatments (Acres) Non-commercial Ve

Burn Pile Burn Misc Fuel Meadow Enhance Thin 

S W 

Estab 

& Seed 

Cut 

S W 

Removal Selection 

Hardwood 

Release 

San & 

Salv Special Tree Plant Site Prep TSI H

w

Re

1992 0 110 0 22 754 877 65 0 28 45 580 1993 0 37 0 42 0 0 0 0 100 0 1994 0 0 0 0 0 0 0 0 0 1995 0 9 0 0 66 86 0 185 77 0 0 1996 0 0 0 360 149 29 397 27 0 26 1997 0 78 0 0 141 53 127 282 132 0 290 1998 0 0 0 322 169 0 0 521 0 80 1999 0 41 0 0 27 0 24 0 0 0 2000 0 2 0 0 0 0 0 0 0 197 2001 0 0 0 127 20 0 0 0 0 2002 0 0 62 147 11 56 51 0 39 2003 0 0 9 149 0 85 0 0 16 2004 215 0 0 41 133 65 0 0 349 2005 0 0 0 608 66 608 0 0 29 2006 0 34 0 156 1,587 279 1,282 0 0 657 2007 0 624 164 48 0 597 0 0 0 853 2008 0 284 224 0 356 163 0 0 67 0 516 2009 0 2,786 597 71 0 0 0 0 0 383 2010 0 14 6 0 0 0 0 0 0 1,002 2011 0 0 0 156 823 0 0 0 0 

Planned 8,357 603 475 400 2,880 172 677 0 14 240 7,591 

Grand 

Total 8,607 5,377 1,545 894 11,995 4,493 3,055 1,030 81 19 1,298 32 577 1,6958 
Environmental Assessment 

Appendix D: Silviculture Findings of Compliance 

with Laws, Regulations, and Policy 
Cold Springs Project 

This page intentionally left blank. 
Appendix D—1 

Appendix D. Silviculture Findings of Compliance 

with Laws, Regulations, and Policy 

Because this project involves vegetative management treatments, compliance with the timber 

harvest provisions of the National Forest Management Act (NFMA) is required. Additional 

information regarding compliance with NFMA can be found in the Cold Springs Forest 

Vegetation Report (Orlemann 2011), which is located in the Cold Springs project file. 

16 U.S.C. 1604 (g)(3)(E) 

Under 16 U.S.C. 1604 (g)(3)(E), a responsible official may authorize site-specific projects and 

activities on National Forest System (NFS) lands to harvest timber only where: 

1. Soil, slope, or other watershed conditions will not be irreversibly damaged (16 U.S.C. 

1604 (g)(3)(E)(i)). 

Response: Best management practices implemented in project design and contract initiation are 

effective in minimizing impacts to site productivity and conserving soil and water resources. 

These are discussed in the Soils and Hydrology report. Contract clauses will be used that 

implement best management practices, such as directional felling, designated skid trails, 

endlining, etc. There has been no finding of irreversible damage to soils, slopes, or other 

watershed conditions from proposed treatments. 

2. There is assurance that the lands can be adequately restocked within five years after final 

regeneration (16 U.S.C. 1604 (g)(3)(E)(ii)). 

Response: Research and experience indicate that the shelterwood method should be the primary 

regeneration method, and that it is ideally suited and widely applicable in the Black Hills. 

Restocking of lands in the Black Hills is generally abundant and prompt (Boldt and others 1983). 

Shelterwood removal cuts under this project are planned for stands that have abundant 

regeneration. 

3. Protection is provided for streams, streambanks, shorelines, lakes, wetlands, and other 

bodies of water from detrimental changes in water temperatures, blockages of water 

courses, and deposits of sediment where harvests are likely to seriously and adversely affect 

water conditions or fish habitat (16 U.S.C. 1604 (g)(3)(E)(iii)). 

Response: Analysis of the proposed action shows that effects to water quality and fish habitat 

would be negligible due to the implementation of the required best management practices. Best 

management practices provide protection for streams, streambanks, shorelines, lakes, wetlands, 

and other bodies of water. There has been no finding that project activities are likely to seriously 

and adversely affect water conditions or fish habitat through changes in water temperatures, 

blockages of water courses, or deposits of sediment. (See hydrologist specialist report.) 

4. The harvesting system to be used is not selected primarily because it will give the greatest 

dollar return or the greatest unit output of timber (16 U.S.C. 1604 (g)(3)(E)(iv)). 

Response: Proposed harvest systems for the Cold Springs Project include shelterwood (evenaged) and single-tree selection (uneven-aged) which are acceptable systems under the Forest Plan 

(II-25). Research and past experience has shown the shelterwood method to be the most reliable 
Appendix D—2 

in managing forest stands on the Black Hills (Shepperd and Battaglia 2002). The selection 

systems proposed are intended to meet habitat requirements, such as uneven-aged structures. In 

neither case has the system been chosen for the greatest dollar return or timber output. 

16 U.S.C. 1604 (g)(3)(F) 

Under 16 U.S.C. 1604 (g)(3)(F), a responsible official may authorize site-specific projects and 

activities on NFS lands using clearcutting, seed tree cutting, shelterwood cutting, and other cuts 

designed to regenerate an even-aged stand of timber as a cutting method only where: 

1. For clearcutting, it is determined to be the optimum method; for other methods it is 

determined to be appropriate and meets the objectives and requirements of the applicable 

land management plan (16 U.S.C. 1604 (g)(3)(F)(i)). 

Response: Shelterwood regeneration harvests are appropriate for meeting the objectives and 

requirements of the Black Hills Forest Plan. Shelterwood removals will be used as specified in 

the Black Hills FEIS, Phase II Amendment Chapter II, pg. 26. 

2. The interdisciplinary review has been completed and the potential environmental, 

biological, aesthetic, engineering, and economic impacts on each advertised sale area have 

been assessed, as well as the consistency of the sale with the multiple use of the general area 

(16 U.S.C. 1604 (g)(3)(F)(ii)). 

Response: The Cold Springs Environmental Assessment and decision notice constitute the 

interdisciplinary review of the potential environmental, biological, aesthetic, engineering, and 

economic impacts. The project is consistent with the multiple uses of the general area. 

3. Cut blocks, patches, or strips are shaped and blended to the extent practicable with the 

natural terrain (16 U.S.C. 1604 (g)(3)(F)(iii)). 

Response: The proposed treatment areas are located within the natural terrain features of the 

project area and generally follow natural stand boundaries. 

4. There are established according to geographic areas, forest types, or other suitable 

classifications the maximum size limits for areas to be cut in one harvest operation, 

including provision to exceed the established limits after appropriate public notice and 

review by the responsible Forest Service officer one level above the Forest Service officer 

who normally would approve the harvest proposal: Provided, that such limits shall not 

apply to the size of areas harvested because of natural catastrophic conditions such as fire, 

insect and disease attack, or windstorm (16 U.S.C. 1604 (g)(3)(F)(iv)). 

Response: Maximum size limits for areas to be treated with regeneration harvests are established 

by the Black Hills Forest Plan (Forest Plan II-17: Standard 2101). The Cold Springs proposed 

action does not include regeneration harvest that will create openings in excess of 40 acres. All 

areas proposed for shelterwood removal are fully stocked with pine regeneration and would not 

be considered openings; they would be considered structural stage 2 or 3 after treatment. 

5. Such cuts are carried out in a manner consistent with the protection of soil, watershed, 

fish, wildlife, recreation, and esthetic resources, and the regeneration of the timber resource 

(16 U.S.C. 1604 (g)(3)(F)(v)). 
Appendix D—3 

Response: The effects on each resource are disclosed in the Cold Springs Environmental 

Assessment and decision notice. Effects of implementing the regeneration harvests proposed by 

the project are consistent with the protection of soil, watershed, fish, wildlife, recreation, and 

esthetic resources, as well as the regeneration of the timber resource. 

16 U.S.C. 1604 (m) 

Under 16 U.S.C. 1604 (m), the Secretary shall establish: 

Standards to insure that, prior to harvest, stands of trees throughout the National Forest 

System shall generally have reached the culmination of mean annual increment of growth 

(calculated on the basis of cubic measurement or other methods of calculation at the 

discretion of the Secretary): Provided, That these standards shall not preclude the use of 

sound silvicultural practices, such as thinning or other stand improvement measures: 

Provided further, That these standards shall not preclude the Secretary from salvage or 

sanitation harvesting of timber stands which are substantially damaged by fire, windthrow 

or other catastrophe, or which are in imminent danger from insect or disease attack; and(16 

U.S.C. 1604 (m)(1)). 

[E]xceptions to these standards for the harvest of particular species of trees in management 

units after consideration has been given to the multiple uses of the forest including, but not 

limited to, recreation, wildlife habitat, and range and after completion of public 

participation processes utilizing the procedures of subsection (d) of this section (16 U.S.C. 

1604 (m)(2)). 

Response: Under the Black Hills Forest Plan, this requirement is met by ensuring that 

“[r]egeneration harvests of even-aged timber stands should not be undertaken until the stands 

have generally reached (or surpassed 95 percent of the) culmination of the mean annual increment 

measured in cubic feet.” (See, Forest Plan, II-26.) Moreover, the requirement does not apply to 

many of the treatments proposed for Cold Springs. For example, much of the thinning and 

hardwood release is excepted from the requirement because they are “sound silvicultural 

practices, such as thinning or other stand improvement” under 16 U.S.C. 1604(m)(1) or would 

meet Forest Plan multiple-use objectives to maintain landscape vegetation diversity under 16 

U.S.C. 1604(m)(2). In addition, none of the salvage or sanitation activities are included. 

Even-aged harvests, on the other hand, including clearcuts and shelterwood harvests are required 

to meet the culmination of the mean annual increment (CMAI) standard. It is the accepted 

practice in the forestry profession to apply the CMAI standard to the timing of the regeneration 

step of even-aged harvests. For a two-step shelterwood, the determination is made at the 

establishment step, and not the overstory removal step. In the case of Cold Springs, 33 stands, 

totaling approximately 1,200 acres, have been proposed for shelterwood establishment cutting. It 

is these treatments that must be checked for CMAI. 

Stand age at CMAI will vary depending on site quality, forest type, management intensities and 

utilization standards, but various analyses indicate that it generally will occur for most sawtimber 

stands in the Black Hills between 80 and 120 years, depending on site index. The applicable site 

index curves are found in Figure 1. Table 1 shows that all of the stands proposed for shelterwood 

establishment treatments have met the CMAI requirement. 

Appendix D—5 

Figure 1. Site index and mean annual increment curves for the Black Hills 
Appendix D—6 

Table 1. Stands proposed for shelterwood establishment as compared to 95 percent of the culmination of the 

mean annual increment 

Partition Stand Site Index 95% CMAI Stand Age Meets Requirement 

070503 142 62 85 120 y 

070505 48 68 80 84 y 

070505 50 64 85 116 y 

070505 78 66 80 100 y 

071205 4 66 80 137 y 

071205 14 70 80 101 y 

071301 29 70 80 121 y 

071301 49 69 80 108 y 

071301 98 60 85 116 y 

071302 15 59 85 115 y 

071302 21 55 100 138 y 

071302 43 60 85 114 y 

071303 28 63 85 85 y 

071304 33 48 100 117 y 

071304 54 66 80 98 y 

071304 65 69 80 104 y 

071304 68 68 80 121 y 

071304 70 65 85 113 y 

071304 73 65 85 103 y 

071304 97 61 85 117 y 

071304 98 75 80 98 y 

071305 4 62 85 111 y 

071305 5 64 85 118 y 

071305 9 54 100 125 y 

071305 12 65 85 115 y 

071305 17 57 85 119 y 

071305 19 64 85 128 y 

071305 24 54 100 117 y 

071306 18 54 100 123 y 

071306 57 66 80 120 y 

071306 72 63 85 96 y 

071308 43 57 85 104 y 

071308 60 52 100 112 y 
Environmental Assessment 

Appendix E: Silvicultural Stand Diagnosis—No 

Treatment Rationale 
Cold Springs Project 

This page intentionally left blank. 
Appendix E—1 

Appendix E. Silvicultural Stand Diagnosis—No 

Treatment Rationale1

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

070309 84 5.9 NT Marked for timber sale. 

070309 96 5.3 NT Rx Burn Marked for timber sale. 

070309 97 2.2 NT Rx Burn Marked for timber sale. 

070309 99 1.2 NT Rx Burn Marked for timber sale. 

070503 24 42.4 NT Not over stocked, no treatment needed. 

070503 25 42.8 NT Aspen, low insect risk rating. 

070503 27 14.7 NT Not over stocked, no treatment needed. 

070503 28 19.8 NT Not over stocked, no treatment needed. 

070503 29 25.1 NT Not over stocked, no treatment needed. 

070503 94 8.3 NT Not over stocked, no treatment needed. 

070503 95 27.2 NT Not over stocked, no treatment needed. 

070503 96 6.9 NT Not over stocked, no treatment needed. 

070503 99 22.2 NT Not over stocked, no treatment needed. 

070503 102 53.4 NT Not over stocked, no treatment needed. 

070503 103 47.9 NT Aspen, low insect risk rating. 

070503 111 5.1 NT Not over stocked, no treatment needed. 

070503 112 9.6 NT Not over stocked, no treatment needed. 

070503 113 2.8 NT Not over stocked, no treatment needed. 

070503 115 4.5 NT Not over stocked, no treatment needed. 

070503 116 14.0 NT Aspen, low insect risk rating. 

070503 127 19.2 NT Not over stocked, no treatment needed. 

070503 130 2.3 NT Recently treated. 

070503 132 5.7 NT Recently treated. 

070503 141 5.8 NT Recently treated. 

070503 143 5.7 NT Not over stocked, no treatment needed. 

070503 144 13.7 NT Not over stocked, no treatment needed. 

070503 145 10.3 NT Not over stocked, no treatment needed. 

070505 7 46.5 NT Not over stocked, no treatment needed. 

070505 8 31.2 NT Aspen, low insect risk rating. 

070505 9 18.5 NT Not over stocked, no treatment needed. 

070505 10 13.8 NT Not over stocked, no treatment needed. 

070505 11 11.5 NT Aspen, low insect risk rating. 

 

1

 Orlemann, Andrew. 2011. Cold Springs Vegetation Management Project Forest Vegetation Report. 

Unpublished report on file at: U.S. Department of Agriculture, Forest Service, Black Hills National Forest 

Northern Hills Ranger District Office, Spearfish, SD. 109 p. 

2

 NT, no commercial timber harvest planned 

3

 Rx Burn: broadcast prescribed burn 

4

 PCT: precommercial thin; AR: aspen release; WL TSI: wildlife timber stand improvement 
Appendix E—2 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

070505 16 17.8 NT Not over stocked, no treatment needed. 

070505 18 17.2 NT Not over stocked, no treatment needed. 

070505 46 22.8 NT Aspen, low insect risk rating. 

070505 47 10.4 NT Not over stocked, no treatment needed. 

070505 51 17.1 NT Eleven acres of this stand is TES5

 plant 

habitat. 

070505 54 26.2 NT Grass cover type. 

070505 55 26.5 NT Old pine along the highway, 70 percent 

hardwoods. 

070505 56 3.9 NT Small stand of old pine along the highway. 

070505 57 52.6 NT Aspen, low insect risk rating. 

070505 60 11.6 NT Not over stocked, no treatment needed. 

070505 61 6.1 NT Not over stocked, no treatment needed. 

070505 64 25.0 NT Aspen, low insect risk rating. 

070505 65 56.7 NT Not over stocked, no treatment needed. 

070505 66 19.4 NT Aspen, low insect risk rating. 

070505 67 30.4 NT Not over stocked, no treatment needed. 

070505 68 10.9 NT Not over stocked, no treatment needed. 

070505 70 14.1 NT Not over stocked, no treatment needed. 

070505 71 8.9 NT Not over stocked, no treatment needed. 

070505 73 32.3 NT Recently treated. 

070505 75 30.0 NT Not over stocked, no treatment needed. 

070505 76 31.8 NT Aspen, low insect risk rating. 

070505 80 11.5 NT Recently treated. 

070505 81 1.0 NT Aspen, low insect risk rating. 

070505 91 4.5 NT Recently treated. 

070505 93 9.3 NT Not over stocked, no treatment needed. 

070505 95 13.7 NT Not over stocked, no treatment needed. 

070505 96 27.9 NT Not over stocked, no treatment needed. 

070505 97 5.2 NT Aspen, low insect risk rating. 

070505 99 16.6 NT Aspen, low insect risk rating. 

071203 9 39.6 NT Not over stocked, no treatment needed. 

071203 32 6.1 NT Not over stocked, no treatment needed. 

071203 65 4.7 NT Not over stocked, no treatment needed. 

071205 2 47.9 NT Recently treated. 

071205 3 13.0 NT Not over stocked, no treatment needed. 

071205 5 24.4 NT 

Steep, rock ledges, site conditions and 

location prohibit tractor and skyline 

harvest operations. 

071205 6 12.8 NT Steep, rock ledges. Ten acres of this 

stand is TES plant habitat. 

071205 7 73.9 NT Not over stocked, no treatment needed. 

 

5

 TES: Threatened, endangered or Region 2 sensitive species 
Appendix E—3 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071205 16 15.9 NT Very steep, over highway, ski trail in it. 

071205 24 22.6 NT Grass cover type. 

071205 25 29.7 NT Very steep, over highway. 

071205 29 6.7 NT Grass cover type. 

071205 36 47.7 NT Recently treated. 

071205 37 7.5 NT Grass cover type. 

071205 38 32.1 NT Recently treated. 

071205 40 3.0 NT Grass cover type. 

071205 42 16.2 NT Not over stocked, no treatment needed. 

071205 44 23.1 NT 

Steep, ledgy. Stand has been identified as 

an important connective corridor for 

marten. Per Forest Plan Standard 3215, 

canopy closure of at least 50 percent is to 

be maintained. Stand conditions indicate 

that commercial treatment would not 

maintain 50 percent canopy closure (44% 

AMD6). 

071205 45 21.8 NT Recently treated. 

071205 55 19.9 NT Not over stocked, no treatment needed. 

071205 57 55.2 NT Recently treated. 

071205 81 18.4 NT Very steep, never treated, along highway. 

071205 82 6.2 NT Very steep, never treated, ski trail 

switchback. 

071205 83 3.5 NT Steep, rock ledges, no treatment needed 

(4A, 23% AMD). 

071206 1 10.5 NT Not over stocked, no treatment needed. 

071206 2 26.2 NT Recently treated. 

071206 3 28.5 NT Grass cover type. 

071206 6 17.6 NT Grass cover type. 

071206 7 3.9 NT Grass cover type. 

071206 8 17.5 NT Not over stocked, no treatment needed. 

071206 11 5.8 NT Not over stocked, no treatment needed. 

071206 12 17.8 NT Not over stocked, no treatment needed. 

071206 14 13.1 NT Not over stocked, no treatment needed. 

071206 27 15.7 NT Recently treated. 

071301 3 22.4 NT Not over stocked, no treatment needed. 

071301 7 7.0 NT Aspen, low insect risk rating. 

071301 8 9.5 NT Grass cover type. 

071301 11 17.6 NT Grass cover type. 

071301 12 35.5 NT Ninety percent hardwoods. 

071301 13 12.1 NT Recently treated. 

071301 14 6.6 NT Not over stocked, no treatment needed. 

071301 15 46.3 NT Recently treated. 

 

6

 AMD: average maximum density 
Appendix E—4 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071301 17 79.7 NT Recently treated. 

071301 18 7.8 NT Grass cover type. 

071301 21 20.5 NT Recently treated. 

071301 22 21.9 NT Recently treated. 

071301 23 35.0 NT Recently treated. 

071301 24 21.2 NT Recently treated. 

071301 25 13.3 NT Rx Burn Recently treated. 

071301 26 139.2 NT Recently treated. 

071301 27 28.7 NT Recently treated. 

071301 30 28.8 NT Recently treated. 

071301 32 7.4 NT Not over stocked, no treatment needed. 

071301 33 13.9 NT Recently treated. 

071301 34 30.2 NT Ninety percent hardwoods. 

071301 35 67.3 NT Recently treated. 

071301 36 21.7 NT Recently treated. 

071301 37 10.3 NT Grass cover type. 

071301 39 4.0 NT Grass cover type. 

071301 41 61.3 NT AR Recently treated. 

071301 44 5.3 NT Recently treated. 

071301 45 30.2 NT Not over stocked, no treatment needed. 

071301 47 5.7 NT Recently treated. 

071301 48 2.0 NT Not over stocked, no treatment needed. 

071301 50 12.4 NT Recently treated. 

071301 51 10.2 NT Recently treated. 

071301 52 41.3 NT Not over stocked, no treatment needed. 

071301 54 5.5 NT Aspen, low insect risk rating. 

071301 56 3.3 NT Not over stocked, no treatment needed. 

071301 57 1.3 NT Very small steep old pine. 

071301 75 9.9 NT Recently treated. 

071301 76 23.2 NT Not over stocked, no treatment needed. 

071301 78 49.4 NT Recently treated. 

071301 79 46.5 NT AR Not over stocked, no treatment needed. 

071301 80 15.1 NT Not over stocked, no treatment needed. 

071301 81 67.6 NT Recently treated. 

071301 82 82.6 NT Not over stocked, no treatment needed. 

071301 83 5.7 NT Aspen, low insect risk rating. 

071301 89 36.7 NT Not over stocked, no treatment needed. 

071301 90 37.6 NT Recently treated. 

071301 91 16.8 NT Recently treated. 

071301 93 1.7 NT Aspen, low insect risk rating. 

071301 94 2.4 NT Aspen, low insect risk rating. 

071301 96 8.7 NT Aspen, low insect risk rating. 
Appendix E—5 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071301 102 27.9 NT PCT Recently treated. 

071301 163 3.7 NT Recently treated. 

071301 165 21.6 NT Recently treated. 

071301 167 2.1 NT Not over stocked, no treatment needed. 

071301 169 7.6 NT Recently treated. 

071301 170 3.9 NT Grass cover type. 

071301 171 13.2 NT Recently treated. 

071301 172 9.4 NT Recently treated. 

071301 174 5.6 NT Aspen, low insect risk rating. 

071301 175 8.5 NT Not over stocked, no treatment needed. 

071302 1 63.4 NT Spruce cover type, marten corridor. 

071302 2 73.0 NT Recently treated. 

071302 3 5.2 NT Grass cover type. 

071302 8 140.8 NT Recently treated. 

071302 9 11.4 NT Not over stocked, no treatment needed. 

071302 13 42.2 NT Grass cover type. 

071302 14 24.1 NT Recently treated. 

071302 20 67.8 NT Spruce cover type, marten corridor. 

071302 22 28.3 NT Rx Burn Grass cover type. 

071302 23 6.1 NT Spruce cover type, marten corridor. 

071302 24 4.0 NT Grass cover type. 

071302 25 45.8 NT Not over stocked, no treatment needed. 

071302 26 17.1 NT Rx Burn Recently treated. 

071302 27 47.3 NT Not over stocked, no treatment needed. 

071302 28 5.7 NT Spruce cover type, marten corridor. 

071302 29 21.1 NT Recently treated. 

071302 31 106.2 NT AR Not over stocked, no treatment needed. 

071302 32 38.1 NT Not over stocked, no treatment needed. 

071302 33 141.0 NT Recently treated. 

071302 34 117.3 NT Not over stocked, no treatment needed. 

071302 35 11.8 NT Ninety percent hardwoods. 

071302 37 15.0 NT Spruce cover type, marten corridor. 

071302 38 79.2 NT Not over stocked, no treatment needed. 

071302 39 67.2 NT Recently treated. 

071302 42 24.8 NT Rx Burn Grass cover type. 

071302 44 50.5 NT Spruce cover type, marten corridor. 

071302 45 21.8 NT Grass cover type. 

071302 46 8.7 NT Rx Burn Not over stocked, no treatment needed. 

071302 49 59.7 NT Recently treated. 

071302 50 79.6 NT Recently treated. 

071302 51 13.3 NT Not over stocked, no treatment needed. 

071302 54 2.8 NT Grass cover type. 
Appendix E—6 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071302 62 10.7 NT Not over stocked, no treatment needed. 

071302 63 14.8 NT Recently treated. 

071302 64 25.5 NT Recently treated. 

071302 65 5.4 NT Not over stocked, no treatment needed. 

071302 66 1.0 NT One isolated acre; excluded from previous 

treatments. 

071302 67 5.0 NT Not over stocked, no treatment needed. 

071302 68 12.2 NT Recently treated. 

071302 70 46.0 NT Not over stocked, no treatment needed. 

071303 1 8.8 NT Recently treated. 

071303 2 9.3 NT WL TSI Spruce cover type, marten corridor. 

071303 3 10.0 NT Grass cover type. 

071303 4 26.9 NT Not over stocked, no treatment needed. 

071303 5 34.2 NT Recently treated. 

071303 8 4.9 NT Recently treated. 

071303 9 41.4 NT Recently treated. 

071303 13 63.9 NT Recently treated. 

071303 19 29.5 NT WL TSI Noncommercial goshawk habitat 

enhancement. 

071303 20 14.6 NT Recently treated. 

071303 21 28.7 NT WL TSI Noncommercial goshawk habitat 

enhancement. 

071303 22 29.3 NT Goshawk habitat stand. 

071303 23 33.4 NT Recently treated. 

071303 24 7.2 NT Grass cover type. 

071303 27 35.3 NT Recently treated. 

071303 29 48.8 NT Recently treated. 

071303 30 6.8 NT 

Small, steep stand. Stand has also been 

identified as an important connective 

corridor for marten. 

071303 31 50.7 NT Not over stocked, no treatment needed. 

071303 34 11.3 NT Recently treated. 

071303 35 2.6 NT Recently treated. 

071303 36 15.0 NT WL TSI Noncommercial goshawk habitat 

enhancement. 

071303 39 4.5 NT Recently treated. 

071303 40 2.8 NT Grass cover type. 

071303 41 14.0 NT Spruce cover type, marten corridor. 

071303 42 23.7 NT Not over stocked, no treatment needed. 

071303 43 4.5 NT Recently treated. 

071303 44 9.3 NT Goshawk habitat nest area. 

071303 45 6.9 NT Spruce cover type, marten corridor. 

071303 50 43.5 NT Rx Burn Grass cover type. 

071303 54 3.2 NT Grass cover type. 
Appendix E—7 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071303 55 26.9 NT Spruce cover type, marten corridor. 

071303 56 14.8 NT Spruce cover type, marten corridor. 

071303 61 1.3 NT Grass cover type. 

071303 62 2.9 NT Grass cover type. 

071303 74 1.2 NT One isolated acre; excluded from previous 

treatments. 

071303 76 0.7 NT One isolated acre; excluded from previous 

treatments. 

071303 77 1.1 NT One isolated acre; excluded from previous 

treatments. 

071303 80 7.2 NT Recently treated. 

071303 81 6.0 NT Spruce cover type, marten corridor. 

071303 82 14.7 NT Recently treated. 

071303 83 2.4 NT Not over stocked, no treatment needed. 

071303 84 1.1 NT Not over stocked, no treatment needed. 

071303 85 6.9 NT Recently treated. 

071304 15 6.6 NT Not over stocked, no treatment needed. 

071304 17 6.5 NT Recently treated. 

071304 18 17.4 NT Recently treated. 

071304 32 20.9 NT Recently treated. 

071304 36 57.2 NT Recently treated. 

071304 37 43.2 NT Rx Burn Grass cover type. 

071304 45 3.9 NT Not over stocked, no treatment needed. 

071304 50 15.3 NT Rx Burn Spruce cover type, marten corridor. 

071304 51 36.1 NT Recently treated. 

071304 55 22.5 NT Recently treated. 

071304 58 16.0 NT Recently treated. 

071304 61 47.1 NT Not over stocked, no treatment needed. 

071304 62 38.6 NT Recently treated. 

071304 63 7.8 NT Steep old pine. 

071304 66 12.6 NT Recently treated. 

071304 67 4.8 NT Not over stocked, no treatment needed. 

071304 71 6.2 NT Non-forest land. 

071304 72 25.3 NT Recently treated. 

071304 74 29.0 NT Recently treated. 

071304 83 3.8 NT Grass cover type. 

071304 84 20.0 NT Very steep; never treated. 

071304 85 6.8 NT Recently treated. 

071304 86 23.5 NT Grass cover type. 

071304 87 3.1 NT Recently treated. 

071304 88 4.4 NT Recently treated. 

071304 89 3.0 NT Rx Burn Small, steep stand, no treatment needed 

(SS1). 
Appendix E—8 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071304 90 17.1 NT Rx Burn Spruce cover type, marten corridor. 

071304 91 3.8 NT Rx Burn Not over stocked, no treatment needed. 

071304 93 6.8 NT Spruce cover type, marten corridor. 

071304 94 13.5 NT Rx Burn Grass cover type. 

071304 99 9.0 NT Six acres of this small stand is TES plant 

habitat 

071304 103 9.5 NT Recently treated. 

071304 104 2.2 NT Two acres, steep, rock ledges. 

071304 105 8.7 NT Recently treated. 

071305 1 73.8 NT Spruce cover type, marten corridor. 

071305 2 70.4 NT Steep, never been treated, TES plant 

habitat, logging inoperable. 

071305 3 8.7 NT Grass cover type. 

071305 6 83.5 NT Spruce cover type, marten corridor. 

071305 7 9.1 NT AR Spruce cover type, marten corridor. 

071305 8 70.4 NT Recently treated. 

071305 10 13.6 NT Grass cover type. 

071305 11 20.5 NT Not over stocked, no treatment needed. 

071305 13 36.1 NT Spruce cover type, marten corridor. 

071305 14 36.9 NT Not over stocked, no treatment needed. 

071305 16 16.1 NT Recently treated. 

071305 18 77.8 NT 

Stand has been identified as an important 

connective corridor for marten. Per Forest 

Plan Standard 3215, canopy closure of at 

least 50 percent is to be maintained. 

Stand conditions indicate that commercial 

treatment would not maintain 50 percent 

canopy closure, no treatment needed (4A, 

36% AMD) 

071305 20 6.7 NT Spruce cover type, marten corridor. 

071305 21 31.5 NT Spruce cover type, marten corridor. 

071305 22 4.9 NT Not over stocked, no treatment needed. 

071305 23 6.7 NT Not over stocked, no treatment needed. 

071305 25 3.6 NT AR Aspen, low insect risk rating. 

071306 2 18.1 NT Grass cover type. 

071306 10 32.6 NT 

Stand has been identified as an important 

connective corridor for marten. Per Forest 

Plan Standard 3215, canopy closure of at 

least 50 percent is to be maintained. 

Stand conditions indicate that commercial 

treatment would not maintain 50 percent 

canopy closure, no treatment needed (4A, 

34% AMD) 

071306 11 62.9 NT Spruce cover type, marten corridor. 

071306 12 8.9 NT Not over stocked, no treatment needed. 

071306 13 18.1 NT Not over stocked, no treatment needed. 

071306 14 25.2 NT Not over stocked, no treatment needed. 
Appendix E—9 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071306 15 39.5 NT Spruce cover type, marten corridor. 

071306 16 39.4 NT 

Stand has been identified as an important 

connective corridor for marten and 

provides habitat for late-successional 

dependent species. 

071306 17 34.0 NT Not over stocked, no treatment needed. 

071306 21 27.1 NT Very steep, never treated. Approximately 

8 acres of this stand is TES plant habitat. 

071306 38 80.6 NT Not over stocked, no treatment needed. 

071306 39 43.6 NT Steep, never treated, TES plant habitat, 

marten corridor. 

071306 40 40.5 NT Recently treated. 

071306 41 83.5 NT Very steep; never treated. 

071306 42 127.4 NT PCT Recently treated. 

071306 43 23.0 NT Recently treated. 

071306 44 94.9 NT Recently treated. 

071306 45 30.1 NT Recently treated. 

071306 46 20.2 NT Not over stocked, no treatment needed. 

071306 49 16.4 NT Recently treated. 

071306 56 10.2 NT 

Stand has been identified as an important 

connective corridor for marten. Per Forest 

Plan Standard 3215, canopy closure of at 

least 50 percent is to be maintained. 

Stand conditions indicate that commercial 

treatment would not maintain 50 percent 

canopy closure, no treatment needed (4A, 

22% AMD). 

071306 58 47.0 NT Spruce cover type, marten corridor. 

071306 59 15.1 NT Recently treated. 

071306 60 8.5 NT Grass cover type. 

071306 61 13.7 NT Grass cover type. 

071306 70 8.3 NT Spruce cover type, marten corridor. 

071306 73 3.4 NT Not over stocked, no treatment needed. 

071306 74 29.3 NT Very steep; never treated. 

071306 76 9.2 NT Not over stocked, no treatment needed. 

071306 78 2.0 NT Two acres, steep, rock ledges, inoperable. 

071306 85 1.4 NT Not over stocked, no treatment needed. 

071308 7 7.0 NT Spruce cover type, marten corridor. 

071308 9 5.1 NT Aspen, low insect risk rating. 

071308 10 18.1 NT Spruce cover type, marten corridor. 

071308 20 27.4 NT Aspen, low insect risk rating. 

071308 21 11.2 NT Spruce cover type, marten corridor. 

071308 25 8.1 NT Spruce cover type, marten corridor. 

071308 29 30.2 NT Not over stocked, no treatment needed. 

071308 40 31.0 NT Spruce cover type, marten corridor. 
Appendix E—10 

Partition Poly_ID Acres Proposed2 Fuels3 Other4 No Treatment Rationale 

071308 41 15.3 NT Recently treated. 

071308 42 75.6 NT Not over stocked, no treatment needed. 

071308 44 25.9 NT Spruce cover type, marten corridor. 

071308 45 15.2 NT AR Spruce cover type, marten corridor. 

071308 59 5.6 NT Spruce cover type, marten corridor. 
Environmental Assessment 

Appendix F: Maps 
Cold Springs Project 

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231.5

US-85

117.

27

1

9

209.1

117.7

232.1

134.1

189.4

189.2 183

267

231.5B

189.3G

117.7G

179.1

209.3C

267.1A

117.5W

631.1

209.3D

631.2C

232.2A

189.4B

209.2D

117.7E

419

209.2C

279.1D

267.1C

177.1A

117.7A

189.4F

117.7J

279.1A

189.2A

134.3A

117.6A

189.4C

177.1

631.2

554.1

268

232.2B

554.1A

179.1B

279.1B

117.7I

189.4A

231.5Q

554.1B

189.3C

117.6C

419.1A

117.5X

209.2G

189.4E

189.3D

555.1

267.1D

733.1A

189.2E

106.1G

200.1

209.2E

231.5O

279.1C

231.5G

117.7K

279.1F

231.5H

117.5Q

117.7H

232.2C

117.6D

231.5E

117.7F

631.1E

231.5P

209.2A

209.2L

209.3A

189.2B

231.5D

117.7C 189.3A

419.1B

631.1C

231.6A

179.1D

117.7B

631.1A

631.1B

209.3B

117.6B

279.1E

134.3H

231.5C

554.1C

231.5K

117.5Y

231.5N

209.2I

179.1C

209.2H

117.7D

209.3G

U100090

267.

1B

189.2D

209.3E

179.1A

209.2N

189.2F

231.5L

502.1E

233

U740062

U100006

209.3F

231.5I

134.3E

231.5R

183.1D

756.1

189.2

Cold Springs Project

Commercial Vegetation Treatments &

Proposed Transportation System

 ̄ 012 0.5 Miles

Legend

Project Area Boundary

Private Land

Transportation System

<all other values>

New Construction

Convert Existing Route to Forest Road System

Reconstruct or Maintain Existing System Road

Decommission Existing Route

Potential Temporary Road Location

Modified Proposed Action

Commercial Treatments

Aspen Release

Commercial Thinning

Single Tree Selection

Shelterwood Establishment

Shelterwood Preparation

Shelterwood Removal

Tinton Road
231.5

US-85

117.7

232.1

134.1

189.4

231.5B

117.7G

179.1

209.3C

63

232.2A

189.4B

117.7E

117.7A

117.7J

134.3A

554.1

232.2B

554.1A

179.1B

117.7I

231.5Q

554.1B

117.6C

189.4E

555.1

106.1G

200.1

231.5O

231.5G

117.7K

231.5H

117.7H

231.5E

117.7F

231.5P

231.5D

117.7C

631.1C

117.7B

134.3H

554.1C

231.5K

231.5N117.7D

179.1A

231.5L

209.3F

231.5I

134.3E

231.5R

756.1

Cold Springs Project

Non-Commercial Vegetation &

Fuel Treatments

 ̄ 012 0.5 Miles

Legend

Project Area Boundary

Private Land

Modified Proposed Action

Non-Commercial Treatments

Aspen Release

Pre-Commercial Thinning

Pre-Commercial Thinning & Aspen Release

Wildlife Timber Stand Improvement

Fuel Treatments

Pile & Burn

Broadcast Burn

Slash, Pile, and Burn
071301

071302

071304

071305

071306

070505

071303

071205

071206

070503

071308

071203

070309

231.5

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US-85

134

117.7

232 1.

189.4

183

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31.5

B

179.1

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209.3C

209.3D

232.2A

189.4B

631.1

209.2D

117.7E

2

6

7.1C

177.1A

117.7A

189.4F

117.7J

209.2C

134.3A

267.1A

267

232.2

B

554.1A

554.1

231.5G

179.1B

231.5Q

117.7I

554.1B

117.6C

189.4E

209.2G

267.1D

555.1

106.1G

209.2E

231.5O

17

7.1

200.1

117.7K

231.5H

232.2C

117.6D

117.7H

231.5E

189.4A

117.7F

231.5

P

631.1E

209.2L

189.4C

231.5D

209.3A

134.3H

117.7C

117.6A

631.1C

179.1D

231.6A

117.7B

631.1A

631.1B

117.6B

631.2F

209.3B

117.7D

231.5C

554.1C

231.5K

231.5N

209.2I

179.1C

209.2H

209.3G

209.3E

179.1A

209.2N

231.5L

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231.5I 231.5R

134.3E

756

5

9

4

5

4

14

10

16

29

19

24

5

6

8

17

7

35

72

30

23

92

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40

40

36

38

17

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31

28

39

15

23

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69

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82

92

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26

68

98

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78

57

79

58

21

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73

47

60

30

43

14 61

28

19

11

46

6

63

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84

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142

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20

54

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41

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88

52

100

12

12

32

57

59

52

94

70

49

98

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64

43

99 42

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77

92

60

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48

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10

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63

55

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36

102

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45

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50

42

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94

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91

89

Cold Springs Project

Proposed Vegetation Treatments by

Partition and Poly ID

 ̄ 0 0.3 0.6 1.2 Miles

Legend

Project Area Boundary

Private Land

Partition

Modified Proposed Action with Poly ID

Tinton Road
231.5

US-85

US-85

231.5

134

209

206

209

209

Cold Springs Project

Past and Planned

Commercial Timber Harvest

0 0.5 1 2 Miles

Legend

Project Area Boundary

Cold Springs 1.5 Mile Buffer

Private Land

Modified Proposed Action

Transportation System

Other

New Construction

Convert Existing Route to Forest Road System

Reconstruct or Maintain Existing System Road

Decommission Existing Route

Potential Temporary Road Location

Planned Commercial Timber Harvest

Fiscal Year of Decision

2005 - 2006

2007 - 2008

Accomplished Commercial Timber Harvest

Fiscal Year Accomplished

2001 - 2002

2003 - 2004

2005 - 2006

2007 - 2008

2009 - 2011

Tinton Road

 ̄
231.5

2

0

9

US-85

134

117.7

232 1.

189.4

18

3

117.1

2

31.5

B

179.1

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209.3C

209.3D

232.2A

189.4B

631.1

209.2D

117.7E

2

6

7.1C

177.1A

117.7A

189.4F

117.7J

209.2C

134.3A

267.1A

267

232.2

B

554.1A

554.1

231.5G

179.1B

231.5Q

117.7I

554.1B

117.6C

189.4E

209.2G

267.1D

555.1

106.1G

209.2E

231.5O

17

7.1

200.1

117.7K

231.5H

232.2C

117.6D

117.7H

2

31.5

E

189.4A

117.7F

231.5

P

631.1E

209.2L

189.4C

231.5D

209.3A

134.3H

117.7C

117.6A

631.1C

179.1D

231.6A

117.7B

631.1A

631.1B

117.6B

631.2F

209.3B

117.7D

231.5C

554.1C

231.5K

231.5N

209.2I

179.1C

209.2H

209.3G

209.3E

179.1A

209.2N

231.5L

209.3F

231.5I 231.5R

134.3E

183.1D

756

Cold Springs Project

Proposed Vegetation Treatments &

Habitat Structure Stage 5

 ̄ 0 0.25 0.5 1 Miles

Legend

Project Area Boundary

Private Land

Habitat Structure Stage 5

Modified Proposed Action Commercial Treatments

Modified Proposed Action Non-Commercial and Fuels Treatments

Tinton Road