Steamboat Project

Final Environmental Impact Statement

Appendix E

Response to Comments
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-2

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Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-3

List of Respondents to DEIS Comment Period 

Letter # Agency, Organization, Business, or Individual

1 Norma Kraemer

2 Marian Atkins, Bureau of Land Management, South Dakota Field Office

3 Robert Stewart, U.S. Department of the Interior, Office of Environmental Policy and Compliance

4 Dick Artley

5 Jeffrey Vonk, South Dakota Department of Game, Fish and Parks

6 Daryl Johnson, Lawrence County Commissioners

7 Suzanne Bohan, U.S. Environmental Protection Agency, Region 8

8 Carson Engelskirger, Black Hills Forest Resource Association

9 Mary Zimmerman

10 Paul Pierson, Neiman Timber Company

11 Nancy Hilding, Prairie Hills Audubon Society

12 Walt Bones, South Dakota Department of Agriculture
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-4

Respondent #1: Norma Kraemer

# Comment Comment Analysis and FS Response

1.1

Thank you for sending the Draft Environmental Impact Statement for the Steamboat Project 

that will be used to decide how to manage some of the Black Hills National Forest. It is good 

to note that previous comments submitted did help in modifying proposed actions.

Comment noted.

1.2

After reading through the various action plans of A, B, C and D we favor using the action plan 

C. Plan C includes treatment of the area in the land adjacent to our own property. We feel 

frustrated that we try to be good stewards of the land, but see neglect of the properties 

around us. The Kraemer family obtained this property in 1932, after Case 1 was ended and 

the Forest Service closed the Box Elder Ranger Station at this location. Attached is a picture 

of the property in 1935 showing a Steamboat Rock with scattered trees and beautiful rock 

formations for people to enjoy their beauty. It also would have been fairly easy to fight a 

forest fire on its slopes and pine beetles would have not been a major threat. 

Also attached is a photograph of Steamboat Rock today from approximately the same 

location as the 1935 picture. The building that housed the Forest Service office is gone and 

the only person in the picture still alive is Vern at the age of 94. As you can see, it is so 

densely overgrown with Ponderosa pine trees it is ripe for a lightning strike fire or pine 

beetles making it their home.

Comment noted.

1.3

The most important thing we feel these pictures illustrate is that the forest is truly a 

“renewable” resource. The Forest Service does not need to replant trees after an area has 

been logged. If anything, they could try to keep some of the millions of baby trees cut back 

in the early stages of forest regeneration to slow the process down. The area should not be 

treated as a “tree farm.” Fire suppression alone seems to encourage more trees growing 

than humans can keep up with managing. Because of all the inholdings of private land in the 

Black Hills National Forest you will always be tasked with keeping fires from growing into 

major disasters.

On many commercial harvest units, non-commercial 

thinning or prescribed burning is also proposed as a 

follow-up treatment. Regeneration surveys are 

conducted following the initial commercial 

treatment to determine if the level of regeneration is 

sufficient or, in some cases, too high. If excessive 

regeneration is observed, then the follow-up 

treatment(s) can be implemented to reduce the 

number of small trees on the site.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-5

1.4

More efforts should be focused on making a more diverse ecosystem with other tree species

and grasslands rather than more Ponderosa pine. This could possibly help in fire 

management by changing the whole dynamic back to a more open forest system as found 

when the Black Hills was invaded by Custer’s expedition of 1874. 

Creation of structural diversity is part of the purpose 

and need for the Steamboat Project. To meet that 

goal, treatments such as patch clearcut, group 

selection and individual tree selection are proposed 

to create open areas and a variety of age classes in 

forest stands. Aspen/birch and meadow 

enhancement are also proposed to maintain these 

areas, which act as natural fuel breaks and provide 

important wildlife habitat.

1.5

The area in the Steamboat Project is at great risk of looking like all the dead timber along 

Rochford Road, the Norbeck Preserve, Mount Rushmore, and Custer Peak, to name a few 

areas plague by beetles, unless the Forest Service takes action now. We were disappointed 

to see that so few people submitted comments about this project in your 1.06kg draft 

environmental impact statement. We doubt if Gifford Pinchot or Grover Cleveland ever 

envisioned draft environmental statements 100 years after they established the Black Hills 

Forest Preserve.

We would appreciate the Forest Service taking action to solve this problem in the near 

future and speed up the whole process. The beetles are not taking comments.

Comment noted.

Respondent #2: Marian Atkins, Bureau of Land Management

# Comment Comment Analysis and FS Response

2.1

The Bureau of Land Management appreciates the opportunity to review and provide 

comment regarding the Notice of Availability of a Draft Environmental Impact Statement 

(EIS) Steamboat Project, Black Hills National Forest, Northern Hills Ranger District; South 

Dakota (ER 11/0704) However, the BLM has no jurisdiction or authority with respect to the 

project, the agency does not have information relevant to the project, nor does the agency 

intend to submit comments regarding the project.

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-6

Respondent #3: Robert Stewart, U.S. Department of the Interior

# Comment Comment Analysis and FS Response

3.1

Page 32, paragraph 3: The document states that “The modified proposed action includes a 

variety of commercial and non-commercial vegetation treatments on approximately 12,336 

acres. Commercial treatments are proposed for approximately 10,048 acres.” We suggest 

the Final EIS describe the locations of the vegetation treatments so that it is possible to 

determine their effect on habitat connectivity and changes in sedimentation load into water 

bodies.

Maps showing the location of the proposed 

vegetation treatments for each alternative are 

included in Appendix A of the Steamboat EIS. 

Analysis of the effects of the proposed treatments on 

habitat connectivity and sedimentation into water 

bodies appears in the ‘Wildlife’ and ‘Hydrology and 

Soils’ sections of Chapter 3 of the EIS.

3.2

Page 33, paragraph 1, and Page 38, paragraph 4: The document states that “All newly 

constructed or converted roads would be closed following the completion of management 

activities...” We suggest the Final EIS describe proposed actions to return the newly 

constructed or converted roads into productive wildlife habitat. Will seeding to promote 

revegetation or other management treatments be applied to stabilize the route surface, 

reduce erosion and reduce the potential for colonization by invasive plants (see pages 101, 

and 131)? Page 101 states that “The method of closure would depend on site conditions and 

be determined at the time of closure.”

We suggest the document present the range of options under consideration so it is possible 

to determine the potential threat from invasive plants (page 131, paragraph 2; page 133, 

paragraph 2 and 5 and following), increases in sediment loading into streams, changes in 

wildlife corridors and habitat connectivity (Section 3). 

Section 3.9 (Transportation Network) of the 

Steamboat EIS states (DEIS, pg. 214):

“The roadway would be reseeded following 

disturbance and sediment basins would be 

constructed where necessary to catch run-off. 

Erosion may be decreased through the addition of 

aggregate surfacing or by placing rock in rolling dips. 

Additional measures to minimize impacts would be 

implemented using “Engineering Design Guidelines

and BMP.” 

The method of closure referred to in the EIS refers to 

the actual barrier that is placed at the beginning 

point of the road. Options include gates, rock 

barriers, felling of trees, and partial demolition of the 

roadbed. The method used would be determined at 

the time of closure depending on factors such as 

terrain and prevalence of unauthorized off-road 

vehicle use.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-7

3.3

Page 93, Section 3.4.3, General: We suggest the document include a description of the 

“Direct and Indirect Effects” to wildlife habitat from fragmentation and loss of habitat 

connectivity (see the reference above). We suggest the document address possible changes 

in the bird communities following “commercial and noncommercial treatment”. Silvicultural 

treatments imitating low-intensity disturbances are most effective in retaining bird 

communities associated with mature forest; high-intensity disturbances such as the twostory and modified clear-cut treatments greatly altered bird community composition 

(Chambers et al 2011). In stands where the tree canopy has been reduced, light and other 

resources increase and Hagar found greater cover of several shrubs and higher abundances 

of some species of shrub-associated birds (Hagar, 2011).

An analysis of the direct and indirect effects to 

habitat connectivity and fragmentation is included in 

the Wildlife and Fisheries Specialist Report and the 

Wildlife and Fisheries Biological Evaluation prepared 

for the Steamboat Project, which are summarized in 

Chapter 3 of the EIS. Both of those documents are 

located in the project file and available upon 

request.

The effects of the Steamboat alternatives on select 

bird species (i.e., Region 2 Sensitive Species, 

Management Indicator Species, Species of Local 

Concern, and Migratory Birds) are also presented in 

the Specialist Report and Biological Evaluation.

3.4

Page 98, paragraph 5: The document states that “Barriers to fish passage, such as 

impassable culverts at road-stream crossings and dams exist in the project area. These fish 

passage barriers reduce the ability of fish to colonize or reoccupy suitable habitat especially 

in an upstream direction, which may limit a species’ distribution over time without human 

intervention. The Steamboat Project would not cause additional incremental increase in 

these barriers and most existing barriers and road-stream crossings would be repaired.”

We suggest the Final EIS clarify whether the repair will remove the blockage to fish.

Repair of these barriers would remove the blockage 

to fish, making the stream passable once again. This 

clarification will be added to the FEIS.

3.5

Page 138, paragraph 2: The document references the USGS (2011) twice but the reference is 

missing from the list of references. The only USGS (2011) reference found on the reference 

list is the Breeding Bird Survey which does not include the information cited.

The USGS reference was erroneously ommitted from 

the DEIS and will appear in the FEIS. The reference is 

for a link to the the stream gauging station 

information discussed in the text.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-8

Respondent #4: Dick Artley

# Comment Comment Analysis and FS Response

4.1

I have reviewed the DEIS for the Steamboat project. Because you are the Responsible Official who will 

sign the ROD I ask you to seriously consider my comments and act on most of my suggestions and 

incorporate them into the final EIS.

Since the DEIS does not contain the email address for a drawer that contains electronic comments 

(which automatically tells the public that their comments have been received, please send me a short 

email indication that you have received these comments.

I’m sure you understand that some ground-disturbing projects in the forest cannot be redesigned or 

mitigated to eliminate natural resource damage. When faced with this dilemma a caring land 

manager would stop wasting taxpayer’s money and stop all further planning for the project. Selecting 

the “no-action” alternative is frowned on by USFS brass but it’s the American people who pay your 

salary.

This should occur regardless of the project’s good intentions portrayed in the Purpose and Need. Over 

90% of the members of the public who use their national forests do so for recreation. Please spend 

their tax money on projects that will improve their experience ... not the corporate financial bottomline.

I will show that based on best science, commercial logging is not the action that should be taken to 

maintain the health of the countless natural resources in the Steamboat project area.

Trees make up a miniscule percentage of these resources. All Forest Service proposed Actions should 

be designed to guarantee that there is no net gain in adverse effects to the countless natural 

resources of the project area after a project is implemented.

Maintaining the proper functioning of the critically important aquatic resources must be at the top of 

the list.

Indeed, the forest is much more than trees. Manipulating trees in the national forests is unjustified if 

the harvest damages other natural resources in the area.

Please be aware that actions that are consistent with the LRMP and contrary to law are still illegal.

Comments noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-9

4.2

In order for members of the public to form reasoned opinions about projects being proposed in their 

national forests they should be aware of both the advantages and disadvantages of implementing the 

project.

This DEIS describes only the Responsible Official’s perceived advantages of harvesting timber and 

constructing roads.

The scientific conclusion papers attached to these comments contain science quotes authored and 

signed by scientists that present a viewpoint that does not agree with 1) the authors of this DEIS 

and/or 2) the authors of the USFS employee-agency authored literature that is cited in the References 

section of this DEIS.

In order for the public to increase their awareness of the natural resource harm that will be caused by 

the Steamboat project please provide the public with access to the scientist’s opposing views by 

including their conclusion papers in an appendix to the final EIS.

After all, it is their land.

In some cases the resource harm discussed by these unbiased, independent scientists in their 

conclusion papers directly contradicts the literature compiled by USFS scientists listed in the 

References section in this DEIS. Please point this out to the public.

As long as these science contradictions are not reconciled before the project is implemented the 

natural resources owned by the public will be at risk.

The USFS science cited in the References section of this DEIS and the opposing science conclusions are 

diametrically opposed. They cannot both be correct for the same issue. The public deserves the truth.

Please describe the potential adverse ecological effects that this timber sale might cause in the final 

EIS. This will result in a better informed public.

Please allow me to repeat: when responding to the statements in the attachments and comments 

please do so legally according to 40 CFR 1503.4. Please respond to the quoted viewpoint, not the 

source document for the viewpoint.

Nothing requires the opposing views to be anything but “reasonable.” If the Responsible Official 

chooses to ignore them, then the Responsible Official must discuss why they are unreasonable.

The ecological effects, both positiive and 

negative, are presented in Chapter 3 of the 

Steamboat EIS and are also included in each 

of the specialist reports completed for the 

project, which are located in the project file 

and available upon request.

The commenter’s attached scientific 

conclusion papers are addressed below as 

they are referenced in other comments. 

The scientific conclusion papers themselves 

are located in the project file and are 

available upon request.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-10

Last I ask the Responsible Official to respond to the comments themselves ... not the source 

documents for the comments. This member of the public provided links to the source documents for 

the convenience of the Responsible Official so the might: 1) assure that the commenter did not makeup the comment and 2) to determine the context of the comment.

4.3

The majority of the American public does not want any timber harvest to occur in their national 

forests. Less than 5% of the wood fiber used in America comes from national forests. There is not a 

softwood shortage in America. The decades-old claim by the Forest Service that a timber famine is 

eminent has not materialized.

The Black Hills National Forest logs so much public land each year in just a few decades the entire 

non-wilderness portion of the forest will have been cut-over and roaded.

Comment and Question: In the FEIS please explain to the public (including pertinent references) how 

and why the Responsible Official has concluded that the public would rather have their forest 

managed like a logged-over private industrial tree farm than a forest with natural disturbance events.

All timber harvest could cease tomorrow in the national forests and the American public would never 

notice any change in the lumber availability.

Tree farms on private land generate more than enough wood fiber raw material to supply the 

domestic demand.

Harvesting of trees for timber production is 

never mentioned in the Steamboat EIS as 

part of the justification for the Steamboat 

Project. The stated purpose and need is to 

reduce mountain pine beetle risk, reduce 

fire hazard and provide structural diversity 

in big game winter range. This stated 

purpose and need is in line with the goals 

and objectives established in the Black Hills 

National Forest Land and Resource 

Management Plan as amended by Phase II 

(Forest Plan). The established timber 

industry in the Black Hills region provides a 

means of accomplishing the proposed

treatments to meet the purpose and need 

for the project.

Historic photos taken during the Custer 

Expedition to the Black Hills in the 1870s 

show that the forest was less densely 

stocked then that it is now, after nearly a 

century of active timber management and 

fire suppression. The Forest Plan, and the 

Steamboat Project, are focused on reducing 

tree density to reduce the Forest’s 

susceptibility to epidemic pine beetle 

infestations and high-intensity fire events 

while also providing a range of habitat 

conditions for native wildlife. In general, 

the residents of the Black Hills area are 

supportive of such efforts. 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-11

4.4

Please review Attachment #13 and decide if this massive timber sale is consistent with the public’s 

wishes contained in the 15 statistically significant polls. These polls represent people across the entire 

nation and of all political affiliations. Please assure that the final EIS contains the reason why the 

Responsible Official feels the proposed timber sale is consistent with these wishes of the public.

If the Responsible Official is aware of public polls showing that the public favors commercial timber 

harvest in national forests please identify the source of this information in the final EIS. If no such 

polls exist then please explain to the public why the Responsible Official is ignoring the will of the 

American citizens. Also please indicate in the final EIS why the Responsible Official believes that 

ignoring the will of the public is synonymous with serving them.

Indeed, “We are the experts and we know what’s best” is not an acceptable reason to ignore the 

wishes of the public. The members of the public concerned enough about their national forests to 

provide the agency with comments are not pesky outsiders attempting to interfere in Forest Service 

business.

The polls referenced in the comment do 

show support for preservation of forest 

lands. However, the majority of the polls 

referenced were conducted outside the 

Black Hills region and outside the current 

timeframe (largely in the late 1990s and 

early 2000s). The most applicable poll, 

which was conducted in the Rocky 

Mountain region in 2011, says nothing 

about timber harvest, it only asks “Should a 

person have to choose between a strong 

economy and clean air and water?” 

While no known polls have been conducted 

in the Black Hills area, several local news 

articles are located in the Steamboat 

project file that show strong support for 

combating the mountain pine beetle 

infestation in the Black Hills through active 

timber management.

The Steamboat Project has adhered to all 

federal laws and regulations regarding 

public involvement. See response to 

Comment 3.6 for details on the public 

involvement process for the Steamboat 

Project.

3.5 Attachment #1 contains 77 statements by independent scientists that discuss the natural resources 

that are harmed by commercial timber harvest regardless of the timber sale location in the forest.

Nowhere in the Steamboat EIS does it state 

that the proposed actions would be entirely 

beneficial, with no impacts whatsoever. 

The purpose of an EIS is to disclose the 

anticipated effects, both negative and 

positive, to the public. The Steamboat EIS 

does that; the anticipated effects of each of 

the alternatives are described in Chapter 3.

The statements presented in Attachment 1 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-12

are addressed individually in Appendix F.

4.6

The DEIS describes the importance of recreation in and near the sale area.

“Approximately 9.5 miles of the Centennial trail crosses the project area. Recreation features located 

in the project area include the Steamboat Rock picnic area and the Dalton Lake campground and 

adjacent trailhead, which provide access to the Centennial trail.” (Pg.10)

“The Steamboat project area is located near the cities of Sturgis and Rapid City, South Dakota and is 

immediately adjacent to the Interstate 90 corridor. Because of its location and the recreation 

opportunities present, it receives a significant amount of recreational use

throughout the year. The Dalton Lake campground and trailhead receives heavy use during the 

summer, especially during holidays or on weekends. The Centennial Trail is a popular destination, 

primarily for non-motorized recreation.” (Pg. 13)

The DEIS describes the direct, indirect and cumulative effects to recreation common to all action 

alternatives at pages 224 and 225:

“Timber sale activity to promote healthy forests would benefit developed recreation sites. Healthier 

forests are safer and provide a visually more appealing appearance for the visitor to enjoy.”

“These management activities would provide the same benefits for trails as listed above for the 

developed sites: healthier forests and reduced fire danger.”

Comment: The recreating public is not concerned about fuels or potential fire. They are concerned 

with their recreational experience.

“The Centennial trail would be minimally affected by any of the alternatives. Several proposed timber 

sale activities are located adjacent to the trail. The recreation staff would work with other Forest 

Service administrators to provide for safety near the trail. These activities would provide the same 

benefits as listed above for the developed sites.”

The commenter refers to the statements 

and conclusions in the recreation and 

scenery sections of the Steamboat EIS as 

“unsubstantiated and untrue”, but provides 

no evidence to back up that claim. Nor is 

there evidence presented to support the 

claims made by the commenter. Both the 

scenery report and the recreation report 

were completed by specialists with many 

years’ experience in their respective field 

and in the Black Hills specifically. Their 

conclusions are based on professional, firsthand knowledge. Without any evidence to 

refute their findings, the USFS has no 

credible reason to reanalyze the recreation 

or scenery sections.

The goal of the Steamboat Project is not to 

“stop the beetle” as implied in the 

comment. It is acknowledged in the 

Steamboat DEIS (pgs. 11-12) that mountain 

pine beetles are native to the Black Hills. 

The stated purpose and need (DEIS, pg. 24) 

is to reduce the risk of pine beetle 

infestation. In other words, the goal is to 

reduce the risk of an epidemic infestation 

that consumes all or most of the trees in a 

given area, not to totally eliminate the 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-13

“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, 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.”

The DEIS describes the direct effects to scenery common to all action alternatives at pages 232:

“Reducing soil disturbance, uneven spacing of the trees remaining in the landscape, and cleaning up 

the slash to natural levels can result in an appearance that is in harmony with the landscape 

character, often resulting in a higher SIO being achieved.”

“Overall, the variety of vegetation that would be enhanced at the stand level should be a very positive 

feature from a scenery standpoint.”

The DEIS describes the indirect effects to scenery common to all action alternatives at pages 237:

“Noxious weeds are generally recognized as non-natives and out-of-place in the landscape by the 

general public. As the quantity of these weeds increase in the landscape they out-compete native 

plants, resulting in a decrease in visual quality. Efforts are made to minimize this potential, so it is 

difficult to predict where and how wide spread this effect will be on the scenery.”

Comment: The average member of the recreating public has no idea what a noxious weed looks like.

“Thinning and reducing the overall density of ponderosa pine vegetation can lead to the amount of 

grasses, forbs, shrubs, and hardwoods increasing in the landscape. This could increase the variety of 

colors evident now, and in the future, across the landscape.”

“There is the potential for hardwoods to increase, creating a greater amount of fall color across the 

landscape as a result of the removal of conifers in fuel breaks that traverse hardwood stands; 

however, it would be limited to these corridors.”

These are all unsubstantiated and untrue statements indicative of a Responsible Official in denial and 

subordinate employees who are frightened and feel compelled to say anything to please the 

Responsible Official. Indeed, the timber sale will not result in improved recreation opportunities as 

the so-called specialist describe.

Any and all sociological surveys and research show that the vast majority of average Americans abhor 

potential for infestation altogether. Past 

treatments conducted on the Black Hills 

National Forest similar to those proposed in 

the Steamboat Project have proven to be 

effective in that regard (Schmid et al 1994).

The Steamboat Project was developed with 

public involvement, as required by NEPA. A 

scoping letter describing and soliciting 

comments on the proposed action was 

mailed to 423 interested parties on 

December 10, 2010. The Notice of Intent to 

prepare an EIS was published in the Federal 

Register on December 15, 2011. A news 

release announcing the scoping period was 

sent to local media on January 7, 2011. A 

public open house was held on January 12, 

2011 in Piedmont, South Dakota. None of 

the scoping comments received raised 

significant issues regarding scenery or 

recreation. 

After the DEIS was completed, it was mailed 

to every party that submitted scoping 

comments. A Notice of Availability and 

legal notice were published in the Federal 

Register and the Rapid City Journal 

respectively on August 12, 2011, beginning 

the 45-day comment period. A news 

release announcing the availability of the 

DEIS was issued on August 10, 2011. The 

DEIS was also available online and in 

hardcopy form to anyone wishing to receive 

it. The comments received on the DEIS are 

addressed in this appendix. 

No additional solicitation of public 

comments or opinions, beyond what has 

already been conducted, is required by law.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-14

commercial logging in their national forests.

Telling the public that the adverse effects to recreation are just “short-term” is not a reason to justify 

the adverse effects. To a recreationist, short term harm to their recreational experience is now!

Telling the public to go elsewhere is unacceptable to a family that has picnicked in the same favorite 

place for years.

In the final EIS please provide references and local survey data taken from recreationists supporting 

the previous statements that the timber sale and road construction will:

· “benefit developed recreation sites”,

· “provide a visually more appealing appearance for the visitor to enjoy”

· “the variety of vegetation that would be enhanced at the stand level should be a very positive 

feature from a scenery standpoint”

· “thinning and reducing the overall density of ponderosa pine vegetation can lead to the amount of 

grasses, forbs, shrubs, and hardwoods increasing in the landscape”.

IDT members Jones and Keegan should be ashamed. Their lies are so blatant and in-your-face that it’s 

clear that lying to the public is routine SOP to them.

Comment: At least 95% of the general public would be concerned by a USFS proposal that would 

damage their recreation opportunities. They don’t care about the perceived need to satisfy the 

objectives of a silviculturist trained in industrial forestry. Given the overwhelming majority of

Americans who dislike logging in their national forests this members of the public feels justified to 

claim that the recreation and scenery effects were contrived to justify the timber sale Let the people 

enjoy a real forest not a forest created by humans to satisfy financial objectives.

Comment and request: Clearly the Responsible Official will conjure up any untruth to sell this timber 

sale. Please rewrite these 2 sections for the FEIS. This time purge the lies.

Comments and requests: The public doesn’t want their recreational experience harmed by logging. In 

the final EIS please discuss why the Responsible Official believes that it’s more important to log the 

trees rather than let them fall and allow the biomass to replenish the forest ecosystem.

Please discuss why a natural disturbance event.

Please discuss how the logging has not stopped the beetle in the past and why the Responsible 

Official believes that this massive timber sale is different.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-15

Please randomly poll the recreating public with a fairly worded poll asking them if they favor logging 

the beetle-damaged pine trees knowing that logging will not stop the insect and the ecosystem 

benefits when the dead trees decompose in the woods.

I ask the Responsible Official to do this before releasing the final EIS so the poll data can be placed in 

the final EIS.

Please use competent employees to rewrite the scenery and recreation associated sections that will 

appear in the FEIS.

4.7

Its sad that so many Forest Service line-officers believe that commercial logging the public land is a 

cure-all for all forest issues ... real and perceived.

There are many scientific research papers that show why wildfire restores the forest far better than 

any human activity.

Please read and heed Attachment #8.

Once again, commercial logging creates more problems in the forested ecosystem than they might 

solve. A forest is more than merchantable conifer species.

The Steamboat DEIS makes no statement 

that fire does not play a role in maintaining 

healthy ecosystems. However, given the 

current fuel conditions and amount of WUI 

in the project area, and Black Hills as a 

whole, it is simply not feasible to allow 

naturally occurring fires to burn for 

resource benefits, as is done in some 

wilderness areas on other forests.

In lieu of natural fire, the Steamboat Project 

proposes up to 10,600 acres of prescribed 

fire, which is intended to mimic the effects 

ofnatural fire under controlled conditions 

that don’t threaten private property.

Individual responses to the statements 

made in Attachment 8 are provided in

Appendix F.

4.8

Its sad that so many Forest Service line-officers believe that commercial logging the public land is a 

cure-all for all forest issues ... real and perceived. In the past the USFS had fire specialists who knew 

their job. Now these USFS employees are called fuels specialists. They have been taught to tell the 

public that using commercial logging will protect their homes from wildfire damage.

This attitude is tragic when human lives and private property in the WUI are at risk.

Dr. Jack Cohen is a respected fire research scientist at the Forest Service’s Fire Sciences Laboratory in 

Missoula, Montana. After years of research Dr. Cohen developed recommendations that significantly 

reduce the risk of home damage by fire that are located in the WUI. Dr. Cohen’s work has been 

Attachment 11 detailing Dr. Cohen’s 

research was reviewed. The Steamboat 

DEIS does not refute Dr. Cohen’s findings or 

the assumptions underlying his models. 

However, the Steamboat DEIS was 

developed to adhere with Forest Plan 

direction regarding fuel reduction both 

inside and outside of the WUI. Per the 

Forest Plan, crown fire hazard is linked to 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-16

conveniently forgotten by agency decision-makers and specialists planning the Steamboat project.

An brief introduction to Dr. Cohen is at:

http://www.firelab.org/staff-directory/8

Please watch the short video #2 “Firewise Series: Why Homes Burn”

Source: http://wn.com/Jack_Cohen

Dr. Cohen is not bashful about accurately describing the issue:

“Vegetation management to prevent ignitions from radiation does not require extensive vegetation 

removal hundreds of meters from a structure. Our analysis indicated that 40 meters was sufficient for 

a 20 meter flame height.”

Exerpt Source: http://www.firewise.org/resources/files/WUI_HIR/Modelingpotentialignitions.pdf

“Extensive wildland vegetation management does not effectively change home ignitability.”

Exerpt Source: http://www.saveamericasforests.org/congress/Fire/Cohen.htm

“It may not be necessary or effective to treat fuels in adjacent areas in order to suppress fires before 

they reach homes; rather, it is the treatment of the fuels immediately proximate to the residences, 

and the degree to which the residential structures themselves can ignite

that determine if the residences are vulnerable.” (Pg.1999)

Exerpt Source: http://www.firewise.org/resources/files/WUI_HIR/fuel-treatment-reinhardt-et-al.pdf

Please consider the information contained in Attachment #11 which explains Dr. Cohen’s methods.

The ineffective treatments that the Responsible Official tells the public will reduce the risk of fire 

damage gives knowledgeable members of the public the impression that obtaining volume is more 

important to the Responsible Official than public WUI safety.

In the final EA please explain why Dr. Cohen’s recommendations are not being implemented to 

protect structures in the WUI.

The public deserves the best fire protection that the Responsible Official is able to provide.

Please implement Dr. Cohen’s recommendations to protect the structures in the WUI.

Dr. Cohen’s methods are applied quite near the structures at risk. Most elderly or handicapped 

structural stage. The Steamboat DEIS 

implements Forest Plan direction for 

reducing fire hazard by changing the 

structural stage of stands across the 

project area, including those stands 

adjacent to private property. Fuel 

reduction immediately adjacent to homes, 

in the narrow zone (100 to 200 feet from 

the structure) suggested by Dr. Cohen is 

largely the responsibility of the homeowner 

unless the structure is located on the edge 

of their property, near the NFS boundary.

Regardless of whether fire hazard is best 

reduced immediately adjacent to a 

structure (as Dr. Cohen suggests) or within 

a 1⁄2 mile WUI buffer (as directed by the 

Forest Plan), fire hazard reduction is not the 

only goal of the Steamboat Project. As 

stated in the purpose and need, the project 

also seeks to reduce mountain pine beetle 

risk and to create structural diversity in big 

game winter range. Many of the 

treatments proposed in the Steamboat 

action alternatives would be valid for 

meeting the purpose and need even if 

reduction of fire hazard were not a project 

goal. 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-17

landowners who cannot do the work themselves will gladly allow USFS employees to help on private 

land.

Please copy Dr. Cohen’s publications and give them to landowners in the WUI.

If the Responsible Official chooses to reduce fuels with commercial logging please attach a short 

paper to the publications explaining why the Forest Service will not use the most effective wildfire risk 

reduction tactics available. The landowner’s insurance company will also be interested.

4.9

A Federal Register notice and an opinion handed down in the Tenth Circuit Court of Appeals indicate 

that the Forest Service must base their projects on best science. Please see below.

“The purpose of this interpretative rule is to clarify that, both for projects implementing plans and 

plan amendments, paragraph (a)’s mandate to use the best available science applies.”

Source: Federal Register / Vol. 69, No. 188, page 58056

Wednesday, September 29, 2004

Rules and Regulations

http://www.fs.fed.us/r1//projects/plan_rule/intrpretative-rule.pdf

“The 1982 forest planning regulations at 36 C.F.R. Part 219 were superseded in November 2000, when 

new regulations were promulgated. 65 Fed. Reg. 67,568 (Nov. 9, 2000). Under the transition provision 

of the 2000 regulations, the Forest Service was required to consider the "best available science" when 

implementing site-specific projects within a forest plan. 36 C.F.R. 219.35(a) (2001).”

Source: The Ecology Center, Inc., v. United States Forest Service United States Court of Appeals, Tenth 

Circuit, June 29, 2006 An Appeal from the United States District Court for the District of Utah (D.C. No. 

2:03-CV-589-TS)

http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=search&case=/data2/circs/10th/054101.html

Clearly the attachments to this comment letter constitute “best science.”

If the Responsible Official does not believe that the science conclusions in the attachments are best 

science, please include best science that refutes the opposing views statements provide by this 

member of the public in the final EIS.

For decades Forest Service leaders have told the public that agency projects are based on and are 

consistent with best science. Please read and consider Attachment #15.

Please do not sully the word of these past Forest Service leaders by not using best science to drive the 

design of this project.

The specialists on the Steamboat 

interdisciplinary team (IDT) used the best 

science available to them, along with 

professional knowledge, experience and 

judgement, when analyzing the effects of 

the Steamboat Project. All science referred 

to or considered during analysis of the 

project is included in the References section 

of the EIS.

All of the attachments provided by the 

commenter were reviewed and the 

statements included therein are addressed 

either in this appendix or in separate 

documents specific to each attachment. 

The Steamboat Project adheres to the 2000 

planning rule regarding best available 

science. All references cited and 

considered during the analysis are included 

in the project file.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-18

In the final EIS please show the public that best science was used to design the project and include 

links to the specific science literature that was used. Including a long list of science literature in the 

References Section of the EIS that may or may not have been used is not what I’m requesting.

Also in the final EIS please provide reasons that the science statements in the attachments do not 

represent best science.

4.10

This DEIS indicates that this timber sale will restore multiple natural resources.

In the final EIS please insert text showing how resources that the Responsible Official claims will be 

restored will be damaged/degraded based on the following information. Withholding important 

information from the public is not nice.

Comment A: Frequently timber harvest removes dead and dying material from the site and inhibits 

the recruitment of downed woody material as time progresses.

Question A: Will this occur as a result of the timber sale activities?

Possible responses to question A:

· If the response to question A is no, please explain why.

· If the response to question A is yes, please explain how this contributes to forest restoration.

Page 43 of the Steamboat DEIS explains 

how activity fuels would be managed under 

any of the action alternatives. In general, 

slash resulting from harvest treatments 

would be left on-site, thereby contributing 

to the amount of coarse woody debris, 

except in WUI areas where it is desirable to 

reduce slash levels through either chipping 

or piling and burning.

Coarse woody debris provides an important 

habitat component for some wildlife 

species. It also retains nutrients on site and

reduces potential for soil erosion. In 

recognition of this, the Forest Plan includes 

Guideline 2307 and Standard 2308a, which 

call for leaving large woody debris on site. 

The Steamboat Project would adhere to this 

direction (Wildlife and Fisheries BE, pages 

52-56). 

4.11

Comment B: Frequently timber harvest increases edge effect and increases sunlight into stands, 

resulting from reduced canopy cover associated with timber harvest. This can directly promote the 

population abundance, productivity and persistence of insects which cause mortality to trees of 

(Roland, 1993; Rothman and Roland, 1998; Kouki, McCullough and Marshall, 1997; Bellinger, Ravlin 

and McManus, 1989).

Question B: Will this occur as a result of the timber sale activities?

Possible responses to question B:

· If the response to question B is no, please explain why.

· If the response to question B is yes, please explain how this contributes to forest restoration.

The primary insect of concern in the Black 

Hills is the mountain pine beetle. 

Treatments proposed in the Steamboat 

Project are designed to reduce the 

susceptibility of forest stands to pine beetle 

infestation (DEIS, pages 65, 70, and 73).
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-19

4.12

Comment C: Frequently timber harvest associated log landings, temporary roads, skid trails and 

skyline chutes are a source of sediment during precipitation events.

Question C: Will this occur as a result of the timber sale activities?

Possible responses to question C:

· If the response to question C is no, please explain why.

· If the response to question C is yes, please explain how this contributes to forest restoration.

There is the potential for increased 

sedimentation in the short-term. However, 

design criteria, Watershed Conservation 

Practices and Best Management Practices 

would reduce or eliminate that potential. 

In the long-term, repair of connected 

disturbed areas would reduce the level of 

sedimentation.

The effects of all proposed activities, 

including timber harvest and road building, 

on water resources are described in the 

Hydrology and Soils section of Chapter 3 of 

the DEIS (beginning on pg. 134).

4.13

Comment D: Frequently timber harvest reduces the organic parent material (duff and woody 

residues) available for soil-formation processes.

Question D: Will this occur as a result of the timber sale activities?

Possible responses to question D:

· If the response to question D is no, please explain why and indicate how it will be replaced.

· If the response to question D is yes, please explain how this contributes to forest restoration.

As described in response to Comment 4.11, 

the Steamboat Project would adhere to 

Forest Plan direction regarding coarse wood 

debris. 

The effects of all proposed activities on soils 

are described in the Hydrology and Soils 

section of Chapter 3 of the DEIS (beginning 

on pg. 134).

4.14

Comment E: Frequently timber harvest damages recreational opportunities and harms visual quality.

Question E: Will this occur as a result of the timber sale activities?

Possible responses to question E:

· If the response to question E is no, please explain how this serves the general public.

· If the response to question E is yes, please explain how this contributes to the public forest 

recreational experience enjoyed by millions of people.

No significant, long-term impacts to 

recreational opportunities are described in 

the Recreation analysis (DEIS, page220).

Silvicultural prescriptions were designed in 

certain stands with visual quality in mind. 

Design criteria are in place to reduce the 

visual impact of some treatments along 

frequently traveled routes (Appendix C).

The effects of the proposed activities on 

recreation and scenery are described in the 

appropriate sections of Chapter 3 of the 

DEIS (beginning on pgs. 220 and 226, 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-20

respectively).

4.15

Comment F: Frequently timber harvest adversely affects hydrologic processes by reducing canopy 

interception and evapotranspiration.

Timber harvest also decreases hydraulic conductivity and increases bulk density in forest soils after 

harvest. Finally, timber harvest collapses some of the subsurface pipes, increasing local pore water 

pressure and the chance of landslides. (Sidle, 1986)

Question F: Will this occur as a result of the timber sale activities?

Possible responses to question F:

· If the response to question F is no, please explain why.

· If the response to question F is yes, please explain how this contributes to forest restoration.

See response to Comment 4.12.

4.16

Comment G: Frequently timber harvest removes material that harbors a myriad of organisms, from 

bacteria and actinomycetes to higher fungi. These organisms play an important role in the forest. This 

damage cannot be mitigated.

Question G: Will this occur as a result of the timber sale activities?

Possible responses to question G:

· If the response to question G is no, please explain why.

· If the response to question G is yes, please explain how this contributes to forest restoration.

Effects to soil nutrients are discussed on 

pages 198-202 of the Steamboat DEIS. 

Many organisms are linked to coarse woody 

debris on the forest floor. The Steamboat 

Project meets Forest Plan direction for 

maintaining levels of coarse woody debris

(see response to Comment 4.10).

4.17

Topic H: Frequently timber harvest removes dead and dying trees which eliminates habitat required 

by bird species that feed on insects that attack living trees, with the result that outbreaks of pests 

may increase in size or frequency (Torgersen et al. 1990)

Question H: Will this occur as a result of the timber sale activities?

Possible responses to question H:

· If the response to question H is no, please explain why.

· If the response to question H is yes, please explain how this contributes to forest restoration.

Snags are protected through design criteria 

(DEIS, Appendix C; Wildlife and Fisheries 

Biological Evaluation, pages 31-34).

Effects to bird species are summarized in 

the Wildlife and Fisheries section of 

Chapter 3, beginning on pg. 86 of the DEIS. 

More detailed analysis is included in the 

Wildlife and Fisheries Specialist Report and 

the Wildlife and Fisheries Biological 

Evaluation, which are both located in the 

project file and available upon request.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-21

4.18

Comment I: Most forest roads have compacted surfaces that generate overland flow during 

precipitation events. Much of this flow often enters the channel system, locally increasing peak flows.

Question I: Will this occur as a result of the road construction activities?

Possible responses to question I:

· If the response to question I is no, please explain why.

· If the response to question I is yes, please explain how this contributes to forest restoration.

See response to Comment 4.12.

4.19

Comment J: Most forest roads fragment wildlife habitat. Forest roads also alter animal behavior by 

causing changes in home ranges, movement, reproductive success, and escape response. Forest road 

avoidance leads to underutilization of habitats that are otherwise high quality. Roads divide large 

landscapes into smaller patches and convert interior habitat into edge habitat.

Question J: Will this occur as a result of the road construction activities?

Possible responses to question J:

· If the response to question J is no, please explain why.

· If the response to question J is yes, please explain how this contributes to forest restoration.

The Black Hills is a heavily-roaded 

landscape. The additional roads proposed 

in Alternatives B and C are not expected to 

significantly impact wildlife (Wildlife 

Specialist Report and Biological Evaluation).

Effects of roads on wildlife species are 

analyzed in the Wildlife and Fisheries 

section of Chapter 3, beginning on pg. 86 of 

the DEIS. Moredetailed analysis is included 

in the Wildlife and Fisheries Specialist

Report and the Wildlife and Fisheries 

Biological Evaluation, which are both 

located in the project file and available 

upon request.

4.20

Comment K: Most forest roads increase the isolation of populations or species which causes adverse

wildlife genetic effects (i.e. inbreeding, depressed fertility/fecundity, and increased natal mortality) 

and decreased genetic diversity from genetic drift and bottlenecks.

Question K: Will this occur as a result of the road construction activities?

Possible responses to question K:

· If the response to question K is no, please explain why.

· If the response to question K is yes, please explain how this contributes to forest restoration.

See response to Comment 4.19.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-22

4.21

Comment L: Most forest road increases the likelihood of poaching, overhunting, overfishing, 

excessive trapping and passive harassment of animals.

Question L: Will this occur as a result of the road construction activities?

Possible responses to question M:

· If the response to question L is no, please explain why.

· If the response to question L is yes, please explain how this contributes to forest restoration.

This would be a concern for three species 

analyzed in the Wildlife Specialist Report: 

ruffed grouse, white-tailed deer and Rocky 

Mountain elk. It is acknowledged that new 

roads could increase disturbance to these 

species (DEIS, pages 110 and 113). 

Hunting is regulated by the South Dakota 

Department of Game, Fish and Parks 

(SDGFP). SDGFP sets harvest quotas for 

deer and elk in the Black Hills and enforces 

hunting regulations. It is impossible to 

predict how much poaching may occur or if 

new road construction would increase the 

level of poaching. Harvest numbers and 

enforcement of regulations is outside the 

scope of the Steamboat Project..

4.22

Comment M: Most forest roads adversely alter the subsurface hydrology of the area. They involve 

slope-cuts and ditching that is likely to intersect the water table and interrupt natural subsurface 

water movement.

Question M: Will this occur as a result of the road construction activities?

Possible responses to question M:

· If the response to question M is no, please explain why.

· If the response to question M is yes, please explain how this contributes to forest restoration.

See response to Comment 4.12.

4.23

Comment N: Most forest roads change the microclimate by altering temperature and moisture 

regimes. This adversely affects wildlife.

Question N: Will this occur as a result of the road construction activities?

Possible responses to question N:

· If the response to Question N is no, please explain why.

· If the response to Question N is yes, please explain how this contributes to forest restoration.

If the Responsible Official believes that the format suggested above is inconvenient and/or ineffective 

please display the same information in another way. Thank you for assisting the public to understand 

See response to Comment 4.19.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-23

this NEPA document.

4.24

Starting with the Bush administration and the infamous Mark Rey the Forest Service told the public 

that commercial timber sales would “restore” the forest.

Sadly, Forest Service employees are taught to use the terms “restoration” and “manage” as a 

synonyms for logging. Even some USFS lineofficers believe this myth.

To “restore” and to “manage” both mean to log. A “restored” and/or “managed” section of forest is a 

logged-over section of forest.

The correct dictionary definitions for the term “restoration” are shown below.

“1) the act of restoring or state of being restored, as to a former or original condition, place, etc.”

Source: Collins English dictionary

“1)the act of restoring; renewal, revival, or reestablishment.

2) the state or fact of being restored.

3) a return of something to a former, original, normal, or unimpaired condition.

4) restitution of something taken away or lost.”

Source: Dictionary.com

“1) the act of restoring something or someone to a satisfactory state”

Source: wordReference.com

“1) a putting or bringing back into a former, normal, or unimpaired state or condition”

Source: The American Heritage Dictionary

“2. The state of being restored; recovery of health”

Source: Dictionary.net

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-24

4.25

Comment: In order for a commercial timber sale to restore the forest, it must not inflict even shortterm natural resource harm. Indeed, commercial timber sales always (emphasis added) inflict some of 

the natural resource damage described below.

· inhibits the recruitment of downed woody material

· reduces structural complexity and age and size class diversity

· reduces population abundance and diversity of ants and a number of birds

· causes increased edge effect and increased sunlight into stands which negatively affects some 

wildlife species

· damages watershed functions

· imperils plant and animal species

· increases fire severity by removing large, fire- resistant trees and leaving behind very small trees and 

flammable "slash debris"--branches, twigs and needles from felled trees and decreases the forest 

canopy, creating hotter, drier conditions on the ground. The result?

Commercial logging (and thinning) to reduce fuels increases the rate of fire spread, intensity, and 

flame length

· is unlikely to improve fuel loadings significantly or alter potential fire behavior for the better

· reduces the organic parent material (duff and woody residues) available for soil-formation processes

· causes harm to the recreation and tourism industries because the public is displeased by stumps

· erodes topsoil, degrades water quality, destroys wildlife habitat, and extirpates species

· removes the larger trees that normally survive fires, leaves behind the trees that are most often 

killed by fire, increases flammable fuel loads, and worsens fire weather conditions

· affect hydrologic processes by reducing canopy interception and evapotranspiration

· decrease hydraulic conductivity and increase bulk density in forest soils

· disturbs the ponds, decreases amphibian populations in the areas that surround these vernal pools

· compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy

· introduces diseases and pests, wounds the trees left behind, and generally disrupts natural 

processes, including some that regulate forest health, all the more so if road construction is involved

· degrades increasingly rare and valuable wildlife habitat

· removes tree parts that would have created and maintained diversity in forest communities

· damages aquatic habitats through siltation, reduction in stream complexity and increased water 

temperatures

· changes the biological components of a stream, and has a direct and indirect on the physical 

environment in streams

· changes the pool/riffle ratios and cover, redistributes fishes, reduces fish numbers, and reduces total 

stream biomass

· reduces biodiversity

· increases sediment input to fish bearing streams

· alters streamflow regimes, increasing the likelihood of scouring flows and flooding

Nowhere does the Steamboat DEIS state 

that the actitivities proposed in the action 

alterantives would occur without impacts to 

some resources. The purpose of an 

environmental impact statement is to 

acknowledge that significant impacts may 

occur and to analyze those impacts so that 

the decision maker can make an informed 

decision weighing the costs and benefits of 

each alternative. 

All of the bulleted items in this comment 

are addressed in the effects analysis

presented in Chapter 3 of the Steamboat 

DEIS. It is acknowledged that some of the 

effects listed might occur, either in the 

short-term or long-term. The decision 

maker will decide if the potential impacts of 

the project outweigh the benefits. 

The term “restore” is never used in the 

Steamboat DEIS in the context suggested in 

this comment. The Steamboat DEIS never 

states that the goal of the project is to 

restore the forest to some previous state. 

The goal, as stated in the purpose and need 

(DEIS, pages 24-25) is to improve forest 

health by increasing structural diversity in 

big game winter range, reducing the risk of 

high intensity wildfire and reducing the risk 

of mountain pine beetle infestation. In 

achieving this goal, some negative impacts 

to various forest resources may occur, and 

those impacts are described in Chapter 3 

and will be considered by the decision 

maker before an alternative is selected.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-25

· is not a good job provider compared to recreation and tourism

· removes biomass critical to future soil productivity of the forest

· requires roads and skid trails which create chronic sources of sedimentation that degrades water 

quality and aquatic organism habitat

· disrupts nutrient cycling and flows

· changes water cycling and water balance in a drainage

· increases peak pipeflow

· increases local pore water pressure and the chance of landslides

In the final EIS please explain how logging the in the Steamboat sale restores the forest using the 

correct dictionary definitions for “restoration”

shown below:

“a return of something to a former, original, normal, or unimpaired condition”

“the act of restoring something or someone to a satisfactory state”

“a putting or bringing back into a former, normal, or unimpaired state or condition”

Given the multitude of likely adverse effects that are caused by logging described above please 

describe the “satisfactory state”, “former and normal state or condition” and “unimpaired state or 

condition” that the tree removal will reinstate.

When describing these states and conditions please include the countless natural resources besides 

conifer trees.

In the final EIS please omit any and all statements that say or infer that this project will restore the 

forest or improve forest health.

4.26

In spite of the clearly established aquatic resource damage caused by forest road construction on 

slopes greater than 20%, the Responsible Official proposes to build roads to make log extraction 

possible for this timber sale.

Comment: The bare earth exposed by all the road construction will generate sediment during 

precipitation events.

At the present time there is enough system road in the national forests of America to stretch to the 

moon and halfway back. No more should be constructed.

Constructing temporary road is not the answer!

Most Forest Service engineers know how temporary roads are located and constructed. Those who 

wish to keep the forest ecosystem functioning properly and are not afraid to speak the truth will 

The effects of roads, both temporary and 

permanent, are analyzed extensively in the 

Steamboat EIS. Based on scoping 

comments, road construction was identified 

as a significant issue that led to the 

development of Alternative D, which does 

not include any new road construction. 

The claim is not made in the Steamboat EIS 

that roads will not cause some negative 

impacts. Each resource section in Chapter 3 

of the EIS analyzes the impacts of roads, 

along with the positive and negative effects 

of the other proposed actions. The 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-26

argue against all road construction. This includes temporary roads.

Sometimes temporary roads create more sediment per mile during precipitation events than system 

roads. This is because:

1) Temp roads are "designed" by a logger on a cat with no knowledge of hydrology and the logger is 

under pressure to work quickly.

2) Most temp roads are outsloped, thus, the water on the road drains off the road at random places.

3) Temp roads have no surfacing to slow the water velocity. High water velocity picks up more 

sediment particles.

4) Temp roads have no ditch. Ditches adjacent to system roads control the water until the road 

designer calls for an appropriate outlet culvert location.

The forest service claims that temporary roads are ecosystem benign because these roads will be 

obliterated after use. Best science indicates otherwise.

There is literature available that explains why temporary roads represent a scar placed upon the 

landscape by humans wishing to manipulate the forest for corporate profit. One example of this 

literature is cited below. Please read and consider this paper.

“Temporary Roads are Like Low Fat Ice Cream” by George Wuerthner , 3-17-09. The link to this article 

is at:

http://www.newwest.net/topic/article/temporary_roads_are_like_low_fat_ice_cream/C564/L564/

Please drop all temporary road construction on this project. Causing this kind of ecosystem harm in 

order to please the timber industry does not serve the public.

Attachment #4 contains 54 statements by independent scientists that discuss the natural resources 

that are harmed (and some destroyed) by road-related work in the forest.

Responsible Official will review the analysis 

to determine if cost/benefit of any of the 

action alernatives exceeds that of not 

taking action.

The provided link to the Wuerthner article 

did not work. The website is down for 

maintenance.

The statements listed in Attachment 4 are 

addressed individually in Appendix F.

4.27

This timber sale is similar to the sales of the 1980s that the agency has tried so hard to put behind 

them. This timber sale is precisely what the USFS is telling the public what the USFS isn’t doing 

anymore.

Any Forest Service line-officer that cares about serving their public constituents would be eager to 

base their projects on the guidance suggested by Forest Service Associate Chief Sally Collins and 

Deputy Chief Jim Furnish.

“our focus today in the Forest Service is no longer on logging and road-building. In the last 5 years, for 

example, we decommissioned 14 miles of road for every mile of road added to our forest road system. 

None of these statements represent firm 

management direction in the form of laws 

or regulations. The management of the 

Black Hills National Forest is guided by the 

Forest Plan, which emphasizes active 

timber management to lessen the risk of 

high severity wildfires and mountain pine 

beetle infestations. The Steamboat Project 

implements the direction set forth in the 

Forest Plan and adheres to all of the 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-27

And where we do cut timber, it is usually a byproduct of forest health projects-like cutting 14-inch 

white fir to protect giant sequoia groves.”

from a speech by Forest Service Associate Chief Sally Collins

“Changing Public Land Uses: A Tale of Two Debates”

Outdoor Writers Association of America, 76th Annual Conference

Columbia, MO-June 17, 2003

http://www.fs.fed.us/news/2003/speeches/06/collins.shtml

“Post-World War II, we entered a new period characterized by timber production. From the 1960s to 

the 1980s, every administration, with strong congressional support, called for more timber harvest 

from the national forests, with the goal of replacing the depleted stocks of private and state timber as 

a result of the war effort. We measured success largely in terms of producing timber and providing 

multiple uses, including outdoor recreation and fish and wildlife.

In the early 1990s, that changed again. Today, we’re in a new period focused primarily on ecological 

restoration and recreation. Maybe more than ever before, we are focusing on delivering values and 

services like clean air and water, scenic beauty, habitat for wildlife, and opportunities for outdoor 

recreation. Not only do Americans want these things from their national forests, but this shift is also 

essential to cope with some huge threats to the sustainability of these forests.” (pp 8-9)

Forest Service Associate Chief Sally Collins

“The Future of Partnering with the Forest Service”

A speech presented at the Annual Meeting of the

National Association of Conservation Districts

Atlanta, GA—February 8, 2005

http://www.fs.fed.us/spf/coop/library/NACDspeech.pdf

“The agency was not bashful about pursuing aggressive timber harvesting for many decades, stopping 

only when required by lawsuits. And it should not be bashful about declaring - firmly and convincingly -

that those days are over. It is time to embrace conservation and lead the country into the 21st century 

with this vision in mind. Rather than asking for more discretion, the Forest Service needs to build trust 

with strong commitments and then keep them. Americans should look for something new-evidence of 

a fierce green fire, a passion for exemplary land stewardship. Secretary of Agriculture Tom Vilsack has 

spoken with urgency about restoring and protecting water and wildlife values, and the Forest Service 

needs to deliver the goods.”

Forest Service Deputy Chief Jim Furnish

applicable standards and guidelines.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-28

Overcoming 'timber-itch'

Published in the Miami Herald

May 25, 2011

http://www.miamiherald.com/2011/05/25/2233904/overcoming-timber-itch.html

Associate Chief Collins says: “Today, we’re in a new period focused primarily on ecological restoration 

and recreation.” Proposing to implement a timber sale of this magnitude is the antithesis of an action 

that restores the proper functioning of the natural resources and recreation in and downstream from 

the sale area.

In the final EIS please tell the public why this proposed timber sale is exempt from complying with 

these wise statements.

4.28

Old Forest Service herbicide approval EISs do not include recent research findings that contradict the 

earlier safety research used in the USFS herbicide approval documents. Most Forest Service safety 

research was done in 2003 and 2004 and documented in EISs in 2005 and 2006.

This research base for the Forest Service herbicide approval EISs was not done by agency scientists. 

The research was done by laboratories contracted and paid by the herbicide manufacturer. These 

research conclusions were then passed on to the Forest Service and formed the basis for the agency 

safety findings documented in EISs.

By far the most dangerous (and sometimes lethal) are herbicides containing glyphosate.

The recent research of hundreds of independent, unbiased Ph.D. scientists not affiliated with the US 

Forest Service or Monsanto Inc. reveals that even casual contact with glyphosate-containing 

herbicides causes the following maladies in birds, fish, and mammals (including human visitors to

the forest):

· birth defects

· non-Hodgkin’s lymphoma

· mitochondrial damage

· cell asphyxia

· miscarriages

· attention deficit disorder

· endocrine disruption

· DNA damage

· skin tumors

· thyroid damage

· hairy cell leukemia

Nowhere in the Steamboat EIS is the type of 

herbicide to be used for spraying noxious 

weeds identified. Nor is the purpose of the 

Steamboat EIS to analyze the physiological 

effects that different herbicides may have. 

The Black Hills National Forest Noxious 

Weed Management Plan calls for using only 

EPA-approved herbicides at their lowest 

effective rate. The plan also calls for using 

non-herbicide methods for weed control, 

such as hand-pulling, mowing or burning. 

The Steamboat EIS does not specify the 

type of treatment to be used for noxious 

weed control; that determination will be 

made at the time of implementation based 

on site-specific conditions.

The Northern Hill Ranger District does not 

use any of the herbicides listed in the 

comment. The primary herbicides used are 

Tordon and 2,4-D in upland areas and 

Milestone in areas near water.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-29

· Parkinson disease

· premature births

· decrease in the sperm count

· harm to the immune system in fish

· death of liver cells

· severe reproductive system disruptions

· chromosomal damage

Herbicides that contain glyphosate include:

Roundup Ultra®, Roundup Pro®, Accord®, Honcho®, Pondmaster®, Protocol®, Rascal®, Expedite®, 

Ranger®, Bronco®, Campain®, Landmaster®, and Fallow Master® manufactured by Monsanto;

Glyphomax® and Glypro® manufactured by Dow AgroSciences; Glyphosate herbicide manufactured by 

Du Pont; Silhouette® manufactured by Cenex/Land O’Lakes; Rattler® manufactured by Helena;

MirageR® manufactured by Platte; JuryR® manufactured by Riverside/Terra; and

Touchdown® manufactured by Zeneca.

As of November 2001, Rodeo® (previously manufactured by Monsanto) is now being manufactured by 

Dow AgroSciences and Monsanto is now producing Aquamaster®.

Certainly, noxious weeds and non-native plants are a major problem. In the final EA EIS please explain 

to the Forest Service is willing to risk inflicting the physical maladies rather than spending a little more 

money to treat the weeds without chemicals or with safe chemicals.

4.29

I have included an article describing recent research by unbiased, independent scientists below.

Why Is Damning New Evidence About Monsanto's Most Widely Used Herbicide Being Silenced?

It turns out that Monsanto's Roundup herbicide might not be nearly as safe as people have thought, 

but the media is staying mum on the revelation.

**NOTE**: Full article is omitted here, but was considered and is located in the project file.

There are alternatives to chemicals that are safe. In spite of the fact they cost more they are safer and 

provide employment for unskilled workers. Please use hand pulling and biological control.

Please consider the opposing scientific views in Attachment #9 and Attachment #18.

Noxious weeds are one of the major threats to the public land in the United States. Doing nothing is 

unacceptable. Taking the risk of causing the birth defects, non-Hodgkin’s lymphoma, mitochondrial 

See response to Comment 4.28.

The Northern Hills Ranger District does not 

use Roundup, nor do any of the herbicides 

used by the Northern Hills Ranger District 

contain glyphosate.

Analyzing whether or not to allow grazing is 

outside the scope of the Steamboat Project. 

Grazing in the allotments located in the 

Steamboat project area was approved 

under the 1997 Livestock Grazing 

Environmental Assessment.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-30

damage, cell asphyxia, miscarriages, attention deficit disorder, endocrine disruption, DNA damage, 

skin tumors, thyroid damage, hairy cell leukemia, Parkinson disease, premature births, decrease in the 

sperm count, harm to the immune system in fish, death of liver cells, severe reproductive system 

disruptions and chromosomal damage in forest wildlife and human visitors is also unacceptable.

Trillion dollar corporations like Monsanto exert undue influence on the US government. If a Monsanto 

executive can be hired to serve as the "senior advisor to the commissioner of the FDA, the same will 

happen in the USFS.

Source: http://www.grist.org/article/2009-07-08-monsanto-FDA-taylor

If you can prove this to be wrong please do so.

The decision to apply glyphosate to public land is like based on an outdated USFS NEPA document 

that approves these herbicides. In the final EIS please explain to the public why the Responsible 

Official prefers to trust dated science rather than new research conclusions that are displayed in 

Attachment #9.

Please treat the weeds with non-chemical eradication methods.

Its well known that livestock spread noxious weed seeds in their manure and fur. Please close all 

livestock allotments in or near the project area.

Please see Attachment #10

4.30

Clearly, this member of the public has established that commercial timber sales “restore” only one 

thing ................ the purchaser’s financial bottom line.

Indeed as Attachment #13 shows, the public does not want their national resources harmed by 

commercial timber sale activities. In the final EIS please include either 1) data that shows public 

acceptance of timber harvest in their public lands, or 2) a believable explanation of why this timber 

sale is important enough to ignore the will of the public ... and the laws of the United States.

Please think of the future generations of Americans. With more population there will be more reasons 

to preserve as much public land in an undeveloped state as possible. Unborn Americans will thank 

you if you do.

Please determine if the adverse harvest-related effects discussed in the scientific conclusions papers 

are likely to occur and display this determination in the final EIS. If the probable adverse ecological 

effect cannot be effectively mitigated please modify the timber sale such that the adverse effects 

See response to Comment 4.6 regarding 

public involvement in the development of 

the Steamboat Project.

Effects of each alternative, both beneficial 

and adverse, are discussed in Chapter 3 of 

the Steamboat EIS. No evidence is provided 

to support the claim the specific findings in 

the DEIS are “deceptive” or “untrue”. 

Analysis appearing in the DEIS was 

completed by experienced professionals in 

their respective fields.

Commercial timber harvest is one aspect of 

the Forest Service’s multiple-use mandate. 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-31

have no chance (emphasis added) of occurring.

Indeed, any harm to the forest’s natural resources is unacceptable in spite of the deceptive, untrue 

text supporting this project in the DEIS.

This DEIS follows the usual Forest Service script intended to show that agency-approved timber

harvest will benefit the natural resources in and near the project area ... which of course it will not.

Please think of the kids that will be born in 2050 when the population of the United States is 450 

million people. They will be desperate for an undeveloped refuge that gives them solitude. If this 

timber sale is implemented many acres will be eliminated from their refuge areas. In 2008 the Forest 

Service sold 162,090 commercial timber sales which accounted for 190,000 acres of logged-over and 

roaded national forest land.

This timber sale is being done in spite of the fact that over 70% of the adults in the United States 

don’t want their national forests logged.

In the final EIS please discuss why tree-farm style silvicultural RXs and timber volume are more 

important that complying with the wishes of the majority of Americans who recreate in national 

forests.

Commercial timber sales are not a cure-all. Commercial timber sales cause long-term ecological 

problems in the forest. The vast majority of unmanipulated national forest acres are in good shape 

and display splendid biodiversity and need no human help. The forests have been healthy for millions 

of years before chainsaws existed.

ANY (emphasis added) vegetative problem that the Responsible Official believes will be corrected by 

commercial logging is not an ecological problem at all. It’s a contrived excuse to prepare the stands 

for future logging that will maximize the purchaser’s revenues while at the same time producing 

volume that will help meet the RO’s expectations for timber outputs when the sale is offered. Its all 

about satisfying the natural resource extraction corporations.

Now ask yourself what percentage of the public want their forests commercially logged for ant 

reason. Ask yourself what percentage of the public is concerned about natural resource extraction 

corporation profits.

Finally, ask yourself who you are paid to serve.

Ranger Obyrne, are you a person who serves 307 million Americans, or a person who assumes the 

The Black Hills National Forest has been 

actively managed, on a sustained yield 

basis, since the early 1900s. Commercial 

timber harvest is a tool that resource 

managers can use to improve forest health 

conditions. Negative impacts from 

commercial timber harvest are possible, but 

positive impacts also occur. The deciding 

official will determine whether the balance 

of impacts favors implementing one of the 

action alternatives for the Steamboat 

Project. Additionally, commercial timber 

harvest provides funds to complete other 

project work, such as hardwood and 

meadow enhancement, stream restoration 

and monitoring activities.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-32

Respondent #5: Jeffrey Vonk, South Dakota Department of Game, Fish and Parks

# Comment Comment Analysis and FS Response

5.1

The Steamboat Project appears to be entirely within Management Area 5.4 (primary 

emphasis on Big Game Winter Range), which is an unusual circumstance for a landscape-scale 

project. We are very supportive that the purposes and needs of the project include providing 

structural diversity in big game winter range while also reducing the risk of conifer stands to 

mountain pine beetle (MPB) and high intensity wildfire. Recently there has been much debate 

and discussion that meeting some wildlife habitat objectives could be contrary to meeting the 

need to create amore resilient forest against MPB and fire. We are well aware of the urgency 

to treat for MPB and are responding to the same conditions on our lands. The DEIS appears to 

have been very carefully thought out and planned using local science. We support Modified 

Action B and offer the following suggestions for your consideration towards the FEIS/Decision.

Comment noted.

5.2

DEIS p. 34, 44, 61. For all hardwood treatments regardless of stand size (inclusion vs. tree 

cover classification), we suggest the FEIS include hinging to create aerial barriers to wild and 

domestic ungulates rather than removal of available, on-site material that is <9" dbh. It costs 

less per acre to hinge than to cut and slash. Hinging (or at a minimum cutting but not slashing) 

to best protect new shoots and give long-term hardwood enhancement has been 

demonstrated in the literature. Long-term protection simply cannot be met on a landscape 

scale without either costly fencing or less expensive hinging (Kota and Bartos. 2010). We 

reference successful practices in the Northern Hills District (V. Carlson. 2011).

Pages C-6 and C-7 of the Steamboat DEIS list design 

criteria applicable to aspen and birch stands under 

all action alternatives. Included in the design 

criteria is a provision for hinging aspen/birch.

5.3

DEIS p. 36-37: While fire is a stimulus, it has been our observation that timing of treatments

followed by prescribed fire sometimes negates the very effort to rejuvenate hardwoods and

unintentionally bums or heat-kills the regeneration. We suggest the FEIS design criteria 

include that larger hardwoods sites (> 1/4 acre) be assessed prior to prescribed burning to 

determine if fire will benefit regeneration or remove it and the protective hinged pine. Design 

criteria should also include a determination if post-fire protection from domestic and wild 

ungulates is warranted.

In general, hardwod stands do not burn as readily 

during a prescribed fire as surrounding pine stands 

due to higher moisture content. Fire that does 

carry through hardwoods is generally of a low 

intensity. In areas where it is identified as desirable 

to keep fire out of hardwoods, provisions are 

included in the prescribed burn plan for that 

specific unit.

role of a corporate lapdog to maintain your promotion possibilities in the agency?

Please implement everything described in the DEIS except commercial timber harvest and road 

construction.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-33

5.4

DEIS p. 35: Patch Clearcut is defined as removal of all conifer. We are unclear why the

definition further states that "non-commercial thinning may occur following commercial

treatment to maintain the stand and achieve desired conditions. Please clarify as it does not

coincide with the logical definition and that on p. 62.

Patch clearcut would result in the removal of all 

commercial conifers. Some non-commercial (less 

than 9 inches DBH) conifers could remain in the 

stand following the initial commercial entry. 

Therefore, non-commercial thinning is also 

proposed on those stands to allow for removal of 

some or all of those smaller diameter conifers if it is 

deemed necessary.

5.5

Alt. C (DEIS p. 40) proposes planting of ponderosa pine where natural regeneration is

insufficient in overstory removal sites. It seems unusual that pine is not regenerating under

established mature pine. It would be valuable to better understand what conditions do not 

allow for pine re-establishment. Because regeneration is prolific and MPB do not kill 

seedlings, we suggest planting is not necessary or desired for Black Hills ponderosa pine.

Along with the federal requirement for pine regeneration, Post-Sale Activities for Alt. B (DEIS

page 44) states that a potential exists for site preparation by scarifying to bare mineral soils. 

Scarifying should be discussed within the effects analysis and in the FEIS. Generally, this

treatment is unnecessary given the prolific pine regeneration in the Black Hills. We have seen

areas on BHNF where scarifying resulted in plowing native soils under a functioning pine

canopy which served to establish invasives and non-desirable vegetation. Soil disturbance at 

this ecological scale, beyond that which already occurs with harvesting equipment, should 

only be carried out after quantified surveys justify the need. Restocking surveys should weigh 

the desire to scarify against the ecological disturbances to native soils (often very thin 0 and A 

horizons) that harbor forbs, shrubs, sensitive plants, and functioning forest-floor processes.

Under Alternative C, planting was proposed for 

some stands following harvest because those 

stands were, under normal silvicultural conditions, 

not ready for harvest at this time. However, 

harvest was proposed in those stands to address 

the issue of mountain pine beetle risk that was 

raised during scoping. 

Regeneration surveys are conducted in the 3rd and 

5

th year following all overstory removal and patch 

clearcut treatments to assess the level of 

regeneration (DEIS, pg. 44). Typically, natural 

regeneration is sufficient without the necessity for 

additional measures. Scarification would only be 

conducted if the regeneration surveys showed a 

lack of natural regeneration on a site (DEIS, pg. 44).

5.6

DEIS p. 42 -43: Acreage for this treatment appears to be limited to 320 acres according to 

Allen (2010). The DEIS indicated that actual treatment design will be determined when greenhits are detected but we did not find treatment definitions for "thinning". Some types of

thinning, along with sanitation, could offer the opportunity to create and restore the dynamic 

patchiness of nonforested and forested communities which spatially move through time. The 

Black Hills is based on disturbance ecology and resilience. Sanitation treatments directly play 

a critical role. We suggest that the FEIS include design criteria for non-hit pine.

In order to maintain an economically viable sale, non-hits will probably be commercial-sized

trees wherein large diameter non-hit trees (> 16"dbh as defined in the BHNF Forest Plan) will

more than likely be removed. MPB' s are currently killing small and large diameter spruce and

pine. Historically, literature indicates older and/or large pines were susceptible to beetle kills.

While this is still true, creating conditions to protect large trees should not be ignored as they 

The sanitation harvest provision, as described in the 

Steamboat DEIS on pgs. 42-43, would allow for 

removal of beetle-hit trees along with thinning of 

surrounding non-hit trees, typically to a residual BA 

of under 80 to increase the stand’s resiliency to 

infestation.

Suggestions for treatments in sanitation stands are 

noted and will be considered.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-34

are a dwindling component across the landscape and clearly have some resilience in order to 

remain on the landscape today. Because silviculture prescriptions will be made at the time of 

treatment (in order to asses site-specific conditions, spatial arrangement and structural stage 

of pine, etc.), we suggest an adaptive management option to retain or leave a percentage of 

some large-diameter non-hits (individual tree selection) in order to meet Forest Plan direction 

for that structural stage. Residual large trees may be solitary or occur in small groups (such as 

3-5 boles) referred to as "genetic neighborhoods" (Egan et. al 2008) or cohorts. For cohorts, 

the prescription could require removal of adjacent pine at a sufficient spacing to reduce 

competition for limited resources, increase sunlight and air flow to the larger leave trees, 

reduce crown density between the cohort and other trees, and still achieve resilience to 

beetle attack. Cohorts of large trees can provide horizontal branches, overlapping crowns, 

and crevices in the bark critical to wildlife. These structures provide habitat components for 

goshawk, red squirrels, brown creepers, bats, roosting turkeys (SDCL classified as big game); 

they intercept snow for winter foraging opportunities for big game, and ecologically should be 

considered while removing common, over-abundant standard sized trees adjacent to these 

cohorts. Sanitation treatments not only offer the ability to quickly remove MPB-hits, but to be 

silviculturally creative to reduce pine densities in small patches with non-traditional options to 

achieve resiliency.

Non-hit trees with little commercial value which have broken tops or numerous large 

horizontal branches could be left for wildlife and then thin around these trees to provide 

resilience.

We suggest that the combined sanitation and thinning treatments utilize proactive measures 

for the future and thin from below the small-diameter (POL) trees and non-commercial to 

reduce competition for limited sun, water, nutrient, and spatial resources. This will create 

more vigorous stands at a lower BA that will remain resistant to MPB attack for a greater 

period of time.

To provide for some form of screening cover and visual obstruction for big game, sanitation 

and thinning prescriptions could include options for variable-spacing and variable-retention. 

As stated above, retention of non-hit cohorts provide great visual obstruction. Cohorts can 

reduce the risk of crown fire (Eagan et. a! 2008) when adjacent trees are removed.

Treatment options of green hit trees in in-operable areas should be mentioned in the FEIS. 

Our experience in Custer State Park with "cut and chunk" is that chunking is up to 80% 

effective in reducing the emergence of beetles. However, rolling the chunks can increase that 

effectiveness to 95-100%. It is logistically difficult both personnel and funding wise to roll the 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-35

chunks, but we suggest design criteria include mandatory rolling whenever possible.

5.7

DEIS (p. 139) identified 10 intermittent stream crossings as currently impassable to aquatic

vertebrates. Please contact our fisheries staff in the Rapid City office to assist in post-project

correction of culverts and restoration of stream habitat as previous audits have revealed 

culverts to cause a serious loss of aquatic habitat and contributed to un-necessary soil erosion 

and loss of stream banks.

Comment noted.

5.8

Overall, we support Modified Proposed Action B with the suggestions included above. Tables 

2-5 through 2-8 (DEIS p. 46-48) were most helpful. We support that understory thinning and 

SS5 were given greater consideration to meet Forest Plan direction for big game winter range.

Modified Action B had considerably less road reconstruction and construction as compared to 

C and we encourage closure at the end of the project. If there is additional need for thinning 

to create resilient stands, it appears that commercial thin and POL targets could be slightly

increased (DEIS p. 46. Table 2-5: Comparison of Activities.) where it is not required for big

game screening cover, elk summer thermal cover, or would negatively impact viability of

sensitive plants and SOLC (DEIS p. 116. Figure 3-7).

The Game, Fish, and Parks applauds the integration of non-traditional treatments such as 

group selection, individual tree selection, and patch clearcuts to maintain and/or increase 

both structural and vegetation diversity. These treatments could offer resiliency to pine 

against MPB, as compared to the traditional shelterwood cuts and overstory removal. We 

encourage monitoring to document efficacy. We support moving forward in finalizing the 

NEPA on this project so that immediate implementation can begin before the next beetle 

flight.

Comment noted.

Respondent #6: Daryl Johnson, Lawrence County Commissioners

# Comment Comment Analysis and FS Response

6.1

We would like to thank you and the Northern Hills District for your hard work on the

Steamboat Project. It is understood that these tough times put tremendous pressure on all

concerned. The USFS's decisions are becoming ever more critical to the continued good 

health of our forests. As we have witnessed repeatedly, areas left untreated are being 

deforested by the Mountain Pine Beetle. Even areas that are treated appropriately are at 

risk if they are in proximity to untreated areas that are infested or will become infested. 

Considering the high population of MPB currently in the Black Hills, these untreated areas 

remain at high risk.

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-36

The commission appreciates the USFS's efforts in developing Alternative C to address our 

concerns. Alternative C does treat many more acres than the proposed alternative.

It is important to critically evaluate the risks of not treating the most acres available. This

fact is very apparent based on what has happened to many other areas in the Black Hills that

have had treatments deferred for one reason or another.

6.2

Purpose and Need for Action

The USFS lists the following 3 purposes and needs for undertaking this project

1. Provide for Structural Diversity in Big Game Range

This area is designated for management as big game winter range. The current overstocking 

of conifers within the project area detracts from this management goal. There are many 

areas where conifers are over-growing hardwood stands. Alternative C treats the most acres 

and creates the largest amount of forest structure diversity and forage. This includes the 

construction of additional roads, which once are closed and grassed-in, will provide forage to 

elk and deer.

2. Reduce the Risk of High Intensity Wildfire

75% of the Project area is rated as high to very high fire hazard. This Project is located near 

Nemo. The area includes a significant number of private inholdings and homes. Moreover, 

this area is only 3 to 4 air miles southwest of large developments along the eastern slope of 

the Black Hills. Some of this area has been burned previously by the Ricco and Little Elk fire. 

Much of this previously burned area currently has heavy fuels loading on the ground. It is 

essential that the USFS reduce the risk as much as possible. Alternative C reduces the very 

high and high fire hazard from 75% to 18% of the project which is 44% better than 

alternative B.

3. Reduce the Risk of Mountain Pine Beetle

85% of the Ponderosa Pine stands have either a high to moderate risk of being infested and 

ultimately killed by MPB. This estimate may be understated based on the rampant

infestation rates witnessed throughout the Black Hills owing to the high bug population.

Stands that normally would not be infested are experiencing a high rate of mortality.

Alternative C reduces the high and moderate risk from 88% from to 23% which is 117%

greater reduction than alternative B (only 50%). Alternative C provides the opportunity for 

an increased rate of success in achieving the primary purpose of need for action in the 

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-37

project area.

6.3

Alternative C and Relation to Forest Plan Goals

Alternative Cis the best selection as it most effectively meets the five Forest Plan goals listed 

in the DEIS. Go all: Protect basic soil, air and water resources. With the implementation of

BMPs and proper harvesting and road building techniques, Alternative C would achieve this 

objective. Reducing the risk of a severe wildfire and MPB infestation will actually improve 

the potential of meeting this goal in the future.

Goal2: Provide for a variety of life through management of biological ecosystems.

This alternative creates the greatest amount of structural stage diversity. It also does

the most to protect biological diversity through time by reducing the risk of severe wildfire 

and MPB infestation.

Goal 3: Provide for sustained commodity uses in an environmentally acceptable manner. 

Alternative C produces significantly more timber than the other 2 action alternatives: 50% 

more than the USFS proposed Alternative B, and 112% more than Alternative D. The 

increased volume is important when considering the effects of the MPB in other areas of the 

BHNF. Please see accompanying economic analysis. In order to sustain the current industry 

infrastructure, the wood is going to have to come from somewhere, and it is going to be 

important that the USFS not miss meaningful opportunities to offer more timber.

Goal 4: Provide for scenic quality, a range of recreational opportunities and protection of 

heritage resources. Recreational opportunities are significantly diminished when forests are 

damaged or destroyed by wildfire and MPB. Alternative C reduces this risk the most, and 

meets the stated objective by reducing the risks of MPB infestation to given stands -

including the risk of severe wild fire, while also protecting at risk cultural resources.

Goal 10: Establish and maintain a mosaic of vegetation conditions to reduce the

occurrences of stand replacing fire and facilitate insect-and -disease and fire fighting 

capability adjacent to at risk communities, sensitive resources and non-federal land

generally across the Forest. Alternative C creates the greatest amount of structural diversity 

and allows for the greatest reduction in the risk of severe wildfire and MPB infestation. 

Furthermore, it allows management on an additional 6,540 acres by commercial thinning 

which otherwise would be excluded from action. This is a significant exclusion and limits the 

ability of the USFS to manage for the stated objectives. This omission should not be taken 

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-38

lightly. MPB or wildfire will destroy timber on these acres according to the USFS's own 

expert's best estimates and past history.

6.4

Full implementation of Alternative C would require 41 miles of new road construction and 10 

miles of non-system conversion. Since most of this Project area is considered suitable, and is 

supposed to be managed - now is the best time build roads for treatments, and any future 

management. It begs the question: If not now, when?

Designation as suitable timber base does not mean 

that a particular stand must be harvested at some 

point in time, only that it can be harvested if the 

management need arises. Roads will not be 

constructed for future timber management; only 

those roads necessary for treatments proposed 

under the Steamboat Project would be constructed.

6.5

The USFS should be mindful that the concern over new construction was the same concern 

raised in the Telegraph Project which led to the exclusion of treatments for significant 

amounts of acreage in the Hop Creek area. At the time, the county commission warned that 

this approach was not advisable due to the significant risk posed from MPB. Reviewing the 

Hop Creek area today shows that the late successional area contained therein, along with 

other forest structures, are now undergoing wholesale deforestation. While new roads 

would not have prevented the infestation from starting, it would have allowed considerably 

more of the area to be thinned and sanitized thereby reducing the potential for large scale 

deforestation.

Two primary differences exist between the 

Telegraph project area and Steamboat. First is that 

Telegraph was adjacent to an area of high beetle 

activity to the south and also had an area of high 

activity (Custer Peak) within its boundaries. The 

Steamboat area does not currently have a high level 

of beetle activity nor is it adjacent to a an area of 

high activity. The second difference is that the 

Steamboat project area is comprised entirely of Class 

III watersheds and has large areas of highly erosive 

soils. 

The USFS recognizes the concern of mountain pine 

beetle infestation, which is why Alternative C was 

created and fully analyzed.

6.6

The US FS raises the concern that the construction of new roads would permanently remove 

over 200 acres of habitat. We disagree with this assertion. It is important to note that 

Alternative B would result in a loss of about half this number of acres. So, there would be 

about 21 miles of impact difference between Alternatives B and C. Most of the roads will be 

constructed of native surface material, and will be closed to vehicle traffic during nonmanagement periods. These roads would grass-in and actually contribute to Structural Stage 

1.

It is impossible to say how long a road template may 

take to grass-in and blend back into the landscape. 

In the short-term, at least, there would be some loss 

of habitat due to road construction under both 

Alternatives B and C. 

Grassed in roads would not necessarily contribute to 

structural stage 1 because structural stage is 

determined on a stand level, and the roads would be 

crossing multiple stands, most of which would have a 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-39

timber cover type and would likely be in structural 

stage 3 or 4. 

6.7

The USFS also raises the concern that there will be increased soil erosion impacting fragile 

watersheds. Most all of the streams in this Project are ephemeral, and all of the proposed 

stream crossings will be over normally dry creek beds. In addition, the roads will be built 

under managed and supervised conditions following BMP and SMZ state recommendations. 

In the life of the road, the construction disturbance will only constitute a short duration. The 

USFS must consider the following point when evaluating the costs and benefits of managing 

the additional 6,500 acres: what is the economic and environmental cost of suppressing a 

severe wildfire or rehabbing an area deforested by mountain pine beetle?

The condition of streams (i.e., ephemeral vs. 

perrenial) and the implemenation of BMPs and 

project specific design criteria were all considered

during the analysis of the effects the Steamboat 

alternatives would have on soils. 

6.8

The USFS asserts that full implementation of Alternative C would require either a Forest

Plan Amendment or project specific forest plan amendment. We disagree. The Forest

Supervisor has given direction to the districts to consider long-term viability as an important 

goal to manage Goshawk habitat. It is suggested that the USFS consider a light thinning while 

maintaining the 4C structural stage to try to reduce the risk of MPB infestation, or at the 

least, insure that these stands are sanitized while treatments are being implemented nearby. 

It is obvious that leaving such stands without treatments, especially if they have any existing 

infestation, will in all likelihood, condemn them to be deforested.

Forest Plan Standard 3108 calls for maintaining or 

enhancing nesting habitat around known goshawks 

nests. The Biological Assessment/Biological 

Evaluation completed for the Phase II Amendment to 

the Forest Plan identifies suitable nesting habitat as 

structural stages 4B, 4C and 5. The commercial 

harvest treatments proposed in goshawk nest areas 

under Alternative C would reduce the structural 

stage below the 4B level, which would represent a 

violation of Standard 3108 (Steamboat Wildlife and 

Fisheries Biological Evaluation, pg. 48).

Alternatives B and D proposed a understory thin in 

the goshawk nest areas that would maintain the 

existing structural stage.

6.9

The USFS states that Alternative C has the largest difference in the cost benefit analysis.

There is disagreement with the USFS' s methodology analyzing the costs and benefits of the 

different alternatives. It is hard to understand that no consideration was given to either job 

creation or sustainability and economic impacts to local economies. The USFS also failed to 

compare the costs of cleanup from wildfire or MPB infestation among the alternatives. While 

it is true that the roads and sale prep will be more expensive for alternative C, the result of 

alternative C management is a significantly lower risk of wildfire and MPB infestation 

compared to alternative B which in turn lowers cleanup costs.

The additional 24.2 MMBF of sawtimber and 20,145 CCF of round wood is economically 

The economic analysis prestented in the Steamboat 

EIS is not intended to be a full evaluation of the 

project’s effect on the local economy. It is merely a 

comparison of the estimated costs and benefits (in 

purely monetary terms) incurred by the USFS while 

implementing each of the alternatives. This analysis 

is for comparative purposes only and is not meant to 

measure the impact of the project on job creation or 

the area’s overall economic well-being.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-40

significant. As job growth is vital to revitalizing our economy, choosing to not harvest this 

sawtimber volume (24.2 nunbf) represents a potential job loss of 84 full time sawmill 

employees, and about 50 contract loggers for an entire year. The executive director of 

Spearfish Economic Development has estimated the direct impact of the Spearfish Forest 

Products sawmill to the Spearfish economy at $46 million per year. The 24.2 million board 

feet represents 44% of the Spearfish Forest Products yearly production making the impact to 

the Spearfish economy around $20 million. In addition, the 20,145 ccf of POL would supply 

the local industry for 2 years worth of product and employ about 80 more workers. Since 

sustainability has been emphasized throughout this Project the long term job impact of 

including the 6,500 additional acres is the creation or maintenance of 60 jobs, directly and 

indirectly, over the next 20 years. Currently the Black Hills timber industry is made up of 

1,400 direct employment jobs. The secondary job creation has been estimated at 2 to 4 jobs 

for every primary job. The sum total of direct and indirect jobs is estimated to be 

approximately 5,600 jobs within the Black Hills area.

6.10

There is disagreement that Alternative B meets the objectives set forth in the county's

Community Wildfire Protection Plan (CWPP). There are two very important examples where 

the USFS's findings are in conflict with the Lawrence County (LC) CWPP. First, the USFS did 

not recognize the CWPP WUI structure buffers. USFS buffers are concentric one-half mile 

circle around structures that are the same regardless of terrain or fuel type. The CWPP onehalf mile structure buffers are based on terrain and fuel type which is believed to be more 

applicable to the on-the-ground conditions. The USFS identifies only 9,099 acres as onehalfmile structure buffers (one-half mile WUI) within the project boundary which is 1,641 

acres short of what Lawrence and Meade County have identified.

The USFS also allows for high and very high fire hazard within the one-half mile structure

WUIs. The CWPP recommends that there should be no high or very high fire hazard areas 

within the one-half mile WU!s. The USFS's alternative B retains areas- 37%- as high and very 

high fire hazard within the one-half mile WU!s, and 25% outside of the WU!s. Alternative C 

does a much better job at reducing the high and very high fire hazard to 14% of the WUI 

areas. The high and very hazard percentage - 25% - remains the same as in alternative B 

which indicates that most, if not all, of the treatments planned in Alternative Care within 

WUI zones.

The USFS asserts it is reducing the risk to some lands near or adjacent to "At-Risk

Communities" (ARC). It is hard to determine which communities (i.e. Nemo or Piedmont) are

referenced. Neither of these communities is sufficiently protected under the treatments 

proposed under Alternative B.

The structure buffers are based off of a 1⁄2 mile radius 

around all structures. However, when considering 

treatments in the WUI, the entirety of any stand 

falling within that radius was considered. For 

example, if there was a 100 acre RIS stand in which 

only 25 acres of the stand fell within the buffer, the 

entire 100 acres was actually considered as WUI for 

the purposes of designing treatments. Therefore, 

the actual area considered for WUI treatments was 

more than the 9,099 acres that fall within the 

structure buffers; the total area considered as WUI 

hazard areas was approximately 14,700 acres. A 

shapefile depicting all stands considered for WUI is 

located in the project file and available upon

request.

Forest Plan Objective10-01 calls for managing for 50-

75% low to moderate fire hazard in the WUI. Under 

Alternative B, 63% of the WUI acres would have a 

low to moderate fire hazard rating, which meets the 

objective.

The ARCs referred to are Nemo and Piedmont, as 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-41

The additional roads that are being proposed in Alternative C could provide very valuable 

access to areas where access is limited. Lack of access was the primary reason that the Ricco 

fire was not suppressed as a small fire.

identified on pg. 78 of the DEIS. Alternative B would 

reduce the fire hazard near these communities. No 

specific standards or objectives are identified in the 

Forest Plan for fire hazard in ARCs, but the ARCs 

overlap the WUI at least partially and Alternative B 

does reduce the fire hazard within the WUI as 

described above.

The comment on road access is noted.

6.11

It is further recommend that the USFS complete an analysis on the entire Project for

treatment so that if access across private lands can be gained, these areas could be 

managed. It is understood that the USFS desires permanent access; nonetheless, it is 

suggested that temporary access is better than no access, and that access is key to being 

able to efficiently manage some of the currently inaccessible areas which could reduce the 

cost of new road construction.

Alternative C was developed in response to the issue 

raised during scoping that the proposed action did 

not do enough to reduce mountain pine beetle raisk. 

Alternative C would treat a large majority of the 

stands within the project area. The stands that were 

left untreated were, for the most part, entirely 

inaccessible due to terrain or were not a viable 

candidate for treatment (e.g., meadows, Ricco burn 

area, etc.).

The Deputy Regional Forester explained the 

rationale for not pursuing temporary road 

easements in a letter to the Lawrence County 

Commissioners dated April 25, 2011. Only 

permanent easements will be pursued for the 

foreseeable future.

6.12

The implementation date of the Steamboat Project is planned for 2014 and 2015. Based on 

the current spread rate of MPB and the existing incipient infestations in the Steamboat 

Project area, the proposed timing will be too late to prevent wide-scale infestation. The USFS 

is urged to integrate sanitization treatments in the Project area until landscape treatments 

can take place. We believe that the BHNF Mountain Pine Beetle Response Plan could be a 

useful tool addressing this need, but two things have to happen as a prerequisite. First, the 

USFS has to agree to overlay the plan area over Steamboat. For some reason it was left out. 

Second, the USFS must implement the MPB Response Plan before the next flight.

The Steamboat project area was left out of the 

Mountain Pine Beetle Response Project (MPBR) 

because there is no need to reanalyze areas under 

MPBR that have already been analyzed under other 

NEPA projects such as Steamboat. Iit is likely that 

the Steamboat Project will be implemented before 

MPBR. The timing of MPBR implementation is 

outside the scope of the Steamboat Project.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-42

6.13

Again, please know that the county commission values the opportunity to offer project

comments. A great deal of time and effort is expended in the county's review process of 

projects. Much valuable input is contained herein. This input is from individuals with 

expertise in various disciplines related to forest management and fire protection, and 

represents the collective experience of those who live and work in the BHNF on a daily basis.

Comment noted.

Respondent #7: Suzanne Bohan, U.S. Environmental Protection Agency, Region 8

# Comment Comment Analysis and FS Response

7.1

In accordance with our responsibilities under the National Environmental Policy Act (NEPA), 

42 U.S.C. Section 4321, et seq., and Section 309 of the Clean Air Act (CAA), 42U.S.C. Section 

7609, the U.S. Environmental Protection Agency Region 8 (EPA) has reviewed the August 

2011 Draft Environmental Impact Statement (DEIS) for the Steamboat Project. This DEIS was 

prepared by the Northern Hills Ranger District of the U.S. Department of Agriculture Forest 

Service (USFS) Black Hills National Forest to analyze potential environmental impacts 

associated with proposed vegetation and fuels treatments to provide structural diversity in 

big game winter range and to reduce the risk of mountain pine beetle (MPB) infestations and 

high severity wildfire.

The Steamboat Project Area is located northwest of Rapid City between the towns of Nemo 

and Piedmont, South Dakota, and consists of 24,596 acres, including 21,833 acres of USFS 

lands and 2,713 acres of interspersed private lands. The No Action alternative (Alternative A) 

and three action alternatives are analyzed in the Steamboat Project DEIS. At this time, the 

USFS has not identified a preferred alternative. Briefly, the action alternatives include the 

following:

• Alternative B (Proposed Action)- 12,336 acres of vegetation treatments; 10,608 acres of

prescribed burning; and 20 miles of new roads;

• Alternative C (developed in response to concerns with MPB infestation) - 18,049 acres of

vegetation treatments; 10,608 acres of prescribed burning; and 41 miles of new roads; and

• Alternative D (developed in response to concerns with new road construction) - 9,394 

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-43

acres of vegetation treatments; 10,608 acres of prescribed burning; and no new roads.

In a January 12, 2011 letter, EPA provided scoping comments for this project. We appreciate 

that the USFS addressed many of our comments in the DEIS. As a result, our concerns with 

the August 2011 DEIS have been narrowed to two main issues: (1) aquatic resources and (2) 

air quality.

7.2

1) Aquatic resources impacts should be more fully mitigated and monitored.

EPA considers protection of aquatic resources to be among the most critical issues to be 

addressed in any NEPA analysis for vegetation management activities. Most activities 

contemplated under the proposed action alternatives (e.g., thinning, prescribed fire, road 

construction) have the potential to adversely impact aquatic resources, including surface and 

ground waters, wetlands, streams, riparian areas, and their supporting hydrology. Generally, 

the DEIS provides a thorough characterization of existing aquatic resource conditions and 

potential impacts from project activities. However, given the potential for aquatic resource 

impacts, we recommend that USFS expand its analyses in the following areas in order to fully 

evaluate and mitigate impacts.

Impact of Roads on Aquatic Resources: We support the DEIS design criteria related to new 

road construction and restoration of stream crossings. As the DEIS notes, these measures 

should reduce impacts from new roads and should help reduce the number of current 

Connected Disturbed Areas. To further reduce impacts, EPA recommends utilizing existing 

roads to the greatest extent possible and limiting the number/density of new roads as well 

as locating roads to limit impacts to surface waters.

The Steamboat Project action alternatives propose varying degrees of new road construction 

(Alternative B - 20 miles, Alternative C - 41 miles, and Alternative D - 0 miles) to facilitate 

treatment activities. As a result, Alternative D would have the least impact on aquatic 

resources. The DEIS notes that all roads constructed under Alternatives B and C would be 

closed following project activities, unless identified for inclusion on the motorized vehicle 

use map of the Forest-wide travel management plan. Since it would be difficult to ensure 

complete closure of these roads and long-term environmental impacts may result, EPA 

recommends developing a monitoring plan and schedule to assess road closure 

effectiveness.

The road network required for each action 

alternative is primarily comprised of existing roads. 

Alternatives B, C and D would include 75 miles, 81 

miles, and 70 miles of road maintenance, 

respecitvely. The entirety of that mileage is on 

existing National Forest System (NFS) routes. In 

addition, each action alternative would use between 

4 and 10 miles of existing non-NFS routes (DEIS, pg. 

46, Table 2-5). All new roads would be located to 

reduce the impact to waterways (DEIS, Appendix C, 

pgs. C-11 and C-12).

Closed roads are patrolled/monitored on a regular 

basis to determine if unauthorized use is occurring.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-44

7.3

Impacts to Water Resources from Chemical Applications: The DEIS notes that the action 

alternatives include activities that require the usc of chemicals, pathogens, or pesticides, but 

Forest Plan standards and Best Management Practices (BMPs) would be employed to reduce 

the risk to water quality. It would be helpful if these standards and/or BMPs were 

summarized in Appendix C, Design Criteria and Monitoring. We support measures, such as 

avoidance of spraying on windy or rainy days, to ensure that application procedures do not 

contribute to potential adverse health and environmental impacts associated with drift of 

chemicals to aquatic areas or other sensitive habitats. Also, procedures for the handling of 

chemicals should be carefully designed since, depending on the chemical, there may not be

threshold limits for accidental spills into a waterbody. Finally, to ensure protection of the 

health of domestic, agricultural, and recreational water users and of the aquatic ecosystem, 

we recommend developing an aquatic monitoring plan to assess any adverse impacts to 

water quality resulting from aqueous transport of hazardous substances.

The full text of the Forest Plan standards and BMPs 

was not included in Appendix C to in an effort to 

reduce the length of the document as much as 

possible. A complete list of standards and 

guidelines, BMPs and other guiding direction is 

located in the Steamboat project file.

Procedures for chemical application are outlined and 

analyzed in the Black Hills National Forest Noxious 

Weed Management Plan (USDA-Forest Service 

2003c).

7.4

Design Criteria and Monitoring: We support Appendix C's extensive list of project design 

criteria and monitoring requirements to protect aquatic resources, including special 

requirements for wetland, streams and springs. To further ensure that project activities do 

not adversely impact aquatic resources, we recommend expanding the list (in addition to the 

above-mentioned suggestions) as follows:

• Require monitoring of revegetation efforts for five years to ensure success.

• Specify steps to protect range improvements (i.e., water improvements, spring exclosures,

corrals) from mechanical vegetation treatments, prescribed burning application and road 

construction.

• Provide a monitoring schedule for the breakdown of hydrophobic soils following 

prescribed

burns. We suggest up to five years, as needed.

Post-harvest surveys are conducted the third and 

fifth year following harvest to monitor regeneration 

(DEIS, pg. 44).

Range improvements a are noted on sale unit maps 

or prescribed burn unit maps and generally 

protected through avoidance. New roads would be 

constructed to avoid these improvements.

Assessment of hydrophobic soils is part of the 

standard soils monitoring protocol that is conducted 

following prescribed burns. The suggestion of 5 

years is noted.

7.5

2) Baseline air quality and project impacts should be fully disclosed.

The project area is near population centers, as well as a mandatory Class I Federal area 

(Wind Cave National Park). In addition to the National Ambient Air Quality Standards, i.e., 

health-based standards to protect ambient air quality, the CAA requires special protection of 

visibility in the nation's large National Parks and Wilderness Areas (identified as mandatory 

Class I Federal areas).

We appreciate the qualitative air quality discussion included in the Fire and Fuels section of 

the DEIS. EPA recommends expanding this discussion to provide a thorough characterization 

of existing air quality conditions in the area. To that end, it would be beneficial if the FEIS 

included the following:

An analysis of air quality appears in the Phase II FEIS 

on pages III-443 through III-447. Smoke 

management is taken into consideration during the 

development of the prescribed burn plan for a 

specific burn unit. Weather conditions most 

favorable to smoke transport and dispersal away 

from nearby populated areas are identified in the 

burn plan and the prescribed burn is not 

implemented unless those conditions are met.

Wind Cave National Park and Badlands National Park 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-45

• Identification of air pollutant sensitive receptors (such as population centers and Class I 

and

Sensitive Class II areas in the vicinity).

• Trending of air quality at the nearby Class I Federal area over the past several years. Such 

data

are readily available from the VIEWS site for air quality related values

(http://views.cira.colostate.edu/web/). Information regarding current conditions will be an

important tool for monitoring the impacts of the various project activities.

are the only two identified Class 1 areas in South 

Dakota. Due to the relatively small size of each 

individual burn unit (often 100 acres or less), 

ambient airflow (generally west to east) and short 

duration of burns (one or two days, typically), the 

impacts to these areas would be expected to be 

minor, if any occur at all.

7.6

Prescribed Fire: The Steamboat Project action alternatives include the application of 

prescribed burning to 10,608 acres over 10 years. This significant prescribed fire activity may 

cause degradation of air quality in the region. It would be helpful if Appendix A included a 

map of proposed prescribed fire treatment areas similar to the information provided on the 

vegetation treatment maps. In addition, while we realize the individual burn plans prepared 

for this project would quantify expected emissions, it would be helpful if the FEIS included an 

estimate of predicted emissions (or at least a qualitative discussion of the types of pollutants 

expected to be generated).

We support the prescribed fire design criteria and monitoring recommendations outlined in 

Appendix C. We recommend elaborating on these requirements in the FEIS to include a 

discussion regarding: 

(1) how the Interagency Prescribed Fire Planning and Implementation Procedures Guide (July 

2008) would be implemented through the site-specific burn plans designed for each 

prescribed burn conducted under this project; and

(2) how the public will be notified of pending burns.

A map of the proposed prescribed burn units is 

included in Appendix A of the FEIS. This map was 

erroneously ommitted from the DEIS.

Burn plans are based on the guidelines in the 

Prescribed Fire Planning and Implementation 

Procedures Guide. Prescribed burn personnel 

adhere to the standards set in the Guide.

The general public is notified of upcoming prescribed 

burns through press releases to local news media. 

Landowners who live in the proximity of prescribed 

burn units are notified via telephone or in person 

prior to implementation.

7.7

EPA's Rating and Recommendation

Consistent with Section 309 of the CAA, it is EPA's responsibility to provide an independent 

review and evaluation of the potential environmental impacts of this project. Since a 

preferred alternative was not identified in the DEIS, we are rating the DEIS based on the 

action alternatives (we do not rate the no action alternative). Based on the procedures EPA 

uses to evaluate the adequacy. of the information and the potential environmental impacts 

of the proposed action, EPA is rating this DEIS as Environmental Concerns- Adequate 

Information (EC-1 ). The "EC" rating indicates that EPA review has identified environmental 

impacts that need to be avoided in order to fully protect the environment. The "I" rating

indicates that EPA believes the DEIS provides adequate information and analyses to disclose 

project impacts. A full description of EPA's rating system is enclosed.

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-46

We hope that our comments regarding aquatic resources and air quality will assist you in 

further

reducing the environmental impacts of this project. We appreciate the opportunity to review 

and comment on this DEIS.

Respondent #8: Carson Engelskirger, Black Hills Forest Resource Association

# Comment Comment Analysis and FS Response

8.1

On behalf of the Black Hills Forest Resource Association and its members, I would like to 

thank you for the opportunity to comment on the Steamboat project. 

We agree with the Steamboat purpose and need and feel it is appropriate, especially given 

the large-scale MPB epidemic plaguing much of the Black Hills. We feel that the selected 

alternative needs to be effective in best satisfying all components of the project purpose and 

need. 

Given the choice between alternatives, we support Alternative C with some minor 

recommendations and modifications as listed below. We feel makes significant progress in 

fully satisfying the purpose and need in addressing the issues identified in the Steamboat 

project.

Comment noted.

8.2

Botany 

There were a significant number of stands deferred from commercial treatments under the 

guise of either containing sensitive plants or qualifying as suitable plant habitat. Nearly all of 

these stands are rated as moderate-high for MPB risk of infestation. In the Direct and 

Indirect effects under the ‘Botany’ section, it explains that “Mechanical equipment may be 

used to accomplish any of the commercial treatments proposed in the action alternatives”, 

yet in the design criteria (p C-8) it says R2 sensitive plants, SOLC, and all suitable plant 

habitat is prohibited from mechanical treatments. This contradiction needs to be clarified. 

It seems by interpreting the design criteria, any area that is associated with R2 sensitive 

plants, SOLC, or suitable plant habitat is deferred from mechanical treatments. Given that 

most of these stands are at a high likelihood of infestation, it seems appropriate that these 

areas be carefully analyzed for mechanical treatments to determine if they are able to 

The analysis in the Botany section states that 

mechanical equipment could be used to complete 

the proposed commercial treatments, but it does not 

state that it could be used in plant habitat. It is a 

general statement that, in general, the proposed 

treatments might be completed with mechanical 

treatment. To protect plant habitat, mechanical 

treatments are excluded from those areas.

Forest Plan direction does not call for conducting 

treatment on every single acre that is at risk to 

mountain pine beetle or in the suitable base. The 

majority of suitable plant habitat occurs in riparian 

areas, which include the WIZ buffer, which is 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-47

benefit from thinning in the face of the largest MPB epidemic recorded on the BHNF. Not 

only does deferring treatments not conform to what is directed in the Forest Plan, but it also 

removes this acreage from the suited base. We would ask the NHRD to go back and look for 

ways to carefully incorporate mechanical treatments in these areas, whether it is on frozen 

ground or some other method. 

• In Table 3-34 leathery grapefern and Greenleaf willow, tail-leaf willow were identified 

as SOLC, but do not appear on the BHNF website or FSM 2600 for the Black Hills 

SOLC. Are they currently listed as BHNF SOLC? 

• On table 3-35, there is also mention of shining willow, which is a BHNF SOLC, but 

inconsistent with Table 3-34. Please clarify in the FEIS.

deferred from treatment regardless of the presence 

of plant habitat. 

The Forest SOLC list was updated after analysis of 

the Steamboat DEIS was completed. The FEIS is 

updated to reflect the new list. There has been 

some confusion regarding the appropriate common 

name for the willow species (i.e., different common 

names being used for the same species). The FEIS 

uses the common names listed in the updated FSM 

supplement.

8.3

Wildlife 

Under this section, it discusses roads under Alternative C, and the mention there would be 

205 acres of habitat lost. While this may be true, what are the impacts from large-scale MPB 

deforestation? We recommend also mentioning the benefits from the ability to treat stands 

and enhance or preserve habitat at risk to fires and infestation. This project proposes to 

treat 16,588 acres with the installation of the proposed roads. 

There is also mention of a Forest Plan Amendment in order to fully implement Alternative C 

(p 39). With lack of meaningful rationale or explanation in the DEIS, we question just what 

treatments are proposed that would require such an amendment? The BHNF has distributed 

further direction and clarification to Standard 3108, which was derived with input from 

Goshawk researchers Russ Graham and Rich Reynolds. Overall we support treatments that 

enhance goshawk sites and feel that just about any treatment implemented with knowledge 

about the desired future conditions in and around nest areas, can enhance the likely 

homogenous, even-aged habitat that exists. Thus we feel that a Forest Plan Amendment is 

not needed. Again, we support treatments in these areas that reduce the likelihood of MPB 

infestation or wildfire, and at the very least, treatments should be modified so they do not 

require an amendment, yet enhance the existing habitat present.

Full analysis of the effects on wildlife, including 

discussion of the effect of reducing fire hazard and 

pine beetle infestation, are found in the Wildlife and 

Fisheries Specialist Report and Biological Evaluation, 

both of which are located in the project file and 

available on request.

Regarding the Forest Plan amendment relating to 

Standard 3108, see response to Comment 10.3.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-48

8.4

Sanitation

We support the sanitation clause mentioned in the DEIS. This is important in stopping initial 

pockets of infestation that may occur. To better implement this sanitation provision, we 

would recommend allowing large sale-area boundaries. This will give the purchaser and the 

USFS flexibility in implementing this direction.

Comment noted.

8.5

Fire and Fuels 

We support the 10,692 acres of prescribed burning proposed in the Steamboat Project. 

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 Steamboat Project. 

1.) Mortality limits of 10% or less in stands. 

2.) 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. 

3.) Burn objectives. 

4.) We strongly urge prescribed burning to be done in stands that have had mechanical 

treatments prior to burning. 

5.) We caution the US Forest Service against 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. 

See response to Comment 10.5.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-49

8.6

We support the 41 miles of new road construction/conversion stated in the DEIS, however, 

when possible, we would recommend the District look for ways to minimize the miles of new 

road construction. In some areas, it looks like temp roads may suffice for what is proposed. 

Comment noted.

8.7

We would recommend beefing up the section on p 137 regarding management activities in 

Class III watersheds and the opportunities and rationale for doing so. We support these

activities and feel they are able to be done while effectively improving watershed

conditions. 

As stated on pg. 137 of the DEIS, watershed 

improvement activities would largely be achieved 

through reducing the number of connected 

disturbed areas that are contributing sediment to 

streams in the project area.

8.8

There are a number of stands deferred for different reasons, including recruitment for SS5,

sensitive plant habitat, goshawk, snails, SIO, etc. We have commented time and time again 

that a need exists to manage these areas to prevent large-scale MPB mortality and loss of 

these important habitats. Careful implementation of commercial treatments have the ability 

to enhance these sensitive areas and protect them – there is abundant research that 

supports this too. We do not have an excess of these habitat types to take a hands-off 

approach and lose these stands. We know what happens if we do nothing. If we know the 

desired future conditions we are looking for in these areas, we can protect them and 

enhance what we desire out of them. We would appreciate a detailed section in the FEIS 

that outlines stand-by-stand, what treatments are implemented in these areas, and if not, 

what the rationale is for deferring treatments. Nowhere in the Forest Plan does it state that 

these areas are off-limits for entry. 

Specific stands were deferred from treatment based 

on the recommendation of individual resource 

specialists who determined that deferral was the 

most appropriate course of action for the resource 

of concern. A list of all stands that were identified 

for “no treatment” and the reason they were 

deferred from treatment is located in the project file 

and available on request.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-50

8.9

Spruce is currently exceeding Forest Plan direction. Design Criteria on C-9 mentions 

exclusions of spruce from treatments. With no rationale or basis for these comments, we 

recommend omitting them for the FEIS. Rather than deferring acres, why not apply the 

treatments that make logical sense and manage these stands to improve conditions. 

See response to Comment 10.8.

8.10

In the end, we still support Alternative C and feel it best meets the Steamboat project 

purpose and need with the incorporation of the above mentioned. We urge the NHRD to 

implement this project as soon as possible to respond to the ongoing MPB epidemic.

Comment noted.

Respondent #9: Mary Zimmerman

# Comment Comment Analysis and FS Response

9.1

Thanks for all the work you’ve done in putting together the DEIS for the Steamboat Project. 

The issues at hand are grave and I’m sure that you do not take lightly the fact that this 

project has important implications for the health of the project area and the ecosystems and 

economies that depend on it. 

I’ll have to be brief because of my own time constraints this week, but do want to take the 

opportunity to comment. I have also copied and pasted two letters below... one you’ll 

recognize as my scoping comments on the Steamboat Project, and the other is the scoping 

comments that I sent to Craig Bobzien for the MPB Response Project.

Comment noted.

9.2

Although I know that you have tried to show a wide range of possibilities in the alternatives 

presented in the DEIS for the Steamboat Project, they are, in reality, all actually only within a 

quite narrow range of possibilities. All three of the action alternatives show the majority of 

areas treated having even aged stands fostered and developed. None of the alternatives 

Under Alternatives B and D, approximately 16% of 

the treated acres would be accomplished through 

uneven-aged management or an understory thin. 

Alternative C treats approximately 10% of the 

treated acres through those methods (DEIS, pg. 46, 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-51

shows a plan to treat any part of the project area (beyond tiny tidbits) with uneven aged 

treatments or understory removals. All of these alternatives continue a practice of removing 

our largest trees almost any time a stand entry is made and leaves untouched large trees at 

the mercy of a sea of dog hair. This is all directly contrary to the plan laid out in the recent 

USFS document from July 2011 “The Western Bark Beetle Strategy for Human Safety, 

Recovery, and Resiliency.” Could there not be an alternative laid out that would reflect the 

types of ideas represented in that document?

Table 2-5). As discussed on pg. 45 of the DEIS, 

additional opportunities for uneven-aged 

management were explored. Alternatives B and D 

include an additional 1,372 acres of non-commercial 

thinning. Alternative C includes 638 acres of noncommercial thinning. This treatment is intended to 

reduce the “dog hair” condition in stands after they 

have been commercially harvested.

The bark beetle strategy document was published in 

July 2011. The Steamboat DEIS was made available 

to the public in the first week of August. 

Development of the alternatives and analysis of their 

effects was largely complete by July. As such, the 

document wasn’t specifically consulted during 

development of the Steamboat alternatives. 

However, the actions proposed in Steamboat do 

incorporate some of the goals outlined in the 

document. The ‘safety’ goal is achieved through 

sanitation harvest provisions in Steamboat. The 

‘resilience’ goal is addressed through thinning forest 

stands and reducing the number of trees per acre.

9.3

The levels of disturbance via what has been traditional logging in the Black Hills thus far, and 

road building are unconscionable in Alternatives B and C. If either of these alternatives is 

elected, we can expect a future of epidemics of not only MPBs and fire, but also of invasive 

weed species. Likewise there is great potential for a collapse of tourism in the region. 

Ironically, the logging industry could be threatened as well.

Analysis of the effects of Alternatives B and C on pine 

beetle risk, fire hazard and noxious weeds, as well as 

scenery (which affects tourism to some degree) are 

disclosed in Chapter 3 of the Steamboat EIS and in 

the associated specialist reports, which are available 

in the project file.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-52

9.4

As this is a time when a feeling of emergency prevails, I would like to assure you that 

carefully working your way through the forest carrying out meaningful and lasting 

treatments is far preferred over a rush to do ‘something’ or ‘anything’. You will not be able 

to road and log your way out of this problem. Budgets will necessitate prioritizing and this is 

a time to work smart, not hard.

Comment noted.

Respondent #10: Paul Pierson, Neiman Timber Company

# Comment Comment Analysis and FS Response

10.1

Neiman Timber Company would like to thank you for the opportunity to review and 

comment on the Steamboat Project. We hope you will find the following comments useful 

in developing and choosing the best action alternative. 

We agree with the purpose and need of the project. It is crucial to insure that the selected 

alternative reduces the mountain pine beetle (mpb) and fire risks to the fullest extent over 

the project area in order to manage for structural diversity in big game winter range. J.M. 

Schmid, S.A. Mata, R.R. Kessler, and J.B. Popp concluded in their research paper ‘The 

Influence of Partial Cutting on Mountain Pine Beetle-caused Tree Mortality in Black Hills 

Ponderosa Pine Stands’ that “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 18 USDA Forest Service RMRS-RP-68. 2007 incipient stage will prevent 

achievement of most other management objectives.” 

It is for this reason we support Alternative C with the following recommendations for 

modifications. Alternative C is the only alternative that will fully meet the purpose and need 

for the project.

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-53

10.2

The design criteria on page C-8 for R2 sensitive plant species and SOLC states that “suitable 

plant habitat would be excluded from mechanical treatment areas”. It also states that 

“plant habitat outside of treatment units would be avoided unless approved by a qualified 

botanist for entry”. These two criterions appear to contradict each other. We recommend 

removing the criterion that excludes mechanical treatment in suitable plant habitat. There is 

nothing in the Forest Plan that mandates no mechanical treatment in suitable plant habitat. 

We request the Forest Service to find ways to mechanically treat these areas in order to 

reduce the risk of mpb and fire to protect this sensitive habitat in the long-term. 

It is important to leave all tools available for management, especially in light of the mpb 

epidemic that is deforesting the Black Hills.

The design criteria were created by the botanist to 

best protect the sensitive plants in the project area. 

The only way to protect the habitat for certain is to 

avoid the areas where plants are likely to occur. 

The majority of sensitive plant habitat in the project 

area occurs in riparian areas, which are often 

excluded from treatment through the Watershed 

Influence Zone buffer, regardless of whether or not 

rare plants may occur.

10.3

It is stated that implementation of Alternative C requires a project-specific amendment to 

the Forest Plan standard 3108. We disagree with this statement and request the Forest 

Service to remove it from the Final EIS. The treatments proposed under Alt. C appear to 

have been selected to reduce the mpb and fire risk in the stand areas while still maintaining 

suitable habitat conditions for nesting. It is clear that reducing these risks will enhance the 

nesting habitat in the long-term, which is the direction for the Forest Supervisor.

Forest Plan Standard 3108 calls for maintaining or 

enhancing nesting habitat around known goshawks 

nests. The Biological Assessment/Biological 

Evaluation completed for the Phase II Amendment 

to the Forest Plan identifies suitable nesting habitat 

as structural stages 4B, 4C and 5. The commercial 

harvest treatments proposed in goshawk nest areas 

under Alternative C would reduce the structural 

stage below the 4B level, which would represent a 

violation of Standard 3108 (Steamboat Wildlife and 

Fisheries Biological Evaluation, pg. 48).

10.4

Under the “direct and indirect effects” for wildlife, it is stated that approximately 205 acres 

of habitat would be lost to new road construction under Alt. C. We disagree with this 

analysis. Given that this project is Big Game Winter Range, it would be assumed that most 

of these roads would be closed to public use. Eventually these roads will provide habitat for 

animals that use SS 1 as these roads grass in. We also request the Forest Service to analyze 

the indirect effects in detail of not choosing Alt. C on wildlife in relation to catastrophic 

wildfire and mpb epidemics. There is an extremely high probability that not choosing Alt. C 

will result in at least 6,000 acres of lost habitat compared just to Alt. B due to wildfire or 

mpb.

205 acres of habitat would be lost for some period 

of time, even if temporarily. There is no guarantee 

that the roaded areas would return to their preroad habitat conditions.

Detailed analysis is located in the Wildlife and 

Fisheries Specialist Report and the Wildlife and 

Fisheries Biological Evaluation, both of which are 

located in the project file and available upon 

request.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-54

10.5

We support the 10,692 acres of prescribed burning proposed. We request the following 

items be incorporated into the FEIS: 

1. Mortality limits for prescribed burning set to 10% or less. 

2. Some statement of burn objectives. 

3. Salvage clause allowing for efficient and effective removal of saleable timber where 

the mortality limits are exceeded. 

4. Recommendation that prescribed burning is done in stands that have been 

mechanically thinned prior to burning. 

5. Recommendation that prescribed burning is not done in stands that have been precommercially thinned prior to burning and slash was left on the forest floor. 

1. Mortality limits are not set at this point to allow 

fuels specialists and the silviculturist flexibility when 

developing the final burn prescription.

2. General burn objectives are outlined on pgs. 36-

38 of the Steamboat DEIS.

3. The Steamboat Project includes a sanitation 

harvest clause (DEIS, pg. 42) but no salvage harvest 

clause related to prescribed burns. The presence of 

some fire-killed trees is beneficial to wildlife.

4. Prescribed burns would be conducted in stands 

with prior timber harvest, either under Steamboat 

or under another past project (e.g. units harvested 

under the Windy, Picnic, Cavern or Kine timber 

sales).

5. Considerations for where prescribed burns are 

conducted are listed on pg. 37 of the DEIS.

10.6

The only additional comments we have is that we ask the FS to utilize the CWPPs. The 1⁄2 

mile buffer identified in your GIS data does not look like the WUI buffer in the CWPPs. The 

Forest Service must use the CWPP when implementing its projects. See response to Comment 6.10. 

10.7

We applaud the FS for making provisions in the project to anticipate future events. We 

support making the whole project area open for sanitation. During sale layout it is 

extremely important to ensure that Sale Area boundaries be adjoining to each other so 

purchasers can address the outbreaks under current contracts.

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-55

10.8

We recommend deleting the design criteria on C-9 that excludes spruce from treatments. 

The forest plan actually states that the amount of white spruce currently on the forest is 

exceeding the forest’s goal. 

The Forest Plan objective pertaining to spruce 

(Objective 239-LVD) calls for reducing spruce when 

there is a discernible management goal for doing so. 

Even though the current acreage of spruce Forestwide is higher than the objective that does not 

mean spruce will be harvested for the sake of 

reducing spruce acres (Phase II Q and A document). 

None of the limited spruce stands within the 

Steamboat project area were identified as 

necessitating management at this time.

10.9

We do not support any design criteria that eliminates a stand from potential treatment. 

There is no reason to limit the tools in the toolbox when managing a dynamic ecosystem. 

The Forest Plan includes a multitude of goals, 

objectives, standards and guidelines. Design criteria 

are intended to protect multiple resources to meet 

Forest Plan direction.

10.10

Neiman Timber Company supports Alternative C. If chosen, this alternative would take large 

strides in truly reducing the risks to our ecosystems that we are facing while providing for a 

diversity of habitat that we desire on our forest.

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-56

Respondent #11: Nancy Hilding, Prairie Hills Audubon Society

# Comment Comment Analysis and FS Response

11.1

Thanks for the map of cover types before treatment, but please also include a map of cover 

types after treatment. Please also provide a map of pine structural stages for each 

alternative. Please provide maps of the understory types. You should provide us with a map 

of the stands with the largest oldest pines.

Please provide maps of the WUI. Please provide a map of the Centennial trail and any other 

hiking or other recreational trails, that don't show up on the road map. Please also show 

any picnic or campground areas.

These maps will be posted to the project website. A 

map of understory cover type is difficult to produce 

as no attribute exists for “understory cover type”. 

Stand exams identify the vegetation present in the 

understory, but that information often contains 

multiple species. Any resulting map is very difficult

to read.

Likewise, it is difficult to produce a map showing the 

largest old pines since not all large trees are aged. 

Large and very large trees are noted in stand exams

and stand age is noted, but ages of individual large 

trees are not. 

11.2

Truth in discussion of fire risk,

If fire risk as calculated by FS, is derived from your data on pine structural stages, we believe 

the risk calculated is for a specific type of fire - catastrophic crown fire. It is not a risk for 

other types of fire. Please be sure not to equate catastrophic crown fire risk with risk of 

other types of fire, when using structural stages as your logic.

The correlation between structural stage and fire 

hazard was established in the FEIS for the Phase II 

Amendment of the Forest Plan. The fire hazard 

described does predict crown fire, as stated in the 

comment. 

11.3

Botany Canyon,

Botany Canyon is the on the South Fork of Stagebarn Canyon in Range 6E, T3N, and it starts 

on private land in the NE Section of 33 after a U shaped curve and flow down stream 

through Section 27 and 22 and we end the recommendation at the Forest Service/Private 

land boundary between Sec 22 and 23. This stream has exceptional recreational value due 

to beauty; pretty cliffs and proximity to populated areas and has exceptional ecological 

value due to rare plants.

Please fully disclose all impacts to Botany Canyon, especially any threat to it from additional 

roads and access to the area. Will cutting and associated soil run off, effect its' water 

quality. Will there be any additional threat from weeds or herbicides as a result of roads or 

treatments? Will any opening of the overstory on land above, effect water flow or 

moistness of the area, and thus affect rare plants?

The effects of each of the alternatives on the project 

area are presented in the Steamboat EIS. Maps 

showing the locations of the treatements proposed 

under each alternative are included in Appendix A of 

the EIS and can be used to identify what treatments 

might occur in specific areas.

Changing management area direction for a specific 

area of land is outside the scope of the Steamboat 

Project and would be best addressed at the Forest 

Plan level.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-57

Please discuss using this DEIS as a vehicle for a LRMP amendment, to change the

management area designation for Botany Canyon to one more protective of its' special 

values.

11.4

Increase aspen and hardwoods,

Please fully disclose the risk (or lack of risk) of catastrophic crown fire and beetle spread, in 

other cover types besides pine. We believe your fire/beetle theories indicate that other 

cover types may provide relief from the various disturbance threats you fear. We believe 

one alternative should more aggressively seek to maximize aspen, birch and oak, and thus in 

your NEPA analysis, you can fully explore and discuss the effects of changes in cover type to 

the risk of fire and beetle spread risk (as alleged by FS). We think the aspen/birch 

enhancement cuts are the same in all alternatives B, C & D. There is not variety shown and 

thus inadequate range of alternatives to explore the use of alternative cover types to

address fire and beetle risk.

It is true that aspen/birch stands can represent 

buffers that help stop or slow the spread of 

mountain pine beetles or wildfires. It is also true 

that all three action alternatives include the same 

level of aspen/birch enhancement. This is because 

the amount of aspen/birch enhancement proposed 

under the action alternatives is the maxmimum that 

could be achieved at this time. New areas of 

aspen/birch can not be simply created from areas 

where these species do not already exist. The 

wildlife biologist and silviculturist sought out as 

many aspen/birch stands as possible during 

alternative development and identified them for 

enhancement so that they would be maintained, 

and perhaps expand, in the future.

11.5

We wish that you would do aspen/birch enhancement that is not just limited to removing 

pine from mixed aspen/pine stands, but also do aspen enlargement cuts, that are designed 

to convert solid pine to aspen, and to do so by clear-cutting pine out of circles or areas 

around aspen stands (doughnut shapes), to allow aspen to expand outward by roots.

Pine would be removed from the perimeter of 

aspen or birch patches at least 1⁄4 acre in size in an 

attempt to encourage the growth of those 

hardwood patches (DEIS, pg. 34).
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-58

11.6

We hope, if you have large diameter, old yellow bark pine trees standing above aspen 

stands in mixed aspen/pine or you have them surrounding aspen, you will leave those old 

large yellow barks standing. Large old yellow barks are more precious and rare than aspen.

The retention of overstory pine trees within or near 

aspen/birch stands would be dependent on the 

prescription for the particular stand (I.e., noncommercial vs. commecial hardwood 

enhancement).

11.7

Moratorium on cutting large trees

One alternative should provide for a moratorium on the cutting of very large diameter and 

old ponderosa pine, such as those pines larger than 19 DBH. However you could select a 

DBH that would be protective of the very large old trees in this area.

You should identify the stands with the oldest largest trees and protect those from cutting,

The Forest Plan objective for retention of very large 

trees is met through movement toward the Forestwide structural stage objectives. Very large trees 

are retained in stands of structural stages 4 and 5. 

The acres remaining in these structural stages postharvest for each action alternativea are displayed on 

pgs. 63, 68, and 71 of the DEIS.

11.8

You should provide us with a map of the stands (which stands have the largest, oldest 

pines).

You should disclose to us where those are. A 4C PP stand could have been a 3C stand 2 

years ago, or it could have been a 4C stand for ages and age of stand approaching 160 years 

in age.

Data such as stand age and average tree size are 

included in the stand exam data, which is used to 

develop the silvicultural prescriptions. The GIS data 

used to develop the project is available upon 

request.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-59

11.9

You have insufficient old growth (SS 5) . There is the risk of fire and beetles killing your 

reserved SS 5 or SS 4 C -- no matter what you do, SS 5 or 4C may die natural deaths. You 

need to identify replacement old growth, and provide that in access of 10%. You need 5% to 

be immediate replacement old growth --- to as quickly as possible give you new SS 5, and 

then another set of high quality SS 4 to also be best 5% to be replacement for that first 

replacement set, allowing that beetles or fire or logging (artificial disturbance, ironically due 

to fear of natural disturbance events), may remove any saved SS 4C or old growth.

The Forest-wide objective for structural stage 5 in 

MA 5.4, which Is the only MA in the Steamboat 

project area, is 5%. Alternatives B and D would each 

identify 485 additional acres of SS 5 (compared to 

the existing condition) and Alternative C would 

identify an additional 153 acres. By increasing the 

amount of SS 5 within the project area, the 

Steamboat Project would be contributing toward 

the Forest-wide goal. 

11.10

Forest-wide Structural Stage charts.

The Forest-wide structural stage charts on pages 64, 69 and 72 don't quite make sense. 

They show the amount of acres of SS 5 increasing but on the same row of chart, the percent 

of the project decreasing, which is not logical. How will you increase old growth by a timber 

sale? If you are dropping from .3% to 0%, why would you want to do that?

The apparent decrease in the Forest-wide 

percentage of SS 5 in the DEIS is due to rounding 

error (i.e., 0.3 rounded down is 0). The charts are 

corrected in the FEIS.

11.11

Big Game,

As this is a management area for Big Game Winter Range, you should discuss the big game 

species found here. Are there elk? You are substantially increasing roads. Please fully 

discuss all literature about the effects of road densities in elk and how more roads will 

adversely affect their habitat. How does your road density relate to that recommended for 

elk?

If there is a section on thermal cover for big game, I did not find it. Please fully discuss all 

thermal cover issues and disclose impact of cutting trees on thermal cover and hiding cover.

Please provide for adequate thermal and hiding cover.

Effects to wildlife, including big game species such 

as white-tailed deer and Rocky Mountain elk are 

summarized in the Wildlife and Fisheries section 

(beginning on pg. 86 of the DEIS). A more detailed 

analysis is documented in the Wildlife and Fisheries 

Specialist Report, which is located in the project file 

and available upon request.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-60

11.12

Wetlands inventories

On page 141 of the DEIS you reference the USFWS National Wetlands Inventory and say 

there were 17 wetlands mapped in that inventory. We believe that inventory may have 

been an aerial inventory and thus may miss the small wetlands or wetlands hidden under 

tree cover.

We request a thorough wetlands inventory that does not miss small wetlands, fens, bogs 

etc. Small wetlands can be impacted by timber skid trails, roads or log lands, or slash piles if 

not properly identified.

As stated in the Steamboat DEIS (pg. 141), 

seventeen wetlands were identified in the USFWS 

inventory and two additional wetlands were 

discovered during the field review for the 

Steamboat Project. All wetlands would be 

protected by design criteria (DEIS, Appendix C).

11.13

Visual impacts

You indicate on page 142 that there are twenty meadows. You say: "Logging has been used 

within 14 meadows to thin out past pine encroachment. Remnant stumps, slash piles, and 

felled trees provide evidence of past thinning. One meadow also showed evidence of past 

burning."

Please discuss the use of meadows for log landings, and slash piles and how you will fully 

remove the debris from past accumulation and new accumulation of logging debris from 

meadows. Please devise a plan that gets rid of the debris.

The language on pg. 142 does not state that there 

are 20 meadows, it states that 20 meadows were 

visited during field surveys.

Design criteria on page C-4 of Appendix C stipulates 

that use of meadows for landings will be avoided if 

at all possible. If not possible, the district 

hydrologist, botanist and wildlife biologist will be 

consulted to determine if any special measures are 

required to protect site integrity. In most cases, 

logging slash left on a landing, whether it’s in a 

meadow or not, is burned. In limited cases, the 

slash is hauled away for use in ethanol production.

11.14

The scenery management system analysis was done in 3 days by Joby Timm on the 

computer at the SO. The computer calculated beauty from computer coverages of things 

like cover types and structural stage data. It is very very rough analysis. It should always be 

ground truthed at the project level. SIO are guidelines and can be changed at the project 

level. Please ground truth the Computers calculation of beauty.

Also the sensitivity levels can have changed in 15 years, especially with all the ATV use.

Updating the scenery analysis at the Forest Plan 

level is outside the scope of the Steamboat Project. 

The purpose and need for the project is to provide 

structural diversity in big game winter range, reduce 

the risk of mountain pine beetle infestation and 

reduce the fire hazard.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-61

11.15

As mentioned below , you need to protect the visuals along the Centennial Trail

Recreation,

Please add birdwatching and nature study as recreational uses.

The Centennial Trail passes through the area. Please fully disclosewhat types of cuts are 

planned along the Centennial Trail (or any other trails) Please consult with the landscape 

architect and provide for protection of the visuals along the view shed of the Centennial 

trail. For example overstory removals should not occur along the Trail and neither should 

slash piles.

Please discuss the ROS class assignments for the area and whether any should be changed, 

those are also guidelines and can be changed at the project level.

Comment noted regarding birdwatching.

The project area maps display the locations of the 

proposed treatments under each alternative and 

can be used to determine what type of treatment is 

proposed adjacent to the Centennial Trail.

Design criteria are in place to protect visuals and 

limit the amount of residual slash near the 

Centennial Trail (DEIS Appendix C, pg. C-5).

Regarding ROS class assignments, see response to 

Comment 11.14.

11.16

Native American

Is there an environmental justice statement in the DEIS? I did not see it. Due to the 

unresolved dispute/outstanding land claims, where various tribes still claim ownership of 

the Black Hills, please consider the Lakota tribes to be part of the affected local community, 

in the socio-economic section.

Environmental justice is discussed on pgs. 250-251 

of the DEIS. 

Comments on the Steamboat Project were sought 

from 30 tribal contacts, including the Lakota tribes 

of North and South Dakota.

Respondent #12: Walt Bones, South Dakota Department of Agriculture

# Comment Comment Analysis and FS Response

12.1

Thank you for an opportunity to comment on the Steamboat Project northwest of Rapid 

City, South Dakota. We appreciate the opportunity. Our comments follow:

Alternative B, the preferred alternative, proposes to treat I 0,048 acres with commercial 

harvest and 2,288 acres with non-commercial harvest. It is difficult to know if some of the 

non-commercial harvest will be completed on the same acres as the commercial harvest, but 

the maps suggest there will be some overlap. According to the issues raised during scoping 

(page 28) 6,755 acres of ponderosa pine forest at moderate to high risk of mountain pine 

Comment noted.
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-62

beetle (MPB) infestation will not be treated under Alternative B. There will be over 10,000 

acres of high (4,000+ acres) and moderate (6,000+ acres) MPB risk remaining in the project 

area after implementation. Areas of high risk MPB stands will be scattered across the project

area. Almost all private land areas within the project area will be immediately adjacent to 

high risk MPB stands on National Forest land. Almost half of the highly visual Nemo Road 

corridor will be along stands that are at high risk to MPB infestation.

Alternative C was developed in response to public concerns that the 6,755 acres of nontreated areas in Alternative B is an inadequate response to the MPB epidemic facing the 

Forest. Alternative C treats an additional 6,540 acres of forest with commercial harvest, and 

non-commercial harvest is reduced by 827 acres. Commercial harvests are modified by 

increasing ovcrstory removal by 328 percent, shelterwood cuts are increased by 90 percent, 

and commercial thinning is increased by 42 percent. After implementation the alternative 

will contain about 4,800 acres of high (1,800 acres) and moderate (3,000 acres) MPB risk 

stands. About half of the private land areas in the project area will be immediately adjacent 

to some part of a high risk stand.

Alternative D was developed to address the issue of new road construction in the project 

area, and was designed to eliminate new road construction. Under Alternative D, 7,106 acres 

will be treated commercially and 2,288 acres non-commercially. There will be slightly over 

12,000 acres of high (6,000+ acres) and moderate (6,000+ acres) MPB risk remaining in the 

project area after implementation. This alternative will result in many large continuous 

acreages of high MPB risk areas, and the least number of acres will be reduced from high to 

low or moderate fuel hazard. Roads are necessary for management work, and provide the 

added benefit of access for wildfire suppression. While we don't agree with Alternative D, 

we believe the Black Hills National Forest (BHNF) should strive to minimize the miles of roads 

to only those necessary to achieve the desired management objectives.

12.2

All three alternatives contain a sanitation harvest provision. However, it is not clear that the 

sanitation provision applies to areas that are not designated for treatment under the 

alternatives. The draft Environmental Impact Study (DEJS) states on page 42: "Sanitation is 

the removal of infested trees; however, il i~ reasonable to do any proposed treatments once 

sanitation is deemed appropriate. " "Proposed treatments would likely involve culling green, 

beetle-infested trees and thinning stands to

residual basal areas below 80. "These statements suggest treatments will take place in 

addition to sanitation harvest. Since 6,755 acres will remain untreated in Alternative B, the 

implication here is that if treatments are not allowed in an area, sanitation harvest will not 

be allowed.

The sanitation harvest provision is designed to allow 

the USFS to treat new areas of mountain pine beetle 

infesation in stands that are not proposed for 

treatment under the Steamboat alternatives. 

After a decision is reached and a selected alternative 

is implemented, if pine beetle activity should occur 

in an stand that was not included in the selected 

action, the USFS would have the leeway to remove 

beetle-hit trees and to lower the stand basal area to 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-63

The DEIS further states: "If the scale of management actions required to address the 

epidemic goes beyond the scope of this sanitation harvest provision, additional NEPA analysis 

would be required to treat larger areas of tree mortality, from beetle infestations. "This 

statement abdicates large areas of infestation within the Steamboat Project area to go the 

way of Beaver Park, Custer Peak, Deerfield, and

Black Elk Wilderness. It will take 18 to 24 months to do additional National Environmental 

Policy Act (NEPA) within this project area. That will allow at least two additional flights of 

MPB after an epidemic population is reached. This delay is unacceptable. It is imperative that 

all NEPA work be completed during this analysis to allow an adequate response to MPB in an 

incipient infestation.

reduce the risk of beetle spread. 

Additional NEPA analysis would only be required if 

an infestation became established and active to the 

point that sanitation harvest would not be effective. 

Avoiding a scenario such as that is part of the reason 

behind the Steamboat Project, as stated in the 

project’s purpose and need.

12.3

The BHNF must take an adaptive management approach to addressing the MPB epidemic on 

the Forest and throughout the Steamboat Project Area. That includes adopting techniques to 

treat small areas of infestation before they become large infestations, and transitioning to 

other techniques as infestations grow to epidemic proportions. Sanitation harvest must be 

specifically allowed throughout the project area, and it should be allowed to occur as 

needed during future years while the epidemic poses a threat to the Forest. The Forest must 

prepare itself through adequate NEPA analysis to implement the full range of accepted 

practices for suppressing MPB including but not necessarily limited to sanitation, salvage,

baiting, lethal baiting, cut and chunk, and preventive spraying on a continuing basis until the 

epidemic subsides.

See response to Comment 12.2 regarding the 

sanitation harvest provision in Steamboat.

Currently, the BHNF is preparing the proposed action 

for the Forest-wide Mountain Pine Beetle Response 

Project, which will allow treatments to combat pine 

beetle infestation across the forest in stands where 

NEPA analysis allowing treatment has not yet been 

conducted.

12.4

Alternative C is most effective at reducing MPB risk across the project area. In addition it is 

most effective at reducing wildfire hazard rating in the Wildland Urban Interface (WUI). 

However, it has serious drawbacks as presented. For example, Alternative C increases 

ovcrstory removal by 328 percent over Alternative B: from 874 acres to 3740 acres, This 

includes 1131 acres that would require planting to achieve reforestation within required 

time frames because no regeneration currently exists in the stands. An overstory removal in 

the absence of regeneration that leaves no remaining seed source is basically a clearcut. 

Clearcutting is not necessary to reduce MPB risk to an acceptable level, nor is it necessary to

reduce wildfire hazard rating to an acceptable level. Another drawback is the need for a 

project specific amendment to the Forest Plan; a need that could probably be avoided with 

less draconian treatments that could still effectively reduce MPB risk and fire hazard.

Commenters during the scoping period felt that the 

proposed action (Alternative B) did not do enough to 

reduce the risk of beetle infestation across the 

project area. Alternative C was developed to 

address this issue. As part of Alternative C’s 

development, the interdisciplinary team proposed 

some stands for treatment that would not be 

included under normal silvicultural conditions, which 

is why overstory removal and planting is proposed 

on some stands where regeneration is not yet 

sufficient. 

The project-specific Forest Plan amendment that full 

implementation of Alternative C would require is not 

related to those overstory removal treatments. 

Rather, it would be required due to commercial 

harvest treatments in goshawk nest areas, which 

would violate Forest Plan Standard 3108 for 
Steamboat Project Final Environmental Impact Statement

Appendix E – Response to Comments E-64

maintaining or enhancing nesting habitat.

12.5

Given the drawbacks of Alternative B including: a large area of high and moderate MPB risk 

stands that will not be treated; sanitation harvest that will not be allowed in untreated 

stands; the juxtaposition of high risk MPB stands on federal lands to private lands; and the 

persistence of high MPB risk stands along the highly visible Nemo Road visual corridor, we 

are compelled to support Alternative C despite its flaws.

Sanitation harvest would be allowed in untreated 

stands under all action alternatives. The sanitation 

harvest provision will be clarified in the FEIS to 

reflect that fact.

12.6

What the Forest needs to develop is an adaptive management approach to MPB infestations 

over time and space so it can respond to small infestations and suppress them before they 

reach epidemic size, and respond to large infestations once they have grown to epidemic 

size. The Forest also needs the flexibility to re-enter stands annually or every few years as 

the threat of epidemic outbreaks continues. Adaptive management would allow the Forest 

to vary its management intensity to create a mosaic of stand structures across the 

landscape, but still be able to respond effectively to the threat of MPB outbreaks. 

Unfortunately, these options don't appear to be included in the Steamboat Project DEIS.

Once again, we appreciate the opportunity to comment. Thank you.

As stated in response to Comment 12.3, the BHNF is 

currently developing a Forest-wide Mountain Pine 

Beetle Response Project. This effort, along with 

ongoing and already completed NEPA analyses 

across the forest, such as the Steamboat Project, 

would allow the BHNF to more quickly respond to 

pine beetle outbreaks.