Steamboat Project

Final Environmental Impact Statement

Appendix B

Silvicultural Findings of Compliance with Laws, Regulations and Policy
Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-2

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Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-3

The following findings are made based on the environmental analysis and the silvicultural prescription for the 

21,833 acres of National Forest System (NFS) land in the Steamboat project area.

Best Science Findings

While conducting my analysis for the Steamboat Project I reviewed information from the following sources: 

• Black Hills National Forest Fiscal Year 2009 Monitoring Report

• Phase II Amendment Final Environmental Impact Statement (FEIS), applicable supporting documents, 

and applicable literature references

• Applicable research that I believe represents a reasonable cross-section of the total range available, 

including responsible opposing views, sufficient to professionally evaluate the effects of this proposal

(see Steamboat Silviculture Report bibliography)

• Literature sources offered in comments provided on this project analysis (see Steamboat Silviculture 

Report bibliography)

• Other sources (see Steamboat Silviculture Report Bibliography)

In considering these sources, I believe I have considered the best available science.

Consistency [16 USC 1604(i)]

Timber harvest would occur on lands suited for timber production or would occur in areas where timber harvest 

is permitted and is necessary to help achieve other resource management objectives.

Table A-1. Suitability Summary (acres)

Alt B Alt C Alt D

Harvest on Suitable Timber 

Production (Timber 

Component 5xx or 6xx)

10,350 16,184 7,411

Harvest Permitted for 

Multiple-Use Objectives 

(Timber Component 8xx)

27 554 27

Timber harvest is also proposed on lands classified as not suited for timber production . Pine removal would 

occur in hardwood stands where pine has invaded to conserve existing hardwood communities and restore 

historic hardwood communities (Forest Plan objective 201). Existing meadows and some historic meadows 

would be restored through the removal of pine from those sites (Forest Plan objective 205). Identified old 

growth stands may be treated to adjust stocking levels. These treatments are proposed to serve multiple use 

objectives and provide diversity and browse for wildlife and cattle and are not required to meet culminatino of 

mean annual increment (CMAI). The following are meadows where pine removal would occur to retain meadow 

characteristics:
Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-4

Table A-2. Meadows with a Pine Removal Prescription

Stand Number (Veg Link) Cover Type Acres Treatment

089902 20 Grass 8

Commercial Meadow 

Enhancement

081509 75 Grass 35 Meadow Enhancement

081506 30 Grass 15 Meadow Enhancement

089904 39 Grass 42

Commercial Meadow 

Enhancement

081708 41 Grass 4 Meadow Enhancement

089901 37 Grass 2 Meadow Enhancement

081509 10 Grass 4

Commercial Meadow 

Enhancement

The following stands have a ponderosa pine cover type where pine removal would occur and the cover type 

would be converted to grass. These areas were determined to have the best opportunity for meadow 

establishment or were erroneously typed as ponderosa pine in the stand exam process. In addition, the 

following stands should have the timber component eliminated.

Table A-3. Ponderosa Pine Stands Converted to Meadows

Stand Number (Veg Link) Cover Type Acres Treatment

089902 45 Ponderosa Pine 7 Meadow Enhancement

081708 37 Ponderosa Pine 3

Commercial Meadow 

Enhancement

089904 92 Ponderosa Pine 6 Meadow Enhancement

089904 29 Ponderosa Pine 14 Meadow Enhancement

089904 47 Ponderosa Pine 10

Commercial Meadow 

Enhancement

081706 30 Ponderosa Pine 2 Meadow Enhancement

089901 18 Ponderosa Pine 13 Meadow Enhancement

089904 12 Ponderosa Pine 28 Meadow Enhancement

081706 36 Ponderosa Pine 2 Meadow Enhancement

089902 17 Ponderosa Pine 11

Commercial Meadow 

Enhancement

Silvicultural treatments are consistent with the Forest Plan. The proposed treatments in the action alternatives 

comply with the Forest Plan Acceptable Silvicultural Systems (Forest Plan, II-25), including the even-aged 

systems of shelterwood and clearcut, and the uneven-aged system of selection cutting. Even-aged regeneration 

harvests are appropriate to meet the objectives and requirements of the Forest Plan. Specific desired conditions 

include a better balance of structural stages, improved age class distribution, and adequate restocking. There 

are also some stands that would be managed using uneven-aged systems. Forest Plan standard 2408a states 

that “both even-aged and uneven-aged management systems can be used and applied at scales ranging from a 

few acres to many hundreds of acres”.

Prescriptions were developed to achieve Forest Plan goal 10: “Establish and maintain a mosaic of vegetation 

conditions to reduce occurrences of catastrophic fire, insect, and disease events, and facilitate insect and 

disease management and firefighting capability”. In addition, they were designed to comply with the Healthy 

Forest Restoration Act (HFRA) of 2003 (HR 1904) and other National level initiatives and policy that emphasize 

reducing the probability and occurrence of severe wildfire in fire adapted ecosystems, especially near at risk 

communities (ARC) and in the wildland urban interface (WUI).
Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-5

Timber Harvest [16 USC 1604(g)(3)(E)] 

Soil, slope, or other watershed conditions would not be irreversibly damaged (see the Hydrology and Soils

specialist report).

There is assurance that the lands can be adequately restocked within five years after final regeneration harvest; 

adequate stocking is 150 conifer seedlings per acre, assuming no intermediate treatments. Where intermediate 

treatments will be done, 300 conifer seedlings per acre are required.

Research and experience indicate the shelterwood method should be the primary regeneration method and is 

ideally suited and widely applicable in the Black Hills (USDA-FS Research Paper RM-124, 6/74). It is a scientifically 

sound method of regeneration for ponderosa pine as described in Agriculture Handbook #445 (revised 12/83) 

pages 80-83. 

Streams, streambanks, shorelines, lakes, wetlands, and other bodies of water are protected from detrimental 

changes in water temperatures, blockages of water courses, and deposits of sediment where harvests are likely 

to seriously and adversely affect water conditions or fish habitat (see Hydrology and Soils specialist report).

The harvesting system to be used was not selected primarily because it would give the greatest dollar return or 

the greatest unit output of timber.

Proposed systems for the Steamboat project area include shelterwood and uneven-aged systems, which are 

acceptable systems under the Forest Plan (II-25). Uneven-aged systems are proposed for minor amounts and 

move toward specific habitat requirements (uneven stand structure, respectively). The shelterwood system is 

proposed on extensive areas in the action alternative. Research (Shepperd 2002) and past experience has 

shown the shelterwood method to be the most reliable in managing the Black Hills.

Even-aged Regeneration Harvests [16 USC 1604(g)(3)(F)]

 

Shelterwood regeneration harvests are appropriate to meeting the objectives and requirements of the Forest 

Plan. Overstory removals will be used as specified in the Phase II Amendment FEIS, Chapter 2, pg. 26. 

An interdisciplinary review was completed and the potential environmental, biological, aesthetic, engineering, 

and economic impacts were assessed and the cutting methods are consistent with the multiple use of the 

project area.

Cut blocks, patches, or strips are shaped and blended with the surrounding terrain to the extent practicable.

Even-aged regeneration harvests made in one operation meet the 40-acre maximum size limit requirement set 

as specified in Forest Plan standard 2101.

Harvest would be consistent with the protection of soil, watershed, fish, wildlife, recreation, aesthetic resources, 

cultural and historic resources, and the regeneration of timber resources.

See specific resource specialist reports for further details.
Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-6

Culmination of Mean Annual Increment [16 USC 1604(m)]

Culmination of mean annual increment occurs when the periodic annual increment exceeds mean annual 

increment.

Determination of CMAI

The stands or portions of stands receiving shelterwood regeneration harvest treatments have generally reached 

CMAI. Per the 1997 Forest Plan, stands that have reached an age of 120 years have reached CMAI. For this 

project area, stands that have met the 120 year age/CMAI requirement are assigned a seed cut or overstory 

removal prescription. It should be noted that some of these stands’ total age is less than 120 years but larger 

trees within that stand have reached 120 years; therefore, CMAI is met in these stands. Silvicultural 

prescriptions were developed while considering NFMA requirements about the timing of harvests. 16 USC 

1604(m)(1) states: “stands of trees shall generally have reached culmination of mean annual increment of 

growth”. The calculation of CMAI is based on the total amount of biomass accumulated in a stand to a specific 

date divided by age. Because stand age must be known, CMAI can only be calculated for even-aged or multiaged stands, but not uneven-aged stands. CMAI is calculated at the stand level, and not on individual trees. 

Even-aged harvests include clearcuts and shelterwood harvests. It is the accepted practice in the forestry 

profession to apply the CMAI standard to the timing of the regeneration step of even-aged harvests. For a twostep shelterwood, the determination is made at the seed step, and not the overstory removal step. 

16 USC 1604(m)(1) allows cultural practices or stand tending, such as commercial or non-commercial thinning, 

to occur prior to CMAI. 16 USC 1604(m)(2) allows harvest to occur prior to CMAI after consideration has been 

given to the multiple uses of the forest. Therefore, it doesn’t apply to the clearcuts and seed cuts of conifers in 

the Black Hills to benefit species, provide diversity, recreation, scenic variety or forage (these exceptions are 

disclosed and decided upon at the project level). It also doesn’t apply for non-commercial treatment of 

hardwoods. 

Although it is possible to approximate CMAI at the planning level (Forest-wide) for the purpose of establishing a 

rotation age, this is not to be confused with the stand CMAI requirement, which is the only requirement 

established by law, and that is actually measured/calculated on a stand basis. Because of the complexities of the 

calculation, CMAI can be accurately determined only at the project level. 

Although not legally required, for the purposes of establishing general rotation ages in FVS simulations, and to 

assure that the Forest Plan can be implemented, an analysis of approximate ranges of CMAI in the Black Hills 

was made. Although the CMAI determination is not straightforward, timber harvests used to implement the 

Revised Forest Plan will generally be able to meet the legal requirement. 

Growth curves developed for the Forest Vegetation Simulator (FVS) are not appropriate for determining CMAI. 

The curves include the growth of smaller aged cohorts of the strata. They also do not take into account the 

volume of trees that have been harvested in previous entries. 

The age at CMAI will vary depending on site quality, forest type, management intensities and utilization 

standards, but various analyses indicate that it generally will occur for most stands between 80 and 120 years 

for conifer sawtimber in the Black Hills. Timing of regeneration harvests for stands specified in FVS simulations

fall within or exceed this range. An analysis of the truly even-aged Stage I plots (4 out of 257 sawtimber and 5 

out of 56 pole plots) shows that the CMAI varied between 88 and 136 years with an average of 108 years. 

The silvicultural system most commonly used for ponderosa pine in the Black Hills is the shelterwood system, 

which is an even-aged system and an acceptable system as specified in the Phase II FEIS (Chapter II, pg. 25). 
Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-7

Most of the overstory removal cuts are in multi-aged stands or stands that have advanced regeneration. These 

treatments can also be considered as liberation cuts or stand improvements cuts. 

OSR = Overstory Removal (CMAI met)

SC = Shelterwood Cut or Shelterwood Tree Harvest (CMAI met)

All stands considered met either the exception to the requirement (multiple-use objective) or the requirement 

for CMAI itself. 

Table A-4. Stands Proposed for Removal or Shelterwood Treatments and CMAI Requirement.

Stand Number Site Index Stand Age Proposed Primary Treatment CMAI

081509 63 60 75 OSR Meets Requirement

089902 41 65 95 SC Meets Requirement

081706 49 60 112 SC Meets Requirement

089901 32 54 104 OSR Meets Requirement

081706 1 56 111 OSR Meets Requirement

081708 89 59 109 SC Meets Requirement

089902 15 51 101 SC Meets Requirement

081508 6 67 108 OSR Meets Requirement

089902 35 69 113 SC Meets Requirement

089904 10 59 112 SC Meets Requirement

081509 34 60 111 OSR Meets Requirement

081708 50 66 94 SC Meets Requirement

081706 60 58 97 SC Meets Requirement

081707 17 65 107 OSR Meets Requirement

081509 2 56 114 SC Meets Requirement

081507 41 57 43 OSR Meets Requirement

089904 37 79 103 SC Meets Requirement

089902 31 58 94 SC Meets Requirement

081706 51 51 104 SC Meets Requirement

089902 54 66 104 SC Meets Requirement

081510 12 56 111 SC Meets Requirement

089901 33 59 97 OSR Meets Requirement

089901 6 57 98 OSR Meets Requirement

081708 33 64 111 SC Meets Requirement

081708 77 65 107 SC Meets Requirement

089901 11 45 95 SC SS Needs

089903 117 57 92 OSR Meets Requirement

089903 104 50 55 SC SS Needs

089902 70 51 7 OSR Meets Requirement

089902 67 69 47 OSR Meets Requirement

081510 35 73 102 SC Meets Requirement

089903 111 70 0 SC SS Needs

081708 69 60 0 SC SS Needs
Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-8

Stand Number Site Index Stand Age Proposed Primary Treatment CMAI

081509 3 62 125 OSR Meets Requirement

081708 67 53 120 SC Meets Requirement

089901 61 56 119 SC Meets Requirement

089904 90 64 119 SC Meets Requirement

081706 52 56 131 OSR Meets Requirement

081707 8 59 135 OSR Meets Requirement

081708 71 60 127 SC Meets Requirement

081708 11 68 118 SC Meets Requirement

089904 133 61 129 SC Meets Requirement

081509 8 57 133 SC Meets Requirement

081506 73 62 125 SC Meets Requirement

081509 71 42 182 SC Meets Requirement

089902 55 58 115 SC Meets Requirement

081509 38 55 137 SC Meets Requirement

081708 6 71 120 SC Meets Requirement

081708 26 69 130 SC Meets Requirement

081706 42 61 127 SC Meets Requirement

081708 78 67 120 OSR Meets Requirement

081706 22 65 150 OSR Meets Requirement

089904 67 73 125 SC Meets Requirement

081509 56 45 129 SC Meets Requirement

089901 58 56 119 SC Meets Requirement

089902 27 65 125 OSR Meets Requirement

081508 7 55 128 OSR Meets Requirement

081708 70 76 123 SC Meets Requirement

081508 15 66 130 SC Meets Requirement

089904 61 51 120 SC Meets Requirement

081708 54 73 129 SC Meets Requirement

081509 40 54 155 SC Meets Requirement

081508 22 61 125 OSR Meets Requirement

081709 72 46 120 SC Meets Requirement

081510 24 57 133 SC Meets Requirement

089901 49 53 117 SC Meets Requirement

089902 42 52 122 SC Meets Requirement

081508 70 65 115 OSR Meets Requirement

081509 61 63 115 OSR Meets Requirement

081509 1 56 123 SC Meets Requirement

081510 50 52 148 SC Meets Requirement

081510 10 63 132 SC Meets Requirement

081708 42 65 125 SC Meets Requirement

081708 1 58 127 OSR Meets Requirement
Steamboat Project Final Environmental Impact Statement

Appendix B –Silvicultural Findings of Compliance with Laws, Regulations and Policy B-9

Findings prepared and

recommended by: /s/ Amy Haas Date: 4/29/11

 (R2 Certified Silviculturist)

Findings accepted by: /s/ Rhonda O’Byrne Date: 4/29/11

_____ District Ranger___________

 (Line Officer Title)

CMAI Discussion and Certification

The age at CMAI will vary depending on site quality, forest type, management intensities and utilization 

standards, but various analyses indicate that it generally will occur for most stands between 80 and 120 years 

for conifer sawtimber in the Black Hills. Timing of regeneration harvests for stands specified in FVS simulations 

fall within or exceed this range. Using the threshold of 120 years of age for CMAI (based on the Forest Plan)

there are 161 sites within the suitable timber base that have exceeded that threshold. 

Many of the sites are multi-storied or patchy containing components (overstory, understory, inclusions etc.) that 

are individually either below or above 120 year old threshold (CMAI). When inventoried, these components are 

all combined and an average age for the stand is computed. Since the age for the stand is an average of the age 

of each of its components, the stand average may fall above or below the age of each of its components. 

Although it is difficult to calculate the CMAI of the components of a stand, portions receiving regeneration 

treatments are similar to other even-aged mature stands in the area that are at CMAI and therefore have 

reached CMAI. The recommended treatments would remove (or regenerate in the case of inclusions) those 

components that show similarities with stands known to be at or beyond CMAI and manage those components 

below CMAI with intermediate treatments (i.e., non-commercial thinning, intermediate thinning).

I certify the stands receiving harvest treatments that are not exceptions to 16 USC 1604(i) have met the 

culmination of mean annual increment. Discussions of CMAI and exceptions to CMAI requirements can be 

found in the silviculture ‘Findings’ report or CMAI Calculations Table.

_/s/ Amy Haas______

Amy Haas

Silviculturist
Steamboat Project Final Environmental Impact Statement

Appendix B – Silvicultural Findings of Compliance with Laws, Regulations and Policy B-10

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