United States

Department of

Agriculture

Forest 

Service

September 2011

Decision Notice and 

Finding of No Significant 

Impact

and

Environmental Assessment

Briggs Spring

Hell Canyon Ranger District, Black Hills National Forest

Pennington County, South Dakota

T01N, R01E Sections 11-14, 21-28, 33-36 

T01S, R01E Sections 1-5, 9-16, 21-24, 28-30, 33-36 

T01S, R02E Sections 6-8, 18, 19, 30-32 

T02S, R02E Sections 5-8, 18, 19 

T02S, R01E Sections 1-5, 9-13, 243

For Information Contact: 

Wendy Steuerwald

330 Mt. Rushmore Road

Custer, SD 57730

Phone: (605) 673-4853

Email: wsteuerwald@fs.fed.us
Briggs Spring Decision Notice & Finding of No Significant Impact 

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Briggs Spring Decision Notice & Finding of No Significant Impact 

1

Decision Notice and Finding of No Significant Impact

Briggs Spring Project

USDA Forest Service

Hell Canyon Ranger District, Black Hills National Forest

Pennington County, South Dakota

Introduction

A Decision Notice (DN) and Finding of No Significant Impact (FONSI) are provided 

here. The DN documents my decision and provides my explanation of the management 

and environmental reasons that I used to make my decision in selecting an alternative to 

implement. The FONSI presents the reasons why I find this action will not have a 

significant effect on the human environment and therefore why an environmental impact 

statement will not be prepared. The completed Briggs Spring Environmental Assessment 

(EA) is incorporated by reference. 

Decision

Based upon my review of the Briggs Spring EA, I have decided to implement Alternative 

3, which was developed to address the key issues identified during scoping: 

1) effects of developing a new OHV campground; 

2) susceptibility to mountain pine beetles. 

To address issue #1, Alternative 3 foregoes the decision to develop of a new OHV 

campground. To address issue #2, Alternative 3 includes additional group shelterwood 

and sanitation treatments in more ponderosa pine stands to further reduce the 

susceptibility to MPB caused mortality in the project area.

Alternative 3 includes the following commercial treatments. All commercial treatments 

include sanitation. 

Treatment Acres

Commercial Thin (CT) 2,204

Group Shelterwood (GRSH) 13,845

Hardwood Release (HWDR) 259

Hardwood Conversion (HWDC) 123

Overstory Removal (OR) 138

Shelterwood Seed Cut (SWSC) 479

Pine Encroachment* (PE) 2,674

Sanitation** 3,678

*Commercial and non-commercial PE treatments would occur on the same acres.

**These acres are planned for sanitation treatment only. All other commercial treatments would include 

sanitation. 
Briggs Spring Decision Notice & Finding of No Significant Impact 

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The following noncommercial treatments are included in Alternative 3. 

Treatment Acres

Pine Encroachment* (PE) 2,674

POL (Products Other than Logs) 

Thinning

8,889

POL Thinning/HWDR** 1,021

Hardwood Release (HWDR) 564

POL Thinning/Deadfall 300

Mechanical Fuels Treatment 1,274

Deadfall 1,693

Prescription (Rx) Burning 7,009

*Commercial and non-commercial PE treatments would occur on the same acres. 

**Commercial and non-commercial HWDR treatments would occur on some of the same acres. 

Alternative 3 would produce approximately 41,531 hundred cubic feet (CCF) of 

commercial sawlog volume and approximately 9,931 CCF of POL as a byproduct of the 

mechanical treatments. In addition, 77.3 miles of roads would be maintained, 33.4 miles 

would be reconstructed, and 0.8 miles of an existing unauthorized road would be 

reconstructed and converted to a Forest system road as part of the mechanical treatments 

proposed in this alternative. See pages 13-14 for maps of Alternative 3. Appendix A of 

the EA includes a vicinity map and detailed maps of the project area and activities. 

Please refer to Map 4-Tiles 1-3 and Map 5-Tiles 1-2, Appendix A, for a detailed view of 

Alternative 3 treatment areas.

Decision Rationale

The purpose and need for action in the Briggs Spring project area is to;

1. Maintain forest health by reducing the potential for mountain pine beetle caused 

mortality

2. Provide for a sustainable supply of commercial timber to contribute to Forest Plan 

Objective 303

3. Manage fuels in order to reduce losses of timber and other desired forest habitat 

and to reduce the risk of large-scale, high intensity wildfire

4. Provide a developed recreation campground facility for Off Highway Vehicle 

(OHV) recreational use, which complements the newly designated trail system.

The Briggs Spring project purpose and need provides the focus and scope for the 

proposed action and alternatives under direction of the 1997 Revised Black Hills National 

Forest Land and Resource Management Plan, as amended by the 2006 Phase II 

Amendment (Forest Plan). Forest Plan direction is summarized in Chapter 1 of the 

Briggs Spring EA. Given the purpose of and need for action, I reviewed Forest Plan 

direction, public comments received on the Draft EA, key issues identified from those 

comments, information contained within the project record, and the analysis disclosed in 

the EA. My decision to implement Alternative 3 is based on this review.
Briggs Spring Decision Notice & Finding of No Significant Impact 

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Three alternatives (one no action and two action) were analyzed in detail in the Briggs 

Spring EA. I have selected Alternative 3 because I feel it best meets the purpose of and 

need for action, is consistent with the Forest Plan, follows other management direction, 

and responds well to the public comments received and issues identified. 

Key issues raised during public scoping include 1) effects of developing a new OHV 

campground and 2) susceptibility to mountain pine beetles. In determining which 

alternative to select for this project, I first considered whether active management would 

be appropriate in this area at this time. After reviewing all materials related to the 

project, including Forest Plan direction, supporting documents, public input and 

specialist’s reports, I believe that active management is appropriate and I reject 

Alternative 1 (No Action). My rationale follows:

After reviewing the silviculture specialist’s report, I learned that currently there are 

approximately 7,632 acres of ponderosa pine stands (approximately 35% of pine stands 

in the project area) at high risk to mountain pine beetle (MPB) infestation and 12,857 

acres (60%) at medium risk. Potential for increased MPB infestation is greater with high 

risk stands. Patches of dead trees ranging from one or two trees to larger groups of 

infested trees could be found in almost every site of the project area. Through 

observation over several years in the project area, increased MPB activity has been noted. 

I believe that, given the percentage of high and medium risk stands in the project area, 

MPB caused mortality will continue to increase and may reach outbreak levels. In the 

Black Hills National Forest thinning dense stands has been very effective in reducing 

MPB susceptibility. Current MPB infestations are spreading into dense stands 

throughout the Black Hills National Forest and infestations would be expected to increase 

throughout the project area. Mountain pine beetle mortality across the Black Hills 

National Forest continues to increase. In 2010, the mapped acreage affected by MPB 

doubled across the Forest, as compared with acres attributed to MPB during each of the 

previous three years, representing significant new pine mortality (Schaupp, 2011). 

Alternative 3 includes increased acres of sanitation and thinning over those proposed in 

Alternative 2, reducing the potential for MPB caused mortality over more area. I realize 

that acres of high, medium and low risk are the same for both action alternatives, but the 

additional treatment in Alternative 3 does reduce the potential for MPB caused mortality. 

The additional treatment in Alternative 3 focuses on the higher density 4A stands, but 

does not change the structural stage. By treating the 4A stands with the denser crown 

closure the potential for MPB caused mortality would be reduced. The medium risk 

rating does not change, however as all 4A stands are considered a medium risk for MPB.

There are no At-Risk Communities (ARC) located within the Briggs Spring project area 

however, five ARC are located less than six miles from the project boundary with one 

being within one mile of the project boundary. Fifty-four percent of the project area has 

a fire hazard rating of High to Very High. In an area such as Briggs Spring, where high 

risk coincides with high hazard, the probability of fire with undesirable conditions is 

more likely and could be very detrimental to many of the values existing in and around 

this project area. Prescribed burning as described in Alternative 3, is expected to reduce 

unnatural buildup of fuels that has accumulated due to decades of effective fire 

suppression and recent storm damage events, it is also expected to reduce the threat and 

risk of large scale, high intensity wildfire. 
Briggs Spring Decision Notice & Finding of No Significant Impact 

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Finally, I considered whether a new campground should be developed for OHV 

recreational use in this project area. Providing a developed campground facility for OHV 

recreation is part of the purpose and need of this project. Alternative 3 does not provide a 

new facility, but in the near future, would rely on the existing campground facilities 

within and near the project area. Currently there are three developed campgrounds 

available within or near the project area and all are used by OHV recreationists. Redbank 

Spring Campground is within the project area and Beaver Creek and Ditch Creek 

Campgrounds are both within eight miles or less of the project area and available for use. 

Comment letters from private land owners expressed concern over developing a new 

campground in the area, as proposed in Alternative 2. These concerns were raised 

through comments about noise pollution, wildlife disturbance, and degrading the land 

owner’s experience on their own property. One commentor suggested promoting exiting 

campgrounds rather than spending money to build a new one. Another commentor 

stated, “...while I agree that there may be an additional need for more camping spaces 

especially for off road users, I certainly don’t agree that the solution is to create a new 

campground as we already have Redbank Springs and Ditch Creek Campground within 

close proximity.” Since Redbank Spring Campground is within the Briggs Spring project 

area, specialists looked at the possibility to expand that campground. Due to several 

resource conflicts, it could not be expanded without significant impacts, primarily to the 

heritage resources. Secondly, the decision to establish motorized trails on the Forest was 

made in December of 2010, and use patterns by OHV recreationists have not been well 

established at this time. 

I believe Alternative 3 would provide the best option for OHV recreation at this time, 

which is promoting the use of exiting campgrounds. At a future date, another analysis 

focused primarily on OHV use in the broader area and after motorized recreation patterns 

are more established, would be more appropriate. For all of these reasons, I believe that 

Alternative 3 best addresses the purpose and need for action, key issues, and public 

comments. 

Other Alternatives Considered

In addition to the selected action, I considered 2 other alternatives in detail. A brief 

summary of these alternatives is presented below. Further information on the alternatives 

can be found in Chapter 2 of the EA and in Appendix A, Maps.

Alternative 1 – No Action

NEPA (National Environmental Policy Act) requires the study of the No Action 

Alternative and that it be used as a basis for comparing the effects of the proposed action 

and other alternatives. The No Action alternative assumes no implementation of any 

elements of the proposed action or other action alternatives would take place in the 

project area. Actions analyzed under past projects or proposed by future projects may still 

occur. This alternative was not selected for reasons stated earlier. 
Briggs Spring Decision Notice & Finding of No Significant Impact 

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Alternative 2 – Proposed Action 

Alternative 2 is the proposed action. It was developed in response to the purpose and 

need for action and was presented to the public during scoping. This alternative would 

improve forest health in the project area by reducing overall susceptibility to mountain 

pine beetle, but to a lesser extent than alternative 3. This alternative also includes the 

development of a new campground for OHV users. This alternative was not selected for 

reasons stated above under ‘Decision Rationale’. 

Alternatives Not Considered in Detail

The Briggs Spring IDT also considered an additional alternative which would have 

expanded the existing Redbank Spring campground to increase overall capacity and to 

provide features conducive to OHV users, such as trailer parking and pull though camp 

sites. A heritage resource survey was conducted in the potential expansion area. It was 

determined that an eligible heritage site extends into this area and any ground disturbance 

would damage the site. Therefore, expanding Redbank Spring campground was not 

considered in detail.

Public Involvement

Scoping

This proposal was listed in the Black Hills National Forest Schedule of Proposed Actions 

in October 2010. The proposal was provided to the public and other agencies and tribes

for comment on October 14, 2010. A detailed scoping document was mailed to 

approximately 108 individuals, tribal representatives, groups, government agencies and 

other interested members of the public. Scoping documents were also uploaded to the 

forest website in October 2010. Eleven scoping comments were received and can be 

found in the project record. Scoping results were used to confirm issues analyzed in this 

document and identify a reasonable range of project alternatives. 

EA Distribution

On July 8, 2011, a legal notice was published in the Rapid City Journal notifying the 

public of their opportunity to comment on the Briggs Spring Project Environmental 

Assessment (July 2011 EA). Copies of the July 2011 EA were mailed to 18 individuals, 

groups and state and local agencies who expressed interest in the project and to 33 tribal 

representatives. The EA was also posted on the Forest website. The comment period

concluded on August 8, 2011. Eight responses were received within the comment period 

and two comments were received after the comment period concluded. See Appendix H

in the EA for responses to comments. None of these comments generated a need for reanalysis or required major substantive changes in the document, although minor factual 

corrections and clarifications have been made to the EA in response to these comments, 

as described in Appendix H of the EA. All letters received are contained within the 

project file.

Best Available Science

My decision is based upon consideration for the best available science. I have reviewed 

the record and found it contains a thorough review of relevant scientific information and 

responsible opposing views. Where appropriate, the record acknowledges incomplete or 

unavailable information, and scientific uncertainty and risk. Specifically, the extensive 

literature citations in both the specialists reports in the project record and in Chapter 5 of 
Briggs Spring Decision Notice & Finding of No Significant Impact 

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the EA shows that relevant literature was reviewed and considered by resource 

specialists. 

In addition, the EA and project record show that literature cited by the public during the 

scoping period and during the comment period was reviewed and considered by resource 

specialists on the Briggs Spring project Interdisciplinary Team. Finally, resource 

specialists acknowledge in the project file their use of the best science available to them 

in preparation of the EA. 

Finding of No Significant Impact

I have reviewed the environmental effects of the selected alternative as disclosed in the 

EA. I have also evaluated whether the selected alternative constitutes a significant 

impact on the quality of the human environment or whether the environmental impacts 

would be significant based on their context and intensity, as defined by the National 

Environmental Policy Act (NEPA) using the criteria in the implementing regulations (40 

CFR §1508.27).

After considering the effects of the actions analyzed, in terms of context and intensity, I 

have determined that these actions will not have significant effect on the quality of the 

human environment. Therefore an environmental impact statement will not be prepared. 

1. Context – This project is local and would affect only the project area. The issues 

identified during scoping and considered in alternative development and analysis are 

local in nature. Effects are limited to the vicinity of the planned activities. The selected 

alternative is consistent with the requirements of the Forest Plan and contributes to 

moving toward or meeting the goals and objectives of the Forest Plan. None of the effects 

disclosed in the Briggs Spring EA are different from those anticipated in the FEIS for the 

Forest Plan or the FEIS for the Phase II Amendment.

2. Intensity –

• Beneficial and adverse impacts of this decision were considered and are addressed 

in Chapter 3 of the EA. My decision is not biased by the beneficial effects of the 

action.

• Effects on public health and safety were considered. No significant public health 

and safety issues were identified during the analysis process. Public safety may 

be improved by the reduction of fire hazard and mountain pine beetle 

susceptibility. 

• There are no known unique characteristics in the area, such as proximity to 

historic or cultural resources, park lands, prime farmlands, wetlands, wild and 

scenic rivers or ecologically critical areas located in the project area. No adverse 

direct and indirect effects will occur to wetlands, prime farmlands, wild and 

scenic rivers or ecological critical areas, as they are either not present or will be 

protected by project design features, as shown in Chapter 3 of the EA. Project 

design criteria (EA, Appendix B) include measures to protect riparian areas and to 

protect and monitor cultural resources. Archaeological sites will maintain their 

National Register eligibility characteristics. For these reasons, there will be no 

adverse effects on unique characteristics of the area.
Briggs Spring Decision Notice & Finding of No Significant Impact 

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• The effects on the quality of the human environment are not likely to be highly 

controversial. The effects on biological diversity, water quality, soils and other 

elements of the environment have been described and design criteria have been 

included, such that this project contributes to maintaining habitat for viable 

populations of plant and animal species, as well as to maintaining water quality 

and soil productivity. No new or unusual methods or activities are proposed. The 

effects on the human environment are not highly uncertain, are very unlikely to 

involve unique or unknown risks, and are not likely to be highly controversial 

because effects of the project are expected to be similar to those of past projects 

and are well understood (EA, Chapter 3).

• The action is not likely to establish a precedent for future actions with significant 

effects (EA, Chapter 1). The action does not represent a decision in principle 

about future considerations. Similar projects conducted in the future will have to 

be evaluated under the National Environmental Policy Act (NEPA) for the 

significance of the effects of those specific actions.

• The cumulative actions considered in the environmental analysis are discussed by 

resource in Chapter 3 of the EA. The cumulative impacts of the proposed action, 

including connected actions, were considered with other past, present, and 

reasonably foreseeable actions (see EA, Chapter 3).

• The potential effects on cultural resources have been considered in the analysis. 

No adverse effects are anticipated. A heritage resource inventory was completed 

for the project area; the survey protocol was concurred with by the South Dakota 

State Historic Preservation Office on September 6, 2011. In a letter dated 

September 6, 2011, SHPO concurred that the project will have no adverse effect 

on heritage resources.

• The action will not adversely affect any endangered or threatened species or its 

habitat that has been determined to be critical under the Endangered Species act 

of 1973, because federally listed species or designated critical habitat do not occur 

within the project area (EA, Chapter 3). A determination for Forest Service 

Region 2 sensitive species for the selected Alternative found that there will be no 

trend towards Federal listing or loss of viability in the planning area, including 

fish, wildlife and plants (EA, Chapter 3). These BA/Es are part of the project 

record and were used in preparation of the EA. In addition, a Management 

Indicator Species (MIS) analysis for this project was completed and it determined 

that the proposed action, and its relationship to MIS species and the habitat types 

they represent, is not expected to impact the viability of these species in the future 

(EA, Chapter 3)

• As described in more detail below, the selected action will not violate federal, 

state, or local laws or requirements for the protection of the environment. 

Applicable laws and regulations were considered in the EA (EA, Chapter 3). All 

state water quality requirements will be met as well as other federal, state, and 

local requirements imposed for the protection of the environment. Effects on 

water quality, floodplains, and wetlands are documented in the EA and project 

file. Design criteria will be used to protect water quality and to meet standards 

imposed by the Forest Plan and the State. No violations of environmental laws 

and requirements were identified through the environmental effects analysis. The 

action is consistent with the Black Hills National Forest Land and Resource

Management Plan.
Briggs Spring Decision Notice & Finding of No Significant Impact 

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Findings Required by Other Laws and Regulations

The National Historic Preservation Act of 1966, as Amended

Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies 

to consider the potential effects of undertakings on historic, architectural or 

archaeological resources that are eligible for inclusion on the National Register of 

Historic Places (NRHP).

Potential impacts to these resources have been evaluated in compliance with Section 106 

of the NHPA. Proposed actions and monitoring are a component of Alternative 3 for the 

purpose of minimizing or avoiding impacts, as described in more detail in the EA. For 

purposes of section 106 consultation, implementation of Alternative 3 would result in no 

adverse effect to cultural resources. The South Dakota SHPO concurred with this finding 

on September 6, 2011. This letter is in the project file. The cultural resource section of 

the EA and the cultural resources report provide more detail on this determination.

The National Environmental Policy Act (NEPA), 1969

The National Environmental Policy Act requires federal agencies to analyze and disclose 

the effects of proposed actions that significantly affect the quality of the human 

environment. The Act’s requirement to prepare an environmental impact statement is 

designed to provide decision makers with a detailed accounting of the likely 

environmental effects of a proposed action prior to adoption and to inform the public of 

such effects. The Act establishes the format and content requirements of environmental 

analysis and documentation. The process of preparing the Briggs Spring EA, DN and 

FONSI was completed in accordance with this Act.

The Endangered Species Act, 1973

Separate Botany and Wildlife Biological Assessment and Evaluations (BA/Es) have been 

prepared to document possible effects of any activities on endangered, threatened, 

proposed or sensitive species in the Briggs Spring project area. A determination was 

made that no threatened or endangered species currently exist in the project area, nor 

does the project area contain critical habitat for any listed species. Therefore, the Briggs 

Spring project would have “No Effect” on threatened, endangered or proposed species 

and no impact on critical habitat. The effects of the Briggs Spring project on Region 2 

sensitive species were analyzed and documented in both the Botany BA/BE and the 

Wildlife and Fish BA/BE for this project. These documents were used in the preparation 

of these sections of Chapter 3 of the EA and each document is included in full in the 

project file. Determinations of effect to sensitive species are summarized in the EA and 

range from no effect to may affect, but not likely to result in a trend toward federal listing 

or loss of viability.

The Clean Water Act

This act establishes a non-degradation policy for all federally proposed projects. There 

are approximately 0.7 miles of perennial streams and 85 miles of intermittent or 

ephemeral streams within the project area; the majority of these are intermittent. None of 

the streams within the Briggs Spring project area or water resources analysis areas are 

listed specifically for other beneficial uses due to the lack of continuous surface water. 

No water bodies within the Briggs Spring project area are currently listed as impaired 
Briggs Spring Decision Notice & Finding of No Significant Impact 

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(SD DENR, 2010), nor have they been listed on previous years reports (SD DENR, 1998; 

2002; 2004; 2006; 2008). 

Proposed timber and fuels management, and prescribed burning activities associated with 

Alternative 3 are not expected to degrade water quality or exceed state specified 

thresholds for the various water quality parameters associated with each beneficial use. 

This will be accomplished through planning, application, and monitoring and 

implementation of design criteria associated with project activities.

Clean Air Act of 1970

The Clean Air Act of 1970 and its amendments provide for protecting and enhancing the 

nation’s air resources. Federal and state ambient air quality standards are not expected to 

be affected or exceeded by implementing the selected action. This action is consistent 

with the Clean Air Act.

Executive Order 11988 – Floodplain Management

As outlined in the Soils and Hydrology section of Chapter 3 of the EA, floodplains will 

not be measurably, negatively affected by implementation. This project is in compliance 

and meets the requirements of the Executive Order for Floodplain Management.

Executive Order 11990 – Protection of Wetlands

As outlined in the EA, there are 27 acres of wetlands mapped by NWI within the project 

area. These are associated with 69 different wetland areas, many of which are associated 

with impoundments used primarily for stock watering. Alternative 3 is expected to 

maintain current conditions of wetlands and riparian areas through implementation of 

design criteria and WCPs/BMPs (Appendix B of the EA). Some improvements in 

condition may occur where road-related problems are addressed through commercial 

timber harvest road work. Alternative 3 is consistent with this Order. 

Executive Order 12898 – Environmental Justice

Executive Order 12898 directs Federal agencies to focus attention on human health and 

environmental conditions in minority communities and low-income communities. The 

purpose of the executive order is to identify and address, as appropriate, 

disproportionately high and adverse human health or environmental effects on minority 

populations and low-income populations. None of the counties in the study area contain 

low-income or minority populations as defined by Executive Order 12898. There would 

be no disproportionate negative effect on such communities under any of the alternatives. 

Public involvement efforts used for this project provided ample opportunity for 

participation in the analysis process. Implementing this decision will not subject anyone 

to discrimination because of his or her race, color or national origin.

Executive order 11593, entitled Protection and Enhancement of the Cultural 

Environment

The Order, issued May 13, 1971, directs federal agencies to inventory cultural resources 

under their jurisdiction, to nominate to the NRHP all federally owned properties that meet 

the criteria, to use due caution until the inventory and nomination processes are 

completed, and to assure that federal plans and programs contribute to preservation and 

enhancement of non-federally owned properties. This project satisfies the requirements of 

E.O. 11593.
Briggs Spring Decision Notice & Finding of No Significant Impact 

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Executive Order 13112

Executive order 13112 directs that federal agencies not carry out actions that would cause 

the introduction or spread of invasive species, unless the agency determines that the 

benefits of such actions clearly outweigh the potential harm, and that all feasible and 

prudent measures to minimize risk to harm will be taken. The risk of noxious weed 

introduction and spread was evaluated in the EA (Botany, Rangeland, and Noxious 

Weeds section of Chapter 3). Analysis concluded that while there is some risk of spread, 

this would be minimized by implementation of project design features and adherence to 

Forest Plan Standards and Guidelines.

Executive Order 13186, Migratory Birds

This project is fully consistent with this executive order. Migratory birds were fully 

evaluated in the Wildlife Report and the Wildlife section of Chapter 3 of the EA. 

Populations are expected to remain stable under implementation of the selected 

alternative and some habitats may improve.

The National Forest Management Act (NFMA) 1976, which amends the

Forest and Rangeland Renewable Resources Planning Act (RPA) of 1974

All alternatives were developed to be in full compliance with NFMA as summarized 

below.

Consistency with the Land and Resource Management Plan

The NFMA law (16 U.S.C. 1604(i)) requires me to ensure that permits, contracts, 

cooperative agreements, and other activities carried out on the Black Hills National 

Forest are consistent with the Forest Plan. My decision is consistent with the 1997 Black 

Hills National Forest Land and Resource Management Plan, as Amended.

• Planned activities will contribute to Forest Plan goals and objectives (EA, Chapter 

1)

• I have reviewed the Black Hills National Forest Region 2 Management Indicator 

Species (MIS) guidance for projects. The effects of planned activities on

management indicator species are consistent with the Forest Plan (EA, Chapter 3).

• Planned activities are consistent with management area direction (EA, Chapter 1).

• Planned activities comply with Forest Plan Standards and Guidelines (EA, 

Chapters 1 and 3)

• Planned activities are consistent with the Watershed Conservation Practices 

Handbook.

Consistency with the National Forest Management Act

The transition language in the 2000 planning rule and interpretive rules explain that the 

1982 rule is not in effect. Projects such as this must be developed considering the best 

available science, and must be consistent with the Forest Plan. (74 FR 67073).

The scope of analysis for a Forest Plan’s management indicator species is determined by 

the Forest Plan’s management direction, specifically, its standards and guidelines 

(Chapter II) and monitoring direction (Chapter IV). The Black Hills National Forest, 

Forest Plan contains no obligation to conduct project-specific monitoring or surveying for 

management indicator species. Phase II Record of Decision, pages 8 and 20; Forest Plan 

as Amended, page I-11, Objective 238. The Forest Plan establishes monitoring and 
Briggs Spring Decision Notice & Finding of No Significant Impact 

11

evaluation requirements that do not require population monitoring for MIS, but rather 

employ habitat relationships (Phase II ROD, pp. 20; Forest Plan as Amended, pg. I-11, 

Objective 238). The Briggs Spring project analyzed several management indicator

species (white-tailed deer, grasshopper sparrow, black-backed woodpecker, brown

creeper, and ruffed grouse) because habitat for these species is available in the project 

area. Populations of MIS evaluated are likely to persist on the Forest under Alternative 3; 

populations would remain stable.

Alternative 3 is consistent with the requirements in the Forest Plan because: 

• It is consistent with objective 238a to maintain or enhance habitat for ruffed 

grouse, white-tailed deer, brown creeper and grasshopper sparrow. See species 

discussions in Chapter 3 of the EA. 

• It is consistent with objective 238b to maintain habitat opportunities for blackbacked woodpeckers. See species discussion in Chapter 3 of the EA.

• It is consistent with objective 221 to conserve or enhance habitat for R2 sensitive 

species and species of local concern. Refer to species discussions in Chapter 3 of 

the EA and to the Wildlife and Fish Biological Assessment/Biological Evaluation. 

Alternative 3 is further consistent with the Forest Plan because it meets the following 

standards: 

• 1101, 1102, 1103, 1301 regarding soil productivity, compaction, erosion, 

disturbance and stream health. Refer to the soil and water discussion in Chapter 3 

of the EA, as well as design criteria in Appendix B. 

• 2205 regarding treatments within mixed conifer/hardwood stands. Refer to 

Chapter 3 discussion of quaking aspen.

Administrative Review (Appeal) Opportunities

This decision is subject to administrative review (appeal) pursuant to 36 Code of Federal 

Regulations (CFR) Part 215. A written appeal must be submitted within 45 days 

following the publication date of the legal notice of this decision in the Rapid City 

Journal, Rapid City, South Dakota. It is the responsibility of the appellant to ensure their 

appeal is received in a timely manner. The publication date of the legal notice of the 

decision in the newspaper of record is the exclusive means for calculating the time to file 

an appeal. Appellants should not rely on date or timeframe information provided by any 

other source. 

Paper appeals must be submitted to: 

Black Hills National Forest Supervisor’s Office

Appeal Deciding Officer

Attn: Ed Fischer

1019 N. Fifth Street

Custer, SD 57730

Phone: (605) 673-9200

Fax: (605) 673-9350

Email: appeals-rocky-mountain-black-hills@fs.fed.us
Briggs Spring Decision Notice & Finding of No Significant Impact 

12

Appeals may be hand-delivered to the office address above between the hours of 8:00 am 

and 4:30 pm, Monday through Friday, excluding Federal holidays.

For appeals filed electronically, the name of the project decision being appealed should 

appear in the subject line. Electronically filed appeals must be readable in Microsoft 

Word, Rich Text or Adobe pdf formats. When an appeal is electronically mailed, the 

appellant should normally receive an automated electronic acknowledgement confirming 

agency receipt. If the appellant does not receive an automated acknowledgement of the 

receipt of the appeal, it is the appellant’s responsibility to ensure timely receipt by other 

means (§ 215.15(c)(3)).

It is an appellant’s responsibility to provide sufficient activity-specific evidence and 

rationale, focusing on the decision, to show why my decision should be reversed. At a 

minimum, an appeal must meet the content requirements of 36 CFR 215.14 and include 

the following information:

1. Appellant’s name and address (§ 215.2), with a telephone number, if available;

2. Signature or other verification of authorship upon request (a scanned signature for

electronic mail may be filed with the appeal);

3. When multiple names are listed on an appeal, identification of the lead appellant 

(§215.2) and verification of the identity of the lead appellant upon request;

4. The name of the project or activity for which the decision was made, the name 

and title of the Responsible Official, and the date of the decision; 

5. The regulation under which the appeal is being filed, when there is an option to 

appeal under either this part or part 251, subpart C (§ 215.11(d));

6. Any specific change(s) in the decision that the appellant seeks, and rationale for 

those changes;

7. Any portion(s) of the decision with which the appellant disagrees, and explanation 

for the disagreement;

8. Why the appellant believes the Responsible Official’s decision failed to consider 

the substantive comments; and

9. How the appellant believes the decision specifically violates law, regulation or 

policy.

Notices of Appeal that do not meet the requirements of 36 CFR 215.14 will be dismissed.

To be eligible to appeal this decision on this project, an individual or group must have 

provided a comment or otherwise expressed interest in this project by the close of the 

comment period.

Implementation Date

Pursuant to 36 CFR Part 215, if no appeal is filed within the 45-day time period, 

implementation of this decision may occur on, but not before, five business days from the 

close of the appeal filing period. If an appeal is received, implementation may occur on, 

but not before, the 15th business day following the date of the last appeal disposition. 
Briggs Spring Decision Notice & Finding of No Significant Impact 

13

Contact

For additional information concerning this decision, contact Lynn Kolund, District 

Ranger, Hell Canyon Ranger District, 330 Mt. Rushmore Road, Custer, SD, 57730 (605-

673-4853). For further information on the Forest Service appeal process, contact Ed 

Fisher, Environmental Coordinator, Black Hills National Forest, 1019 N. 5th Street, 

Custer, SD, 57730. 
Briggs Spring Decision Notice & Finding of No Significant Impact 

14
Briggs Spring Decision Notice & Finding of No Significant Impact 

15

United States

Department of

Agriculture

Forest 

Service

September 2011

Environmental 

Assessment

Briggs Spring

Hell Canyon Ranger District, Black Hills National Forest

Pennington County, South Dakota

T01N, R01E Sections 11-14, 21-28, 33-36 

T01S, R01E Sections 1-5, 9-16, 21-24, 28-30, 33-36 

T01S, R02E Sections 6-8, 18, 19, 30-32 

T02S, R02E Sections 5-8, 18, 19 

T02S, R01E Sections 1-5, 9-13, 243

For Information Contact: 

Wendy Steuerwald

330 Mt. Rushmore Road

Custer, SD 57730

Phone: (605) 673-4853

Email: wsteuerwald@fs.fed.us
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its 

programs and activities on the basis of race, color, national origin, age, disability, 

and where applicable, sex, marital status, familial status, parental status, religion, 

sexual orientation, genetic information, political beliefs, reprisal, or because all or 

part of an individual’s income is derived from any public assistance program. (Not 

all prohibited bases apply to all programs.) Persons with disabilities who require 

alternative means for communication of program information (Braille, large-print, 

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

and TDD).

To file a complaint of discrimination, write to USDA, Director, Office of Civil 

Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call 

(800)795-3272 (voice) or (202)720-6382 (TDD). USDA is an equal opportunity 

provider and employer.
Briggs Spring Environmental Assessment 

Table of Contents

Table of Contents

Summary............................................................................................................................. i

Chapter 1: Introduction .................................................................................................. 1

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

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

Location............................................................................................................................2

Management Direction.....................................................................................................2

Purpose and Need for Action ...........................................................................................4

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

Decision Framework ........................................................................................................5

Public Involvement ..........................................................................................................5

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

Chapter 2: Comparison of Alternatives, Including the Proposed Action....................6

Alternatives Considered in Detail ....................................................................................6

Alternative 1 – No Action........................................................................................6

Alternative 2 – Proposed Action..............................................................................6

Alternative 3...........................................................................................................12

Design Criteria ...............................................................................................................16

Alternatives Not Considered in Detail ...........................................................................16

Comparison of Alternatives ...........................................................................................17

Chapter 3: Affected Environment and Environmental Consequences......................21

Past, Present, and Reasonably Foreseeable Future Activities........................................21

Forest Vegetation..........................................................................................................21

Affected Environment............................................................................................21

Environmental Consequences................................................................................27

Wildlife ..........................................................................................................................38

Affected Environment............................................................................................38

Snags and Down Woody Material .............................................................38

Riparian Habitat.........................................................................................39
Briggs Spring Environmental Assessment 

Table of Contents

Management Indicator Species (MIS) .......................................................39

Species of Local Concern (SOLC) ............................................................42

Threatened and Endangered Species .........................................................48

Region 2 (R2) Sensitive Species................................................................49

Migratory Birds..........................................................................................54

Demand Species.........................................................................................55

Environmental Consequences................................................................................56

Snags and Down Woody Material .............................................................56

Riparian Habitat.........................................................................................57

Management Indicator Species (MIS) .......................................................58

Species of Local Concern (SOLC) ............................................................61

Threatened and Endangered Species .........................................................68

Region 2 (R2) Sensitive Species................................................................68

Migratory Birds..........................................................................................75

Demand Species.........................................................................................76

Fire and Fuels...............................................................................................................78

Affected Environment............................................................................................78

Environmental Consequences................................................................................85

Botany, Rangeland, and Noxious Weeds....................................................................91

Affected Environment............................................................................................91

Environmental Consequences................................................................................95

Minerals and Geologic Resources.............................................................................101

Affected Environment..........................................................................................101

Environmental Consequences..............................................................................102

Lands and Special Uses..............................................................................................102

Affected Environment..........................................................................................102

Environmental Consequences..............................................................................103

Heritage Resources.....................................................................................................104

Affected Environment..........................................................................................104

Environmental Consequences..............................................................................105

Scenery ........................................................................................................................106
Briggs Spring Environmental Assessment 

Table of Contents

Affected Environment..........................................................................................106

Environmental Consequences..............................................................................107

Transportation............................................................................................................111

Affected Environment..........................................................................................111

Environmental Consequences..............................................................................112

Recreation ...................................................................................................................114

Affected Environment..........................................................................................114

Environmental Consequences..............................................................................117

Soils and Water Resources ........................................................................................119

Soils - Affected Environment ..............................................................................119

Soils - Environmental Consequences...................................................................123

Water Resources - Affected Environment ...........................................................129

Water Resources - Environmental Consequences ...............................................134

Chapter 4: Consultation and Coordination................................................................140

Chapter 5: Literature Cited and Glossary .................................................................146

Literature Cited ....................................................................................................146

Glossary ...............................................................................................................156

List of Tables and Figures

Table 1. Alternative 2-Proposed Action commercial treatments ...................................7

Table 2. Alternative 2-Proposed Action non-commercial treatments.............................9

Table 3. Alternative 3 commercial treatments .............................................................12

Table 4. Alternative 4 non-commercial treatments ......................................................13

Table 5. Comparison of commercial treatments by alternative ...................................17

Table 6. Comparison of non-commercial treatments by alternative ............................18

Table 7. Comparison of structural stages (SS) by cover type for all alternatives ........19

Table 8. Total miles of all Forest system roads and OHV trails on National Forest 

lands within the project area, by alternative ..................................................................19

Table 9. Total miles of Forest system roads within the project areas, for all alternatives 

........................................................................................................................................19
Briggs Spring Environmental Assessment 

Table of Contents

Table 10. Total miles of Forest system OHV trails within the project area, by 

alternative ......................................................................................................................19

Table 11. Road density for all Forest system roads on National Forest lands within the 

project area, by alternative ............................................................................................20

Table 12. Effects of issues by alternative......................................................................20

Table 13. Existing cover types in the Briggs Spring project area ................................22

Table 14. Existing structural stages (SS) by cover type in the Briggs Spring project 

area (shown in acres)......................................................................................................22

Table 15. Structural stage objective percentages for ponderosa pine in MA 5.1 across 

the Black Hills National Forest .....................................................................................23

Table 16. Forest Plan objectives versus existing ponderosa pine structural stage 

distribution in MA 5.1 across the Black Hills National Forest (USDA Forest Service, 

2010) ..............................................................................................................................24

Table 17. Forest Plan objectives versus existing condition of ‘VL’ tree size 

distribution in MA 5.1 across the Black Hills National Forest (USDA Forest Service, 

2010)...............................................................................................................................24

Table 18. Current MPB rating for ponderosa pine in the Briggs Spring project area 

........................................................................................................................................25

Table 19. Structural stage/MPB risk rating relationship ..............................................25

Table 20. Alternative 1-MPB risk rating for the Briggs Spring project area ...............28

Table 21. Alternative 2-ponderosa pine structural stages throughout MA 5.1, across 

the Black Hills National Forest .....................................................................................32

Table 22. Mountain pine beetle risk rating – Comparison for all alternatives .............33

Table 23. Existing screening cover in the Briggs Spring project area on Forest lands

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

Table 24. Fire regimes in the Black Hills (USDA Forest Service, 2005).....................78

Table 25. Fire Regime Condition Class (FRCC) rating descriptions (Hann et al., 2003)

........................................................................................................................................79

Table 26. Known fire history in the Briggs Spring project area from 1950 to present 

........................................................................................................................................81

Table 27. Area of each large fire falling within the project perimeter .........................81

Table 28. Current acres of each structural stage and existing Fire Hazard Rating ......84

Table 29. Total acres and percentage of project area for the existing Fire Hazard 

Rating ............................................................................................................................84
Briggs Spring Environmental Assessment 

Table of Contents

Table 30. Fire Hazard Rating by alternative ................................................................90

Table 31. Forest Service R2 Sensitive Species in Briggs Spring project area .............93

Table 32. Historical use by allotment in the Briggs Spring project area ......................94

Table 33. Existing roads and OHV trails within the Briggs Spring project area .......111

Table 34. Travel Management – NFSRs in miles and road density ...........................112

Table 35. Travel Management – National Forest System (NFS) OHV trails in miles 

and trail density ............................................................................................................112

Table 36. Approximate mileages of system trails in the project area ........................116

Table 37. Soil Map Units in the Briggs Spring project area and respective percentage 

of the project area.........................................................................................................119

Table 38. Soil Map Units in the Briggs Spring project with elevated risk of erosion 

......................................................................................................................................121

Table 39. 6th Level Watersheds (HUC 12) associated with the Briggs Spring project

......................................................................................................................................130

Table 40. Wetlands within Briggs Spring project area ..............................................131

Table 41. Miles of perennial, intermittent, and ephemeral streams in the Briggs Spring 

project area ..................................................................................................................132

Figure 1. Map 2-Alternative 2 commercial treatments. ................................................11

Figure 2. Map 4-Alternative 3 commercial treatments. ...............................................15

Figure 3. Existing condition of age class distribution of ponderosa pine in the Briggs 

Spring project area. .......................................................................................................23

Figure 4. Typical stand structure for each Fire Regime Condition Class (FRCC).. .....80

Figure 5. Large fire history in and around the project area and the point fire history 

within the project boundary. ..........................................................................................82

Figure 6. At-Risk Communities (ARC) adjacent to the project boundary and structures 

located within the project area. ......................................................................................83

Figure 7. Fire Hazard Rating by Alternative ................................................................91
Briggs Spring Environmental Assessment 

Table of Contents

Appendices

Appendix A: MAPS

Appendix B: DESIGN CRITERIA

Appendix C: MONITORING PLAN

Appendix D: TREATMENTS and POST SALE ACTIVITIES BY SITE

Appendix E: FINDINGS: SILVICULTURE 

Appendix F: PAST, PRESENT, and REASONABLY FORESEEABLE 

FUTURE ACTIVITIES

Appendix G: SUMMARY: BIOLOGICAL ASSESSMENT and 

BIOLOGICAL EVALUATION

Appendix H: RESPONSE TO COMMENTS
 

Commonly Used Acronyms and Abbreviations

APE Area of Potential Effect 

AUM Animal Unit Months

BA Basal Area 

BABE Biological 

Assessment/Biological 

Evaluation 

BCC Birds of Conservation 

Concern 

BCR Bird Conservation Region 

BHNF Black Hills National Forest 

BHNF 

LRMP 

Black Hills National Forest 

Revised Land and Resource 

Management Plan 

BMP Best Management Practices

CCF Hundred Cubic Feet 

CDA Connected Disturbed Areas 

CEQ Council on Environmental 

Quality 

CFR Code of Federal Regulations 

CWD Coarse Woody Debris

DBH Diameter at Breast Height 

DENR Department of Environment 

and Natural Resources 

EA Environmental Assessment

EPA Environmental Protection 

Agency 

FEMA Federal Emergency 

Management Agency 

FPS&G Forest Plan Standards and 

Guidelines 

FRCC Fire Regime Condition 

Class 

FSM Forest Service Manual 

FSPro Fire Spread Probability 

FSR Forest Service Road 

GIS Geographic Information 

Systems

HUC Hydrologic Unit Code 

IDT, ID 

Team 

Interdisciplinary Team 

LRMP Land and Resource 

Management Plan 

MA Management Area 

MBBH Monitoring Birds of the 

Black Hills 

MIS Management Indicator 

Species 

MPB Mountain Pine Beetle 

NEPA National Environmental 

Policy Act 

NFMA National Forest 

Management Act 

NFSR National Forest System 

Road 

NHPA National Historic 

Preservation Act 

NRHP National Register of 

Historic Places 

OHV Off Highway Vehicle

POL Products Other than Logs 

R2 Forest Service Region 2 

(Rocky Mountain Region) 

RIS Resource Information 

System 

RMBO Rocky Mountain Bird 

Observatory 

RMRS Rocky Mountain Research 

Station 

ROS Recreation Opportunity 

Spectrum

RX Prescribed Fire

SD South Dakota 
SDDENR South Dakota Department 

of Environment and Natural 

Resources

SDGFP South Dakota Game Fish 

and Parks 

SDNHP South Dakota Natural 

Heritage Program 

SHPO State Historic Preservation 

Office 

SHR Stream Health Rating 

SIO Site Integrity Objective 

SOLC Species of Local Concern 

SOPA Schedule of Proposed 

Action 

SS Structural Stage 

TES Threatened, Endangered, & 

Sensitive Species 

USC United States Code 

USDA United States Department of 

Agriculture 

USFS United States Department of 

Agriculture Forest Service 

USFWS United States Fish and 

Wildlife Service 

USGS United States Geological 

Survey 

WCP Watershed Conservation 

Practice 

WIZ Water Influence Zone 

WUI Wildland Urban Interface 
Briggs Spring Environmental Assessment Summary

i

SUMMARY

The Hell Canyon Ranger District of the Black Hills National Forest proposes to

implement multiple resource management actions, including commercial and noncommercial vegetation treatments, prescribed burning, and construction of a new 

campground within the Briggs Spring project area. Proposed resource management 

actions apply only to National Forest lands. The project area is located approximately 

twenty-five miles northwest of the town of Custer, South Dakota and is in Pennington 

County, South Dakota (Map 1, Appendix A). The project area is entirely within 

Management Area (MA) 5.1, Resource Production Emphasis. There are 24,548 acres of 

National Forest land and 4,368 acres of private owned land, totaling 28,916 acres 

included within the project area. This action is needed, because the current condition of 

forested stands does not meet Forest-wide objectives for this management area; there is 

existing mountain pine beetle outbreak near the Briggs Spring project area and there is

opportunity to reduce potential mountain pine beetle caused mortality by sanitation and 

thinning; there is an opportunity to reduce fire hazard through fuels treatments; and in 

support of the recently decided Black Hills Travel Management Plan there is opportunity 

to develop a new off highway vehicle (OHV) campground.

The proposed action was described in a scoping document and mailed to approximately 

108 individuals, tribal representatives, groups, government entities and other interested 

members of the public. The proposed action includes vegetation treatments, prescribed 

fire, fuel treatments, and construction of a campground.

The Forest Service also evaluated the following alternatives:

Alternative 1 – No Action: The National Environmental Policy Act 

(NEPA) requires the study of the ‘No Action’ alternative as a basis 

for comparing effects of the proposed action and other alternatives. 

The ‘No Action’ alternative assumes no implementation of any 

elements of the proposed action or other action alternatives would 

take place within the Briggs Spring project area. This alternative 

represents no attempt to actively respond to the purpose and need for 

action or the issues identified during scoping. For example, there 

would be no effort to modify existing vegetation or related fuels 

conditions in the project area; current timber sales, fire suppression 

efforts, noxious weeds treatments and regular system road 

maintenance would continue on National Forest lands.

Alternative 2 – Proposed Action: This alternative was developed to 

meet the purpose and need for action and it represents the agency’s 

recommendations prior to public scoping. The proposed action would 

manage vegetation within the project area to provide for a sustainable 

supply of commercial timber, and manage fuels in order to reduce 

losses of timber and other desired forest habitat and reduce the risk of 

large-scale, high intensity wildfire. The proposed action includes a 
Briggs Spring Environmental Assessment Summary

ii

developed recreation campground facility which is designed for OHV 

recreational use, including both day use and overnight camping.

Alternative 3: This alternative addresses the key issues identified 

during the scoping process, which are 1) effects of developing a new 

OHV campground; and 2) susceptibility to mountain pine beetle. The 

elements that differ from the proposed action (Alternative 2) are an 

increase in thinning and sanitation and there is no new campground 

proposed.

Based upon the effects of the alternatives, the responsible official will decide:

(1) whether or not vegetation and fuels treatments should be implemented

(2) if treatment is selected, in what manner and in which locations

(3) whether or not an OHV recreation campground should be developed and, if so, in 

what manner and in which location.
Briggs Spring Environmental Assessment Chapter 1

1

CHAPTER 1: INTRODUCTION

Document Structure

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

National Environmental Policy Act (NEPA) and other relevant Federal and State laws 

and regulations. This Environmental Assessment discloses the direct, indirect, and 

cumulative environmental impacts that would result from the proposed action and 

alternatives. The document is organized into five chapters:

• Chapter 1: Introduction: The section includes information on the history of the 

project proposal, the purpose of and need for the project, and the agency’s proposal 

for achieving that purpose and need. This section also details how the Forest Service 

informed the public of the proposal and how the public responded.

• Chapter 2: Comparison of Alternatives, including the Proposed Action: This 

section provides a more detailed description of the agency’s proposed action as well 

as alternative methods for achieving the stated purpose. These alternatives were 

developed based on significant issues raised by the public and other agencies. 

Finally, this section provides a summary table of the environmental consequences 

associated with each alternative.

• Chapter 3: Affected Environment and Environmental Consequences: This section 

describes the environmental effects of implementing the proposed action and other 

alternatives. This analysis is organized by resource area (i.e. Silviculture, Wildlife, 

Recreation). Within each section, the affected environment is described first, 

followed by the effects of the No Action Alternative that provides a baseline for 

evaluation and comparison of the other alternatives that follow.

• Chapter 4: Consultation and Coordination: This section provides a list of preparers, 

agencies and persons consulted during the development of the environmental 

assessment.

• Chapter 5: Literature Cited and Glossary

• Appendices: The appendices provide more detailed information to support the 

analyses presented in the environmental assessment.

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

may be found in the project planning record located at the Hell Canyon Ranger District 

Office in Custer, South Dakota.

Background

The first known photographs ever taken in the Black Hills were taken during General 

George A. Custer’s 1874 expedition. These historic photographs give a glimpse of the 

appearance of the Black Hills in pre-European settlement times. The Black Hills 

represented a fire adapted ecosystem and past fires created a landscape quite different 

than what we see today. There were far fewer trees and open spaces were more 
Briggs Spring Environmental Assessment Chapter 1

2

abundant. Alteration of natural fire cycles in the Black Hills, as a means of protecting 

people, timber resources, and private property, has created dramatic changes in the 

landscape. The development of continuous, dense forest with few open spaces has led to 

both recent large forest fires and increased mountain pine beetle activity. These are 

issues familiar to many people living and working in the Black Hills, and to people that 

visit this unique region. The number of fires on lands managed by the Black Hills 

National Forest has remained fairly constant at 65-130 starts per year.

The mountain pine beetle, Dendroctonus ponderosa, is showing increased activity in the 

densely stocked pine stands within the project area. In the late 1990’s mountain pine 

beetle infestation started becoming more widespread, eventually reaching the current 

level of epidemic across the forest. Over the past 10 years there has been extensive tree 

mortality across the forest, changing the forest at landscape levels. Within the project 

area, patches of dead trees ranging from 1-2 trees to small groups (5-10) of infested trees 

can be found in almost every site of the project area. The most noticeable areas of 

infestation are in the north-eastern area and south of Bert Howey spring. The most recent 

beetle activity was noted just south of Six-mile Road (Forest Service Road [FSR] 301) 

and along Custer-Limestone Road (FSR 284), just east of Heggie Road (FSR 284.5D).

The proposed management actions within the action alternatives are designed to reduce 

the risk of MPB infestation and to provide a sustainable supply of commercial timber 

(consistent with Forest Plan direction). The action alternatives are also designed to 

reduce hazards related to large scale wildfire.

The forest-wide Black Hills National Forest Travel Management Plan was signed on 

March 22, 2010, with implementation beginning on December 01, 2010. This decision 

designated approximately 13 miles of system trails within the project area.

Location

The Briggs Spring project area is located approximately twenty-five miles northwest of 

the town of Custer in Pennington County, South Dakota (see Map 1, Appendix A). The 

project area is located with T01N, R01E Sections 11-14, 21-28, 33-36; T01S, R01E 

Sections 1-5, 9-16, 21-24, 28-30, 33-36; T01S, R02E Sections 6-8, 18, 19, 30-32; T02S, 

R02E Sections 5-8, 18, 19; and T02S, R01E Sections 1-5, 9-13, 24. The gross acreage of 

the project area is 28,916 acres with approximately 24,548 acres of National Forest 

System land and 4,368 acres of interspersed private land. Major arterial roads that access 

the project area include FSR 117.1 (Boles Canyon Road) which provides north-south 

access throughout, FSR 301 (Six Mile Road) which provides east-west access centrally, 

and FSR 284 (Custer-Limestone Road) is the southern-most boundary.

Management Direction

The Revised Land and Resource Management Plan (Forest Plan), as amended (2006), 

provides direction for the management of the forest. The Forest Plan contains 

management goals and objectives, management area direction, and identifies desired 

future conditions for the forest. Resource specialists reviewed the current condition of the 

project area and compared these conditions with the desired conditions identified in the 

Forest Plan including applicable goals and objectives. Opportunities for improvement 

were identified.
Briggs Spring Environmental Assessment Chapter 1

3

The Decision for the Phase II Amendment to the Forest Plan was signed on October 31, 

2005 and became effective on February 28, 2006. The Forest Plan, as amended, 

establishes 11 goals and associated objectives for multiple-use management of the Forest. 

Goals 1, 2, 4, and 10 address natural resource objectives for multiple-use management of 

the Forest. Goals 3 and 5-9 provide socioeconomic emphasis for management of the 

Forest. Goal 11 addresses recovery rates and fuel-loading after significant fire or other 

natural event. Goals and objectives provide basic direction for defining a purpose and 

need for a project and developing a proposed action. Forest Plan goals are discussed in 

Chapter 1 of the Phase II Amendment of the Forest Plan.

The Forest Plan assigns a management emphasis to each portion of the Forest to meet 

multiple-use objectives. For each designated Management Area (MA), Chapter 3 of the

Forest Plan includes a description of desired future conditions, goals, objectives, 

standards, and guidelines. National Forest lands within the Briggs Spring project area are 

completely within MA 5.1 (USDA Forest Service, 2006).

MA 5.1: Resource Production Emphasis. These areas are managed for wood products, 

water yield, and forage production, while providing other commercial products, visual 

quality, diversity of wildlife and a variety of other goods and services. Numerous open 

roads provide commercial access and roaded recreation opportunities, while closed roads 

provide non-motorized recreation opportunities.

Goals and objectives within the Forest Plan were used to develop the proposed action for 

the Briggs Spring project.

Goal 2: Provide for a variety of life through management of biologically diverse 

ecosystems.

Objective 201: Manage for a minimum of 92,000 acres of aspen, and 

16,000 acres of bur oak during the life of the Plan. The highest priority 

for hardwood restoration is where conifers (e.g., spruce and pine) have 

out-competed aspen adjacent to riparian systems that once supported 

beaver.

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

Objective 303: Offer the following allowable sale quantity (ASQ) of 

timber on suitable and available timber lands.

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

of heritage resources in response to the needs of the Black Hills National Forest visitors 

and local communities.

Objective 420b: Provide recreation facilities, trailheads, trail crossings 

and other road corridor components to meet demand.

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. Three objectives associated with this goal that 

pertain to this project include:
Briggs Spring Environmental Assessment Chapter 1

4

Objective 10-01: Manage for 50 to 75 percent moderate-to-low fire 

hazard in the wildland-urban interface and reduce fire hazard within 

proximity of structures to current NFPA standards...

Objective 10-04: Reduce or otherwise treat fuels commensurate with risks 

(fire occurrence), hazard (fuel flammability), and land and resource values 

common to the area, using the criteria in Forest-wide Guideline 4110.

Objective 10-07: Where outbreaks of mountain pine beetle could present 

risks to management objectives for ponderosa pine, reduce acreage of 

ponderosa pine stands that are in medium or high risk for infestation.

Purpose and Need for Action

The purpose of this project is to maintain forest health, to manage ponderosa pine within 

this portion of MA 5.1 in order to provide for a sustainable supply of commercial timber, 

to manage fuels in order to reduce losses of timber and other desired forest habitat and 

the risk of large-scale, high intensity wildfire, and to provide a developed recreation 

campground facility which is designed for OHV recreational use, including large trailers, 

in support of the recently designated Travel Management OHV trail system within the 

Briggs Spring project area. This action is needed because: the current mountain pine 

beetle outbreak in forest stands within and near the Briggs Spring project area indicates 

there is opportunity to reduce potential mountain pine beetle caused mortality by thinning 

dense timber stands (Forest Plan, Goal 10 and Objective 10-07); there is opportunity to 

contribute to the Forest-wide objective (Forest Plan, Goal 3 and Objective 303) through 

timber harvest throughout the project area; there is opportunity to reduce fire hazard 

through fuels treatments (Forest Plan, Goal 10 and Objective 10-01 & 10-04); and in 

light of the recently closed Moon Campground, which is adjacent to the project area, the 

opportunity exists to create a recreation campground in support of the newly developed 

OHV trail system (Forest Plan, Goal 4 and Objective 420b).

This action responds to the goals and objectives outlined in the Forest Plan and helps 

move the project area toward desired conditions described in that plan.

Proposed Action

The Forest Service proposes to implement vegetation treatments with both commercial 

and non-commercial activities. Commercial treatments include commercial thinning, 

group shelterwood, overstory removal, shelterwood seedcut, hardwood release or 

conversion, pine encroachment, and sanitation treatments. Commercial treatments would 

occur on approximately 12,224 acres with the potential to treat an additional 6,063 acres 

through sanitation treatment, if needed. Non-commercial treatments include hardwood 

release, pine encroachment, products other than logs (POL) thinning, deadfall, 

mechanical fuels treatments, and prescribed burning. Non-commercial treatments would 

occur on approximately 22,305 acres, including 6,295 acres of prescribed burning. Some 

commercial and non-commercial treatments overlap each other within the same sites. A 

recreation campground facility (New Moon Campground) which is designed for OHV 

recreational use, including both day use and overnight camping would be developed 

along the east boundary, within sites 040704-23 and 25, northeast of the junction of roads 

FSR 296.3A and FSR 296.2.
Briggs Spring Environmental Assessment Chapter 1

5

Decision Framework

Given the purpose and need, the deciding official reviews the proposed action, the issues 

identified during scoping, the other alternatives, and the environmental consequences of 

implementing each alternative in order to make the following decisions:

(1) whether or not vegetation and fuels treatments should be implemented

(2) if treatment is selected, in what manner and in which locations

(3) whether or not an OHV recreation campground should be developed and, if so, in 

what manner and in which location.

Public Involvement

The proposal was listed in the Schedule of Proposed Actions in October, 2010. The 

proposal was provided to the public and other agencies for comment during scoping on 

October 14, 2010. In addition, as part of the public involvement process, the agency 

mailed a detailed scoping document to approximately 108 individuals, tribal 

representatives, groups, government agencies and other interested members of the public. 

Scoping documents were also uploaded to the forest website, 

http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=28361, in October 2010. Scoping 

comments received are located in the project record.

Using the comments from the public, other government agencies, groups, tribal 

representatives the interdisciplinary team (IDT) developed a list of issues to address.

Issues

Issues are unresolved conflicts concerning alternative uses of available resources. 

Comments received during the scoping process raised various issues in relation to 

management activities in the Briggs Spring project area. From these comments and other 

sources, the project interdisciplinary team identified two key issues that drove the 

development of the alternatives. A brief description of the issues follows.

The Forest Service identified two topics raised during scoping. These issues include:

Issue #1: Effects of Developing a New OHV Campground – Some 

commentors noted that the proposed action would result in two 

campgrounds located within close proximity of each other. It was 

suggested that expanding the existing Redbank Spring Campground 

should be considered to meet the anticipated needs of OHV users, rather 

than creating a new campground. Measures: Number of campgrounds 

and size. Number of acres of ground disturbance.

Issue #2: Susceptibility to Mountain Pine Beetle – Some commentors 

were concerned that the proposed action would not sufficiently reduce the 

potential for mountain pine beetle caused mortality throughout the project 

area. Further sanitation and thinning was suggested. Measures: Acres of 

sanitation and thinning in pine sites and level of insect risk rating.
Briggs Spring Environmental Assessment Chapter 2

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CHAPTER 2: COMPARISON OF ALTERNATIVES, 

INCLUDING THE PROPOSED ACTION

This chapter describes and compares the alternatives considered for the Briggs Spring 

project. It includes a description of each alternative. This section includes a description of 

each alternative considered in detail, including the No Action Alternative (Alternative 1), 

the Proposed Action (Alternative 2), and one alternative to the Proposed Action, 

Alternative 3, as well as alternatives not considered in detail. This section also presents 

the alternatives in comparative form, defining the differences between each alternative 

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

public.

Alternatives Considered in Detail

The Forest Service developed three alternatives, including a no action and proposed 

action alternative. The alternatives considered in detail by the interdisciplinary team are 

discussed below. This section provides the summary of activities proposed to occur 

during implementation of any action alternative. Exact figures, such as acres, miles, or 

other numerical units of any particular activity, may vary slightly. These figures, which 

are based on inventory and survey estimates, may vary during preparation of a timber 

sale, prescribed burn, or other project based upon various site factors such as topography, 

non-uniform site structure, fuels, refinement of the standard of road needed, etc.

Alternative 1 – No Action

National Environmental Policy Act (NEPA) requires the study of the ‘No Action’ 

alternative as a basis for comparing effects of the proposed action and other alternatives. 

Under the No Action alternative, current management plans would continue to guide 

management of the project area. This alternative represents no attempt to actively 

respond to the purpose and need for action or the issues presented during scoping. No 

effort would be made to modify existing vegetation or related fuel conditions within the 

project area. No vegetation treatments, fuels treatments, or prescribed burning would be 

implemented; nor would the construction of an OHV campground be implemented to 

accomplish project goals.

Alternative 2 – Proposed Action

This alternative was developed to meet the purpose and need for action and it represents 

the agency’s recommendations prior to public scoping. The proposed action would 

manage vegetation within the project area to provide for a sustainable supply of 

commercial timber, and manage fuels in order to reduce losses of timber and other 

desired forest habitat and reduce the risk of large-scale, high intensity wildfire. The 

proposed action includes a developed recreation campground facility which is designed 

for OHV recreational use, including both day use and overnight camping.

The proposed OHV recreation campground facility, New Moon Campground, would be a 

Roaded Natural Recreation Opportunity Spectrum (ROS) Design, located within sites 
Briggs Spring Environmental Assessment Chapter 2

7

040704-23 & 25 (see Map 2-Tile 2, Appendix A). A defined ‘training’ lot would be 

constructed for hands-on learning of common OHV trail features. The proposed location 

for the New Moon Campground is on an existing OHV trail, eliminating the need for a 

connector trail from the campground to an existing trail system.

Features of the New Moon Campground would include the following:

• OHV facility would be approximately 17 acres in size, including approximately 15 

units of OHV Specialized Fee Campground and 4 units of OHV Day Use Trailhead. 

o Campground – approximately 15 acres

 Pull through design for camping units (~15 units) with parking spurs 

for two vehicles with trailers for each site. 

 Two Unisex Vault Toilets.

 Alternative 2 specific – Defined and fenced training lot (~1 acre) for 

hands-on learning of common OHV trail features.

 No potable water or garbage collection services, “visitor pack it in –

pack it out”. 

o Day Use Trailhead – approximately 2 acres

 Four gravel surface parking spaces to accommodate vehicles with 

trailers. 

o Hardened surface roads and concentrated use areas with crushed gravel. 

o The facility would be fenced for cattle exclusion and resource protection.

Vegetation treatments for Alternative 2 include both commercial (see Table 1) and 

noncommercial treatments (see Table 2). All commercial treatments include sanitation.

Table 1. Alternative 2-Proposed Action commercial treatments

Commercial Treatments Acres Description

Commercial Thin (CThin) 2,204 Thinning of immature ponderosa pine stands, 

generally 9-12” in diameter. Objective is to reduce 

basal area in stands to improve health, tree vigor, 

and future growth capacity of the stand and to 

reduce stand susceptibility to mountain pine beetle 

attack. This treatment would reduce stand basal 

area (BA) to 50 ft2/ac or 60 ft2/ac depending upon 

existing and desired condition of the stands. A 60 

BA will be used in stands to minimize stand 

susceptibility to mountain pine beetle (MPB) and 

wildfire. Reducing the basal area will minimize 

the expansion of the MPB infestation. A 50 BA 

will be used in stands that are located within or 

adjacent to areas of existing MPB infestations. A 

60 BA will be used in areas that do not have 

current MPB infestation.

Group Shelterwood 6,376 This is a shelterwood system treatment that is 
Briggs Spring Environmental Assessment Chapter 2

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(GRSH) applied within pine sites which are not 

homogenous, but rather have patches or groups of 

trees of various age classes throughout the stand. 

A GRSH prescription may include all phases of a 

shelterwood system such as a commercial thin, 

seed cut or overstory removal. 

Hardwood Release 

(HWDR)

250 Removal of encroaching conifers from existing 

hardwood stands. No change of cover type results. 

Removal of non-commercial conifers will follow 

commercial removal.

Hardwood Conversion 

(HWDC)

123 Removal of conifers from mixed conifer/hardwood 

sites that contain an abundance of hardwoods for 

the purpose of converting the site to an aspen 

stand. Removal of non-commercial conifers will 

follow commercial harvest.

Overstory Removal (OSR) 138 Removal of mature to over-mature trees in the 

overstory of stands which have been successfully 

regenerated. 

Shelterwood Seed Cut 

(SWSC)

479 An even-aged regeneration cutting in mature 

stands. The most desirable seed trees are retained 

at basal areas of 30-50 ft2/ac. Opening the canopy 

creates a favorable growing environment for pine 

regeneration. 

Pine Encroachment (PE)* 2,674 Removal of pine trees from existing meadows to 

maintain the meadow into the future. Both 

commercial and non-commercial sized trees may 

be removed. No change in cover type results.

Sanitation** 6,063 Sanitation is used to remove only individual green 

trees, which have live mountain pine beetle brood 

in them. These trees are already dead, however, 

the foliage will not change color until the 

following summer. This is a suppression strategy 

designed to remove live beetles from the site. The 

stands prescribed for sanitation are in areas of high 

beetle concentration. This treatment will also be 

used within commercially treated stands if there is 

beetle infestation occurring.

 Total Acres 18,307

*Commercial and non-commercial PE treatments would occur on the same acres. 

**These acres are planned for sanitation treatment only. All other commercial treatments would include sanitation. 
Briggs Spring Environmental Assessment Chapter 2

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Table 2. Alternative 2-Proposed Action non-commercial treatments

Non-Commercial 

Treatments Acres Description

Pine Encroachment (PE)* 2,674 See description in Table 1.

POL (Products other than 

log) Thinning

8,478 Non-commercial thinning of dense stands of pine 

that are less than 9-inches in diameter. Stands of 

trees will be thinned to reach a desired basal area 

of 60 ft2/acre. The objective is to reduce stand 

density to concentrate future growth on the most 

desirable trees.

POL Thinning/HWDR** 1,021 See description above. A hardwood release 

treatment would occur in areas that have 

hardwood inclusions. See description of HWDR 

above.

Hardwood Release 

(HWDR) 564 See description in Table 1.

POL Thinning/Deadfall 300 See POL description above and Deadfall 

description below. Both types of treatment 

would occur on these sites.

Fuels Treatments:

 Mechanical 1,252 Mechanical thinning of pine less than 9-inches in 

diameter and to desired tree spacing of 14’ x 14’ 

spacing. Mechanical fuels treatment may 

include hand cutting and piling. Slash piles 

resulting from this treatment would be burned, 

however no broadcast burning would occur. 

 Prescription (Rx) Burning 6,295 Management-ignited fire used for reducing 

woody material fuel loading in order to modify 

potential fire behavior which can reduce risks to 

life and property associated with wildfire. The 

objective of using prescribed fire in this project 

is to consume a portion of the dead/down fuels 

as well as limb a portion of the green trees in 

support of decreasing overall fire behavior. This 

treatment contributes to creating a mosaic of 

burned and unburned areas which results in an 

appearance of a naturally-burned landscape. 

Ignition may include but is not limited to both 

hand and aerial ignition.

 Deadfall 1,693 Mechanical treatment of existing slash to a 

height within 18-24 inches of the ground. May 

include various methods but not limited to 

lopping, chipping, crushing, piling and burning, 

or mastication. No snags would be removed as 
Briggs Spring Environmental Assessment Chapter 2

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part of this treatment. Some of these sites 

include hardwood inclusions that would be 

released (HWDR). 

 Total Acres 22,305

*Commercial and non-commercial PE treatments would occur on the same acres.

**Commercial and non-commercial HWDR treatments would occur on some of the same acres.

Alternative 2 would produce approximately 30,127 hundred cubic feet (CCF) of 

commercial sawlog volume and approximately 8,075 CCF of POL as a byproduct of the 

mechanical treatments. In addition, 75.9 miles of roads would be maintained, 31.9 miles 

would be reconstructed, and 0.8 miles of an existing unauthorized road would be 

reconstructed and converted to a Forest system road, as part of the mechanical treatments 

proposed in this alternative. Figure 1 shows the entire project area, however Appendix A 

has more detailed maps. Please refer to Map 2-Tiles 1-3, Appendix A, for a detailed 

view of Alternative 2 treatment areas.
Briggs Spring Environmental Assessment Chapter 2

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 Figure 1. Map 2-Alternative 2 commercial treatments.
Briggs Spring Environmental Assessment Chapter 2

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Alternative 3

This alternative was developed to address the issues identified during scoping: 1) effects 

of developing a new OHV campground; 2) susceptibility to mountain pine beetles.

To address issue #1, Alternative 3 eliminates the development of a new OHV 

campground. To address issue #2, Alternative 3 proposes additional group shelterwood 

and sanitation treatments in more ponderosa pine stands to further reduce MPB 

susceptibility.

Vegetation treatments for Alternative 3 include both commercial (see Table 3) and noncommercial (see Table 4) treatments. All commercial treatments include sanitation. 

Table 3. Alternative 3 commercial treatments

Commercial Treatments Acres Description

Commercial Thin (CThin) 2,204 Thinning of immature ponderosa pine stands, 

generally 9-12” in diameter. Objective is to reduce 

basal area in stands to improve health, tree vigor, 

and future growth capacity of the stand and to 

reduce stand susceptibility to mountain pine beetle 

attack. This treatment would reduce stand basal 

area (BA) to 50 ft2/ac or 60 ft2/ac depending upon 

existing and desired condition of the stands. A 60 

BA will be used in stands to minimize stand 

susceptibility to mountain pine beetle (MPB) and 

wildfire. Reducing the basal area will minimize 

the expansion of the MPB infestation. A 50 BA 

will be used in stands that are located within or 

adjacent to areas of existing MPB infestations. A 

60 BA will be used in areas that do not have 

current MPB infestation. 

Group Shelterwood 

(GRSH)

13,845 This is a shelterwood system treatment that is 

applied within pine sites which are not 

homogenous, but rather have patches or groups of 

trees of various age classes throughout the stand. 

A GRSH prescription may include all phases of a 

shelterwood system such as a commercial thin, 

seed cut or overstory removal. 

Hardwood Release 

(HWDR)

259 Removal of encroaching conifers from existing 

hardwood stands. No change of cover type results. 

Removal of non-commercial conifers will follow 

commercial removal.

Hardwood Conversion 

(HWDC)

123 Removal of conifers from mixed conifer/hardwood 

sites that contain an abundance of hardwoods for 

the purpose of converting the site to an aspen 

stand. Removal of non-commercial conifers will 

follow commercial harvest.

Overstory Removal (OSR) 138 Removal of mature to over-mature trees in the 
Briggs Spring Environmental Assessment Chapter 2

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overstory of stands which have been successfully 

regenerated. 

Shelterwood Seed Cut 

(SWSC)

479 An even-aged regeneration cutting in mature 

stands. The most desirable seed trees are retained 

at basal areas of 30-50 ft2/ac. Opening the canopy 

creates a favorable growing environment for pine 

regeneration. 

Pine Encroachment (PE)* 2,674 Removal of pine trees from existing meadows to 

maintain the meadow into the future. Both 

commercial and non-commercial sized trees may 

be removed. No change in cover type results.

Sanitation** 3,678 Sanitation is used to remove only individual green 

trees, which have live mountain pine beetle brood 

in them. These trees are already dead, however, 

the foliage will not change color until the 

following summer. This is a suppression strategy 

designed to remove live beetles from the site. The 

stands prescribed for sanitation are in areas of high 

beetle concentration. This treatment will also be 

used within commercially treated stands if there is 

beetle infestation occurring.

 Total Acres 23,400

*Commercial and non-commercial PE treatments would occur on the same acres. 

**These acres are planned for sanitation treatment only. All other commercial treatments would include sanitation. 

Table 4. Alternative 3 non-commercial treatments 

Non-Commercial 

Treatments Acres Description

Pine Encroachment (PE)* 2,674 See description in Table 1.

POL (Products other than 

log) Thinning

8,889 Non-commercial thinning of dense stands of pine 

that are less than 9-inches in diameter. Stands of 

trees will be thinned to reach a desired basal area 

of 60 ft2/acre. The objective is to reduce stand 

density to concentrate future growth on the most 

desirable trees.

POL Thinning/HWDR** 1,021 See POL description above and the HWDR 

description in Table 1. A hardwood release 

treatment would occur in areas that have 

hardwood inclusions. See description of HWDR 

above.

Hardwood Release 

(HWDR)

564 See description above.

POL Thinning/Deadfall 300 See POL description above and Deadfall 

description below. Both types of treatment 

would occur on these sites.

Fuels Treatments:
Briggs Spring Environmental Assessment Chapter 2

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 Mechanical 1,274 Mechanical thinning of pine less than 9-inches in 

diameter and to desired tree spacing of 14’ x 14’

spacing. Site 040705-170 (Redbank Spring 

Campground) would have tree spacing of 24’ x 

24’. Mechanical fuels treatment may include 

hand cutting and piling. Slash piles resulting 

from this treatment would be burned, however 

no broadcast burning would occur. 

 Prescription (Rx) Burning 7,009 Management-ignited fire used for reducing 

woody material fuel loading in order to modify 

potential fire behavior which can reduce risks to 

life and property associated with wildfire. The 

objective of using prescribed fire in this project 

is to consume a portion of the dead/down fuels 

as well as limb a portion of the green trees in 

support of decreasing overall fire behavior. This 

treatment contributes to creating a mosaic of 

burned and unburned areas which results in an 

appearance of a naturally-burned landscape. 

Ignition may include but is not limited to both 

hand and aerial ignition.

 Deadfall 1,693 Mechanical treatment of existing slash to a 

height within 18-24 inches of the ground. May 

include various methods but not limited to 

lopping, chipping, crushing, piling and burning, 

or mastication. No snags would be removed as 

part of this treatment. Some of these sites 

include hardwood inclusions that would be 

released (HWDR). 

 Total Acres 23,452

*Commercial and non-commercial PE treatments would occur on the same acres. 

**Commercial and non-commercial HWDR treatments would occur on some of the same acres.

Alternative 3 would produce approximately 41,531 hundred cubic feet (CCF) of 

commercial sawlog volume and approximately 9,931 CCF of POL as a byproduct of the 

mechanical treatments. In addition, 77.3 miles of roads would be maintained, 33.4 miles 

would be reconstructed, and 0.8 miles of an existing unauthorized road would be 

reconstructed and converted to a Forest system road as part of the mechanical treatments 

proposed in this alternative. Figure 2 shows the entire project area, however Appendix A 

has more detailed maps. Please refer to Map 4-Tiles 1-3, Appendix A, for a detailed 

view of Alternative 3 treatment areas.
Briggs Spring Environmental Assessment Chapter 2

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 Figure 2. Map 4-Alternative 3 commercial treatments.
Briggs Spring Environmental Assessment Chapter 2

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Design Criteria

Design criteria include Forest Plan standards and guidelines, USFS Region 2 Watershed 

Conservation Practices (WCPs), Best Management Practices, and site specific design to 

avoid resource impacts. They are applicable and to be implemented as a matter of 

standard operating procedure for the action alternatives. Design criteria are applied to 

protect resources and forest users. All activities proposed in this project, including any 

post-sale activities or monitoring, must implement these design criteria. A complete list 

of project design criteria is available in Appendix B.

Alternatives Not Considered in Detail

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all 

reasonable alternatives, and to briefly discuss reasons for eliminating any alternatives that 

were not developed in detail (40 CFR 1502.14). Public comments received in response to 

the proposed action provided suggestions for alternative methods for achieving the 

purpose and need. Some of these alternatives may have been outside the scope of the 

project, duplicative of the alternatives considered in detail, or determined to be 

components that would cause unnecessary environmental harm. Therefore, the following 

alternatives were considered, but dismissed from detailed consideration for reasons 

summarized below.

• An alternative that includes a developed recreation campground facility which is 

designed for OHV recreational use, including both day use and overnight 

camping, by expanding the existing Redbank Spring Campground. This 

alternative was not considered in detail because heritage surveys determined that 

an eligible heritage site extends into the area and any ground disturbance would 

damage the site.

• One commentor suggested that some of the stands are being thinned too much at a 

40 BA, creating abundant regeneration issues in the future and delaying the next 

harvest far greater than if thinned to a higher residual stand density. They also 

suggest that more acres could be treated than if a 40 BA were applied. They 

recommend thinning to a 60-70 BA in both commercial thins and group 

shelterwood treatments. 

This alternative was not considered in detail because the action alternatives 

already include a target BA for commercial thinning, whether as a standalone

treatment or as part of a group shelterwood, in this project is 60 ft2

/acre, except 

where MPB activity is pronounced, the BA is reduced to 50 ft2/acre. This would 

allow for flexibility during implementation. None of the proposed treatments 

have a target stand density of 40 ft2

/acre, which is of concern to this commentor.

• One commentor suggested that a ‘Salvage clause’ be included to allow for the 

removal of trees killed by prescribed burning, if the mortality limits are exceeded 

or an escape occurs. This alternative was not considered in detail because it 

would be based on the assumption that the project would not be implemented as 

planned. Furthermore, if a situation occurs where large areas of trees are killed by 

fire, whether prescribed or natural fire, this would represent a changed condition, 

not analyzed in this EA. 
Briggs Spring Environmental Assessment Chapter 2

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• An alternative which reduces road density was suggested by commentors. This 

alternative was not considered in detail because a need to reduce road density was 

not identified as part of the purpose and need for this project. The Forest Travel 

Management Decision in December, 2010 included a Forest-level review of 

existing and needed roads and trails. Furthermore, a Roads Analysis Process 

(RAP) was conducted for this project area by the project interdisciplinary team 

(IDT). No road closures were recommended by the IDT in the project RAP.

• One commentor suggested that an alternative which only uses prescribed burning 

should be developed to manage for mountain pine beetle. This alternative was not 

considered in detail because burning, as a tool, is difficult to implement in a 

manner resulting in a certain stand density. In addition, killing mature trees with 

prescribed fire will result in stressing of the remaining trees which makes them 

more susceptible to mountain pine beetles.

Comparison of Alternatives

This section provides a summary of each alternative. Appendix A, Maps 2-5 with 

corresponding tiles, provide a detailed visual display of vegetation treatments.

Comparison of Vegetation Treatments:

Table 5. Comparison of commercial treatments by alternative 

Commercial Treatments by Alternative

Acres

Alternative 2 Alternative 3

Commercial Thin (CThin) 2,204 2,204

Group Shelterwood (GRSH) 6,376 13,845

Hardwood Release (HWDR) 250 259

Hardwood Conversion (HWDC) 123 123

Overstory Removal (OSR) 138 138

Shelterwood Seed Cut (SWSC) 479 479

Pine Encroachment (PE)* 2,674 2,674

Sanitation** 6,063 3,678

*Commercial and non-commercial PE treatments will occur on the same acres.

**These acres are planned for sanitation treatment only. All other treatments will include sanitation.
Briggs Spring Environmental Assessment Chapter 2

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Table 6. Comparison of non-commercial treatments by alternative 

Non-Commercial Treatments by Alternative

Acres

Alternative 2 Alternative 3

Pine Encroachment (PE)* 2,674 2,674

POL Thinning 8,478 8,889

POL Thinning (with HWDR) 1,021 1,021

POL Thinning/Deadfall 300 300

Hardwood Release (HWDR)** 564 564

Deadfall 1,693 1,693

Mechanical Fuels Treatment 1,252 1,274

Prescription (Rx) Burning 6,295 7,009

* Commercial and non-commercial PE treatments will occur on the same acres.

**Commercial and non-commercial HWDR treatments will occur on some of the same acres.

Comparison of Structural Stages (SS) by Cover Type:

Structural stage definitions (USDA Forest Service, 2005):

SS1 (grass/forb): This stage is dominated by grasses and forbs lasting until tree seedlings 

become established. 

SS2 (shrub/seedling): This stage consists of shrubs and seedlings. This stage remains 

until seedlings reach 1” diameter at breast height (DBH). 

SS3 (sapling/pole): This stage contains trees with stems 1-9” DBH.

SS3A – sapling/pole stage with less than 40% canopy cover

SS3B – sapling/pole stage with 40-70% canopy cover

SS3C – sapling/pole stage with greater than 70% canopy cover

SS4 (mature): This stage contains trees which are at least 9” DBH.

SS4A – mature stage with less than 40% canopy cover

SS4B – mature stage with 40-70% canopy cover

SS4C – mature stage with greater than 70% canopy cover

SS5 (late succession): This stage is characterized by very large trees (16+ inches DBH). 

Trees are at least 160 years in age. Late succession ponderosa pine may occur in dense 

stands but may also grow in the open or in “park-like” stands.
Briggs Spring Environmental Assessment Chapter 2

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Table 7. Comparison of structural stages (SS) by cover type for all alternatives

Cover Type → 

Structural 

Stage ↓

Ponderosa Pine Aspen Meadow Total Acres

Alt. 1 Alt. 2 Alt. 3 Alt. 1 Alt. 2 Alt. 3 Alt. 1 Alt. 2 Alt. 3 Alt. 1 Alt. 2 Alt. 3

Meadow/Grassland 0 0 0 0 0 0 2,697 2,697 2,697 2,697 2,697 2,697

SS1 497 497 497 0 0 0 0 0 0 497 497 497

SS2 485 485 485 65 65 65 0 0 0 550 550 550

SS3A 49 133 133 130 242 242 0 0 0 179 375 375

SS3B 132 175 175 47 50 97 0 0 0 179 225 272

SS3C 42 42 42 0 0 0 0 0 0 42 42 42

SS4A 12,725 16,570 16,570 42 97 50 0 0 0 12,767 16,667 16,620

SS4B 7,590 3,495 3,495 47 0 0 0 0 0 7,637 3,495 3,495

SS4C 0 0 0 0 0 0 0 0 0 0 0 0

SS5 0 0 0 0 0 0 0 0 0 0 0 0

Total Acres 21,520 21,397 21,397 331 454 454 2,697 2,697 2,697 24,548 24,548 24,548

Comparison of Roads and Trails:

Table 8. Total miles of all Forest system roads and OHV trail on 

National Forest land within the project area, by alternative

Existing/Alt. 1 Alt. 2 Alt. 3

System Roads 108.9 109.7 109.7

System OHV Trails 12.8 12.8 12.8

Total Miles 121.7 122.5 122.5

Table 9. Total miles of Forest system roads within the project area, for 

all alternatives

Existing

 Roads Closed to All, Yearlong (as storage) 7.9

 Roads Open to All, Seasonal 11.3

 Roads Open to All, Yearlong 14.3

 Roads Open to Highway Legal Vehicles Only, Seasonal 5

 Roads Open to Highway Legal Vehicles Only, Yearlong 70.4

System Roads – Total Miles 108.9

Table 10. Total miles of Forest system OHV trails within the 

project area, by alternative

Existing/Alt. 1 Alt. 2 Alt. 3

Trails Open, Seasonal 8.2 8.2 8.2

Trails Open, Yearlong 4.6 4.6 4.6

System Trails – Total Miles 12.8 12.8 12.8
Briggs Spring Environmental Assessment Chapter 2

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Table 11. Road density for all Forest system roads on National Forest land within the 

project area, by alternative

Existing/Alt. 1 Alt. 2 Alt. 3

Miles Miles/Sq. Mile Miles Miles/Sq. Mile Miles Miles/Sq. Mile

Closed

Roads 7.9 0.2 8.8 0.2 8.8 0.2

Open

Roads 84.7 2.2 84.7 2.2 84.7 2.2

Seasonal 

Roads 16.3 0.4 16.3 0.4 16.3 0.4

Total 108.9 2.8 109.8 2.9 109.8 2.9

Comparison of Effects to Issues by Alternative:

Table 12. Effects of issues by alternative

1. Effects of Developing a 

new OHV Campground

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Number of campgrounds 1 2 1

Acres of new or expanded 

campground 0 acres 18 acres 0 acres

2. Susceptibility to 

Mountain Pine Beetles

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Acres of sanitation and 

thinning in pine sites 0 acres 15,383 acres 20,467 acres

Acres of Low Risk Acres of Medium Risk** Acres of High Risk***

Alt. 1 Alt. 2 Alt. 3 Alt. 1 Alt. 2 Alt. 3 Alt. 1 Alt. 2 Alt. 3

Acres of Low, Medium, and 

High Insect Risk Rating* 1,031 1,115 1,115 12,857 16,745 16,745 7,633 3,538 3,538

*Insect Risk Ratings were evaluated by linking them to structural stages in ponderosa pine. The Forest Plan lists Insect 

Risk Rating by structural stages. (FEIS Phase II Amendment, p. III-385)

**Note that acres of medium risk would not change between Alternatives 2 and 3. The additional treatments in 

Alternative 3 would occur on sites that are currently structural stage (SS) 4A and after treatment the stands would 

remain at SS 4A. The additional treatment in Alternative 3 focuses on higher density 4Astands, but does not change 

the structural stage. By treating 4A stands with the denser crown closure the potential for MPB caused mortality would 

be reduced. 

***Acres of high risk stands remain the same between Alternatives 2 and 3. These sites are wildlife sites that require a 

higher density of trees, placing them into the high risk category. 
Briggs Spring Environmental Assessment Chapter 3

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CHAPTER 3: AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES

This section summarizes the environment of the affected project area and the potential 

changes to those environments due to implementation of the alternatives. It also presents 

the scientific and analytical basis for comparison of alternatives presented in Chapter 2. 

For the purposes of this analysis and under federal regulations, “impacts” and “effects” 

are assumed to have the same meaning and are interchangeable.

The information presented here is based on analysis prepared by resource specialists from 

the interdisciplinary team (IDT). Analysis was accomplished by field observations and 

surveys, past experience and professional recommendations, aerial photography, resource 

modeling, literature review, information obtained through monitoring, Forest Plan 

direction and associated analysis, and public participation. The specialist reports are 

included in the project file, which is located at the Black Hills National Forest, Hell 

Canyon Ranger District, 330 Mount Rushmore Road, Custer, South Dakota. All resource 

specialists used the best available science in completing their analysis, in accordance with 

Forest Service Manual (FSM) 1920.

Past, Present, and Reasonably Foreseeable Actions 

Analysis of cumulative effects include past, present, and reasonably foreseeable future 

activities that could affect the biological or social environments. See Appendix F for a 

listing of past, present, and future activities considered in the Briggs Spring project 

cumulative effects analysis. The project area boundary was used to address cumulative 

impacts, unless otherwise noted in the resource discussions. Rationale for cumulative 

effects boundaries is noted in the cumulative effects discussions by resource.

Forest Vegetation

Affected Environment

Cover Type

The vegetation in the Briggs Spring area is dominated by ponderosa pine (Pinus 

ponderosa) (88%). Very little white spruce (Picea glauca) is present but can be found 

growing along the bottom of north facing slopes which have limestone cliffs and as 

scattered individuals in some pine stands. Quaking aspen (Populus tremuloides) stands 

(1%) are found throughout the analysis area but are mainly found in the northern half. 

There are many small aspen clones and individuals found within the pine stands 

throughout the project area. Large meadows/grasslands (11%) tend to dominate the wide 

drainage bottoms throughout the northern half of the analysis area. While smaller 

meadows run up the draws in the southern half of the analysis area. See Table 13 for 

existing cover types within the project area.
Briggs Spring Environmental Assessment Chapter 3

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Table 13. Existing cover types in the Briggs 

Spring project area

Cover Type Acres Percent (%)

Meadow/Grassland 2,697 11

Aspen 331 1

Ponderosa Pine 21,520 88

Total Acres 24,548 100

Structural Stage

There are several age classes and diameter size classes within the forested sites. 

Approximately 50% of the stands are multi-storied, 33% of the stands are two-storied and 

the remaining (approximately 20%) is single-storied. The multistoried stands may 

contain patches or groups of trees of various age classes throughout the stand. They may 

include all phases of a shelterwood system such as a commercial thin, shelterwood seed 

cut, or overstory removal all within the same stand. See Table 14 for existing structural 

stages by cover type within the project area.

Table 14. Existing structural stages (SS) by cover type in the Briggs 

Spring project area (shown in acres)

Cover Type →

Structural Stage 

↓

Ponderosa 

Pine Aspen Meadow Total Acres

Meadow/grassland 0 0 2,697 2,697

SS1 497 0 0 497

SS2 485 65 0 550

SS3A 49 130 0 179

SS3B 132 47 0 179

SS3C 42 0 0 42

SS4A 12,725 42 0 12,767

SS4B 7,590 47 0 7,637

SS4C 0 0 0 0

SS5 0 0 0 0

Total Acres 21,520 331 2,697 24,548

The slope in the project area ranges from level ground to 65%. Approximately 95% of 

the project area has a slope less than 20% with an average of 10%. The average elevation 

is 6,465 feet.

Ponderosa Pine

Ponderosa pine (Pinus ponderosa) dominates the Briggs Spring analysis area with 21,520 

acres, 88% of the area. Pine is often in pure ponderosa pine stands, however pine is 

associated with quaking aspen in most of the analysis area with the exception of the far 

northern location (040502), where pine is associated with white spruce and quaking

aspen. In the southern locations (040807, 040808) ponderosa pine can be found with 

Rocky Mountain Juniper (Juniperus scopulorum) on occasion.
Briggs Spring Environmental Assessment Chapter 3

23

The overall average stand age for ponderosa pine stands of 8-inch trees and larger is 99 

years old. Thirteen percent of the pine stands are over 120 years old, rotation age for 

pine in the Black Hills, while 8% of pine stands are less than 80 years old (See Figure 3). 

Figure 3. Existing condition of age class distribution of ponderosa pine in the Briggs 

Spring project area. 

Structural Stage – Management Area 5.1 has a structural stage objective (Objective 5.1-

204) within the ponderosa pine cover type (Table 15). This objective is to manage for the 

following percentages of structural stages in the ponderosa pine cover type across the 

management area in a variety of sizes and shapes.

Table 15. Structural stage objective percentages for ponderosa pine in

MA 5.1 across the Black Hills National Forest

Structural

Stage

Objective

Percentage

Structural

Stage

Objective

Percentage

SS1 5% SS4A 25% *

SS2 5% SS4B 25% *

SS3A 10% SS4C 5% *

SS3B 15% SS5 5% **

SS3C 5%

*10% of the SS4 ponderosa pine acres in the management area will have an average tree size of 

‘very large’ (16-inches or greater DBH). Seek opportunities to increase understory shrubs in 

open-canopy structural stages.

**Active management is allowed, and may be necessary to provide desired late-successional 

characteristics. 

The current condition of the structural stage percentages for ponderosa pine cover type 

throughout MA 5.1, including the Briggs Spring project area, is as follows:

0

5

10

15

20

25

30

35

40

45

50

0-20 21-40 41-60 61-80 81-100 101-120 121-140 141-160 161-180

P

e

r

c

e

n

t

Age Class in Years

Age Class Distribution of Ponderosa Pine
Briggs Spring Environmental Assessment Chapter 3

24

Table 16. Forest Plan objectives versus existing ponderosa pine 

structural stage distribution in MA 5.1 across the Black Hills National 

Forest (USDA Forest Service, 2010)

Structural

Stage

Forest Plan 

Objective (%)

Existing 

Condition

Pine Acres

Existing* 

Condition (%)

SS1 5% 26,760 6%

SS2 5% 16,673 4%

SS3A 10% 24,236 5%

SS3B 15% 17,047 4%

SS3C 5% 10,269 2%

SS4A 25% 185,062 39%

SS4B 25% 142,228 30%

SS4C* 5% 50,437 11%

SS5* 5% 1,227 0.3%

Total 100% 473,939 100% *Note that SS4C and SS5 are not present within the Briggs Spring project area.

In MA 5.1, pine sites in SS4 have 13% of the stands in the ‘very large’ (VL) tree size 

(16” DBH or greater), which is 3% over the management area objective of 10%.

Table 17. Forest Plan objective versus existing 

condition for VL tree size distribution in MA 5.1 across 

the Black Hills National Forest (USDA Forest Service, 

2010)

Structural

Stage

Forest Plan

Objective

VL Tree Size

Existing Condition

VL Tree Size

Percentage

4A, B, C 10% 13%

Structural stages change over time within a management area due to harvest activities, 

large wildfires, wind events, or mountain pine beetle (MPB) infestations that would affect 

an entire stand. Natural or artificial regeneration of a SS1 site would also change 

structural stages.

Late Succession – The Black Hills Forest Plan defines late succession as: “Ecosystems 

distinguished by very large old trees and related structural features (Mehl, 1992). This 

term encompasses the later stages of stand development that typically differ from earlier 

stages in structure, composition, function, and other attributes. 

There are two types of late-successional ponderosa pine defined for the Black Hills. The 

first type, open-canopy late-successional ponderosa pine, occurs where periodic, lowintensity fires have been part of the ecosystem. These late-successional stands would 

consist of clumps or groups of trees with grasses in the openings between the clumps. 

They would contain large old trees with open branches, irregular, and flattened crowns. 

The clumps or groups of trees would contain little down dead material and few small 

trees. 
Briggs Spring Environmental Assessment Chapter 3

25

The second type, closed-canopy late-successional ponderosa pine occurs where periodic, 

low-intensity high-frequency fires have not been a significant part of the ecosystem. 

These stands would contain large old trees with open branches and irregular crowns. The 

stands would have multiple canopy layers made up of various-aged trees.” 

Structural stage 5 represents the late succession condition. There is no late succession SS 

5 in the Briggs Spring project area. 

Mountain Pine Beetle – Mortality in ponderosa pine from MPB continues to be the most 

evident of any insect or disease problem in the analysis area. The MPB epidemic 

continues to increase within the Black Hills National Forest. In 2010, the mapped 

acreage affected by MPB doubled, as compared with acres attributed to MPB during each 

of the previous three years, representing significant new pine mortality (Schaupp, 2011).

Currently, there are approximately 7,633 acres of ponderosa pine at high risk for MPB 

infestation. This is about 35% of the pine stands in the analysis area (Table 18). Highrisk pine stands are at a greater potential for increased MPB activity. Generally, stands 

are considered to be most susceptible to infestation if 75% of the stand is in the 7-13 inch 

diameter range and the stand density is over 120 ft2/ac of basal area (Allen, 2003). 

Table 18. Current MPB rating for ponderosa pine in 

the Briggs Spring project area 

Insect Rating Acres Percentage

Low 1,031 5%

Medium 12,856 60%

High 7,633 35%

Total 21,520 100%

Mountain pine beetle risk ratings were determined by structural stages in ponderosa pine 

(Table 19).

Table 19. Structural stage/MPB risk

rating relationship

Ponderosa Pine

Structural

Stage

MPB Risk

Rating

1 Low

2 Low

3A Low

3B Medium

3C High

4A Medium

4B High

4C High

5 High
Briggs Spring Environmental Assessment Chapter 3

26

Even though a SS4A is in the lowest tree density the tree size of SS4 (>9 inches DBH) is 

largely in the 7-13 inch diameter range and therefore 4A stands remain at medium risk 

(Table 19).

The MPB is showing increased activity in the ponderosa pine stands in the project area. 

Patches of dead trees ranging from one or two infested trees to small patches, consisting 

of several infested trees, could be found in almost every site of the analysis area. The 

most noticeable areas of infestation are in the northeastern area (location 40705) just 

north of the old powerline and the area to the south of Bert Howey spring in location 

40806. Most recently, increased activity was noted in the goshawk stands (location 

40802) just south of Six-mile Road (FSR 301) and in a stand (location 40805) along the 

Custer-Limestone Road (FSR 284) just east of the Heggie Road (FSR 284.5D).

Quaking Aspen

There are 331 acres of quaking aspen (Populus tremuloides) in the Briggs Spring project 

area. More than half of these stands are in the northern half of the project area (north of 

Six-mile Road; FSR 301). Most of the pine stands within the analysis area are commonly 

intermixed with smaller aspen clones and individuals scattered throughout the site. Aspen 

stands within the project area have an average stand age of 70 years within trees of 5-

inches DBH and larger, while the average age of aspen less than 5-inches DBH is 13 

years. Approximately two-thirds of the aspen stands have large conifers that are outcompeting the hardwoods.

White Spruce

There are no white spruce (Picea glauca) stands within the project area, however white 

spruce individuals can be found within the project area. In the northern half of the 

project area spruce can be found intermixed with ponderosa pine stands and aspen clones. 

In the southern half of the project area spruce are also found along the northern face of 

rimrock ledges. Because the presence of white spruce is so minimal throughout the 

project area, discussion of white spruce will not be carried further in the analysis. 

Understory Vegetation

Shrubs, forbs, and grasses are plentiful in the forest understory. Common juniper 

(Juniperus communis) is the most widespread shrub found in the project area. Common 

juniper typically reaches a height of approximately two to three feet. Oregon grape 

(Berberis repens) and kinnikinnik (Arctostaphylos uva-ursi) are also common shrubs 

found in most sites, while snowberry (Symphoricarpos albus) is found in greater numbers 

in the southern half of the analysis area. Other shrubs include russet buffalo berry 

(Shepherdia canadensis) in the southern locations and shrubby cinquefoil (Potentilla 

fruticosa) in the northern locations. There are a large variety of forbs and grasses in the 

analysis area.

Meadows/Grasslands

Large meadows throughout the northern half of the project area dominate the wide 

drainage bottoms while smaller meadows run up the draws in the southern half dividing 
Briggs Spring Environmental Assessment Chapter 3

27

the conifer stands. There are areas where conifers are encroaching upon the meadows. 

Conifer regeneration can be found coming into the meadows that are adjacent to conifer 

stands while other areas with meadow soils have larger conifers already well established.

Environmental Consequences

Cover Type

Alternative 1 – No Action

Under this alternative, no new vegetation management activities would occur within the 

project area.

Direct and Indirect Effects

No changes would occur to existing cover types in the Briggs Spring project area. 

Common to Both Action Alternatives

Direct and Indirect Effects

The number of existing pine acres would decrease as 123 acres of ponderosa pine are 

converted to aspen. Pine acres would decrease from 21,520 to 21,398 in both action 

alternatives, a 1% reduction. 

Structural Stage

Alternative 1 – No Action

Under this alternative, no new vegetation management activities would occur within the 

project area.

Direct and Indirect Effects

No changes would occur to existing forest vegetation structural stages in the Briggs 

Spring project area. 

Common to Both Action Alternatives

Direct and Indirect Effects

All action alternatives would move structural stages toward correcting deficiencies in 

early structural stages in MA 5.1. Both action alternatives would have the same minor 

impact on the range of structural stages in ponderosa pine in MA 5.1. 

Ponderosa Pine

Alternative 1 – No Action

Under this alternative, no new vegetation management activities would occur within the 

project area. 

Direct and Indirect Effects

The effects of deferring treatment in the pine stands would be a slower increase a yield as 

the size of the existing trees would increase at a reduced rate due to competition, a 

reduction of diameter growth due to age and overstocking, an increased risk to MPB 
Briggs Spring Environmental Assessment Chapter 3

28

infestations, and an increased risk of large-scale, high intensity wildfire. The number of 

ponderosa pine acres would remain the same. 

Age class distribution may change where mortality occurs due to MPB. The mortality 

caused by MPB would open up the pine stands creating large openings or whole stands 

could be reduced to SS1 (grass stage). 

Structural Stage – The forest-wide structural stage objective (Objective 5.1-204) 

percentages for MA 5.1 would not change with this alternative in the short term 

(approximately <10 years) unless the MPB infestation would change stand structure. 

Structural stages 1, 4A, 4B, and 4C would continue to be over target percentages for MA 

5.1, while SS 2, 3A, 3B, 3C, and 5 would be under the target percentages for MA 5.1. 

In the long term, structural stages would change as trees grow and regenerate, wildfires or 

wind events take place, or insects and disease related mortality occurs. These changes 

could take decades, or depending on the event, could happen overnight. Eventually, the 

majority of structural stages would grow into SS4B or SS4C without any disturbances to 

the stand. This would not move ponderosa pine stands toward the forest objective 

(Objective 5.1-204) for structural stages for the management area. 

There would be no changes to the ‘very large’ tree size percentages for MA 5.1. 

Alternative 1 would not move the stand conditions towards the Forest Plan objectives for 

structural stages.

Late Succession – The no action alternative would allow some SS 4A and SS 4B stands 

to eventually grow into SS 5. The criteria for SS 5 is the stand must be at least 160 years 

old and to have a tree size class of ‘Very Large’ (VL), trees 16-inches in diameter at 

breast height (DBH) or greater, however this would take several decades or longer to 

achieve. With the current MPB infestation it is highly likely that the development of SS 

5 would be delayed due to an increase in MPB caused tree mortality. 

Mountain Pine Beetle – Mountain pine beetle risk would not be reduced with Alternative

1. The analysis area would continue to have 35% of the stands in high risk and 60% of 

the stands in medium risk for susceptibility to MPB infestation. Mortality is expected to 

increase from present numbers. The current infestations (Table 20) are expected to 

increase in size and spread to healthy green trees.

Table 20. Alternative 1-MPB risk rating for the Briggs 

Spring project area

MPB Risk 

Rating

Existing 

Acres Existing Percent (%)

Low 1,031 5 %

Medium 12,856 60 %

High 7,633 35 %

Total 21,520 100 %

Alternative 2 – Proposed Action

In this alternative 12,244 acres would be commercially harvested, including 6,063 acres 

of sanitation; 6,295 acres prescribe burned; and 22,305 acres of non-commercial 
Briggs Spring Environmental Assessment Chapter 3

29

treatments. An estimated volume of 30,127 CCF (14,110 MBF) and 8,075 CCF of POL

is expected. 

Direct and Indirect Effects

Group shelterwood (6,376 acres) is the main treatment proposed. Group shelterwood was 

recommended because many of the stands in the project area are not homogeneous, but 

rather have patches or groups of trees of various age classes throughout the stand. This 

prescription may include all phases of the shelterwood system such as overstory removal, 

commercial thin and shelterwood seed cut and would all be harvested to the same basal 

areas as previously mentioned. After harvest, residual trees would increase in yield as the 

size of existing trees and their diameter would increase due to reduced competition. The

resulting less dense stands would provide a decreased risk of catastrophic wildfire. 

POL thinning improves the residual stand by increasing the quality of the timber through 

the removal of damaged, diseased, and poorly formed trees. An increase of individual 

tree growth also occurs by releasing the remaining trees from competition.

In this alternative, 6,295 acres are planned for prescribed burning, of which 5,669 acres 

would occur in pine sites. Mortality limits were designed to prevent excessive mortality 

within pine stands differentiated by tree diameter sizes. 

Structural Stage – See “Common to All Action Alternatives” below.

Late Succession – See “Common to All Action Alternatives” below.

Mountain Pine Beetle – See “Common to All Action Alternatives” below. 

Alternative 3

In this alternative 23,400 acres would be commercially harvested; 3,678 acres of 

sanitation treatment; 23,452 acres of non-commercial treatment, including 7,009 acres of 

prescribed burning; and an estimated volume of 41,531 CCF of sawtimber and 9,931 

CCF of POL would be expected. This alternative harvests the most volume from the 

greatest amount of acres. This alternative was designed to treat the project area more 

aggressively and to incorporate more acres of preventative treatments for mountain pine 

beetle infestation. 

Direct and Indirect Effects

The majority of proposed treatments would occur in ponderosa pine stands as in 

Alternative 2. This alternative proposes to treat more than 11,000 additional acres than 

Alternative 2. 

Group shelterwood is the main proposed treatment as in Alternative 2; however 

Alternative 3 increases group shelterwood treatments to 7,469 more acres than 

Alternative 2. Alternative 3 has converted many of the sanitation only treatments from 

Alternative 2 to group shelterwood treatments. Group shelterwood may include all 

phases of the shelterwood system such as overstory removal, commercial thin and 

shelterwood seed cut. 

After harvest, residual trees would increase in yield as the size of existing trees would 

increase due to the reduced competition and increased diameter growth as a result of less 

competition. These results would be the same as in Alternative 2, but spanning across
Briggs Spring Environmental Assessment Chapter 3

30

more acres in the project area. There would be a greater decrease in catastrophic wildfire 

potential because of a more open canopy created by more acres treated than Alternative 

2. 

Up to 8,889 acres of POL thinning is proposed with this alternative. This is 411 more 

acres than Alternative 2. Trees less than 9-inches DBH would be thinned to a stand basal 

area of 60 ft2/acre. POL thinning improves the residual stand by increasing the quality of 

the timber through the removal of damaged, diseased, and poorly formed trees. An 

increase of individual tree growth also occurs by releasing the remaining trees from 

competition. Mechanical fuels treatments would increase by 22 acres more than 

Alternative 2, to 1,274 acres. These areas would be thinned to 14’ x 14’ spacing.

This alternative would prescribe burn 7,009 acres (5,964 acres of which are pine sites), 

which is 714 acres (295 acres of which are pine sites) more than Alternative 2. The same 

mortality limits listed in Alternative 2 would be used for Alternative 3. 

Structural Stage – See “Common to All Action Alternatives” below.

Late Succession – See “Common to All Action Alternatives” below.

Mountain Pine Beetle – Sanitation only treatments would be done in sites where no other 

commercial treatments are proposed. These sites were deferred from other treatments for 

wildlife reasons and to maintain the current stand structure. Sanitation would be 

implemented if the stand becomes infested with MPB. Alternative 3 increases the acres 

of commercial treatment from Alternative 2, resulting in 2,385 acres less than Alternative 

2 of sanitation only treatment. 

The additional treatment in Alternative 3 is within SS 4A medium risk stands. Stands 

that have a structural stage of 4A can have a crown closure of 10-40%. The additional 

treatment in Alternative 3 focuses on the higher density 4A stands, but does not change 

the structural stage. By treating the 4A stands with the denser crown closure the potential 

for MPB caused mortality would be reduced. The medium risk rating does not change, 

however as all 4A stands are considered a medium risk for MPB.

See “Common to All Action Alternatives” below.

Common to All Action Alternatives

Direct and Indirect Effects

Commercial thinning would occur on 2,204 acres where a basal area of 60ft2/ac would be 

prescribed for the majority of the stands. In areas with MPB infestation a 50ft2/ac would 

be prescribed. Overstory removal would occur on 138 acres to release established 

seedlings and 479 acres of shelterwood seed cut to regenerate mature pine stands.

For SS4 pine sites, 13% of all stands within the management area would maintain a tree 

size of ‘very large’ (16” DBH or greater) with all alternatives. This is 3% over the target 

of 10%.

A combination of POL (Products Other than Logs) thinning and a fuels treatment 

(deadfall) is proposed on 300 acres in both action alternatives. The fuels treatments are 

interspersed with the POL thinning. These acres are located within the Jasper Fire area 

on the south end of the project area. Trees less than 9-inch DBH would be thinned to a 
Briggs Spring Environmental Assessment Chapter 3

31

stand basal area of 60 ft2/acre. POL thinning improves the residual stand by increasing 

the quality of the timber through the removal of damaged, diseased, and poorly formed 

trees. An increase of individual tree growth also occurs by releasing the remaining trees 

from competition. The fuels treatment would be to reduce the existing slash to a height 

within 18-24 inches of the ground.

A combination of POL thinning and hardwood release is proposed on 564 acres in both 

action alternatives. Pine trees less than 9-inch DBH would be thinned to a stand basal 

area of 60 ft2/acre. POL thinning improves the residual stand by increasing the quality of 

the timber through the removal of damaged, diseased, and poorly formed trees. An 

increase of individual tree growth also occurs by releasing the remaining trees from 

competition. Inclusions of aspen occur within these pine stands. Removing all sizes of 

competing conifers would allow more sunlight to reach the forest floor, which would 

promote sprouting.

The number of existing pine acres would decrease as 123 acres are converted from pine 

to aspen. Pine acres would decrease from 21,521 to 21,398 in both action alternatives, a 

1% reduction. An additional 53 pine acres would be converted to aspen, but new sites 

would need to be created.

Structural Stages – Both action alternatives would move the project area toward Forest 

Plan structural stage objectives for MA 5.1. Timber harvesting would open up the stands 

and change stand densities and/or tree size depending on the treatment prescribed. 

A shelterwood seed cut in the short term would cause more acres to move into SS4A by 

maintaining tree size but reducing stand density. Initially, more SS4A would need to be 

created in order to move to the other structural stages. A shelterwood seed cut is a 

regeneration cut; after implementation the area would regenerate naturally. The 

shelterwood seed cut would enable the stand to move towards early SS2 and SS3.

An overstory removal would change tree size from sawtimber (SS4) to seedlings/saplings 

(SS2) following the commercial harvest. This would increase the number of acres of

SS2. 

Commercial thinning would maintain tree size but depending on residual basal area, the 

stand could be reduced to SS4A or SS4B.

In the short term, the percentages for all structural stages after harvest would remain the 

same except SS4A and SS4B. Structural stage 4A would increase by 1% to 40%, which 

moves away from the objective of 25%. Structural stage 4B would decrease by 1% to 

29%, which moves toward the objective of 25%. See Table 21 for SS comparisons by 

alternative.
Briggs Spring Environmental Assessment Chapter 3

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Table 21. Ponderosa pine structural stages by alternative throughout MA 5.1, across 

the Black Hills National Forest

Structural 

Stage

Forest Plan 

Objective 

5.1-204

(%)

Existing Condition 

Ponderosa Pine 

Acres

Existing 

Condition 

(%)

Alt. 2 

Ponderosa Pine 

Acres

Alt. 2

(%)

Alt. 3

Ponderosa Pine 

Acres

Alt. 3

(%)

SS1 5% 26,760 6% 26,760 6% 26,760 6%

SS2 5% 16,673 4% 16,673 4% 16,673 4%

SS3A 10% 24,236 5% 24,320 5% 24,320 5%

SS3B 15% 17,047 4% 17,090 4% 17,090 4%

SS3C 5% 10,269 2% 10,269 2% 10,269 2%

SS4A 25% 185,062 39% 188,909 40% 188,909 40%

SS4B 25% 142,228 30% 138,133 29% 138,133 29%

SS4C* 5% 50,437 11% 50,437 11% 50,437 11%

SS5* 5% 1,227 0.3% 1,227 0.3% 1,227 0.3%

Total 100% 473,393 100% 473,818 100% 473,818 100%

*Note that SS4C and SS5 are not present within the Briggs Spring project area.

The forest objective for structural stages applies to the entire management area. 

Depending on the type of harvests that are prescribed and how many acres are treated 

will depend on how soon the percentages of the forest plan objectives are reached. Forest 

growth rates and funding of post harvest treatments also must be taken into consideration. 

As a result, it may take two or more decades to achieve the Forest Plan structural stage 

objectives (USDA Forest Service, 2005).

Late Succession – Both action alternatives would allow some SS 4A and 4B stands to 

eventually grow into SS 5 over several decades or longer. The potential to develop SS 5 

is improved over the no action alternative. Reducing the risk for MPB caused mortality 

increases the possibility of retaining mature stands that could develop into late 

succession. 

Mountain Pine Beetle – Both action alternatives would reduce the same amount of acres 

of pine in the high-risk and medium risk categories for MPB infestation. Acres in the 

high-risk rating would decrease by approximately 18% to 3,538 acres of ponderosa pine. 

Pine stands at the medium risk rating would increase by approximately 18% (16,745 

acres). The low risk rating would remain the same at 5% (1,115 acres). See Table 22.

Table 22 shows no difference in MPB risk rating between the two action alternatives. 

The additional treatment in Alternative 3 is within SS 4A medium risk stands. Stands 

that have a structural stage of 4A can have a crown closure of 10-40%. The additional 

treatment in Alternative 3 focuses on the higher density 4A stands, but does not change 

the structural stage. By treating the 4A stands with the denser crown closure the potential 

for MPB caused mortality would be reduced. The medium risk rating does not change, 

however as all 4A stands are considered a medium risk for MPB.
Briggs Spring Environmental Assessment Chapter 3

33

Table 22. Mountain pine beetle risk rating - Comparison for all alternatives

MPB 

Risk 

Rating

Existing 

Condition 

Acres

Alt. 1

Existing 

Condition

%

Alt. 1

Acres 

PostSale

Alt. 2

PostSale 

%

Alt. 2

Acres 

PostSale

Alt. 3

PostSale 

%

Alt. 3

Change 

(%) from 

Existing 

Conditon

Low 1,031 5% 1,115 5% 1,115 5% 0%

Medium 12,857 60% 16,745 78% 16,745 78% + 18%

High 7,633 35% 3,538 17% 3,538 17% - 18%

Total 21,521 100% 21,398* 100% 21,398* 100%

*Pine acres minus 123 acres converted from pine to aspen or meadow.

Quaking Aspen

Alternative 1 – No Action

Under this alternative, no new vegetation management activities would occur within the 

project area. 

Direct and Indirect Effects

This Alternative would not move the aspen stand conditions towards the forest objective. 

Alternative 2 – Proposed Action

Direct and Indirect Effects

Eighty-six acres would be prescribed burned in this alternative. A light prescribed fire 

could initiate a new cohort of suckers in an aspen clone by killing all of the exiting stems. 

Combining a harvest of conifer overstory with subsequent prescribed burning of scattered 

slash may most closely approximate the natural fire disturbances that historically 

maintained aspen in the Black Hills (Sheppard & Asherin, 2004).

Alternative 3

Direct and Indirect Effects

A commercial hardwood release would occur on 259 acres of aspen. This is nine acres 

more than Alternative 2. Removal of conifers 9-inches DBH or greater would be 

commercially harvested.

Alternative 3 would prescribe burn 255 acres of aspen stands. This is 169 acres more 

than Alternative 2. Prescribe burning would be used to stimulate suckering in aspen and 

introduce new age classes within aspen stands in this alternative.

Common to All Action Alternatives

Direct and Indirect Effects

Existing aspen acres (331 acres) would increase as three pine sites (123 acres) and 

portions of eight additional pine sites (53 acres) would be converted to aspen sites (total 

of 176 acres). This would contribute to Forest Plan Objective 201. 

Aspen stands would receive more light, moisture, and nutrients, as the more shade 

tolerant conifers would be removed from the existing aspen stands. Removing conifers 
Briggs Spring Environmental Assessment Chapter 3

34

growing in and around an aspen clone can reduce competition for moisture and light, 

which will favor the aspen. Aspen roots extend a considerable distance away from 

existing stems. Clearing the surrounding conifer forest back 1-1.5 tree heights away from

a declining aspen clone will allow new aspen suckers to establish and expand the area 

occupied by the clone (Sheppard & Battaglia, 2002). Eliminating conifers from the 

understory would keep conifers from taking over aspen stands in the future. Conifers less 

than 9-inches DBH would be removed as a post sale activity from the understory of 331 

acres of existing aspen stands.

Understory Vegetation

Alternative 1 – No Action

Under this alternative, no new vegetation management activities would occur within the 

project area. 

Direct and Indirect Effects

Within conifer stands, forbs, shrubs, and grasses would be shaded out reducing benefits 

to other resources such as wildlife and range. In areas with MPB infestation there would 

be an increase in forbs, shrubs, and grasses where MPB has caused mortality in pine 

allowing sunlight, moisture, and nutrients to become available to the understory 

vegetation creating more grass and forage for cattle and wildlife. 

Alternative 2 – Proposed Action

Direct and Indirect Effects

This alternative would harvest and open up the canopy on 12,244 acres. This would 

allow an increase in light, nutrients, and moisture to become available to the understory 

vegetation of forbs, shrubs, and grasses. The result would be an increase in grass and 

forage for cattle and wildlife.

Alternative 3

Direct and Indirect Effects

This alternative would harvest and open up the canopy on 23,400, which is 11,156 more 

acres than Alternative 2. This would allow an increase in light, nutrients, and moisture 

over more acres to become available to the understory vegetation. Forbs, shrubs, and 

grasses would increase creating more grass and forage for cattle and wildlife than 

Alternative 2.

Common to All Action Alternatives

Direct and Indirect Effects

The understory vegetation within timbered stands could be set back in the short term (3-5 

years) by prescribe burning. Shrubs may be temporarily reduced in size by the prescribe 

burning but most would re-sprout.
Briggs Spring Environmental Assessment Chapter 3

35

Meadows/Grasslands

Alternative 1 – No Action

Under this alternative, no new vegetation management activities would occur within the 

project area. 

Direct and Indirect Effects

Meadows would continue to be encroached by conifers, decreasing grass and forage 

production. Conifers currently growing in meadows would continue to increase in 

numbers, taking over the meadows. Meadows without conifer encroachment at present 

may eventually become encroached. 

Alternative 2 – Proposed Action

Direct and Indirect Effects

Prescribe burning in meadows could delay or help remove conifer regeneration from 

occurring if the tree seedlings are very small in size. Alternative 2 would prescribe burn 

540 acres within meadow sites.

Alternative 3

Direct and Indirect Effects

Prescribe burning in meadows could delay or help remove conifer regeneration from 

occurring if the tree seedlings are very small in size. Alternative 3 would prescribe burn 

790 acres within meadow sites, which is 250 acres more than Alternative 2.

Common to All Action Alternatives

Direct and Indirect Effects

Approximately 2,674 acres of existing meadows would be maintained by removing 

encroaching pine in both action alternatives. All conifers are to be removed 

commercially for trees 9-inches DBH or greater or as a post harvest activity for trees less 

than 9-inches DBH.

Cumulative Effects

The Briggs Spring analysis area has been commercially harvested many times in the past 

with recorded activities going back to the 1960s. Post sale activities followed with 

natural disturbances occurring throughout the years, such as wildfires and insect and 

disease. Appendix F lists past, present, and future activities considered in this analysis.

Time Boundary (1980 to 2022) - Commercial and non-commercial treatments in the early 

1980’s are the earliest known activities that still affect the landscape today. 

Implementation of activities could occur starting in 2012. Full implementation of all 

activities is expected to be completed by 2022. 

Space Boundary - The Briggs Spring analysis area boundary will be used for the 

cumulative effects analysis. Harvest activities along with post sale activities are confined 

to the stand level while natural disturbances such as wildfire or insects and disease may 

be confined to the stand level or the project area.
Briggs Spring Environmental Assessment Chapter 3

36

Ponderosa Pine

Much of the Briggs Spring analysis area has been harvested in the past. At least 19 

timber sales have taken place since 1980. The effect of past treatments has been an 

increase of merchantable volume growth and improvement in the quality of timber. 

There has also been an improvement in the quality of timber through removal of 

damaged, diseased, and poorly formed trees. Precommercial thinning has occurred and 

improved stand health by removing damaged, diseased, and poor quality trees.

Past timber harvesting has reduced overall MPB risk in the project area. It reduced stand 

densities and created vegetative diversity by allowing for development of several age 

classes and diameter sizes.

Future treatments for the area might be further thinning or regeneration cuts. Any 

treatments for growth and yield purposes would not occur until stands became 

overstocked again or regeneration cuts were prescribed at culmination of mean annual 

increment or when more even-aged treatments were desired.

The Black Hills, including the Briggs Spring analysis area, had been in an on-going 

drought condition the last 10 years. While MPB does not depend on drought conditions 

for the insect to continuously increase their population, the drought aided the MPB by 

increasing stress in healthy trees thus making the trees more vulnerable to a successful 

MPB attack.

The current forest level epidemic episode has not shown signs of slowing down but 

continuously increasing in numbers. In 2010 the mapped acreage affected by MPB 

doubled, as compared with acres attributed to MPB during each of the previous three 

years, representing significant new pine mortality (Schaupp, 2011). From the mapping of 

the 2010 Aerial Overview Detection Survey, areas of MPB mortality have increased in 

the Briggs Spring analysis area.

There would be potential adverse cumulative effects to ponderosa pine with the no action 

alternative. Mountain pine beetles would continue to move into the project area from 

infested areas adjacent to the project area. Lack of vegetation treatment within ponderosa 

pine sites would amplify the potential for beetle populations to increase throughout the 

project area. Not harvesting ponderosa pine stands would encourage beetle populations 

to rise and would contribute to the growing MPB infestation in the analysis area. The 

MPB population is expected to increase in numbers.

There would be positive cumulative effects under both of the action alternatives. 

Treatment of ponderosa pine stands intended to lower stand density would reduce the 

susceptibility to MPB infestation. The proposed activities would result in MPB caused 

mortality to decrease with the action alternatives.

Late Succession – Past timber harvest has had both positive and negative impacts on late 

succession. It allowed some mature trees to grow into the ‘Very Large’ tree size (greater 

than 16 inches DBH) by increasing diameter growth as a result of less competition. In 

addition, MPB risk to mature stands has been reduced due to harvest. Post harvest has 

also removed old trees from stands that may have had the potential to become late 

successional. 
Briggs Spring Environmental Assessment Chapter 3

37

The action alternatives would have a beneficial cumulative effect by increasing the 

potential for retention of ‘Very Large’ and old trees on the landscape because of reduced 

MPB risk. The no action alternative would not reduce MPB risk and therefore would not 

have a beneficial cumulative effect. However, no direct removal of any ‘Very Large’ or 

old trees would occur.

Quaking Aspen

Many of the aspen stands have been invaded by conifers. Under the no action alternative, 

the aspen stands would not be released from competition by having conifers removed. 

This would result in a loss of aspen stands throughout the project area. Under the action 

alternatives the aspen stands would be released and not be further invaded by conifers as 

conifer seed sources would be removed. Future hardwood releases and prescribed 

burning would maintain and enhance the existing aspen stands. 

Past timber harvesting has opened up the pine stands which have allowed scattered aspen 

clones to receive more light, moisture, and nutrients which favor the intolerant aspen. 

The Jasper fire has increased the amount of aspen in the southern end of the project area. 

Several stands which burned in the fire have had an increase in aspen regeneration.

Grazing and browsing in aspen by cattle, elk, and deer can be detrimental to young aspen. 

Most young aspen in the project area appear to be in good health and are growing above 

browse height. The last several years have had good moisture and growing conditions.

Understory Vegetation

Past harvest activities have opened the forest canopy and produced more understory 

vegetation in forest stands. In the long term (greater than 10 years) trees would reoccupy the understory and future treatments would be needed to maintain and enhance 

understory vegetation. 

Under the no action alternative, canopy closure would continue to increase through time 

and less and less understory vegetation would be present under the forest canopy. 

Currently dense stands would not have their canopy opened up. Existing stands with a

more open canopy would start to close as tree crowns grow together and additional trees 

begin to grow from regeneration.

There would be no adverse cumulative effects to understory vegetation as a result of the 

action alternatives. Both action alternatives would improve understory vegetation by 

opening up the forest canopy. 

Meadows/Grasslands

The historic meadow sites within the project area have been encroached upon by conifers. 

Pine encroachment would occur in both action alternatives. Removing conifers of all 

sizes would fully restore existing meadows. As a result increased grass and forage 

production would occur. Proposed non-commercial treatments would remove any new 

pine invasion from adjacent forest stands, maintaining the meadows. There would be no 

adverse cumulative effects to meadows in the project area as a result of either action 

alternative. 
Briggs Spring Environmental Assessment Chapter 3

38

The cumulative effect under the no action alternative would be that ponderosa pine would 

remain in meadows and continue to seed into more trees, eventually replacing existing 

meadow sites. Grass and forage production would continue to decrease.

Wildlife

Affected Environment

Vegetative conditions in the project area were described in Tables 12 & 13 in the 

Silviculture section. The project area contains many different habitat types. Some of 

these include: ponderosa pine (Pinus ponderosa)/common juniper (Juniperus 

communis), ponderosa pine/bearberry (Arctostaphylos uva-ursi), ponderosa 

pine/snowberry (Symphoricarpos albus), quaking aspen (Populus tremuloides)/bracken 

fern (Pteridium aquilinum), bebb willow (Salix bebbiana) shrubland, shrubby cinquefoil 

(Potentilla fruticosa) shrubland, western snowberry (Symphoricarpos occidentalis) 

shrubland, and a small acreage of white spruce (Picea glauca)/grouseberry (Vaccinium 

scoparium). The project area is large and therefore consists of many habitat 

classifications (see Marriott & Faber-Langendoen, 2000 for detailed descriptions of each 

habitat type).

Topography is generally gentle rolling hills that support contiguous pine stands broken by 

meadows and/or grasslands with or without aspen. The majority of the 

meadow/grassland acreage is on private lands, mostly unoccupied, within the project 

boundary. This project area contains a mixture of tree species such as aspen and 

ponderosa pine. Spruce is very limited within the project area. There are several 

intermittent/ephemeral drainages within the project area but no measurable perennial 

reaches. Developed and undeveloped springs are present on Forest Service lands. The 

project area has an extensive road system. The road density for all roads within the 

project area is 2.8 miles/square mile. These roads provide access for various forest 

management activities and recreational use, including snowmobile routes. In addition 

there are approximately 12.8 miles (0.3 miles/square mile) of National Forest System

OHV trails within the project area.

Refer to the Forest Vegetation section presented earlier in this chapter for more 

information on these habitat components and the effects of the alternatives on each. The 

cumulative effects area for this analysis includes the project area boundary and activities 

that have occurred within the last 10 years and 10 years into the future. Appendix F

provides a summary of past, present, and reasonably foreseeable future activities 

considered in the cumulative effects analysis.

Snags and Down Woody Material

Stand exam data collected in 2004 and 2005 was used to determine amounts of down 

woody material and snag numbers. Data shows sufficient amounts of down woody debris 

throughout the Briggs Spring project area. Down woody material either meets or exceeds 

Forest Plan Standard 2308. Snags > 9” diameter at breast height (DBH) and > 25 feet in 

height were tallied from the stand exam data tree sheets. Snags per acre ranged from 0.80 

to 9.33 across the project area. The average snag density by location was 2.92

snags/acre. Snag densities in this project area, from data in 2004 and 2005, were below 
Briggs Spring Environmental Assessment Chapter 3

39

Objective 211. Areas where mountain pine beetles (MPB) were evident generally had 

higher snag and down woody material counts and snag clumping was common.

Mountain pine beetle infestations are present within the Briggs Spring project area. 

There are 7,764 acres of pine habitat present in the project area that are considered at 

high risk for MPB infestation. High risk sites are those pine stands that are designated as 

structural stages 3B, 3C, 4B, 4C and 5. Pine beetles and recent fires have created more 

snags and downed wood in the last five years. Wildfires have occurred in the project 

area, one of the most recent was the Jasper Fire. Jasper burned more than 83,000 acres 

on the Forest in 2000, creating many snags. More than 4,500 acres were burned within 

the Briggs Spring project area boundary.

A new policy is in effect allowing cutting of snags, for fuelwood, within 300’ of roads 

where dispersed camping is also permitted. Within the Briggs Spring project area that 

would include the area north of Six Mile Road (FSR 301) to the northern extent of the 

project boundary. Refer to the latest Motorized Vehicle Use Map (MVUM)

(implemented December 1, 2010) for areas allowing snag cutting. For the rest of the 

project area, Standard 2304 would apply and snags would not be cut.

Riparian Habitat

Perennial reaches of water in the Briggs Spring project area are lacking. There are 

intermittent and ephemeral reaches in the project area as well as numerous ponds, 

reservoirs and springs. Numerous reservoirs have been created for livestock watering 

within the project area. Ponds have also been specifically created for wildlife use. 

Northern leopard frogs, a Region 2 (R2) sensitive species, were found at one of these 

riparian areas created for wildlife in 2010 surveys. Currently, some riparian areas within 

the Briggs Spring project boundary are meeting Forest Plan Guidelines 3210 and 3211 

for riparian health. There are riparian areas that could use enhancements. Riparian areas 

are also discussed in the Water Resources section. 

Management Indicator Species (MIS)

The Phase II Amendment to the 1997 Forest Plan-FEIS (USDA Forest Service, 2005) 

lists MIS to be considered during project-level planning. MIS species were selected from 

that list for analysis if they have habitat or populations present within the Briggs Spring 

project area. Some MIS species have other status (such as R2 sensitive), and additional 

analyses are provided for them in the Briggs Spring Biological Assessment/Biological 

Evaluation (BA/BE). Full analyses and rationale are found in the Briggs Spring project 

record. 

The MIS species carried forward in this document are: 

• White-tailed deer

• Grasshopper sparrow

• Black-backed woodpecker

• Brown creeper

• Ruffed grouse

Monitoring of MIS is accomplished through coordinated efforts involving US Forest 

Service biologists, research, contracted monitoring surveys and State agencies. Forest 
Briggs Spring Environmental Assessment Chapter 3

40

monitoring of land bird species is accomplished currently by a contract with the Rocky 

Mountain Bird Observatory (RMBO). Game species (e.g., white-tailed deer) are 

monitored by a combination of research by South Dakota State University (SDSU), South 

Dakota Game, Fish, and Parks (SDGFP) biologists and reported observations.

White-tailed Deer (MIS)

The Briggs Spring area is mainly spring, summer and fall range for white-tailed deer

(Odocoileus virginianus); although they may inhabit the area in winter if the season is 

mild. Usually if snow depths exceed 6” deep, deer move to lower elevations. The Briggs 

Spring area is normally snow covered all winter. For white-tailed deer, spring migration 

back to summer range generally takes place from mid-to-late May. Fall migration to 

winter range is normally done during the September to October time frame but is 

primarily dependent on snow accumulation (Griffin et al., 1999). During field surveys in 

2007, 2008, and 2010, white-tailed deer were commonly observed. The area is used for 

white-tailed deer fawning.

Habitat trend at the Forest-level suggests that summer habitat is increasing while winter 

habitat is stable to slightly decreasing. The Forest is meeting Objective 238a, with regard 

to summer habitat, but the Forest may not be maintaining winter habitat, although the 

decline might not be significant (USDA Forest Service, 2009).

Big Game Screening – Screen cover is defined as: being able to hide 90% of an adult 

deer or elk from human view at a distance of 200 feet or less (of the road). There are six 

collector and arterial roads in the Briggs Spring project area where the screening cover 

requirement (Guideline 3203) applies. Currently five of the six roads are in compliance 

(Table 23). Screening cover was determined by driving these six roads and measuring 

distances providing adequate screening cover either from vegetation (generally pine 

regeneration) or topography (slope and landform). These measurements were then 

compared to total distances (through Forest Service lands only) along the roads.

One arterial road, FSR 301, has inadequate hiding cover (less than 20%). Many of the 

sites along this road have been treated (harvested) and have an open canopy. 

Regeneration is not yet adequate to provide 20% hiding cover. Four of the six roads have 

more than adequate screen cover from vegetation and/or topography. Arterial road FSR 

117.1 has just over the recommended 20% hiding cover.

Table 23. Existing screening cover in the Briggs Spring project area 

on Forest lands

Roads Functional Class Percent Screening Cover

117.1 Arterial 21%

284 Arterial 28%

284.5D Collector 27%

294 Collector 31%

296.1 Collector 42%

301 Arterial 10%

Grasshopper Sparrow (MIS and R2 Sensitive Species)

The grasshopper sparrow (Ammodramus savannarum) is considered a locally common 

migrant and summer resident for South Dakota (Tallman et al., 2002). Monitoring in 
Briggs Spring Environmental Assessment Chapter 3

41

2002 showed that grasshopper sparrows were found almost exclusively in native mixed 

grass prairies in the Black Hills (Panjabi, 2003), however, they have been recently 

recorded in the Jasper Fire burn area (Panjabi, 2005) and the Rogers Shack Fire burn 

areas (White & Giroir, 2009). Observations by the Rocky Mountain Bird Observatory 

(RMBO) tripled from 2004 to 2006 (Giroir et al., 2007). Suitable habitat is present in the 

Briggs Spring project area. The Jasper fire of 2000 has created suitable habitat for the 

grasshopper sparrow in the project area.

Black-backed Woodpecker (MIS and R2 Sensitive Species)

The black-backed woodpecker (Picoides arcticus) is distributed in low densities 

throughout most of the Black Hills. In the Black Hills, the black-backed woodpecker 

seems to favor late successional pine forests and areas that have been burned over or 

impacted by insects. Research conducted by Mohren (2002) indicated that this species 

prefers dense stands of mature ponderosa pine (SS 4C) and avoids the more open nature 

of SS4A and 4B stands. In 2005-2007, there was almost 2-3 times as much SS4C 

available than is desired by the Forest Plan objectives (USDA Forest Service, 2006; 

2007; 2008). There are currently 7,590 acres of SS4B ponderosa pine and no SS4C 

ponderosa pine acres within the project area.

Throughout the Black Hills National Forest, a total of 7,672 acres of burned forest habitat 

was created and largely retained over the last five years (USDA Forest Service, 2010). 

Where wildfires have recently occurred, the species has been observed much more 

frequently and in higher densities. The “aging” of large burned areas, such as the Jasper 

Fire, into less suitable habitat is likely being offset by the increasing acreage of insectinfested timber stands and the stable acreage of large diameter, older pine trees. Tree 

mortality from insects from 1996-2007 is estimated at 300,000 acres, and insect-infested 

timber stands are increasing. Overall the habitat is relatively abundant and Forest Plan 

Objective 238b is being met on the Forest. This species’ Forest-wide population trend is 

likely to decline in the future as vegetation management efforts to reduce the fire-hazard 

and insect-risk continue (USDA Forest Service, 2010).

Potential suitable habitat is present in the project area. Late succession stands containing 

large diameter dead trees (snags) created by natural events (wind, lightening), areas of 

mountain pine beetle activity, and burned acres are present within or adjacent to the 

Briggs Spring project area. From 2001-2007 the RMBO has observed black-backed 

woodpeckers just south of the project boundary (Panjabi, 2001, 2003-2005; Giroir et al., 

2007). In 2005 one was observed within the project area (Beason et al., 2006).

Brown Creeper (MIS)

The brown creeper (Certhia Americana) is considered an uncommon permanent resident 

of the Black Hills (Tallman et al., 2002), largely tied to late-succession pine and whitespruce habitats (Panjabi, 2003, 2005). In 2007 brown creepers were observed during 

RMBO surveys in all forested habitat types and burn habitat (Giroir et al., 2007). In 

2002, 2003 and 2005 brown creepers were observed in the project area (Panjabi, 2003, 

2004; Beason et al., 2006).

Observation data for the brown creeper reveals a short-term downward Forest-wide 

population trend. It appears that Objective 238a is being met, although short-term 

activities to meet the SS4C objective may be affecting the Forest’s ability to provide very 
Briggs Spring Environmental Assessment Chapter 3

42

large trees in SS4C. Continued effort and additional time is needed to increase the acres 

of SS5 (USDA Forest Service, 2008; 2009).

Ruffed Grouse (MIS)

Ruffed grouse (Bonasa umbellus) is considered an uncommon permanent resident in the 

Black Hills (Tallman et al., 2002) with greatest abundance in the northern Hills (Panjabi, 

2003). Ruffed grouse prefer young to medium aged aspen stands (Tallman et al., 2002) 

but have been observed in other habitat types in the Black Hills (Panjabi, 2003). In 2002 

and 2005 ruffed grouse were observed just north of the project area (Panjabi, 2003; 

Beason et al., 2006).

Aspen acreage in the project area totals 331 acres. This does not include scattered 

hardwood clones within conifer dominated sites. The hardwood sites represent many 

structural stages from SS2 up to SS4B (Table 13in the Silviculture section). A good 

portion of the existing aspen acreage is in the northern tip of the project area.

Species of Local Concern (SOLC)

Black Hills Supplement “r2_bh_2600-2005-1” to Forest Service Manual 2600 became 

effective November 7, 2005 and provides direction for the management of SOLC (USDA 

Forest Service, 2005a). As defined by this supplement, a species of local concern is a 

plant, fish or wildlife species (including subspecies or varieties) that does not meet the 

criteria for sensitive status. These could include species with declining trends in only a 

portion of R2, or those that are important components of diversity in a local area. The 

local area is defined as Forest Service lands within the Black Hills National Forest. This 

supplement also provides a detailed explanation of the evaluation criteria used to select 

species of local concern and a current list for the Black Hills National Forest (USDA 

Forest Service, 2005a). 

Only SOLC species that occur in the Briggs Spring project area or whose habitat occurs 

in the project area is carried forward in this document. Full analyses and rationale are 

found in the Briggs Spring project record. 

The SOLC species carried forward in this document are: 

• Butterflies: 

o Atlantis fritillary

o Tawny crescent

• Snails: 

o Callused vertigo

o Mystery vertigo

o Frigid ambersnail 

o Striate disc

• Sharp-shinned hawk

• Cooper’s hawk

• Broad-winged hawk

• Northern saw-whet owl

• Pygmy nuthatch

• Northern flying squirrel
Briggs Spring Environmental Assessment Chapter 3

43

• Meadow jumping mouse

• Bats:

o Northern long-eared myotis

o Small-footed myotis

o Long-eared myotis

o Long-legged myotis

Atlantis Fritillary (SOLC)

The Atlantis fritillary (Speyeria atlantis pahasapae) is an endemic butterfly of the Black 

Hills. In general, it occurs in riparian areas adjacent to openings, moist meadows and in 

boreal forests (NatureServe, 2009). In the Black Hills, this subspecies is restricted to 

Custer, Lawrence, and Pennington counties. It prefers wet meadows and moist canyons 

(Marrone, 2002).

Due to the restricted nature of the Atlantic fritillary’s distribution in the Black Hills, 

development or management activities within suitable habitats pose a risk to long-term 

persistence. Much of the fritillary’s habitat is privately owned. There are currently no 

reliable estimates of the Black Hills population (NatureServe, 2009). No records were 

found of this species in the project area.

Tawny Crescent (SOLC)

In South Dakota, the tawny crescent (Phycoides batesii) is restricted in its distribution to 

the Black Hills. The populations inhabiting the Black Hills of South Dakota and 

Wyoming are considered genetically isolated and disjunct from crescents elsewhere 

(Royer & Marrone, 1992). Tawny crescents were observed at two of 20 monitoring sites 

on the Mystic Ranger District in 2002 (USDA Forest Service, 2004). However, there 

continue to be no reliable estimates of local abundance or population estimates for the 

Black Hills (Stefanich, 2001). Stefanich (2001) hypothesized that the only limiting factor 

in the Black Hills is the destruction of this butterfly’s habitat or isolation of colonies to 

the extent that populations are unable to disperse. No records were found of this species 

in the project area.

Callused Vertigo (SOLC)

In 2007 and 2008 surveys were conducted by biological technicians. No callused vertigo

(Vertigo arthuri) snails were found in the project area. In 2002, the Forest received the 

final report for a contract to inventory and/or monitor 357 sites for land snails (Frest & 

Johannes, 2002). Callused vertigo was found sparingly in 63 of the 357 sites

inventoried/monitored. Specimens were found at Frest site 73, northeast of the 

decommissioned Moon Campground, within the Briggs Spring project area (refer to Frest 

& Johannes, 2002 for exact location of this site).

The narrowly restricted geographical range of the callused vertigo includes South Dakota 

(51 sites), Wyoming (12 sites in the Bear Lodge Mountains), North Dakota, Minnesota, 

and Alberta (Frest & Johannes, 2002). The callused vertigo is currently ranked imperiled 

globally and in South Dakota; it has not been ranked in Wyoming (NatureServe, 2009).

The monitoring protocol for snails was not funded in 2005 - 2008 (USDA Forest Service, 

2006a; 2007; 2008; 2009); therefore data to assess the status of SOLC snails is not 
Briggs Spring Environmental Assessment Chapter 3

44

available. Avoidance of known sites is currently the best available option for conserving 

and/or enhancing habitat at known snail colonies.

Mystery Vertigo (SOLC)

In 2002, the Forest received the final report for a contract to inventory and/or monitor 

357 sites for land snails (Frest & Johannes, 2002). Mystery vertigo (Vertigo paradoxa) 

was found in 23 of the 357 sites inventoried/monitored. They were not generally 

abundant at any site. This snail was not found in the Briggs Spring project area by Frest 

or by biological technicians (2007 and 2008). All sites with mystery vertigo were in the 

central or northern Black Hills or the Bear Lodge Mountains in Wyoming. 

The mystery vertigo is rare in the United States and occurs only in South Dakota (21 

sites); Wyoming (2 sites in the Bear Lodge Mountains); Michigan (1 site); Maine (2 

counties); and a few northern Wisconsin, Michigan, and Minnesota sites (Frest & 

Johannes, 2002). The species appears to be more common in adjoining areas of southern 

Canada, generally from the Great Lakes eastward. Mystery vertigo is currently ranked 

vulnerable globally and critically imperiled in South Dakota; it has not been ranked in 

Wyoming (NatureServe, 2009).

Frigid Ambersnail (SOLC)

In 2002, the Forest received the final report for a contract to inventory and/or monitor 

357 sites for land snails (Frest & Johannes, 2002). The frigid ambersnail (Catinella 

gelida) was found in 12 (none of which are in the Briggs Spring project area) of the 357 

sites inventoried/monitored. The frigid ambersnail was rare at all locations, and very few 

live adults were observed during the early 1990’s surveys. Locations are widely 

distributed geographically across the Forest at varying elevations (3,800 to 6,800 feet). 

The frigid ambersnail is currently found only in Iowa (14 sites), South Dakota (12 sites), 

and Wisconsin (Frest & Johannes, 2002). The frigid ambersnail is currently ranked as 

critically imperiled globally and in South Dakota and Iowa; it is ranked 

imperiled/critically imperiled in Wisconsin (NatureServe, 2009). The state of Iowa 

considers the frigid ambersnail an endangered species. At the time of this report, a status 

review is underway to determine if the frigid ambersnail warrants listing under the 

Endangered Species Act (ESA). This snail was not found in the Briggs Spring project 

area by Frest or by biological technicians (2007 and 2008).

Striate Disc (SOLC)

In 2002, the Forest received the final report for a contract to inventory and/or monitor 

357 sites for land snails (Frest & Johannes, 2002). The striate disc (Discus shimekii) was 

found live in only 18 of the 357 sites inventoried/monitored. Sites where the striate disc 

occurs appear restricted to the higher elevations of the limestone plateau of the westcentral and north-central portions of the Black Hills.

The range of the striate disc includes Wyoming (2 sites), Montana (1), Colorado (perhaps 

26 sites), South Dakota (1), Oregon (1), California (2), Utah (5), Arizona (3), and New 

Mexico (7) (Frest & Johannes, 2002). Hendricks (2003) also lists 5 records in Montana. 

Live sites have also been reported from several Canadian provinces. The striate disc is 

currently ranked globally as G5 (secure), and S2 (imperiled) in South Dakota 
Briggs Spring Environmental Assessment Chapter 3

45

(NatureServe, 2009). No striate disc snails were found during district survey efforts and 

none were located in the four Frest sites within the Briggs Spring project area.

Sharp-shinned Hawk (SOLC)

In South Dakota, the sharp-shinned hawk (Accipiter striatus) is considered “uncommon,” 

with the only recorded occurrences in the western part of the state (Peterson, 1995). In 

the Black Hills, they have been observed at all elevations (Peterson, 1995), but estimates 

of local abundance are not available due to their low numbers (Panjabi, 2003). The 

species has been observed an average of three times per year since bird monitoring began 

in 2001 (Giroir et al., 2007). 

On the Black Hills National Forest, sharp-shinned hawk nests occur in white spruce 

(Stephens & Anderson, 2002) and ponderosa pine (district biologists). Sharp-shinned 

hawks have also recently been detected in riparian, aspen, and burned habitats on the 

Forest, but these were not observations of nest sites (Panjabi, 2001; 2003; 2005). Sharpshinned hawks occur in most forest types across their range (Bildstein & Meyer, 2000). 

The amount of potential nesting habitat (SS3B, SS3C, SS4B, SS4C and SS5 ponderosa 

pine) in the project area is 7,764 acres or 32% of the project area. There is no SS4C or 

SS5 in the project area.

A single sharp-shinned hawk has been observed in the project area north and east of 

Redbank Spring Campground in recent years. There are no known nests in the project 

area.

Cooper’s Hawk (SOLC)

In South Dakota, the Cooper’s hawk (Accipiter cooperi) is considered “uncommon,” with 

the only recorded occurrences in the western part of the state (Peterson, 1995). The 

Cooper’s hawk has been observed in a variety of habitats in the Black Hills, including 

ponderosa pine, white spruce, riparian, shrublands, and burned areas (Panjabi, 2001; 

2003; 2005; Peterson, 1995). The species appears to be widespread but uncommon on 

the Forest. Bird monitoring over the past three years has yielded an average of five 

sightings per year (Giroir et al., 2007). 

In ponderosa pine, SS4B (mature stands with 40 to 70% canopy closure), SS4C (mature 

stands with >70% canopy closure), and SS5 (late succession) correspond most closely to 

the nesting habitat preferences of the Cooper’s hawk. There are currently 7,590 acres of 

SS4B pine in the project area. There are no acres of SS4C or SS5 in the project area.

There are no known sightings or nests of the Cooper’s hawk in the project area.

Broad-winged Hawk (SOLC)

In the Black Hills, the broad-winged hawk (Buteo platypterus) nests primarily in 

ponderosa pine, in mixed pine and deciduous habitats, occasionally with a white spruce 

component (Powder River Eagle Studies, 2000). It is expected that late-successional pine 

and aspen make-up the majority of desirable habitat for the species in the Black Hills 

(Panjabi, 2005). Although considered rare in South Dakota (Peterson, 1995), the species 

was the second most frequently encountered raptor during surveys in 1996 and 1997 

(Powder River Eagle Studies, 2000). Of the 27 broad-winged hawk nests found on the 

Forest, 25 were in ponderosa pine while one was in an aspen and one was in a paper 
Briggs Spring Environmental Assessment Chapter 3

46

birch. Nest trees had an average DBH of about 16 inches; canopy closure in nest stands 

averaged 66% with a range of 45 to 96% (Stephens & Anderson, 2003). These nest-stand 

characteristics equate to SS4B, SS4C and SS5. Nest sites typically were in areas with 

slopes less than 10%. No association between nest sites and forest openings or wetlands 

was detected on the Forest (Stephens & Anderson, 2003).

There were 24 broad-winged hawks identified along transects in 2004, mainly in the 

northern Black Hills and Bear Lodge mountains. Fourteen of these were located in 

aspen, eight in late-successional pine and two in the Jasper Burn Area (Panjabi, 2005). 

Nineteen were detected in 2005. Only two were detected in 2009 (USDA Forest Service, 

2010). There are no known sightings or nests of the broad-winged hawk in the project 

area.

Northern Saw-whet Owl (SOLC)

In South Dakota, the northern saw-whet owl (Aegolius acadicus) is considered an 

uncommon resident (Tallman et al., 2002). The saw-whet owl was determined to be 

widely distributed and common in the Black Hills (Fauna West Wildlife Consultants, 

2003; Drilling, 2010). In the Black Hills, seasonal migration is likely among high- and 

low-elevation habitat (Johnson & Anderson, 2003). The northern saw-whet owl is 

tracked by the South Dakota Natural Heritage Program (SDNHP) as a rare species and is 

ranked three on a rarity scale of one to five, with one being critically imperiled and five 

being secure (SDNHP, 2006).

Structural stages 4C and SS5 most closely resemble the preferred breeding and nesting 

habitat for the saw-whet owl. The Briggs Spring project area is lacking SS4C and SS5 

acreage, however there may be small suitable pockets of habitat. There are no known 

sightings or nests in the project area. 

Pygmy Nuthatch (SOLC)

The pygmy nuthatch (Sitta pygmaea) subspecies of the Black Hills (Sitta pygmaea 

melanotis) is found from southern interior British Columbia and south throughout the 

forests of the Rocky Mountain West into Mexico and western Texas (DeGraaf et al., 

1991). It is considered an uncommon resident in South Dakota (Peterson, 1995). There 

are no reliable estimates of pygmy nuthatch abundance for the Black Hills (Ghalambor, 

2003). Estimates of local abundance are unavailable due to the scarcity of this species 

and its unpredictable distribution (Panjabi, 2003). From 2001 through 2007 RMBO has 

recorded 19 pygmy nuthatches on the Forest in eight different habitat types (Giroir et al., 

2007). Three pygmy nuthatches were recorded by RMBO in 2009 (USDA Forest 

Service, 2010). 

There are no records of sightings in the project area.

Northern Long-eared Myotis (SOLC)

At the western edge of its range, the northern long-eared myotis (Myotis septentrionalis)

is found in the wooded riparian zone in badlands and prairies to higher elevation 

coniferous and deciduous woodlands. In the Black Hills region, this species has been 

captured at elevations ranging from 4,000 to 6,500 feet (Schmidt, 2003a). Turner (1974) 

reported northern myotis from Pennington and Custer counties in South Dakota. 
Briggs Spring Environmental Assessment Chapter 3

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NatureServe (2009) reported records of this species from Meade and Lawrence counties 

as well.

Luce et al. (1999) listed habitat associations as dense ponderosa pine and mixed 

coniferous/deciduous forest. Hibernacula for this species include mines and caves. 

Northern myotis have been documented using ponderosa pine snags as summer/maternity 

roosts in the Black Hills (Cryan et al., 2001) and in other regions (Rabe et al., 1998). 

A northern myotis was observed on private land, southeast of Moon Campground, within 

the project area in August 1993. No caves or mines were found in the Briggs Spring 

project area during field surveys. 

Small-footed Myotis (SOLC)

In the Black Hills region, the small-footed myotis (Myotis ciliolabrum) has been captured 

at elevations ranging from 3,800 to 6,000 feet (Schmidt, 2003b). Hibernacula for this 

species include mines and caves. Maternity and summer roosts are usually associated 

with rock features (e.g., bluffs, ridges, cliffs, boulders, and major outcroppings) within a 

variety of habitats (Schmidt, 2003b). The small-footed myotis is one of the few bat 

species that actually roosts in cavities at ground level.

This species has been reported from all five South Dakota counties of the Black Hills 

(Turner, 1974). Turner (1974) reported this species as widespread but not abundant in 

the Black Hills. No records were found for this species in the project area. No caves or 

mines were found in the Briggs Spring project area during field surveys.

Long-eared Myotis (SOLC)

The only records of long-eared myotis (Myotis evotis) in the Black Hills come from 

unpublished reports. It is unknown whether the Black Hills supports a self-sustaining 

population. This species is associated with coniferous montane habitats and has been 

reported foraging among trees and over woodland ponds (Schmidt, 2003c). Limited data 

suggest that the long-eared myotis uses ponderosa pine snags as summer and maternity 

roosts in other regions (Rabe et al., 1998; Vonhof & Barclay, 1997). Although relatively 

little is known about this bat’s specific hibernation needs, hibernation sites include caves 

and mines (Higgins et al., 2000), but there are no known reports of them hibernating in 

the Black Hills (Schmidt, 2003c).

No records were found for this species in the project area. No caves or mines were found 

in the Briggs Spring project area during field surveys.

Long-legged Myotis (SOLC)

The long-legged myotis (Myotis volans) is considered the most common and widely 

distributed member of the genus Myotis in the Black Hills region and has been reported 

from all counties occupied by the Black Hills in both South Dakota and Wyoming 

(Schmidt, 2003d; Luce et al., 1999; Clark & Stromberg, 1987; Turner, 1974).

In the Black Hills, this species occurs primarily at elevations between 4,500 and 6,500 

feet (Turner, 1974). This species has been documented using ponderosa pine snags as 

summer/maternity roosts in the Black Hills (Cryan et al., 2001) and in other regions 

(Rabe et al., 1998). Cryan et al. (2001) found the long-legged myotis roosting in rock 

crevices in the Black Hills where they may be subject to disturbance by rock climbing 
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activities. Snags used for roosting in the Black Hills were larger in diameter, in a greater 

state of decay, and were in higher densities when compared to random snags (Cryan et 

al., 2001). Hibernating individuals are known to use caves in the Black Hills, including 

Bush’s and Jewel Caves (Schmidt, 2003d; Luce et al., 1999; Turner, 1974).

The long-legged myotis forages over meadows, ponds, streams, and open mesic habitats 

of the Black Hills where it feeds on flying insects, particularly moths (Luce et al., 1999; 

Turner, 1974). Although this species is the most common and widely distributed bat in 

the Black Hills (Turner, 1974), general limits to persistence include availability of roost 

sites, hibernacula, and foraging areas. The reported preference of this bat for roosting in 

snags suggests that the availability of mature forests with abundant snags may be a 

limiting factor (Schmidt, 2003d).

No records were found for this species in the project area. No caves or mines were found 

in the Briggs Spring project area during field surveys.

Northern Flying Squirrel (SOLC)

There is a lack of specific data on habitat use by northern flying squirrels (Glaucomys 

sabrinus) in the Black Hills. Turner (1974) noted that the highest densities are likely 

found in white spruce forests in moist canyons of the northern Black Hills. Duckwitz 

(2001) found flying squirrels in Wind Cave National Park in ponderosa pine types that 

had an open canopy allowing understory grasses to prosper. Open pine types may 

provide the “openness” necessary for gliding. Locations where flying squirrels were

found in Wind Cave National Park did have large pines while stands of dense dog-hair 

pine were avoided (Duckwitz, 2001).

The northern flying squirrel in the Black Hills is an isolated population with the nearest 

population located in the forests of western Wyoming (Clark & Stromberg, 1987; WellsGosling & Heaney, 1984).

Meadow Jumping Mouse (SOLC)

Meadow jumping mice range across Alaska through Canada, the northern and eastern 

United States, and across the Great Plains to the eastern foothills of the Rocky Mountains 

(WYNDD, 2002; Whitaker, 1972). The Bear Lodge meadow jumping mouse (Zapus 

hudsonius campestris) is a separate subspecies that occurs in the Black Hills region 

(Beauvais, 2001). There are seven recorded occurrences of this species on the Bearlodge 

Mountains of the Black Hills, including the type specimen collected in 1864 (WYNDD, 

2002). Turner (1974) collected a total of 207 specimens from across the Black Hills and 

Bear Lodge Mountains in South Dakota and Wyoming. He collected the species as far 

south as Wind Cave National Park and characterized it as common throughout the study 

area (Black Hills and Bear Lodge Mountains). 

There are no known observations of this species in the Briggs Spring project area.

Threatened and Endangered Species

A list of federally threatened, endangered and proposed species has been provided by the 

U.S. Fish and Wildlife Service (USFWS), South Dakota State Office, and was last 

updated on December 21, 2010 (USFWS, 2011). The South Dakota State Office is the 

primary center for all of the Black Hills, including Wyoming. The USFWS lists the 
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following endangered and/or threatened species for Pennington County, South Dakota: 

whooping crane, least tern and black-footed ferret. No known occurrences or suitable 

habitat for these species exists in the Briggs Spring project area. 

Consultation with U.S. Fish and Wildlife Service 

The whooping crane and least tern have been removed from the list of species considered 

on the Black Hills National Forest under section 7 consultation (letter of concurrence 

from D. Gober, Field Supervisor, USFWS, Pierre, South Dakota, dated August 8, 2003). 

Although the black-footed ferret is listed for Pennington County, it is an experimental 

population located in eastern Pennington County, where they have been re-introduced 

into Badlands National Park and the Conata Basin of Buffalo Gap National Grassland. 

Habitat for the black-footed ferret is not present in the project area. There are no prairie 

dog colonies present. 

With the determination that there are no federally listed species in the project area, no 

further consultation with the USFWS pursuant to the Endangered Species Act is required. 

As of August 8th, 2007 the bald eagle was removed from the list of threatened and 

endangered species under the Endangered Species Act. The bald eagle continues to be 

protected under the Bald and Golden Eagle Protection Act, and the Migratory Bird Treaty 

Act. And, in accordance with Regional policy, upon de-listing the bald eagle is 

automatically given sensitive species status for a period of at least 5 years to ensure 

recovery of the species is maintained over that period (R2 Supplement, FSM 2672.11 

(6)).

There are no Threatened or Endangered species which have habitat within the Briggs 

Spring project area. Refer to the wildlife BA/BE in the project record.

Region 2 (R2) Sensitive Species

The current sensitive species list for the Rocky Mountain Region (R2) was renewed on 

June 10, 2011. Sensitive species for the Black Hills National Forest are listed on the R2 

threatened, endangered, and sensitive species home webpage (USDA Forest Service, 

2011). 

The pre-field review of R2 sensitive species and federally endangered, threatened and 

proposed species was completed using survey results, district records, communication 

with District personnel, literature reviews, on-line databases and the South Dakota 

Natural Heritage Database. Of the 26 R2 sensitive species, six species have confirmed 

records of occurrence and suitable habitat exists and eight species are expected to be 

present and suitable habitat exists in the project area. These 14 species may be impacted 

by the Briggs Spring project. 

Species Presence Confirmed & Habitat Present:

• Bald eagle

• Northern goshawk

• Northern harrier

• Black-backed woodpecker

• Northern leopard frog 

• Black Hills redbelly snake
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Species Presence Expected and Habitat Present:

• Fringed myotis

• Townsend’s big-eared bat

• Hoary bat

• Flammulated owl

• Lewis’s woodpecker

• Grasshopper sparrow

• Cooper’s mountain snail

• Regal fritillary butterfly
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These sensitive species were analyzed in the Briggs Spring Wildlife BA/BE due to the 

species presence and/or presence of potential habitat in the project area. Two of the 

species listed, the black-backed woodpecker and grasshopper sparrow, are also 

designated as MIS species. Those species with duel MIS and R2 Sensitive Species 

designations will be discussed under the MIS section. 

Bald Eagle (R2 Sensitive Species)

Bald eagles (Haliaeetus leucocephalus) have been documented in all counties in the 

Black Hills. In South Dakota, approximately 300 bald eagles winter in the Black Hills 

and along the Missouri River (USFWS, 2010). In the Black Hills, this species utilizes 

winter habitat where carrion is available (along highways and in big game winter range) 

and where there are open lakes and streams. In addition, this species population is in an 

upward trend in South Dakota with successful nesting in twenty-two counties (South 

Dakota Game, Fish and Parks [SDGFP], 2010a). South Dakota trends based on midwinter surveys are reported by the SDGFP (2010b). The first nesting attempt in the 

Black Hills was in 2007 at Deerfield Reservoir (USDA Forest Service, 2009).

There have been no reported bald eagle sightings during the breeding season in the 

project area. The project area lacks any suitable nesting habitat for the bald eagle. Bald 

eagles have been sighted in the Briggs Spring project area during winter.

Northern Goshawk (R2 Sensitive Species)

In the Black Hills, the northern goshawk (Accipiter gentilis) is considered a rare 

permanent resident and has been found nesting in all the counties in the Black Hills 

(Tallman et al., 2002).

In the Black Hills, this species is usually found in ponderosa pine, especially in more 

closed canopy with multiple vegetation structure. Nest stands are typically mature, 

closed canopy (greater than 60%) ponderosa stands with high basal area. Little is known 

about migration of this species (NatureServe, 2009).

There is foraging and nesting habitat in the Briggs Spring project area. The nesting 

habitat is limited. There are two known goshawk territories. One of these territories was 

found due to new survey efforts within the project area in 2007. The other territory is 

historical with success prior to 2007. Both nest territories were active in 2007. Neither 

was successful in 2008. In 2009 both were successful. Neither was successful in 2010. 

These two territories are monitored yearly.

Northern Harrier (R2 Sensitive Species)

The northern harrier (Circus cyaneus) is considered an uncommon migrant and summer 

resident in South Dakota (Tallman et al., 2002). Although the Black Hills is not 

considered within their range, recent large fires in the central and southern Hills may 

have produced desirable habitat. Northern harriers have been seen on a few occasions in 

the Jasper Burn Area, near Elk Mountain and in large grasslands/meadows (personal 

observation).
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52

The open grasslands/meadows within the Briggs Spring project area provide suitable 

foraging and nesting habitat for the northern harrier. The Jasper fire created suitable 

habitat for this species in the Briggs Spring project area. In spring of 2004 a harrier was 

observed approximately two miles north of Moon Campground flying over a meadow.

Black-backed Woodpecker (R2 Sensitive Species and MIS)

The black-backed woodpecker (Picoides articus) is discussed under the MIS section. 

Northern Leopard Frog (R2 Sensitive Species)

In the Black Hills, the northern leopard frogs’ (Rana pipiens) current distribution is 

considered high where suitable habitat is available (USDA Forest Service, 2004). This 

species is vulnerable to habitat alteration/loss, introduced predaceous fish, susceptible to 

overgrazing, low water quality and wetland loss (Smith, 2003). At the time of this report 

the northern leopard frog has been petitioned for listing under the Endangered Species 

Act (ESA).

This species requires three types of habitat. Winter habitat, usually lakes, streams or 

ponds, is needed for winter torpor. High oxygen saturation is best in the winter waters. 

Summer habitat for this insectivorous frog is considered upland forage ground often near 

the breeding ponds. The third habitat is breeding/tadpole habitat. This is usually shallow 

bodies of water with little to no current, aquatic vegetation, good water quality, and little 

overhead canopy. Warmth from the sun is needed for proper development of the 

tadpoles. Larval development becomes an issue if water is too cold. This could explain 

why frogs are not breeding at springs in the Black Hills (Smith, 2003).

Suitable habitat exists in the Briggs Spring project area. During surveys 2007-2010, 

leopard frogs were only observed in 2010 at one site.

Black Hills Redbelly Snake (R2 Sensitive Species)

The Black Hills subspecies (Storeria occipitomaculata) is an isolated population; the next 

nearest population is located in the eastern part of South Dakota, some 300 miles away. 

Suitable habitat may be broadly distributed or abundant in the Black Hills. The snake is 

not rare in good habitat and is considered quite common in the Black Hills (USDA Forest 

Service, 2000; SDGFP, 2010c).

Suitable habitat for this species exists in the Briggs Spring project area. A Black Hills 

redbelly snake was observed by a district biologist at Redbank Spring in July 2003.

Fringed Myotis (R2 Sensitive Species)

This subspecies (Myotis thysanodes pahasapensis) only occurs in the Black Hills and 

possibly northwest Nebraska. This species is considered a rare to uncommon year-round 

resident. Known locations are found in Lawrence, Meade, Pennington and Custer 

Counties of South Dakota and possibly Crook and Weston Counties in Wyoming (Luce 

et al., 1997; Tigner & Stukel, 2003).

There are no known caves, mines or documented roost sites within the Briggs Spring 

project area. However, there are some exposed rock outcrops and snags within the area 

that have the potential for use as roost sites for bats. There is no evidence to suspect that 

a major hibernaculum (cave) site exists within this project area. There was a fringed 
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53

myotis captured southwest of Moon Campground in August of 1993, outside of the 

Briggs Spring project area.

Townsend’s Big-eared Bat (R2 Sensitive Species)

Within the Black Hills, the Townsend’s big-eared bat (Corynorhinus townsendii) has 

been recorded in Fall River, Meade, Pennington, Custer and Lawrence counties (Higgens 

et al., 2000). Population trends appear to be declining in the Black Hills as well as 

throughout their range. Loss of habitat is the main contributor to lower numbers, which 

is attributed to the loss of large caves and dilapidation of mines. This species is highly 

sensitive to human disturbance, especially at maternity roost sites (USDA Forest Service, 

2000).

Suitable foraging habitat and potential roosting/hibernating habitat is present in the 

Briggs Spring project area. There are no known caves or abandoned mine adits in the 

project area. However, there are man-made structures, rock outcrops, and cliff-face 

crevices and fissures. There are no records of Townsend’s big-eared bats in the Briggs

Spring project area. There is a known Townsend’s big-eared bat hibernation site about 

one mile from the southwest corner of the project area.

Flammulated Owl (R2 Sensitive Species)

The flammulated owl (Otus flammeolus) has recently been confirmed in the Black Hills. 

An incidental observation (unconfirmed) was reported in the summer of 1994 by a bat 

biologist doing mist netting in the southern Black Hills. He reported a “small, dark-eyed 

owl” becoming entangled in the net and was released. However, in 2002 at least two, 

maybe three, flammulated owls were observed in the northern Black Hills (Panjabi, 

2003). These observations do not prove a flammulated owl population has established 

itself in the Black Hills.

Migration in this species is still poorly understood but recent review of the data suggests 

that this species may be a long distance, north-south, migrant. Experiments have found 

that this owl does not become torpid in cold temperatures. It is likely that prey 

availability also plays a large role in the migratory behavior of this species (McCallum, 

1994).

Based on published information, and the recent Black Hills sightings it is reasonable to 

expect that suitable habitat for flammulated owls is present in the Briggs Spring project 

area.

Lewis’s Woodpecker (R2 Sensitive Species)

In the Black Hills, the Lewis’s woodpecker (melanerpes lewis) is considered an 

uncommon, permanent resident (Tallman et al. 2002). The Rocky Mountain Bird 

Observatory (RMBO) has recorded three to nine occurrences of this species on the Black 

Hills National Forest each year from 2001-2007 (Giroir et al., 2007). Three times as 

many Lewis’s woodpeckers were observed in 2009 compared to 2007 (USDA Forest 

Service, 2010). This species has been documented in all counties in the Black Hills of 

South Dakota (Peterson, 1995). This species’ breeding range is closely related to the 

range of ponderosa pine (Saab & Vierling, 2001). This species is vulnerable to loss of 

large snags, salvage timber harvest and fire suppression.
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Potential suitable habitat is presumed present in the project area in respect to large dead 

trees, snags created by MPB activity and late succession pine stands. RMBO has 

recorded Lewis’s woodpeckers just south of the project area (Beason et al., 2006). A 

district biologist has observed this species just outside of the southeast corner of the 

project area.

Grasshopper Sparrow (R2 Sensitive Species and MIS)

The grasshopper sparrow (Ammodramus savannarum) is discussed under the MIS 

section.

Cooper’s Mountain Snail (R2 Sensitive Species)

Distribution data for the United States and Canadian provinces is known to be incomplete

for Cooper’s mountain snail (Oreohelix strigosa cooperi). Current identified distribution 

is in the Black Hills of South Dakota and Wyoming. Populations are limited in the Black 

Hills to suitable habitat mostly in Spearfish Creek, upper reaches of Rapid Creek, 

Higgins Gulch, Prospect Gulch and Grand Canyon near Deadwood, SD. This species 

could also be found in other drainages in the northwest region of the Black Hills. 

According to Frest and Johannes, 2002, Pilsbry (1939) cited a wider range. 

Frest (1991-2001) surveyed four sites within the Briggs Spring project area: 40701-32

(Frest site #73), 40702-23 (Frest site #356), 40705-148 (Frest site #270) and 40803-101

(Frest site #74) (Frest & Johannes, 2002). No R2 sensitive Oreohelix were found at these 

sites. However, there is limited suitable habitat in the project area. No surveys 

conducted by district biologists and/or technicians in 2007 and 2008 produced any 

Oreohelix snails.

Regal Fritillary Butterfly (R2 Sensitive Species)

The Black Hills is at the western edge of the regal fritillary butterfly’s (Speyeria idalia)

range. Distribution within the Black Hills may be related to moisture gradient (USDA 

Forest Service, 2000). In South Dakota, it is most commonly associated with tall-grass 

prairie near wet areas and mixed-grass sites along the Missouri River breaks and Fort 

Pierre National Grassland (Marrone, 2002). The main component of all habitat types is 

the presence of extensive grassland with a readily available supply of Viola spp. and

nectar (Royer & Marrone, 1992).

There is potential habitat in the Briggs Spring project area within the Jasper Burn acreage 

and large grasslands/meadows. There are no records of the species in the project area.

Migratory Birds

Many species of migratory birds are of international concern due to naturally small 

ranges, loss of habitat, observed population declines and other factors. Species of 

concern applicable to project-level conservation are identified by many sources, 

including the Endangered Species Act, the R2 sensitive species list, the Black Hills 

National Forest MIS and Species of Local Concern list, internal and public scoping 
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55

efforts, and the USFWS Birds of Conservation Concern (BCC) (USFWS, 2008). BCC 

2008 publication partitions North America into 37 Bird Conservation Regions (USFWS, 

2008). The Black Hills is included in BCR 17 – Badlands and Prairies. Of the 28 bird 

species found in BCR 17 (USFWS, 2008), fifteen are duplicated on the R2 sensitive 

species list, and are evaluated in the BA/BE if they have potential to occur in the Black 

Hills. Six species are not expected to occur in the Black Hills due to lack of habitat. 

There are seven remaining species that could potentially occur in the Black Hills: golden 

eagle, prairie falcon, upland sandpiper, black-billed cuckoo, red-headed woodpecker, 

pinyon jay and dickcissel. Of these seven species, the golden eagle, prairie falcon, 

upland sandpiper and red-headed woodpecker have the potential to occur within the 

project area. The black-billed cuckoo, pinyon jay and dickcissel will not be analyzed 

because suitable habitat is not present in the Briggs Spring project area.

Golden Eagle (Migratory Bird)

Golden eagles (Aquila chrysaetos) are considered uncommon permanent residents in 

western South Dakota (Tallman et al., 2002) and only ten have been detected during 

recent bird monitoring efforts (Giroir et al., 2007). Golden eagles were observed in the 

project area in the summers of 2007 and 2008. Golden eagles are commonly seen 

feeding on carrion along roads in the Black Hills during winter (personal observation).

Contiguously forested habitats, such as those found within most of the Briggs Spring 

project area are not preferred by golden eagles, but they may be included in a home range

if suitable nesting or foraging habitat is nearby. The Briggs Spring project area contains 

limited small areas of rim-rock outcrops, but there are no substantial cliffs or rock faces 

that provide typical nesting substrates. Eagles could forage within the meadows 

(primarily on private land) of the project area, or in nearby grasslands and burned forest 

(e.g., Jasper Burn area).

Prairie Falcon (Migratory Bird)

The prairie falcon (Falco mexicanus) is considered an uncommon permanent resident in 

far western South Dakota (Tallman et al., 2002). Two nest sites were discovered in the 

Black Hills in 2002, one in Spearfish Canyon and one in Redbird Canyon. Redbird 

Canyon is about 6 miles south of the project area. Additionally, a nest site was found in 

Hell Canyon in 2001, but was not active in 2002. Prairie falcons within the Black Hills 

were located primarily at the periphery of the Hills where high cliffs and open grassland 

exist (Panjabi, 2003). Prairie falcons have been observed every year since the RMBO 

study began n 2001 except for the 2007 field season (Giroir et al., 2007).

No prairie falcons were observed in the project area during field visits. A prairie falcon 

was observed, by a wildlife biologist, foraging in an open meadow in August 2003 just 

east of the Briggs Spring project area. This is the closest observation on record. There is 

no nesting habitat in the Briggs Spring project area. Limited foraging habitat is available 

in the north half of the project area and consists of open meadows interspersed with 

forested sites. The Jasper Fire of 2000 created foraging habitat in the south portion of the 

project area.

Upland Sandpiper (Migratory Bird)
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56

The upland sandpiper (Bartramia longicauda) is considered uncommon and local in the 

Black Hills (Tallman et al., 2002). The 1966 to 2004 BBS population trend data for BCR 

17 indicates that the species has been increasing slightly at a rate of 0.3% per year (Sauer 

et al., 2005). Monitoring data from 2004 found the species restricted entirely to the 

mixed-grass prairie habitat type in the southern Hills (Panjabi, 2005). There is suitable 

habitat in the south portion of the project area that has been burned by the Jasper Fire of 

2000. There are no recorded observations in the project area. However, there was an 

observation of an upland sandpiper just south of the project boundary in the Jasper burn 

in 2007 (Giroir et al., 2007).

Red-headed Woodpecker (Migratory Bird)

The red-headed woodpecker (Melanerpes erythrocephalus) occurs locally in the Black 

Hills, where they are generally uncommon to rare. At present, they occur in very low 

densities, primarily in burn areas. Red-headed woodpeckers breed in the eastern portion 

of Colorado in riparian habitat and urban parks. They are found throughout Wyoming 

but primarily breed in the eastern and north-central parts of the state.

Monitoring data from 2001 through 2007 showed that this species was detected 

exclusively in burned habitat. The highest density was in 2007 with 1.48 birds/km2

. 

RMBO has recorded red-headed woodpeckers in the south end of the project area in 

2001, 2003, 2004, 2005 and 2007 (Panjabi, 2001; 2004; 2005; Beason et al., 2006; Giroir 

et al., 2007). The Jasper Fire of 2000 created habitat for this woodpecker within the 

project area.

Demand Species

Demand species are important local game animals which are not included in other 

emphasis groups above. The Rocky Mountain elk (Cercus elaphus nelsoni) and 

Merriam’s wild turkey (Meleagris gallapavo merriami) are two of these demand species 

and each will be analyzed.

Rocky Mountain Elk (Demand Species)

The elk population of the Black Hills is difficult to estimate in part because of interstate 

movements of the species. However, the 2007 estimate placed the population level at 

3,800 elk in the South Dakota Black Hills (Huxoll, 2008). The 2008 estimate decreased 

to 3,600 elk (Huxoll, 2009). The 2009 estimate decreased to 3,300 elk (Huxoll, 2010). 

No population estimates are available for the Wyoming portion of the Black Hills. The

elk herd in Wyoming appears to be growing, but at a slower rate than in the past 

(Sandrini, 2007). The Forest has committed (through Objective 217) to managing habitat 

for a total of 4,350 elk, which was the combined population objective establish by the 

two state game agencies in 1996 (USDA Forest Service, 2005).

Elk are commonly seen in the Briggs Spring project area. The project area is entirely 

within MA 5.1 (resource production emphasis) which includes management for a 

diversity of wildlife species. The Rocky Mountain Elk Foundation (2002) considers the 

majority of the project area as crucial annual range for elk. The southern tip is 

considered crucial annual, summer and winter range. Rumble et al. (2005) found that elk 

generally avoid areas within 1 km of primary and secondary roads during this time 
Briggs Spring Environmental Assessment Chapter 4

57

period. Currently, open system road density within the project area is 2.8 mi/mi2. There 

are also approximately 13 miles of OHV system trail within the project area.

Merriam’s Wild Turkey (Demand Species)

The wild turkey is a non-migratory species. There are six recognized subspecies of wild 

turkey and of these the Merriam’s (wild) turkey is the race introduced in the Black Hills 

in the late 1940s and early 1950s (Flake et al., 2006). The Merriam’s turkey is common 

and widespread on the Forest, with an estimated population of 35,000 birds in the South 

Dakota portion of the Black Hills (Huxoll, 2009). The 2009 population estimate for 

turkeys in the Black Hills was 40,000 (Huxoll, 2010). Turkey populations on the Forest 

have been on a steady increase since 1998 (USDA Forest Service, 2004; 2004a).

Turkeys are common in the Briggs Spring project area throughout the summer. Turkeys 

would remain in the area during mild winters. Adequate roosting habitat is available in 

the project area.

Environmental Consequences

Snags and Down Woody Material

Under all alternatives, no snags would be cut unless deemed a safety hazard during 

operations. As per Standard 2301, if the project area does not meet Objective 211 than all 

snags will be left during treatments unless deemed a safety hazard.

Alternative 1 – No Action

Direct and Indirect Effects

Snags would be expected to increase because of natural mortality. Trees would become 

more dense and over time, competition for water and nutrients would stress the trees, 

which would make them more susceptible to insects and disease agents. Dense trees 

would increase wildfire risk as well. Natural mortality levels would be higher with this 

alternative than any of the action alternatives. As these trees die and fall to the ground 

there would be an increase in down woody debris. Since there would be no project 

activities all snags and down woody debris would be left in place. 

Alternative 2 – Proposed Action

Direct and Indirect Effects

Alternative 2 proposes sanitation treatment on 6,063 acres if needed. This treatment 

would only harvest those trees that have been hit by pine beetles but are still green. 

Proposed fuel treatments on 9,303 acres, including mechanical thinning, broadcast 

burning, and deadfall treatment have the potential to destroy snags and downed wood. 

Vegetation treatments, both commercial and non-commercial have the potential to 

destroy snags and downed wood as well. This alternative would have more potential than 

Alternative 3 to retain future snags. Any protection of standing snags would move snag 

densities toward Forest Plan standards and guidelines. 

Alternative 3

Direct and Indirect Effects
Briggs Spring Environmental Assessment Chapter 4

58

Alternative 3 proposes sanitation treatment on 3,678 acres. Fuel treatments are similar to 

those under Alternative 2; however, there are 714 more acres of prescribed burning 

planned under this alternative. Under this alternative, snags and downed wood may be 

destroyed during commercial and non-commercial vegetation treatments as well as fuel 

treatments. Alternative 3 proposes harvesting pine trees from more acres (7,469 more 

acres of group shelterwood) and accomplishing more prescribed burning than Alternative 

2. This may mean that there would be fewer replacement snags in the future and there is 

a higher potential to destroy more snags, if considered safety hazards, under Alternative 

3. 

Cumulative Effects

Past firewood cutting, timber harvest and fuels management activities have contributed to 

the loss of snags and downed woody habitat. Fire, MPB and other causes of tree 

mortality continue to create snag/downed wood habitat. With restrictions on cutting 

standing dead for firewood (except where designated), an increase in MPB outbreaks, 

past and potential future wildfires the outlook for improving snag densities for this area is 

good. The effects of the new Forest Policy (implemented December 01, 2010) of 

allowing cutting of snags within 300’ of roads, where dispersed camping is allowed, are 

not known yet. MPB infestations within the project area are enlarging and infestations 

are showing up in new areas throughout the project area. It is expected that by the time 

project activities would be initiated, snag densities would potentially be higher than 

current numbers due to the numerous “bug” pockets that have started killing trees in the 

area. Proposed activities would add to past management activity impacts. 

Riparian Habitat

Alternative 1 – No Action

Those riparian areas that are fenced to exclude livestock would continue to be maintained 

or re-built where failing. Riparian areas that are not receiving protection from excessive 

use by livestock and/or wildlife may continue to suffer.

Common to Both Action Alternatives

Direct and Indirect Effects

Both action alternatives propose the same riparian protection/enhancement projects (post 

harvest). These include: planting willows, building more exclosure fencing, constructing 

road closures and installing new stock tanks farther from riparian corridors. Design 

criteria are included in Appendix B for specific riparian sites and protection guidance. 

Cumulative Effects

Past fire suppression, timber harvest, road use, recreation (motorized), livestock grazing, 

and natural events such as drought and flooding have caused impacts to riparian areas 

within the project area. Fire suppression has resulted in an increase of pine trees which 

may lead to a change in water tables. Drought conditions and livestock/wildlife use can 

also negatively impact the water level in the riparian areas. Timber harvest, road use, 

motorized recreation, flooding and livestock grazing can contribute sediment buildup. 

The harvest of trees may also be beneficial for riparian areas by decreasing acreage of 

pine trees and thereby decreasing water use.
Briggs Spring Environmental Assessment Chapter 4

59

Neither the no action alternative nor the action alternatives would cause detrimental 

impacts to riparian areas within the Briggs Spring project area. There are design criteria 

in place to protect/enhance some riparian areas where mechanical and burning treatments

are proposed. Some fence projects and willow plantings are proposed in post-harvest 

activities in the action alternatives, near riparian areas in order to protect/enhance the 

resource. Therefore the action alternatives would move the riparian areas to better

conditions overall in the project area. The action alternatives may help to meet Forest 

Objectives, Standards and Guidelines.

Management Indicator Species (MIS)

Summary of Effects on MIS

The following is a summary of effects to the previously mentioned wildlife MIS. A 

detailed analysis can be found in the Wildlife Report in the project record. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

White-tailed Deer

(Odocoileus 

virginianus)

Direct and Indirect Effects

No immediate 

effects. Potential for 

additional hiding 

cover along roads. 

Potential for pine to 

further encroach in 

meadows and 

hardwoods, reducing 

quality forage. 

Increased potential in 

competition for 

forage between 

livestock and big 

game. 

 

Low impact on screening 

cover along roads where 

vegetation treatments are 

proposed. Increased forage 

production and quality than 

Alt 1. Potential to decrease 

fawning cover due to 

vegetation treatments. 

Increased potential of OHV 

and recreation disturbance to 

deer by creating a second 

campground within the 

project area.

Low impact to screening 

cover along roads where 

vegetation treatments are 

proposed. Increased 

potential of amount & 

quality of forage over Alt 

2. Potential to decrease 

fawning cover more than 

Alt 2 due to increased 

vegetation treatments. 

Cumulative Effects

Would not have 

adverse cumulative 

effects. May 

decrease forage, but 

increase hiding cover

and screening cover.

Would add to positive effects 

of past prescribed burns and 

timber harvests by increasing 

diversity of forage, and 

increasing early successional 

vegetative stages. May 

slightly reduce screening 

cover. Potential to decrease 

winter habitat for big game 

species. Expected to add to 

disturbance by OHV and 

recreation use. 

Would add to positive 

effects of past prescribed 

burns and timber harvests 

by increasing diversity of 

forage, and increasing early 

successional vegetative 

stages more than Alt 2. 

May slightly reduce 

screening cover. Increased 

potential from Alt 2 to 

decrease winter habitat for 

big game species. 

Expected to minimally add 

to disturbance by OHV use.

Summary

None of the alternatives would contribute to a Forest-wide loss of summer habitat or 

decrease in population for white-tailed deer, allowing for attainment of Objective 

238a. 
Briggs Spring Environmental Assessment Chapter 4

60

Both action alternatives would slightly decrease screening cover and Guideline 3203

would be met along five of the six arterial and collector roads. One of these road’s 

existing condition currently does not meet Guideline 3203, this is not a result of any 

action alternatives. Both action alternatives may decrease big game winter habitat, 

however adequate habitat across the forest would allow attainment for Objective 

217.

The proposed action alternatives would meet Forest Plan standards and guidelines. 

Therefore, this species is likely to persist on the Forest.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Grasshopper 

Sparrow

(Ammodramus 

savannarum)

Note: Also R2 

Senistive Species

Direct and Indirect Effects

No immediate effects. 

Ponderosa pine would 

continue to encroach into 

meadows/grasslands. 

This would exacerbate the 

utilization of forage on 

remaining 

meadows/grasslands and 

could affect species that 

use meadows/grasslands 

as food, nesting and/or 

cover. 

Rx burning in spring and 

summer may negatively 

impact this species’ 

nesting attempts. Design 

criteria for fall burning 

would improve habitat 

and eliminate nesting 

conflicts with burning. 

Harvest activities are not 

expected to affect this 

species. 

Rx burning in spring and 

summer may negatively 

impact this species’ nesting 

attempts more than Alt 2. 

Design criteria for fall 

burning would improve 

habitat and eliminate 

nesting conflicts with 

burning. Increased burning 

acres may enhance or 

create more habitat for this 

species than Alt 2. Harvest 

activities are not expected 

to affect this species.

Cumulative Effects

Would not have adverse 

cumulative effects. The 

Jasper Fire increased 

grasshopper sparrow 

habitat within the project 

area. Continued grazing 

and chemical herbicide 

treatments may negatively 

impact the grasshopper 

sparrow.

Vegetation treatments, 

such as Rx burning and 

pine encroachment, 

would improve and 

expand habitat, adding to 

previous vegetation 

treatments. Continued 

grazing and chemical 

herbicide treatments may 

negatively impact the 

grasshopper sparrow. 

Vegetation treatments, such 

as Rx burning and pine 

encroachment, would 

improve and expand 

habitat, even more so than 

Alt 2. Continued grazing 

and chemical herbicide 

treatments may negatively 

impact the grasshopper 

sparrow.

Summary

Following design criteria all alternatives would allow the Forest-wide grasshopper 

sparrow population to remain stable and allow for the attainment of Objectives 221 

& 238a. The action alternatives in this project would move toward attainment of 

Objective 205. The proposed action alternatives would meet Forest Plan standards 

and guidelines; therefore this species is likely to persist on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Black-backed 

Woodpecker

(Picoides articus)

Note: Also R2 

Senistive Species

Direct and Indirect Effects

Would allow natural 

successional changes to 

occur in vegetation. 

Existing stands may 

become more dense and 

stressed and eventually 

may be more susceptible 

to MPB infestations 

and/or wildfires. This 

alternative would provide 

Proposed fuel and 

harvest treatments would 

potentially decrease snag 

habitat. May disturb 

nesting woodpeckers if 

harvest occurs during 

nesting season, expected 

to be a short-term 

impact. 

Increased acres of proposed 

fuel treatments and harvest 

treatments would 

potentially decrease snag 

habitat, more than Alt 2. 

Potential is greater to 

disturb nesting 

woodpeckers, but still 

expected to be a short-term 

impact. 
Briggs Spring Environmental Assessment Chapter 4

61

greatest potential for 

increase in woodpecker 

habitat. Snags would 

increase due to natural 

mortality. 

Cumulative Effects

Past wildfires and past 

and existing MPB 

infestations have created 

habitat throughout the 

Forest and project area. 

No additive effects on 

existing snag densities. 

Proposed pine treatments 

would add to the loss of 

larger diameter trees 

from past harvest 

activities. May result in 

decreased preferred or 

potential habitat. 

No additive effects on 

existing snag densities. 

Proposed pine treatments 

would add to the loss of 

larger diameter trees from 

past harvest activities. 

Increased potential to result 

in decreased preferred or 

potential habitat. 

Summary

Alternative 1 has the greatest potential for increasing woodpecker habitat. Both 

action alternatives may decrease preferred and/or potential habitat, but they would 

not affect the habitat or population trend Forest wide because of providing for 

Objective 211 (snags). Snags are not allowed to be cut unless deemed a safety 

hazard or within designated firewood cutting areas. The project area is only a small 

portion of the currently available habitat, new habitat acres are currently being 

created across the Forest. Objectives 221 (sensitive species) and 238b are currently 

being met and would be met under either action alternative. The proposed action 

alternatives would meet Forest Plan standards and guidelines; therefore this species 

is likely to persist on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Brown Creeper

(Certhia Americana)

Direct and Indirect Effects

Existing mature stands 

would eventually become 

SS5, a more desirable 

habitat. The MPB and 

wildfire risk would not be 

decreased, leaving mature 

stands susceptible to MPB 

infestation and/or 

catastrophic wildfire. 

Would reduce acres of 

SS4B (more preferred

habitat) to SS4A, 

impacting brown creeper 

habitat. May cause 

displacement of 

individuals; however 

creepers may return to 

the affected area. 

Harvest activities may 

disturb nesting, but is 

expected to be a short 

term impact. Risk of 

MPB infestation and 

wildfire would be 

reduced. 

Would reduce acres of 

SS4B to SS4A, even more 

so than Alt 2, increasing 

potential impact on brown 

creeper habitat. May cause 

displacement of 

individuals; however 

creepers may return to the 

affected area. Harvest 

activities may disturb 

nesting, but is expected to 

be a short term impact. 

Risk of MPB infestation 

and wildfire would be 

reduced.

Cumulative Effects

Would not have adverse 

cumulative effects.

Would add to preferred 

habitat reduction within 

the project area, however 

with lack of treatment 

habitat may be lost to 

fire or MPB. Would add 

to positive impacts of 

previous vegetation 

treatments by reducing 

MPB and fire risk. 

Would add to preferred

habitat reduction within the 

project area. Would add to 

positive impacts of 

previous vegetation 

treatments by reducing 

MPB and fire risk. 
Briggs Spring Environmental Assessment Chapter 4

62

Summary

Alternative 1 results in the most potential for preferred habitat for the brown creeper. 

Both action alternatives would reduce SS4B from the existing condition, however 

with treatment risk of MPB infestation and wildfire would be reduced. Habitat 

would be maintained and the project meets Objective 238a. 

The proposed action alternatives would meet Forest Plan standards and guidelines; 

therefore this species is likely to persist on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Ruffed Grouse

(Bonasa umbellus)

Direct and Indirect Effects

Habitat quality & quantity 

may decrease due to pine 

continuing to encroach 

into hardwood stands. 

Could result in a decrease

of aspen clones or groups 

of clones. Would not 

benefit habitat. 

Treatments would 

increase and/or enhance 

habitat. 

Treatments would increase 

and/or enhance habitat. Rx 

burning of aspen sites 

could enhance stands by 

stimulating growth or cause 

mortality within aspen 

sites. 

Cumulative Effects

Would not have adverse 

cumulative effects. 

Would help offset 

negative impacts from 

past activities. Would 

enhance species habitat 

over the next 10 years. 

Future hardwood 

treatments would 

continue to improve 

habitat. 

Would help offset negative 

impacts from past 

activities. Would have 

slightly more potential to 

enhance species habitat 

over the next 10 years. 

Future hardwood 

treatments would continue 

to improve habitat.

Summary

Alternative 1 would allow pine encroachment to continue within the hardwood 

stands, eventually reducing ruffed grouse habitat. Both action alternatives would 

increase and/or re-establish hardwoods (aspen), enhancing the health of hardwoods 

within the project area. Alternative 3 would potentially release more aspen 

compared to Alternative 2, due to harvesting more pine acres. 

The action alternatives would not contribute to a loss of habitat or decrease in 

population Forest-wide for the ruffed grouse. The action alternatives would enhance 

habitat by increasing acres of hardwoods. Therefore Forest Plan Objective 238a

would be met. The proposed action alternatives would meet Forest Plan standards 

and guidelines; therefore this species is likely to persist on the Forest.

Species of Local Concern (SOLC)

Summary of Effects on SOLC

The following is a summary of effects to the previously mentioned wildlife SOLC. A 

detailed analysis can be found in the Wildlife Report in the project record.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Direct and Indirect Effects
Briggs Spring Environmental Assessment Chapter 4

63

Atlantis Fritillary

(Speyeria atlantis 

pahasapae)

Tawny Crescent

(Phycoides batesii)

Conifers would continue 

to encroach into 

meadows/grasslands and 

riparian hardwood 

communities, resulting 

in a decrease in foraging 

plants for butterflies. 

MPB risk & wildfire risk 

would not be decreased, 

however this would 

increase potential habitat 

that benefits these 

species.

Riparian fencing projects would 

enhance habitat. Noxious weed 

treatments would positively 

impact these species by aiding in 

native plant restoration, however 

there is potential to harm the 

species by treating nectar or 

larval host plants. Rx burning & 

vegetative treatments have 

potential for direct mortality to 

individuals; however positive 

impacts would be created 

through pine encroachment by 

opening up meadows/grasslands. 

Same as Alt 2, but 

slightly increased in 

potential negative 

impacts due to more 

acres treated with 

Rx burning & 

vegetative 

treatments. 

Cumulative Effects

Would not have adverse 

cumulative effects. 

Would not enhance 

butterfly habitat. 

Would improve current habitat 

conditions, would offset 

negative effects from livestock 

grazing. Would benefit species 

due to habitat enhancement. 

Same as Alt 2, but 

slightly increase 

potential for positive 

habitat enhancement 

due to more acres of 

vegetation 

treatments. 

Summary

Alternative 1 would not enhance or increase butterfly habitat and conifer 

encroachment would continue. Both action alternatives would benefit these species 

by creating more hardwood communities, meadows/grasslands, and by enhancing 

riparian areas. 

The proposed action alternatives would meet Forest Plan standards and guidelines. 

Therefore the alternatives would contribute toward meeting Objective 221. These 

species are likely to persist on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Callused Vertigo

(Vertigo arthuri)

Mystery Veritgo

(Vertigo paradoxa)

Frigid Ambersnail

(Catinella gelida)

Striate Disc

(Discus shimekii)

Direct and Indirect Effects

Existing forested stands 

would be expected to 

become denser. MPB 

risk and wildfire risk 

would not be decreased. 

Conifer would continue 

to encroach into 

hardwood stands. 

Rx burning and vegetation 

treatments would have 

potential to cause direct 

mortality to individual snails 

& potential to impact habitat, 

negatively. However, 

opening up forested sites 

would create more potential 

habitat for the frigid 

ambersnail. Opening up 

forested sites would have 

negative impacts, there by 

decreasing habitat for the 

callused vertigo, mystery 

vertigo, and striate disc. 

Hardwood treatments would 

enhance sites, enhancing 

snail habitat. MPB & 

wildfire risk would be 

reduced.

Same as Alt 2, but 

would increase Rx 

burning in hardwood 

sites more than Alt 2 

allowing the increased 

potential of negative 

impacts to snails and 

habitat, in the shortterm. Long-term effects 

would include increased 

potential habitat for the 

frigid ambersnail, and 

hardwood enhancement, 

in the long term, would 

benefit callused vertigo, 

mystery vertigo, and 

striate disc. Would 

reduce MPB & wildfire 

risk more than Alt 2. 

Cumulative Effects

Would not have adverse 

cumulative effects. 

Would add to past positive &

negative impacts to snail 

Same as Alt 2, but 

increased potential to 
Briggs Spring Environmental Assessment Chapter 4

64

Would not enhance snail 

habitat.

habitat from management 

activities. Would decrease 

dense pine forest conditions.

negatively impact snails 

& habitat, as well as 

more potential positive 

effects to frigid 

ambersnail habitat. 

Summary

Alternative 1 would allow dense forest conditions to be maintained or become 

denser. Both action alternatives would create a more open pine forest condition. 

These actions would have potential for both positive and negative impacts on 

individual snails and habitat. Alt 3 would have the most potential for negatively 

impacting individual snails. The frigid ambersnail would benefit from opening 

stands. Vegetative treatments along with prescribed burning would follow Forest 

Plan Standard 3103, and would not result in cumulative impacts to known snail 

colonies. 

The proposed action alternatives would meet Forest Plan standards and guidelines. 

Therefore the alternatives would contribute toward meeting Objective 221. These 

species are likely to persist on the Forest.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Sharp-shinned 

Hawk

(Accipiter striatus)

Direct and Indirect Effects

Would not reduce 

existing MPB risk and 

wildfire risk. Dense 

forested stands would 

remain and become 

denser, enhancing 

nesting habitat. Conifer 

encroachment would 

continue. 

Would reduce nesting habitat 

which may cause 

displacement and unknown 

nests would be disturbed; 

nesting disturbance may be a 

short term effect. Would 

decrease existing MPB and 

wildfire risk. 

Same as Alt 2, effects 

would be slightly 

increased due to the 

increased treatment 

acres. 

Cumulative Effects

Would not have shortterm adverse cumulative 

effects. Potential for 

long-term adverse 

cumulative effects due to 

stand replacing events.

Would add to negative 

effects of past timber harvest 

by creating more open 

density forest, increasing 

hardwoods and shrubs, and 

reducing MPB and wildfire 

risk. Would reduce nesting 

habitat in short-term, but 

create a more diverse habitat 

long-term. 

Same as Alt 2.

Summary

Alternative 1 would provide the most diverse habitat and the most potential nesting 

habitat. Both action alternatives would result in the same potential nesting habitat 

acres, as well as increasing shrubs and tree species diversity by increasing hardwood 

and meadow acres. Known nests would be protected through Standard 3204. 

The proposed action alternatives would meet Forest Plan standards and guidelines. 

The alternatives would contribute toward meeting Objective 221. Therefore this 

species is likely to persist on the Forest.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Direct and Indirect Effects
Briggs Spring Environmental Assessment Chapter 4

65

Cooper’s Hawk

(Accipiter cooperi)

MPB risk and wildfire 

risk would not decrease. 

Conifers would continue 

to encroach. Forested 

stands would continue to 

become denser, 

providing for the most 

nesting habitat from 

other alternatives. 

Preferred nesting habitat (SS4B) 

would decrease. Potential to 

cause present Cooper’s hawks to 

move or avoid the area. 

Unknown nests would be 

disturbed. Avoidance may be 

short-term. Would reduce the 

MPB risk and wildfire risk. 

Would enhance hardwood sites, 

adding diversity. 

Same as Alt 2, but 

effects slightly 

increased due to 

increase in 

treatment acres. 

Cumulative Effects

Would not have shortterm adverse cumulative 

effects. Potential for 

long-term adverse 

cumulative effects due to 

stand replacing events.

Would offset past negative effects 

to hardwood stands by enhancing 

and increasing these sites, 

including future activities. 

Same as Alt 2. 

Summary

Alternative 1 would provide the most acres of preferred nesting habitat; however the 

risk of a stand replacing wildfire or MPB infestation would remain high. Both 

action alternatives would reduce preferred nesting habitat, but lower the MPB and 

wildfire risk. Known nests would be protected through Standard 3204. The 

proposed alternatives would meet Forest Plan standards and guidelines and would 

contribute toward meeting Objective 221. Therefore this species is likely to persist 

on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Broad-winged 

Hawk

(Buteo platypterus)

Direct and Indirect Effects

MPB risk and wildfire 

risk would not decrease. 

Conifers would continue 

to encroach. Forested 

stands would continue to 

become denser, 

providing for the most 

nesting habitat from 

other alternatives. 

Preferred nesting habitat (SS4B) 

would decrease. Potential to 

cause present Broad-winged

hawks to move or avoid the area. 

Unknown nests would be 

disturbed. Avoidance may be 

short-term. Would reduce the 

MPB risk and wildfire risk. 

Would enhance hardwood sites, 

adding diversity. Fuel treatments 

may help maintain mature and 

late successional stage stands. 

Same as Alt 2, but 

effects slightly 

increased due to 

increase in 

treatment acres. 

Cumulative Effects

Would not have shortterm adverse cumulative 

effects. Potential for 

long-term adverse 

cumulative effects due to 

stand replacing events.

Would offset past negative effects 

to hardwood stands by enhancing 

and increasing these sites, 

including future activities. This 

would result in enhanced nesting 

habitat within hardwood 

communities. 

Same as Alt 2. 

Summary

Alternative 1 would provide the most acres of preferred nesting habitat; however the 

risk of a stand replacing wildfire or MPB infestation would remain high. Both 

action alternatives would reduce preferred nesting habitat, but lower the MPB and 

wildfire risk. Known nests would be protected through Standard 3204. The 

proposed alternatives would meet Forest Plan standards and guidelines. The 

alternatives would contribute toward meeting Objective 221. Therefore this species 
Briggs Spring Environmental Assessment Chapter 4

66

is likely to persist on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Northern Sawwhet Owl

(Aegolius acadicus)

Direct and Indirect Effects

MPB risk and wildfire 

risk would not decrease. 

Conifers would continue 

to encroach. Forested 

stands would continue to 

become denser having 

potential for more future 

snags. 

SS 4B (nesting habitat) acreage 

would decrease, there would be a 

slight incrase in SS 3B (roosting 

habitat). Potential to cause 

present northern saw-whet owls 

to move or avoid the area. 

Unknown nests would be 

disturbed. Avoidance may be 

short-term. Would reduce the 

MPB risk and wildfire risk. 

Potential loss of snags, however 

snags may be created through Rx 

burning. Would enhance 

hardwood sites, adding diversity. 

Same as Alt 2. 

Effects slightly 

increased due to 

increase in 

treatment acres, 

except preferred 

nesting habitat 

acres would remain 

the same between 

Alt 2 and 3. 

Cumulative Effects

Would not have shortterm adverse cumulative 

effects. Potential for 

long-term adverse 

cumulative effects due to 

stand replacing events.

Would add to past harvest and 

firewood cutting activities by the 

potential to reduce more snags. 

Same as Alt 2. 

Summary

Alternative 1 would provide the most acres of dense habitat; however the risk of a 

stand replacing wildfire or MPB infestation would remain high. Both action 

alternatives would decrease potential nesting habitat (SS4B) and slightly increase 

roosting habitat (SS3B). Potential for the loss of snags is greatest in action 

alternatives due to harvest activities. However snags would not be cut during 

harvest activities unless deemed safety hazards. Known nests would be protected 

through Standard 3204. The proposed alternatives would meet Forest Plan 

standards and guidelines. The alternatives would contribute toward meeting 

Objective 221. Therefore this species is likely to persist on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Pygmy Nuthatch

(Sitta pygmaea 

melanotis)

Direct and Indirect Effects

MPB risk and wildfire 

risk would not decrease. 

Conifers would continue 

to encroach. Forested 

stands would continue to 

become denser having 

potential for more future 

snags. 

Preferred nesting habitat would 

decrease. Potential to cause 

present pygmy nuthatches to 

move or avoid the area, nesting 

may be disturbed; these impacts 

would be short-term. Would 

reduce the MPB risk and wildfire 

risk. Potential loss of large trees 

snags, however snags may be 

created through Rx burning. 

Same as Alt 2. 

Effects slightly 

increased due to 

increase in 

treatment acres. 

Increased potential 

for loss of large 

diameter trees and 

snags, more than 

Alt 2. 

Cumulative Effects

Would not have shortterm adverse cumulative 

effects. Potential for 

long-term adverse 

cumulative effects due to 

stand replacing events. 

Would add to past harvest and 

firewood cutting activities by the 

potential to reduce and create 

more snags. The MPB has and 

continues to create snags. 

Proposed fuels treatments would 

Same as Alt 2. 

Effects slightly 

increased due to 

increase in 

treatment acres. 
Briggs Spring Environmental Assessment Chapter 4

67

add to past treatments to have 

potential to maintain mature and 

late successional stage stands. 

Summary

Alternative 1 would provide the most acres of nesting habitat; however the risk of a 

stand replacing wildfire or MPB infestation would remain high. Both action 

alternatives would decrease preferred nesting habitat and lower the MPB and 

wildfire risk. Potential for the loss of snags is greatest in action alternatives due to 

harvest activities. However MPB mortality and Rx burning would have the potential 

to create snags. Snags would not be cut during harvest activities unless deemed 

safety hazards. The proposed alternatives would meet Forest Plan standards and 

guidelines and would contribute toward meeting Objective 221. Therefore this 

species is likely to persist on the Forest. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Northern Longeared Myotis

(Myotis septentrionalis)

Small-footed 

Myotis

(Myotis ciliolabrum)

Long-eared 

Myotis

(Myotis evotis)

Long-legged 

Myotis

(Myotis volans)

Direct and Indirect Effects

Forested stands would 

become denser. MPB 

risk and wildfire risk 

would not decrease. 

Conifers would 

continue to encroach. 

Potential to reduce future replacement 

and existing snags. Would decrease 

potential snag roosting habitat (SS4B). 

Rx burning may create snags. MPB 

infestation would create snags. Would 

reduce large diameter trees. May 

disturb roosting/nesting sites, present 

bats may be displaced or avoid area; 

these would be short term effects. 

Would benefit grasses, shrubs, and 

forbs, increasing prey species and 

foraging habitat for these species of 

bats. Would reduce MPB and wildfire 

risk. 

Same as Alt 2, 

with increased 

potential for 

snag loss and 

large diameter 

tree loss. 

Cumulative Effects

Would not have shortterm adverse 

cumulative effects. 

Potential for long-term 

adverse cumulative 

effects due to stand 

replacing events.

Would add to past wildfires & burning, 

harvest and firewood cutting activities

creating and losing snags. The MPB 

has and continues to create snags. 

Future riparian area projects would 

benefit bat foraging habitat. Proposed 

fuels treatments would add to past 

treatments to have potential to maintain 

mature and late successional stage 

stands. 

Same as Alt 2.

Summary

Alternative 1 would allow for the most suitable roosting snags for these species. 

Both action alternatives would enhance forage habitat and suitable roosting snags 

would be available. Alternative 2 would provide more future snags than Alternative 

3. The proposed alternatives would meet Forest Plan standards and guidelines. The 

alternatives would contribute toward meeting Objective 221. Therefore these 

species are likely to persist on the Forest.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Northern Flying 

Squirrel

(Glaucomys sabrinus)

Direct and Indirect Effects

Forested stands would 

become denser. MPB 

risk and wildfire risk 

Potential to reduce future replacement 

and existing snags. Would decrease 

potential snag roosting habitat (SS4B). 

Same as Alt 2, 

with increased 

potential for 
Briggs Spring Environmental Assessment Chapter 4

68

would not decrease. 

Conifers would 

continue to encroach, 

possibly increasing 

spruce habitat. 

Rx burning may create snags. MPB 

infestation would create snags. Would 

reduce large diameter trees. May 

disturb nesting sites and potential to 

directly harm individuals; these would 

be short term effects. Would increase 

and enhance hardwood stands. Would 

reduce MPB and wildfire risk. 

snag loss and 

large diameter 

tree loss. 

Cumulative Effects

Would not have shortterm adverse 

cumulative effects. 

Potential for long-term 

adverse cumulative 

effects due to stand 

replacing events.

Would add to past wildfires & burning, 

harvest and firewood cutting activities 

creating and losing snags. The MPB 

has and continues to create snags. 

Proposed fuels treatments would add to 

past treatments to have potential to 

maintain mature and late successional 

stage stands. 

Same as Alt 2.

Summary

Alternative 1 would allow for the most potential of large snags for this species. 

However hardwoods would suffer due to encroachment by conifers. Alternative 2 

would retain more large trees, have less potential for snag loss, and more potential 

for snag replacement than Alternative 3. The proposed alternatives would meet 

Forest Plan standards and guidelines and would contribute toward meeting 

Objective 221. Therefore these species are likely to persist on the Forest.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Meadow Jumping 

Mouse

(Zapus hudsonius 

campestris)

Direct and Indirect Effects

Riparian areas would 

continue to receive 

high seasonal use. 

Many exclosure fences 

would remain to 

protect riparian areas. 

Conifers would 

continue to encroach

into 

meadows/grasslands. 

Would enhance meadows/grasslands 

through pine encroachment treatments. 

Riparian areas would be enhanced 

through post sale activities (fencing, 

willow planting, etc.). Rx burning in 

meadows would have potential to 

negatively impact this species in the 

short-term. Long term Rx burning 

impacts would enhance meadow 

vegetation. 

Same as Alt 2. 

Cumulative Effects

Would not have 

adverse cumulative 

effects. 

Past activity impacts would be offset by 

proposed actions. No adverse 

cumulative effects are expected from 

action alternatives. Enhancing riparian 

areas (meadow jumping mouse habitat) 

would move them, overall, into a better 

condition. Post-sale activities would 

have potential to enhance habitat. 

Same as Alt 2.

Summary

All alternatives, including the no action, would not cause detrimental impacts to 

riparian areas within the project area. Both action alternatives would increase 

protection of this habitat through post-sale projects, such as exclosure fencing. Both 

action alternatives would move riparian areas toward a better overall condition. The 

proposed alternatives would meet Forest Plan standards and guidelines and would 

contribute toward meeting Objective 221. Therefore this species is likely to persist 

on the Forest.
Briggs Spring Environmental Assessment Chapter 4

69

Threatened and Endangered Species 

It was determined that management activities on the Forest would have ‘no effect’ on any 

Threatened and Endangered species since the Black Hills National Forest lacks suitable 

habitat.

There are no Threatened or Endangered species which have habitat within the Briggs 

Spring project area. Therefore, no effects to Threatened or Endangered species would 

occur. Refer to the Wildlife BA/BE in the project record. 

Region 2 (R2) Sensitive Species

Summary of Effects on R2 Sensitive Species

The following is a summary of effects to the previously mentioned wildlife R2 sensitive 

species. A detailed analysis can be found in the Wildlife Report and BA/BE in the 

project record.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Bald Eagle

(Haliaeetus

leucocephalus)

Direct and Indirect Effects

None expected. Would remove large trees that 

provide winter roost and perch 

sites. 

Same as Alt 2, but with 

an increased potential 

for large tree loss due to 

increase in treatments. 

Cumulative Effects

Would not have any 

cumulative effects 

expected.

Would not have any cumulative 

effects expected. 

Same as Alt 2. 

Determination

All alternatives would have ‘no impact’ on the bald eagle. Therefore the 

alternatives would contribute toward meeting Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Fringed Myotis

(Myotis thysanodes 

pahasapensis)

Direct and Indirect Effects

Potential for increased 

MPB infestation and 

wildfire would create 

more roosting 

habitat/snags and 

increased grass/forbs 

structural stages would 

increase prey base.

Would affect roosting individuals 

during harvest activities and Rx 

burning. Would have potential 

for snag loss and replacement 

snag loss, resulting in less 

potential roosting habitat. May 

decrease prey species habitat. 

Noxious weed treatments would 

have potential to decrease prey 

base. Would have potential for 

loss of small water catchments 

due to sedimentation. 

Same as Alt 2, but 

with an increased 

potential for loss and 

habitat disturbance 

due to increase in 

treatments. 

Cumulative Effects
Briggs Spring Environmental Assessment Chapter 4

70

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events, resulting in 

enhanced habitat.

 Would add to past wildfires & 

burning, harvest and firewood 

cutting activities creating and 

losing snags (roosting habitat). 

The MPB has and continues to 

create snags. Prey species may 

increase due to increased 

grass/forbs SS. 

Same as Alt 2. 

Determination

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. The determination would be the same under the No Action 

Alternative due to the new Forest Policy of cutting standing dead trees within 300 

feet of some roads. The Forest is conserving and enhancing habitat for this species 

through cave, mine, and snag management and is therefore meeting Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Townsend’s Bigeared Bat

(Corynorhinus 

townsendii)

Direct and Indirect Effects

None expected. Harvest activity may disturb 

roosting bats or may cause 

individual mortality. Vegetation 

treatments may change 

microhabitats of roosting habitat. 

Would result in loss of large 

diameter trees and a more open 

forest condition, which may affect 

prey species short-term. Would 

increase hardwoods, benefiting 

prey species. Noxious weed 

treatments may affect prey 

species. May result in loss of 

small water catchments, which 

would negatively impact this 

species. 

Same as Alt 2, but 

with increased 

potential due to 

increased treatments. 

Cumulative Effects

Would not have any 

adverse cumulative 

effects expected.

Would add to past harvest 

impacts to roosting habitats, but 

would not contribute to adverse 

cumulative effects. 

Same as Alt 2. 

Determination

Alternative 1 would have ‘no impact’ on the Townsend’s big-eared bat. 

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. The Forest is conserving and enhancing habitat for this species 

through cave, mine, and snag management and is therefore meeting Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Northern 

Goshawk

(Accipiter gentalis)

Direct and Indirect Effects

Forested stands would 

continue to become 

denser. MPB risk and 

wildfire risk would not 

decrease. In the longterm, would provide 

Preferred nesting habitat would 

decrease. Would treat deferred 

goshawk sites with sanitation, 

which may prevent habitat loss in 

the event of MPB infestation. 

Harvest activities have timing 

Same as Alt 2, but 

with increased 

potential due to 

increased treatments. 
Briggs Spring Environmental Assessment Chapter 4

71

the most nesting 

habitat of all 

alternatives. 

restrictions minimizing 

disturbance to goshawk 

territories. May cause direct 

mortality to individuals in 

unknown nests. This impact 

would be short-term. Potential 

loss of cover habitat would 

increase susceptibility of young to 

predators. Would affect prey 

species through opening of forest 

canopy, loss of snags, loss of 

down woody material, and ground 

cover. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events.

Would add to past harvest, MPB 

mortality, and wildfire impacts to

nesting habitats, however the 

action alternatives would provide 

two nest protection areas as well 

as other areas of suitable nesting 

habitat. Activities proposed in 

the action alternatives may cause 

adverse effects to northern 

goshawks in the project area 

within the next 10 years.

Same as Alt 2. 

Determination

Forest Plan Objective 221 is currently being met in the project area. Either action 

alternative would meet Objective 221, due to conserving known territories and 

conserving additional habitat. 

Alternative 1 would have ‘no impact’ on the northern goshawk. 

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Northern Harrier

(Circus cyaneus)

Direct and Indirect Effects

None expected. Rx burning may displace 

present harriers, but nearby 

habitat exists. Rx burning 

would enhance grassland 

habitat. Noxious weed 

treatment may affect 

grass/forbs growth and prey 

base. 

Same as Alt 2, but with 

increased potential due to 

increase treatments. 

Would benefit habitat 

more than Alt 2 due to 

increased Rx burning. 

Cumulative Effects

Would not have any 

adverse cumulative 

effects expected.

May add to past burning, 

grazing, and noxious weed 

treatment impacts. Rx burning 

and potential wildfires may 

displace individuals and may 

interfere with nesting 

attempts. Would overall 

enhance habitat. 

Same as Alt 2. 

Determination

Alternative 1 would have ‘no impact’ on the northern harrier. 
Briggs Spring Environmental Assessment Chapter 4

72

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. Prescribed burning showed enhance grassland habitat for this 

species; therefore the alternatives would contribute toward meeting Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Flammulated Owl

(Otus flammeolus)

Direct and Indirect Effects

None expected. May directly impact 

individuals in unknown 

occupied cavities. Potential to 

reduce preferred habitat. 

Would remove large diameter 

trees. Potential loss of snags. 

Would enhance and increase 

hardwoods. Would enhance 

prey species habitat. 

Same as Alt 2, but with 

increased potential due to 

increase treatments. 

Cumulative Effects

Would not have any 

adverse cumulative 

effects expected.

Would add to past fire, insect 

mortality, and harvest impacts 

to snags and replacement 

snags. Prey species habitat 

may improve on a general 

scale. 

Same as Alt 2. 

Determination

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. Fuel reduction and thinning of understory pine and hardwood 

enhancement may benefit this species, therefore the action alternatives would 

contribute toward meeting Objective 221. The determination would be the same 

under the No Action Alternative due to the new Forest Policy of cutting standing 

dead trees within 300 feet of some roads.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Lewis’s 

Woodpecker

(Melanerpes lewis)

Direct and Indirect Effects

Existing snags would 

fall, adding to down, 

woody material and 

new snags would be 

created (MPB, disease, 

wildfire).

Potential to loss of 

snags/cavities. Would, 

overall, decrease habitat. 

Future nesting habitat would 

be decreased. Potential to 

decrease prey species habitat

through burning. Rx burning 

may create snags and 

replacement snags. Noxious 

weed treatments may impact 

prey species.

Same as Alt 2, but with 

increased potential due to 

increase treatments. 

Cumulative Effects

Would not have any 

adverse cumulative 

effects expected.

Past wildfires created a large 

area of suitable habitat, the 

increase in potential loss of 

suitable habitat and potential 

creation of snags would add to 

these impacts. 

Same as Alt 2. 

Determination

Both action alternatives ‘may adversely impact individuals, but not likely to 
Briggs Spring Environmental Assessment Chapter 4

73

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. The Forest is conserving habitat for this species through snag 

management. In addition recent large wildfires and MPB infestation are contributing 

towards Objective 221. Therefore the alternatives would contribute toward meeting 

Objective 221. The determination would be the same under the No Action 

Alternative due to the new Forest Policy of cutting standing dead trees within 300

feet of some roads.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Black-backed 

Woodpecker

(Picoides articus)

Note: Also MIS

Direct and Indirect Effects

See effects under the 

MIS section.

See effects under the MIS 

section.

See effects under the 

MIS section.

Cumulative Effects

See effects under the 

MIS section.

See effects under the MIS 

section.

See effects under the 

MIS section.

Determination

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. The Forest is conserving habitat through snag management. In 

addition recent wildfires and MPB infestations are contributing towards Objective 

221. Therefore the alternatives would contribute toward meeting Objective 221. 

The determination would be the same under the No Action Alternative due to the 

new Forest Policy of cutting standing dead trees within 300 feet of some roads.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Grasshopper 

Sparrow

(Ammodramus 

savannarum)

Note: Also MIS

Direct and Indirect Effects

See effects under the 

MIS section.

See effects under the MIS 

section.

See effects under the 

MIS section.

Cumulative Effects

See effects under the 

MIS section.

See effects under the MIS 

section.

See effects under the 

MIS section.

Determination

Alternative 1 would have ‘no impact’ on the grasshopper sparrow. 

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. Prescribed burning and pine encroachment may enhance grassland 

habitat for this species. Therefore the alternatives would contribute toward meeting 

Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Northern Leopard 

Frog

(Lithobates pipiens)

Direct and Indirect Effects

None expected. Harvest and post-harvest 

activities near riparian sites 

may have direct adverse 

effects. Potential for habitat 

disturbance or loss. Noxious 

weed treatments may affect 

water quality and plant species 

diversity. Would enhance 

habitat for this species by 

protecting riparian areas. 

Same as Alt 2. 

Cumulative Effects
Briggs Spring Environmental Assessment Chapter 4

74

Would not have any 

adverse cumulative 

effects expected.

Would add to past activities 

impacts on habitat. Would 

supplement habitat, overall. 

Past fires have removed 

canopy, increasing ground 

temperatures, which may limit 

distribution. Past and 

potential future OHV use can 

impact this species. 

Same as Alt 2.

Determination

Alternative 1 would have ‘no impact’ on the northern leopard frog. 

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. Riparian habitat would be conserved and/or enhanced due to postsale riparian enhancement projects. Therefore the action alternatives would 

contribute toward meeting Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Black Hills 

Redbelly Snake

(Storeria 

occipitomaculata)

Direct and Indirect Effects

None expected. Potential for direct individual 

impact by harvest and Rx 

burning activities. Potential 

for habitat disturbance and/or 

loss due to harvest, burning, 

and OHV use. Potential for 

loss of down woody material. 

Noxious weed treatments have 

potential to affect habitat. 

Potential for enhanced habitat 

due to post-sale riparian 

enhancement projects. 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events, resulting in 

loss of habitat.

Would add to past harvest, 

wildfire, and livestock grazing 

impacts. Burning and wildfire 

would impact the redbelly 

snake and its habitat. 

Continued OHV use and 

potential increase in use would 

impact this species if present. 

Same as Alt 2.

Determination

Alternative 1 would have ‘no impact’ on the Black Hills redbelly snake. 

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. Riparian habitat would be conserved and/or enhanced due to postsale riparian enhancement projects. Therefore the action alternatives would 

contribute toward meeting Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Cooper’s 

Mountain Snail

(Oreohelix strigosa 

cooperi)

Direct and Indirect Effects

None expected. Potential for direct individual 

impact by harvest and Rx 

burning activities. Potential 

for habitat disturbance and/or 

loss due to harvest, burning, 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 
Briggs Spring Environmental Assessment Chapter 4

75

and OHV use. Potential for 

loss of down woody material. 

Noxious weed treatments have 

potential to affect habitat. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events, resulting in 

loss of habitat.

Would add to past harvest, 

wildfire, and livestock grazing 

impacts where this species is 

present. Continued OHV use 

and potential increase in use 

would impact this species if 

present. 

Same as Alt 2.

Determination

Alternative 1 would have ‘no impact’ on the Cooper’s mountain snail. 

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. All alternatives would meet Standard 3103, protection of known 

sensitive species snail habitat. In addition, other potential habitat would be 

conserved; therefore the action alternatives would contribute toward meeting 

Objective 221.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Regal Fritillary 

Butterfly

(Speyeria idalia)

Direct and Indirect Effects

None expected. Potential for direct individual 

mortality from Rx burning. 

Would have temporary habitat 

loss, short term. Would 

enhance habitat, including 

riparian habitat, long term. 

Noxious weed treatments may 

affect habitat. 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events, resulting in 

increase of habitat.

Would add to past harvest, 

wildfire, and livestock grazing 

impacts where this species is

present. Past and continued 

livestock grazing would 

impact this species. Would 

impact species in the short 

term, but would enhance 

habitat in the long term. 

Same as Alt 2.

Determination

Alternative 1 would have ‘no impact’ on the regal fritillary butterfly. 

Both action alternatives ‘may adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend toward 

federal listing’. Meadow and grassland habitat would be enhanced by activities in 

the action alternatives, therefore the action alternatives would contribute toward 

meeting Objective 221.

Migratory Birds

Summary of Effects on Migratory Birds
Briggs Spring Environmental Assessment Chapter 4

76

The following is a summary of effects to the previously mentioned migratory birds 

species. A detailed analysis can be found in the Wildlife Report and BA/BE in the 

project record.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Golden Eagle

(Aquila chrysaetos)

Prairie Falcon

(Falco mexicanus)

Direct and Indirect Effects

Conifers would 

continue to encroach 

into 

meadows/grasslands. 

MPB risk and wildfire 

risk would not 

decrease.

Would maintain and enhance 

existing habitat through 

harvest and burning. Harvest 

activities may benefit foraging 

habitat by opening up the 

canopy. 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events, resulting in 

potential for more 

foraging habitat.

Would add to past harvest and 

burning impacts to habitat. 

Existing and potential increase 

of OHV use may disturb 

nesting birds. 

Same as Alt 2.

Summary

Golden eagle and prairie falcon habitat would be expected to be maintained. All 

alternatives would meet Forest Plan standards, therefore populations of both species 

would remain stable. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Upland Sandpiper

(Bartramia longicauda)

Direct and Indirect Effects

Conifers would 

continue to encroach 

into 

meadows/grasslands, 

which could create 

more habitat. 

Rx burning would have 

potential to impact nesting 

attempts, but expected to 

improve habitat overall. 

Harvest activities are not 

expected to impact this 

species. Would improve 

habitat overall. Noxious 

weed treatments have potential 

to impact habitat. 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events, resulting in 

potential for more 

habitat.

Would add to past harvest and 

burning impacts to habitat. 

Past and continued grazing 

and weed treatments may 

impact the habitat. Overall 

improvement to habitat for 

this species. Habitat would be 

maintained or enhanced. 

Same as Alt 2.

Summary

Upland sandpiper habitat would be expected to be maintained or enhanced. All 

alternatives would meet Forest Plan standards; therefore the Forest-wide population 

of upland sandpipers would remain stable. 
Briggs Spring Environmental Assessment Chapter 4

77

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Red-headed 

Woodpecker

(Melanerpes 

erythrocephalus)

Direct and Indirect Effects

None expected. Would have impacts 

benefiting habitat for this 

species. Rx burning may 

create snags and replacement 

snags. Would improve 

riparian habitats. 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events, which would 

enhance habitat.

Would add to past harvest, 

burning, and MPB impacts. 

Overall habitat would benefit 

from project activities. 

Same as Alt 2.

Summary

Red-headed woodpecker habitat would be expected to be maintained or enhanced. 

All alternatives would meet Forest Plan standards; therefore the Forest-wide 

population of red-headed woodpeckers would remain stable. 

Demand Species

Summary of Effects on Demand Species

The following is a summary of effects to the previously mentioned Demand Species. A 

detailed analysis can be found in the Wildlife Report in the project record.

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Rocky Mountain 

Elk

(Cercus elaphus 

nelsoni)

Direct and Indirect Effects

Forested stand would 

become denser, 

providing more cover. 

MPB risk and wildfire 

risk would not 

decrease. Conifers 

would continue to 

encroach into 

meadows and 

hardwoods, reducing 

forage. Potential to 

increase forage 

competition between 

livestock and big 

game.

Potential to displace 

individuals in the short term. 

Would enhance forage habitat. 

Loss of cover in areas. Rx 

burning would have potential 

to cause decrease in calving 

cover. Potential of increased 

OHV use may increase 

disturbance to this species. 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

Would add to past harvest and

burning impacts. Overall 

foraging habitat would 

increase and cover habitat 

would decrease from project 

activities. 

Same as Alt 2.
Briggs Spring Environmental Assessment Chapter 4

78

events.

Summary

Rocky Mountain elk habitat would be enhanced; however cover and calving habitat 

would be lost. All alternatives would meet Forest Plan standards and would allow 

attainment for Objective 217; therefore the Forest-wide population of Rocky 

Mountain elk would remain stable. 

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3

Merriam’s Wild 

Turkey

(Meleagris gallapavo 

merriami)

Direct and Indirect Effects

Forested stand would 

become denser, 

providing more 

roosting habitat. MPB 

risk and wildfire risk 

would not decrease. 

Conifers would 

continue to encroach 

into meadows and 

hardwoods. Existing 

down woody material 

and regenerating pine 

would provide cover 

and foraging habitat.

Potential to displace 

individuals in the short term. 

Potential to disturb nesting 

turkeys. Potential for direct 

individual mortality or nest 

loss due to harvest and 

burning activities. Would 

enhance forage habitat. 

Would increase summer 

habitat and decrease winter & 

roosting habitat. Rx burning 

would have potential to cause

loss of down woody material 

and microhabitats. Potential 

increase in OHV use may 

impact turkeys. 

Same as Alt 2 with 

increased potential for 

impacts due to increased 

treatment acres. 

Cumulative Effects

Would not have any 

short-term cumulative 

effects expected. 

Potential for long-term 

cumulative effects due 

to stand replacing 

events. Would provide 

the most roosting 

habitat throughout the 

project area. 

Would add to past harvest, 

wildfire, livestock grazing, 

recreation and drought 

impacts. Overall foraging 

habitat may be enhanced while 

roosting and winter habitat

may decrease. 

Same as Alt 2.

Summary

Merriam’s wild turkey foraging habitat would be expected to be enhanced. Roosting 

and winter habitat is expected to decrease under the action alternatives. All 

alternatives would meet Forest Plan standards and would allow attainment for 

Objective 217; therefore the Forest-wide population of Merriam’s wild turkey

would remain stable. 

Fire and Fuels

Affected Environment

From historic conditions, much more of the landscape is now forested and we are losing 

our open meadows and hardwood stringers which serve as natural fuel breaks (USDA 

Forest Service, 2005). Estimates show that 40% of the forest was non-stocked or
Briggs Spring Environmental Assessment Chapter 4

79

meadow in 1875 compared to less than 6% in 2000. As a result of this increased fuel 

loading, more of the Black Hills is available for, and affected by, large, intense forest 

fires. The ponderosa pine cover type dominates the landscape and as a result of fire 

exclusion, ponderosa pine has encroached on the non-forested communities, contributing 

to the reduction in size of the hardwood cover type, creating dense, closed canopy 

ponderosa pine stands. Surface fuels include duff, small woody debris, dead down logs 

and long needle litter. Isolated areas of storm damage and slash from past management 

activities exist within the project area.

Fire Regime and Condition Class

Historically, fires were more frequent and less severe. Fire suppression activities have 

trended the forest outside historic ranges. Currently, there are three general types of fire 

regimes in the Black Hills (USDA Forest Service, 2005). Fire regimes characterize the 

role fire plays in an ecosystem. Table 24 describes each of the three fire regimes. The 

Condition Class rating can be used to describe the degree of departure from the historic 

fire regime (Hann et al., 2003). Table 25 describes each followed by a typical stand 

structure for each Conditions Class.

Table 24. Fire regimes in the Black Hills (USDA Forest Service, 2005) 

General 

Characteristics

Major Controlling 

Variables Distribution

Frequent, 

Low-Severity 

Fire Regimes

Fires recur within any

stand at relatively 

short intervals (10-50 

years), burning at low 

severity in the canopy 

and soil, and variable 

severity in the 

understory.

Weather (fires occur during 

dry periods), Climate

(extensive fires tend to 

occur in dry years that 

follow 1-3 wet years), and 

Fuels (fuels gradually 

accumulate during the 

intervals between successive 

fires).

Evidence of surface fire in 

ponderosa pine forests 

throughout the Black Hills, 

most frequent at the PrairieForest ecotone and less 

frequent in interior forests at

mid to high evlevations 

(Fisher et al. 1987, Brown 

and Sieg 1999, Brown et al. 

2000, Wienk 2001, Brown 

2003, Wienk et al. 2004).

Infrequent, 

High-Severity 

Fire Regimes

Fires recur within any 

stand at long intervals 

(100-500+ years), 

burning at high 

severity in the canopy 

and understory, and at 

variable severity to the 

soil.

Weather and Climate are 

the primary controllers 

(most ignitions extinguish 

by themselves because of 

wet conditions; extensive 

fires occur only in very dry 

summers; variability in fuels 

usually has little influence 

on fire frequency, extent, or 

severity).

Large areas of even-aged and 

dense forest and of closed 

canopy, mature or old-growth 

forest at the time of 

settlement are evidence of 

stand-replacing disturbance 

(Graves 1899, Shinneman 

and Baker 1997).
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Mixed 

Severity Fire 

Regimes

These fire regimes are 

intermediate between 

the Frequent, LowSeverity and the 

Infrequent, HighSeverity Fire Regimes. 

Fires occur at variable 

intervals (10- >100 

years), and burn at 

variable severity 

(patches of high 

severity intermingled 

with patches of low or 

intermediate severity).

Weather, Climate, and 

Fuels all influence fire 

frequency, extent, and 

severity, in complex ways 

that are not well understood, 

with enormous variability 

over time and space.

Proposed as the dominant 

model for fire regimes in 

ponderosa pine forests of the 

Black Hills. Under this 

model, surface fire forms the 

background process creating 

forest structure and landscape 

pattern. However, fires 

sometimes burn with mixed 

severity, with both a surface 

fire and a stand-replacing fire

component, and may 

sometimes create large areas 

of high severity burns. Forest 

patches are variable in size 

and within patch structure 

(Lentile et al. in press)

Table 25. Fire Regime Condition Class (FRCC) rating descriptions (Hann et al., 

2003)

Fire Regime 

Condition Class Description

FRCC1

Low Departure from the 

central tendency* of the 

historic fire regime.

Fire regimes are within the historical range.

Risk of losing key ecosystem components is low.

Vegetative attributes are intact and functioning within the 

historical range.

FRCC2

Moderate Departure 

from the central 

tendency* of the 

historic fire regime.

Fire regimes are moderately altered from their historical 

range.

Risk of losing key ecosystem components is moderate.

Vegetation attributes have been moderately altered from 

their historical range.

Fire frequencies have departed from natural frequencies by 

one or more return intervals, resulting in changes to fire 

size, intensity, severity, and landscape patterns.

FRCC3

High Departure from 

the central tendency* of 

the historic fire regime.

Fire regimes are significantly altered from their historical 

range. 

The risk of losing key ecosystem components is high. 

Vegetation attributes have been significantly altered from 

their historical range.

Fire frequencies have departed from historical frequencies 

by multiple return intervals, resulting in dramatic changes 

to fire size, intensity, severity, and landscape patterns. 

*Central tendency refers to a composite estimate of vegetation characteristics including: species 

composition, structural stages, stand age, canopy closure, and mosaic pattern; fuel composition; fire 

frequency, severity, and pattern; and other associated natural disturbances.
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The coarse scale national data characterizes the Black Hills as primarily Condition Class 

III, high relative risk of significantly altering or losing key components of the ponderosa 

pine forest system (USDA Forest Service, 2005). These conditions significantly increase 

the probability of a surface fire transitioning to a crown fire with increased burn severity 

and tree mortality. See Figure 4 for differences of FRCC stand structure. Evidence of 

past fires shows the potential for large, high intensity surface fires, and, given the right 

conditions, stand-replacing fires. Recent examples include the Jasper, Elk Mountain II, 

Battle Creek, Rico and Alabaugh fires.

Figure 4. Typical stand structure for each Fire Regime Condition Class (FRCC).

Fire Risk

Risks are defined as those uses or human activities which have the potential to result in a 

wildfire ignition. Fire history occurrence of both large and point fires were analyzed 

using the project perimeter. The fire history data includes fires occurring from 1950 to 

present. Table 26 displays known fire history within the Briggs Spring project area. Of 

the fires identified, 46 are known lightning-caused, 11 human caused, two miscellaneous, 

and two unknown. Both fire history occurrence data as well as large fire history, those 

fires exceeding 20 acres, in and around the project area are depicted in Figure 5. In 

addition, the percent of the project area impacted was analyzed. Table 27 displays large 

fire history within the project boundary.
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Table 26. Known fire history in the Briggs Spring project area 

from 1950 to present

Fire Size Class Fire Size (acres) Number of Fires

A 0 – 1⁄4 61

B 1⁄4 to 9 17

C 10-99 1

D 100 – 299 0

E 300-999 0

F 1000-4999 0

G 5000 + 0

U Unknown 0

Table 27. Area of each large fire falling within the project perimeter

Fire 

Name

Fire 

Year Total Acres Acres Within Project Area

Percent of 

Project Area

Jasper 2000 83,511 4,739 6%

The number of fires on the entire Black Hills National Forest system lands has remained 

fairly constant at 65-130 starts per year. The number of fires that have escaped initial 

attack has also remained constant. However, these escaped fires have become larger and 

are more difficult to control with an average large fire size increasing from under 1,000 

acres per fire in the early 1900’s to over 8,000 acres in recent years, having burned 

approximately 239,000 acres since 1980.
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Figure 5. Large fire history in and around the project area and the point fire history 

within the project boundary.

Values at Risk

Values are defined in the forest plan environmental impact statement (EIS) (USDA 

Forest Service, 2005, Appendix E-80) as any or all natural resource improvements, or 

other values that may be jeopardized if a fire occurs. There are no At-Risk Communities 

(ARC) located within the Briggs Spring project area however, five ARC are located less 

than six miles from the project boundary with one being within one mile of the project 

boundary (Figure 6). To further assess the level of wildfire risk for each community 

buffer zones were created at distances of one half, one, two, and three miles around each 

community (Figure 6). Based on the Pennington County RapidMap, it was determined 

there are approximately 11 residences contained within the project area, and an additional 

15 more within a three mile radius of the project boundary.
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Additional values at risk include commercial timber stands, power lines, range 

improvements, such as fences and spring developments, investments in timber stand 

improvement and reforestation, wildlife habitat, including snags, forage, riparian areas, 

security cover, and mid to late seral ponderosa pine stands, sensitive species, recreation 

sites, as well as water, air and visual quality.

Figure 6. At-Risk Communities (ARC) adjacent to the project boundary

and structures located within the project area.

Fire Hazard

Fire hazard is defined as a fuel complex that determines the ease of ignition and the 

resistance to control. Hazard is an expression of what kind of fire may potentially occur 

and how it affects human values. The fire hazard rating increases as the amount and 

continuity of surface and canopy fuels increases. As the amount of fuel on a given 

landscape increases and fuel profiles become more horizontally and vertically 

continuous, the intensity of a wildfire in that landscape is expected to increase. Areas 

with high fire hazard rating have the potential to exhibit more extreme fire behavior with 

more severe effects than those with a low hazard rating.
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A detailed examination of the Hazard Rating is best accomplished by reviewing known 

data regarding the arrangement of the vegetation, or structural stage. The structural stage 

gives an indication of the current fire hazard and is a stand level rating of crown fire 

susceptibility. Table 28 gives an approximate area of each structural stage and indicates 

the existing fire hazard.

Table 28. Current acres of each structural stage and existing Fire Hazard 

Rating

Structural Stage Approximate 

Acres

Fire Hazard

Non-structured 2,697 Low

1 – Grass/Forb 497 Low

2 – Shrubs/Seedlings 550 Moderate

3A – Sapling/Pole (<40%) 179 Moderate

3B – Sapling/Pole (40-70%) 179 High

3C – Sapling/Pole (>70%) 42 Very High

4A – Mature >9” (<40%) 7,366 Moderate

4A – Mature <9” (<40%) 5,401 Very High

4B – Mature >9” (10-70%) 5,031 High

4B – Mature <9” (10-70%) 2,606 Very High

4C – Mature <9” (>70%) 0 Very High

5 – Old Growth 0 Very High

In assessing hazard, an overall Hazard Rating of high to very high exists in 

approximately 54% of the project area (Table 29). It is suspected that much of the nonforest land also follows this trend resulting in a higher percentage of high to very high 

Hazard Rating, however to what extent is unknown. The high to very high fire hazard 

rating is determined on the availability of fuels to sustain a fire. The high fire hazard that 

exists in the Briggs Spring project area is a result of the disruption of the historic fire 

regime, creating a landscape dominated by large contiguous stands of dense ponderosa 

pine with a high loading of surface and ladder fuels. In addition, recent pockets of tree 

mortality caused by insect and disease will increase fuel concentrations on the ground 

resulting in an overall increase of fire hazard. In an area such as Briggs Spring, where 

high risk coincides with high hazard, the probability of fire with undesirable conditions is 

more likely and could be very detrimental to many of the values existing in and around 

this project area.

Table 29. Total acres and percentage of project area for the existing Fire 

Hazard Rating

Approximate Total Acres Fire Hazard Approximate Percentage 

of Project Area

3,194 Low 13%

9,260 Moderate 33%

4,227 High 21%

7,725 Very High 33%
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Air Quality

Air quality in the Black Hills is considered to be excellent, having pollution concentration 

lower than both State and Federal standards (USDA Forest Service, 2005). Maintaining 

and improving air quality in the Black Hills and western South Dakota is desired. 

Although usually short in duration, smoke from wildfires and prescribed fires has the 

potential to affect air quality. The Environmental Protection Agency (EPA) addresses 

smoke from wildland fire under their natural events policy at 

http://www.epa.gov/ttn/caaa/t1/memoranda/nepol.pdf (USDA Forest Service, 2005).

The Briggs Spring project area is in the vicinity of two Class 1 Airsheds; Badlands 

National Park and Wind Cave National Park and five communities; Deerfield, Buckhorn, 

Breakneck, Newcastle and Ferguson Canyon. The project area is designated as a Class II 

area allowing higher concentrations of pollutants than the Class I Airsheds. Smoke 

generated by wildfire is usually greater and cannot be mitigated; however, smoke 

generated under controlled conditions can be mitigated using the following means:

• Limit treatment area size

• Specify wind directions and speed

• Specify minimum mixing heights 

• Stagger ignitions

These mitigation techniques in addition to other control methods for smoke management 

minimize the impacts of smoke to visibility and human health.

Environmental Consequences

Alternative 1 – No Action

The no action alternative assumes that no change in management would occur within the 

project area. Management actions currently being practiced, including suppression would 

continue to be practiced. The only other changes that would occur on the landscape 

would be those that occur as a result of natural occurrences, wildfire suppression or those 

resulting from other project decisions.

Direct and Indirect Effects

A no action alternative would continue the trend of the current FRCC 3 resulting in 

increasing fire hazards. In the absence of vegetation treatments, tree densities would 

continue to increase, as would crown cover and ladder fuels. As a result, there would be 

higher resistance to control and increased likelihood of wildfire escape with increased 

risk of losses. This trend would continue until interrupted by a natural disturbance such 

as a catastrophic fire. Recent fires in the Black Hills area provide examples of what type 

of fire behavior can be expected and its effects on the landscape.

This alternative would not alter human activities or usage in the area therefore fire risk is 

not expected to change because the probability of an ignition occurring is not expected to 

change. 

The value rating would also remain unchanged unless a wildfire occurred and destroyed 

values in the project area.
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87

In the next 10-20 years, as regeneration develops and fills in openings across the 

landscape, fire behavior would favor large scale stand replacing events. High flamelengths, fireline intensities, spread rates, and probabilities of ignition can be expected. 

The closely spaced regeneration would have a ladder effect in the remaining stands of 

trees, enabling fire to transition to the crowns. This fire behavior would make heavy 

equipment necessary for fire suppression. Firefighters could not use direct attack tactics.

Fire behavior in both the moderate and high severity areas of the project area would 

result in an increase in resistance to control and a greater likelihood of wildfire escape 

leading to an increased risk of loss of natural forest resources as well as private property, 

and decreased firefighter and public safety. The high intensity could also cause 

consumption of the remaining duff layer and soil heating as well as other resource 

damage, depending on the burn characteristics of the fire (i.e. whether canopy fire or 

surface fire, fuel loading, fire residence time, etc). Without treatment, the fire hazard 

would continue to move toward very high. The greatest potential for wildland fire 

growth exists with this alternative.

Qualitatively, in the absence of treatments or the use of prescribed fire, the fire hazard is 

expected to worsen across the project area. The only action that could improve the fire 

hazard under the no action alternative is a wildfire and the longevity and improvement of 

fire hazard would be directly associated to the intensity of that fire.

Although air quality would not be directly impacted under the no action alternative, there 

would not be any control over the timing or amount of emissions released into adjacent 

airsheds in the event of a wildfire. A large wildfire has the potential to make a much 

greater impact on adjacent communities and Class 1 Airsheds, possibly exceeding 

National Air Quality Standards. The EPA addresses smoke from wildland fire under 

their natural events policy at http://www.epa.gov/ttn/caaa/t1/memoranda/nepol.pdf . 

(USDA Forest Service, 2005)

Alternative 2 – Proposed Action

Alternative 2 focuses on the management of vegetation to maintain forest health, provide 

for a sustainable supply of commercial timber, and reduce the risk of large-scale, high 

intensity wildfire.

This alternative would treat 18,307 acres commercially, 16,010 acres non-commercially 

and 6,295 acres with prescribed fire. Of the non-commercial treatments 1,693 acres 

would be treated by deadfall treatments and 1,252 acres designed specifically for 

mechanical fuels treatments. Many follow-up treatments or consecutive treatments 

including both mechanical and prescribed fire are planned, resulting in more than one 

treatment in some sites.

The commercial treatments would reduce basal area (BA) to 50 ft2

/ac. or 60 ft2/ac., which 

would reduce the susceptibility to mountain pine beetles as well as the possibility of 

crown fire spread. Pre-commercial thinning would also decrease crown fire potential. 

Prescription burning would reduce the current fuel loadings changing fire behavior of 

future wildfires, reducing risk to life and property. Mechanical fuels treatments would 

treat slash to within 18 inches of the ground to break up fuel continuity, reducing fire 

hazard and providing greater tactical opportunities during fire suppression.
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Direct and Indirect Effects

Treatments outlined in Alternative 2 would decrease the risk for large-scale, high 

intensity fires, allowing for characteristic low to mixed severity fires to occur. The 

treatments proposed in Alternative 2 would also have a substantial effect on fire behavior. 

The chances for successful initial attack under this alternative are much greater than 

Alternative 1, and the risk to residential areas, the general public, and firefighters is also 

greatly reduced. This is a result of treated stands generally burning in a surface fire 

configuration with isolated and small group torching. In addition, an improvement of 

FRCC can be expected as conditions move towards a more natural condition.

The actions associated with this alternative are not substantial enough to significantly 

alter human activities or usage in the area therefore fire risk is not expected to change 

because the probability of an ignition occurring is not expected to change.

The value rating would also remain unchanged unless a wildfire occurred and destroyed 

values in the project area.

This alternative would move 9,916 acres from the high to very high fire hazard rating to 

the low and moderate fire hazard rating. The timber treatments, fuels treatments, and 

prescribed burning would decrease ladder fuels, reduce the surface fuel loading, and 

break up the continuity of the fuels. Prescribed burning would also enhance the mosaic 

of burned and unburned fuels that resulted from past wildfires. The result of these 

treatments would be a decrease in flame length, intensity, duration, spotting, probability 

of ignition, and crown fire potential. This would create more strategic and tactical 

firefighting opportunities resulting in greater success during initial attack due to the fact 

that fireline construction rates would be enhanced, line placement opportunities would 

increase, and resistance to control would decrease. Suppression costs would also 

decrease due to the improved initial attack success rate. The reduction in fire behavior 

would create a safer environment for firefighters as well as the public. The break up in 

fuel continuity would also lead to more opportunities for locating safety zones. The risk 

of MPB outbreaks and the resulting accumulation of surface fuels would also be reduced 

by thinning.

Accomplishing prescribed broadcast burning objectives is estimated to require 

approximately 10-15 ignition days per year for 3 to 10 years. Although usually short in 

duration, smoke from prescribed fires has the potential to affect air quality. Smoke 

generated by wildfire is usually greater and cannot be mitigated; however, smoke 

generated under controlled conditions can be mitigated using the following means:

• Limit treatment area size

• Specify wind directions and speed

• Specify minimum mixing heights 

• Stagger ignitions

These mitigation techniques in addition to other control methods for smoke management 

minimize the impacts of smoke to visibility and human health.

This alternative would meet Forest Plan Goal 10 of establishing and maintaining a 

mosaic of vegetative conditions to reduce occurrences of large-scale, high intensity fire, 

insect, and disease events, and facilitate insect and disease management and firefighting 
Briggs Spring Environmental Assessment Chapter 4

89

capabilities, and Standard 4103, utilizing prescribed fire to achieve management 

objectives. This alternative would also meet Guideline 4110. 

Alternative 3 

Alternative 3 was designed to further reduce the susceptibility to MPB by including more 

thinning and sanitation as well as additional acres of prescribed fire.

This alternative would treat 23,400 acres commercially, 16,443 acres non-commercially 

and 7,009 acres with prescribed fire. Of the non-commercial treatments 1,693 acres 

would be treated by deadfall treatments and 1,274 acres designed specifically for 

mechanical fuels treatments. Many follow-up treatments or consecutive treatments 

including both mechanical and prescribed fire are planned, resulting in more than one 

treatment in some sites.

Direct and Indirect Effects

Reduction in crown fire hazard should result from the creation of a mosaic pattern, 

breaking vegetative continuity both vertically and horizontally across the landscape. An 

improvement of FRCC can be expected as in Alternative 2, however more acres would be 

moving towards a more natural condition as a result of additional acres being treated with 

this alternative.

As with alternative 2, the actions associated with this alternative are not substantial 

enough to significantly alter human activities or usage in the area therefore fire risk is not 

expected to change because the probability of an ignition occurring is not expected to 

change.

As with Alternative 2, the value rating would also remain unchanged unless a wildfire 

occurred and destroyed values in the project area.

Treatments outlined in Alternative 3 would have a greater effect to reducing fire hazard 

than Alternative 2. This alternative would move 15,935 acres (6,019 acres more than 

Alternative 2) from the high to very high fire hazard rating to the low to moderate fire 

hazard rating. 

Accomplishing prescribed broadcast burning objectives is estimated to require 

approximately 10-15 ignition days per year for 3 to 10 years. Although usually short in 

duration, smoke from prescribed fires has the potential to affect air quality. Smoke 

generated by wildfire is usually greater and cannot be mitigated; however, smoke 

generated under controlled conditions can be mitigated using the same means as in 

Alternative 2.

This alternative would meet Forest Plan Goal 10 of establishing and maintaining a 

mosaic of vegetative conditions to reduce occurrences of large-scale, high intensity fire, 

insect, and disease events, and facilitate insect and disease management and firefighting 

capabilities, and Standard 4103, utilizing prescribed fire to achieve management 

objectives. This alternative would also meet Guideline 4110.

Cumulative Effects

The cumulative effects in the Briggs Spring project were analyzed using those activities 

occurring within the project boundary. Those effects were analyzed from 2000, the year 

that Jasper Fire occurred, through 2026, which allows for MPB activity, mechanical and 
Briggs Spring Environmental Assessment Chapter 4

90

prescribed fire activities to be complete. The cumulative effects would occur on all types 

of ownerships that fall within the designated area.

In the Briggs Spring project area, past, present, and reasonably foreseeable future actions 

contribute to changes in fuel conditions. Past management activities may have created 

situations that could have increased as well as decreased the risk of large scale, high 

intensity wildfires. For example, wildfire suppression leads to a buildup in down woody 

material, increased stocking, and increased ladder fuels, which all increase fire hazard. 

The previous lack of thinning in dense stands has also contributed to an increase in 

wildland fire behavior, tree densities, the presence of ladder fuels, and dense crown 

closures, again all contributing to higher fire hazard. In addition, these dense stands have 

also contributed to the growth of MPB. If fires had been allowed to burn instead of 

pursuing an aggressive fire suppression program over the last 75-100 years, a 

considerable increase in the amount of acreage in stands would have burned at a more 

frequent interval and a lower intensity. However, today’s conditions favor wildfires of 

increased fire intensity at longer fire return intervals.

Management activities which have reduced fire hazard in the project area include the past 

timber sales, Redbank, Dumbuk and Thumb, as well as some private timber sales which 

occurred on private land. Reductions in fire hazard occurred on most, but not all of the 

sites treated in these activities, depending upon the amount of biomass removed. In 

addition, prescribed fire projects, including the Stateline and Thumb prescribed burns, 

have occurred in the project area and have reduced fire hazard in those areas. Vegetation 

treatments identified on adjacent lands within the cumulative effects area would enhance 

the cumulative value of both FRCC and fire hazard. In areas not being treated, the 

potential for sustained crown-fires, as well as fireline intensity would increase. With this 

type of fire behavior, forest suppression objectives would not be met.

Fire occurring several miles outside of the project boundary may affect the project area 

under the right conditions. On the Black Hills National Forest, fires in adjacent areas 

have previously had the ability to make large runs of up to 12 miles. Although this event 

is rare and requires extreme conditions, a large scale high intensity fire is more probable 

if no treatment is implemented. A fire start in the Briggs Spring project area (under the 

right conditions) would not only threaten or damage/destroy improvements in the 

immediate area, but also has the potential to burn into or affect surrounding communities 

such as Newcastle, Deerfield, Ferguson Canyon, Buckhorn, or Breakneck within one 

burning period (12 hours). A large scale, high intensity wildfire brings with it numerous 

risks and effects. Homes in the path of a wildfire are perhaps the most immediately 

recognized value at risk, however severe wildfires put numerous other important values 

at risk including: critical infrastructure, critical fish and wildlife habitat, firefighter and 

public health and safety, soil productivity, clean air, and functional fire-adapted 

ecosystems (Graham et al., 2004). Some of these values are also threatened by the 

secondary effects of wildfire, such as increased runoff, soil erosion and the spread of 

exotic species (Graham et al., 2004).

The action alternatives are expected to have positive long term cumulative effects. The 

proposed treatment combined with monitoring and foreseeable future projects would 

decrease the risk of large scale, high intensity damage of wildfire as well as decrease fuel 

loading, moving the project area to a more desirable condition. The proposed treatments 
Briggs Spring Environmental Assessment Chapter 4

91

would reduce stand density and canopy closure bringing the forest back to a more 

historical type condition. Projects in adjacent areas would also have an impact. These 

projects combined with the treatments proposed in the Briggs Spring project would 

decrease the hazardous fuels much more efficiently for longer periods of time.

Summary of Effects

Analysis has demonstrated that all action alternatives would have a change on fire 

behavior within treated areas. This change is expected to be mixed severity in nature,

opposed to those areas not treated which will experience more high severity to stand 

replacement fire behavior. The chances for successful initial attack would also increase 

in all action alternatives and the risk to the identified values at risk would decrease. In 

addition, an improvement of FRCC can be expected as conditions move towards a more 

natural condition. Under the no action alternative, there would be no change in fire 

behavior therefore no improvement in existing FRCC.

The fire risk is not expected to change in any of the alternatives because the actions 

associated with this alternative are not substantial enough to considerably alter human 

activities or usage in the area therefore fire risk is not expected to change because the 

probability of an ignition occurring is not expected to change.

Fire hazard is expected to improve in all action alternatives. Alternatives 2 and 3 are 

very comparable with only 667 acres separating these alternatives. Treatments identified 

in Alternative 2 will shift 9,916 acres, or 40% of the project area, from a high to very 

high rating to a low to moderate rating. Treatments identified in Alternative 3 will shift 

10,583 acres, or 43% of the area, from a high to very high rating to a low to moderate 

rating (Table 30 and Figure 7). Under the no action alternative, there would be an 

increase in fuel loading resulting in increased fire behavior, which also has the potential 

to further impact wildlife, soils, visual qualities, and timber. The no action alternative 

would not improve fire hazard.

Table 30. Fire Hazard Rating by alternative

Fire Hazard 

Rating

Alternative 1 Alternative 2 Alternative 3

Acres % Acres % Acres %

Low 3,194 13 17,236 70 17,384 71

Moderate 8,095 33 3,969 16 4,488 18

High 5,211 21 2,054 8 1,834 7

Very High 8,048 33 1,289 5 842 3

Total 24,548 100 24,548 100 24,548 100
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Figure 7. Fire Hazard Rating by alternative.

Air quality would be affected by all action alternatives. More smoke would be generated 

by Alternative 3 then Alternative 2. Smoke generated by prescribed burning can be 

mitigated while smoke generated by wildfire is usually greater and cannot be mitigated; 

however, smoke generated under controlled conditions can be mitigated using the same 

means as stated in Alternative 2.

All action alternatives would meet the Forest Plan Goal 10 of establishing and 

maintaining a mosaic of vegetative conditions to reduce occurrences of catastrophic fire, 

insect, and disease events, and facilitate insect and disease management and firefighting 

capabilities, and Standard 4103, utilizing prescribed fire to achieve management 

objectives.

It is important to understand that fuel treatments would not prevent wildland fires from 

occurring. However, with fuel treatments, the risk of an extreme wildfire event would be 

greatly decreased. Fuel treatments would also need to occur in adjacent planning areas in 

order for treatments to be most effective at a landscape scale.

Botany, Rangeland, and Noxious Weeds

Affected Environment

A large portion of the project area contains the community type Black Hills Montane 

Grasslands (Marriot & Faber-Langendoen, 2000). While most grasslands/meadows 

within the project area would fit into this community type, the majority of areas have a

considerable proportion of exotic grasses such as Kentucky bluegrass (Poa pratensis), 

common timothy (Phleum pratense), and smooth brome (Bromus inermis). Many of 

these areas also have a major proportion of non-native clovers (Trifolium spp.). These 

0

5000

10000

15000

20000

25000

Alternative 1 Alternative 2 Alternative 3

Acres

Fire Hazard Rating

Very High

High

Moderate

Low
Briggs Spring Environmental Assessment Chapter 4

93

exotic invaders greatly reduce the botanical potential in these grasslands. However, a 

few large grasslands, and several isolated meadows, do exist within the project area that 

are not completely dominated by exotics and contain a rich diversity of native plants. 

The areas that are not dominated by exotic grasses or clovers are especially important to 

the area because of their limited acreage. Many of these areas are being affected by pine 

encroachment. Total acres dominated by grasslands and/or meadows total approximately 

2,697 acres.

Several small springs/seeps occur throughout the project area. Many of these have been 

developed in the past to be used as livestock water facilities and have small reservoirs 

built around them. Springs are also discussed in the Water Resources section. 

Botany

A comprehensive botanical survey was completed in 2007 exclusively for the Briggs 

Spring project area to collect information related to plant communities, assess sensitive 

species habitat, and identify locations of target plant species (sensitive species, statelisted species, and species of local concern). Subsequent surveys were completed in 2010 

as a result of long-term rangeland monitoring for the livestock grazing program and 

general plant surveys of the area. Surveys will be ongoing in the project area.

South Dakota state listed species are plant species that have been identified as rare in 

the state of South Dakota. The state has identified these plants for tracking by the South 

Dakota Natural Heritage Program. There are occurrences of four of these species located 

within the Briggs Spring analysis area. These four species will be carried forward in this 

analysis:

• Moonwort grapefern (Botrychium lunaria) 

• Least grapefern (Botrychium simplex) 

• Fendler’s whitethorn (Ceanothus fendleri) 

• Giant lousewort (Pedicularis procera)

A pre-field review was conducted of available information to assemble occurrence 

records, describe habitat needs and ecological requirements, and determine whether field 

reconnaissance is needed to complete the analysis. Sources of information included 

botanical surveys, Forest Service records and files, local professional judgment, and 

published research.

Species of Local Concern (SOLC) – Based on known conditions of this project area,

pleated gentian (Gentiana affinis) is the only SOLC which is present and there may be 

suitable habitat and will be carried forward in this analysis. There were numerous 

occurrences of this species found during the survey of this project area.

Region 2 (R2) Sensitive Species – No R2 sensitive plant species have been located 

within the project area, but suitable habitat is present for two species: Iowa moonwort 

(Botrychium campestre) and narrowleaf grapefern (Botrychium lineare). Since no R2 

sensitive species have been identified in the project area, only suitable habitat will be 

analyzed. A pre-field review was conducted of available information to assemble 

occurrence records, describe habitat needs and ecological requirements, and determine 

whether field reconnaissance is needed to complete the analysis. Sources of information 
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included botanical surveys, Forest Service records and files, local professional judgment, 

and published research.

No further analysis is needed for species that are not known or suspected to occur in the 

project area, and for which no suitable habitat is present. Table 31 documents the two 

species that will be carried forward in this analysis.

Table 31. Forest Service R2 Sensitive Species in Briggs Spring project area

Scientific Name/

Common Name/

Plant Code

Distribution and Habitat

Known To 

Occur in 

Project 

Area?

Suitable 

Habitat 

Present?

Botrychium 

campestre/Iowa 

moonwort/BOCA5

Rangewide the species occurs primarily on welldrained soils in non-forested habitats, 

occasionally under shrubs in or at the margins of 

these habitats. Black Hills occurrences are 

known from BKF lands, private land and Wind 

Cave National Park. Botrychium campestre is 

extremely inconspicuous. Rangewide, it is 

considered a grassland species associated with 

sandy grassland habitats in prairies, dunes, 

railroad sidings, and fields over limestone. Black 

Hills sites occur on limestone substrates and are 

primarily in open grassland dominated habitats 

usually with high to moderate forb diversity. 

Little bluestem (Schizachyrium scoparium) 

occurs at several of the sites. Black Hills 

occurrences range in elevation from 

approximately 3,850 to 6,700 ft.

No Yes

Botrychium 

lineare/narrowleaf 

grapefern/BOLI7

Western populations of the species occur 

primarily on limestone substrates in a variety of 

habitats including heavily forested sites and 

grassy meadows, fen-like seeps and gravelly 

roadsides. Black Hills sites occur on limestone 

substrates in open grassland habitats (both high 

elevation montane grasslands and lower 

elevation little bluestem dominated habitats), on 

old (estimated 15-25 years) native surface 

roadbeds and in openings along perennial 

streams. Elsewhere in its range, this species has 

often been documented in areas of road 

disturbances and other human and natural 

disturbances. Black Hills occurrences range in 

elevation from approximately 4,200 (in Wind 

Cave national Park) to 6,700 ft.

No Yes

Rangeland

Range condition, trend and inventory for the analysis area were measured on the various 

allotments many times during the 1960’s, 1970’s and 1980’s in addition to more recent 

studies conducted in 2002 and 2010.

The Briggs Spring project area includes portions of three grazing allotments as follows: 

Central Allotment, the entire allotment except a small portion of the Estes Springs 
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pasture; Crow’s Nest Upper Beaver Allotment, Unit D, Antelope Unit, and portions of 

Units 5, 4, B, C, 4, 3, and 1; and, Lower Beaver Allotment, Units Moon, Summit Ridge, 

and Wilson. Table 32 shows historical grazing use by allotment.

There are currently a total of 24 grazing permits, (4 private land permits and 20 term 

permits) within the analysis area. Cattle are present in the allotments from June 1st –

October 15th annually.

Table 32. Historical use by allotment in the Briggs Spring project area

Central 

Grazing 

Allotment

The first recorded actual use on this allotment dates back to 1930, use was 

primarily by cattle with five to 43 horses permitted in the 1940’s. The grazing 

system was season-long continuous grazing. The allotment was first cross 

fenced in 1964. Today seven permittees graze the allotment under a deferred 

rotation grazing system.

Crow’s Nest 

Upper Beaver 

Grazing 

Allotment

Past grazing management of the allotment was season-long use, with water 

being the only distributing factor. In the late 1940’s the first division fence was 

constructed, dividing the allotment into two units. In the early 1950’s voluntary 

reductions and partial stocking occurred, and in 1956 permittees were offered a 

choice of taking massive reductions or implementing a range improvement 

program and intensive management system. This program led first to 

development of rest rotation and increased numbers, and later to the deferred 

rotation systems that are currently in use. Because of overstocking disclosed in 

the production-utilization study done in the late 1980’s, livestock numbers were 

reduced by 120 head in the analysis area in 1991.

Lower Beaver 

Grazing 

Allotment

Grazed by cattle season-long until it was first cross-fenced in 1966. Prior to 

1966 distribution was a concern on the allotment, with the north end receiving 

heavy use while the southern end received very light use. The cross fence 

allowed for a season-long unit in the southern end of the allotment and a twounit deferred grazing system on the northern portion. In 1973 the season-long 

use of the southern portion was changed to a two-unit deferred rotation system.

Noxious Weeds

The Briggs Spring project area contains the past analysis areas of Dumbuk, Redbank and 

Thumb. Those areas were surveyed during noxious weed treatment in 2005-2010. 

Canada thistle (Cirsium arvense) and hound’s tongue (Cynoglossum officinale) are the 

main invaders in this analysis area. Smaller infestations of common tansy (Tanacetum 

vulgare), yellow toadflax (Linaria vulgaris), and oxeye daisy (Leucanthemum vulgare)

also exist. In 2010 leafy spurge was found and treated. The Redbank Campground is 

surveyed and treated for weeds annually.

In the project area it is known that there is at least 440 acres of noxious weed infestations. 

Previous disturbances within the project area and current infestations put this area at high 

risk for continued invasion.

Documented noxious weed species found in the area include:

• leafy spurge (Euphorbia esula)

• Canada thistle (Cirsium arvense)

• hound’s tongue (Cynoglossum officinale)

• yellow toadflax (Linaria vulgaris)
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• common tansy (Tanacetum vulgare)

• oxeye daisy (Leucanthemum vulgare)

• sulfur cinquefoil (Potentilla recta)

• common mullein (Verbascum thapsus)

• bull thistle (Cirsium vulgare)

• musk thistle (Carduus nutans)

Environmental Consequences

Botany

State Listed Species and SOLC 

Effects to the following species are similar and are analyzed together. State listed species 

include: moonwort grapefern, least grapefern, Fendler’s whitethorn, and giant lousewort. 

SOLC include: pleated gentian. 

Alternative 1 – No Action

No new proposed activities would occur in the project area.

Direct and Indirect Effects

There would be no direct effects, since no activities would occur. There would be no 

damage to any unknown individuals from forestry treatments, prescribed fire, or 

campground developments. Conifers would continue to encroach into 

meadows/grasslands and forest stands would continue to become denser, which may 

result in loss of habitat for these species. Risk of MPB infestations and wildfire would 

not be decreased; there would likely be an increase in risk for both, resulting in potential

negative affects to state listed and SOLC plant species.

Noxious weed infestations are a risk for these plant species, as exotics are often able to 

out-compete native vegetation for available nutrients. In addition, the treatment of such 

infestations with herbicides might present a risk to these plants if unknown occurrences 

are inadvertently sprayed. The lack of additional disturbance associated with the no 

action alternative would reduce the possibility of noxious weed infestations in state listed 

and SOLC species habitat.

Common to Both Action Alternatives

Direct and Indirect Effects

Direct effects of the disturbances associated with the vegetation treatments would be the 

loss of individual plants from heavy equipment operations, locations of burn piles, skid 

trails, or any activity in suitable habitat. However the overall effect of treatments would 

be neutral to beneficial. The proposed pine encroachment treatment in both alternatives 

would likely enhance habitat for these species. Both action alternatives would reduce the 

overall risk of MPB infestation and large-scale, high intensity wildfire.
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Indirect effects would be the increased potential for noxious weed infestations in 

disturbed areas. This can be detrimental to state listed and SOLC plant species, as 

noxious weeds and invasive species have the ability to out-compete desired native plant 

species. The herbicides used in noxious weed control can also be detrimental to these

species if the individuals are inadvertently exposed to the herbicides.

Prescribed burning and tree thinning appear to have the potential to increase the growth 

and reproduction of Fendler’s whitethorn according to Huffman and Moore (2004). Thus

the management activities proposed in the action alternatives would be expected to have 

a beneficial effect on these species.

Giant lousewort would potentially be affected. The stand it occurs in is proposed for a 

group shelterwood treatment under both action alternatives. No available sources 

indicate known effects to giant lousewort from disturbances such as forestry treatments. 

While adverse effects may occur to this species in the project area it would not affect the 

overall population in the Black Hills.

The proposed campground sites occur in areas that do not contain any known populations 

of any state listed or SOLC plants, or suitable habitat. 

The alternatives would meet Forest Plan standards and guidelines, therefore it is 

determined pleated gentian is likely to persist on the forest. 

R2 Sensitive Species 

Effects to the following species are similar and are analyzed together. R2 sensitive 

species include: Iowa moonwort and narrowleaf grapefern.

Alternative 1 – No Action

No new proposed activities would occur in the project area.

Direct and Indirect Effects

Under the no action alternative, there would be no direct effects, since no activities would 

occur. There would be no damage to any unknown individuals from forestry treatments, 

prescribed fire, or campground developments.

By not treating stands infested with mountain pine beetle and reducing hazardous fuels, 

there would likely be an increased risk for a large-scale, high intensity wildfire. This 

type of fire often times has effects such as deep soil heating and intensities that could 

negatively affect both the belowground and aboveground portions of Iowa moonwort and 

narrowleaf grapefern individuals (USDA Forest Service, 2005, Appendix C).

A decrease of suitable habitat (grass dominated communities) would likely result with 

implementation of the no action alternative. With the current absence of a natural fire 

regime and without treatment, it is expected that forested stands will become denser and 

ponderosa pine will continue to encroach upon suitable habitat. Allowing pine 

encroachment to continue may result in a loss of suitable habitat for these species.

The lack of additional disturbance associated with the no action alternative would reduce 

the possibility of noxious weed infestations in the sensitive plant habitat. Noxious weed 

infestations are a risk for R2 sensitive plants, as exotics are often able to out-compete 
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native vegetation for available nutrients and moisture. In addition, the treatment of such 

infestations with herbicides might present a risk to sensitive plants if unknown 

occurrences are inadvertently sprayed.

This alternative would result in both positive and negative impacts to these two species. 

There would not be any disturbance to unknown individuals nor would the potential to 

increase noxious weed infestations exist through the no action alternative. The negative 

impacts could result in an increased risk of a large-scale, high intensity wildfire damaging 

species habitat and a loss of habitat from conifer encroachment. Since both species 

occupy similar habitat the following determination is valid for both: “May adversely 

impact individuals, but not likely to result in a loss of viability in the Planning Area, 

nor cause a trend for federal listing.”

Common to Both Action Alternatives

Direct and Indirect Effects

Both action alternatives would potentially benefit suitable habitat for these species. The 

earlier successional conditions that occur with opening the overstory canopy could 

produce conditions that would be beneficial to site colonization by wind-dispersed, sporeproducing Botrychium species (Iowa moonwort and narrowleaf grapefern), if the 

associated mycorrhizal species and other microsite conditions are present (Farrar, 2004). 

Reducing canopy cover, amount of biomass, and hazardous fuels would reduce the 

likelihood of a severe, high intensity wildfire that could degrade habitat for sensitive

species. Hardwood stands are typically not considered suitable habitat for Iowa 

moonwort and narrowleaf grapefern. Removing conifers would likely have a neutral to 

beneficial effect on any unknown Iowa moonwort and narrowleaf grapefern populations. 

Treatment of the sites that are proposed for pine encroachment would likely enhance 

habitat for Iowa moonwort and narrowleaf grapefern. There is potential for treatments to 

have short-term impacts to any unknown individual plants during the treatments; but 

long-term, the proposed pine encroachment treatments would likely have a beneficial 

impact for these species by enhancing or conserving the habitat conditions.

Prescribed fire would unlock nutrients bound in un-decomposed organic matter above the 

soil and release them to be available for plants. Decreasing the ponderosa pine density 

and the proposed prescribed burning would be expected to reduce the risk of wildfire, 

which would help protect sensitive plant species habitat. Prescribed burning would not 

be expected to have negative impacts to these species. 

The proposed campground sites occur in areas that do not contain any known populations 

of Iowa moonwort or of narrowleaf grapefern, nor does it contain suitable habitat. The 

sites are dominated by ponderosa pine and the soils that occur on the sites are typically 

not conducive for these two species in the Black Hills.

Negative direct effects of any of the proposed treatments would be the loss of any 

unknown individuals from heavy equipment operations, locations of burn piles, skid 

trails, or any activity in suitable habitat.

Indirect effects from any of the proposed treatments would be the increased potential for 

noxious weed infestations in disturbed areas. The herbicides used in noxious weed 

control can also be detrimental to sensitive species if the individuals are inadvertently 
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exposed to the herbicides. While unknown individuals may exist on these sites and may 

be damaged during operations, the overall effect would be neutral to beneficial.

Both Alternative 2 and 3 would likely result in positive and negative impacts. Any 

negative impacts to unknown individuals are expected to be short-term, while long-term 

impacts should be beneficial. Since both species occupy similar habitat the following 

determination is valid for both: “May adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend for federal 

listing.”

Rangeland

Alternative 1 – No Action

No new proposed activities would occur in the project area.

Direct and Indirect Effects

The no action alternative would eventually result in a decrease of grassland communities 

in the project area as forested stands become denser and ponderosa pine continues to 

encroach upon grassland and meadow areas. As a result, the amount of available forage 

would decrease as grassland communities decline and ponderosa pine becomes denser. 

Also, access to available forage would eventually decrease as forested stands become 

denser and livestock travel within forested areas becomes difficult. Having less forage 

available in forested areas, grazing animals would increase the grazing pressure on nonforested areas. This may result in a possible decrease in the condition of those 

rangelands. A decrease in condition of the rangelands would eventually lead to an 

additional decrease in the amount and quality of forage available. With all of the above, 

this would make it more difficult to meet the Forest Plan Guideline 2505, Proper Use or 

Residual Levels-Riparian/Uplands, with the current grazing permits.

This alternative would not increase the potential for livestock-recreational user conflicts 

with the addition or expansion of an OHV campground as proposed in either of the action 

alternatives. An increase in OHV traffic leads to the potential of conflicts with livestock 

as OHV oftentimes lead to the disruption of livestock behavior.

Common to Both Action Alternatives

Direct and Indirect Effects

Both action alternatives would increase the overall amount of forage available by 

decreasing ponderosa pine density in the grasslands/meadows, uplands, and aspen stands. 

Decreasing pine density may also open areas up that were previously inaccessible to 

livestock. The treatments may allow for more even-distribution of livestock throughout 

the pastures and reduce utilization in more critical areas such as meadows and grasslands.

Cattle are permitted and present in allotments within the project area as follows: Crow’s 

Nest/Upper Beaver and Lower Beaver Allotments from June 11th – September 30th; and, 

Central Allotment from June 11th - October 10th. Conflict with permitted uses may occur 

if fences are left down or gates are left open.
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The proposed campground in either action alternative would have the potential to 

increase livestock-recreational user conflicts. The number of recreation user days would 

be expected to increase with the implementation of either campground site. This would 

lead to an increased potential for gates to be left open and livestock to be harassed by 

OHV’s. Within the developed recreational area conflict would be minimal as these areas 

would be fenced out from livestock grazing.

Noxious Weeds

Alternative 1 – No Action

No new proposed activities would occur in the project area.

Direct and Indirect Effects

Noxious weed populations would be limited to current infestations unless disturbance 

occurs from natural events, or large-scale fire. The lack of additional disturbance 

associated with the no action alternative would reduce the possibility of noxious weed 

infestations.

Noxious weed infestations are known to increase with large fire events. The lack of 

treatment of hazardous fuels would lead to the potential increase of a large-scale high 

intensity wildfire, thus increasing the potential for a large-scale outbreak of noxious 

weeds.

Common to Both Action Alternatives

Direct and Indirect Effects

There is a potential for 21,866 acres (under Alternative 2) or 23,917 acres (under 

Alternative 3) being disturbed from timber harvest, fuels treatments, and prescribed fire. 

Skid trails, landings, burn piles and areas where machinery is working would create 

conditions in favor of seedbeds for noxious weeds. The actual amount of disturbance is 

dependent on the scope and amount of acres infested with MPB, type of equipment used, 

and the time of year the disturbance occurs.

Because parts of this project area are within areas that burned under intense wildfire 

conditions (Jasper Fire) and were heavily infested with Canada thistle, there is a very 

high risk that the existing seedbank would result in a marked increase in Canada thistle 

infestation. Past experience indicates that populations of plants with pappiferous fruit, 

such as Canada thistle, have the potential to spread 30% a year with disturbance. The 

potential in this project area could be much greater due to the existing seedbank that 

might have resulted from recent infestations. However there are design criteria set in 

place to help minimize this effect.

Prescribed burning temporarily reduces the grassland vegetation for one or two growing 

seasons thus reducing the competition of noxious weeds. Existing fuel loads (wood 

currently on the ground) would naturally burn with higher temperatures in relation to fuel 

loads associated with grassland vegetation increasing the heat of the soil beneath these 

heavy fuels allowing noxious weeds to germinate with no competition of native grasses. 

Anytime activities remove the protective herbaceous cover and soil is exposed, (such as 
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severe fire, skid trails resulting from timber harvest, road creation, etc.) there is an 

increase in the likelihood of exotic plants being introduced into an area. Proposed 

thinning treatments would also include ground disturbance with similar results of existing 

and new infestations of noxious weeds. Previous disturbances within the project area and 

current infestations put this area at high risk for continued invasion. The infestations can 

be expected to spread at least 30% per year when there is disturbance. At highest risk 

will be areas containing larger fuel loads and downed timber which create a place for past 

seed accumulation and will burn with much higher intensities.

It is critical that the proposed post harvest activity of using herbicides for noxious weed 

control be implemented to mitigate the spread of invasive plant species. Monitoring of 

the effectiveness of treatment, and retreatment as needed, is essential.

Cumulative Effects

The cumulative impact area for this analysis is the identified project area within the 

Briggs Spring project area. Activities beyond the project area have a diminished effect on 

the botany, rangeland, and noxious weeds within the project area. The timing limit for 

the cumulative effects analysis is estimated at 20 years, ten years prior to present and ten 

years in to the future, which allows for an adequate length of time to record vegetative 

changes.

Past, present and reasonably foreseeable activities within the Briggs Spring project area 

include timber harvest, timber thinning, limited mining, wildfire, prescribed burning, 

grazing, road construction and maintenance, noxious weed control, wildlife habitat 

improvement projects, and dispersed recreational use on both the public land and private 

land in the area. A list documenting known past and planned future activities for this area 

is included in Appendix F.

Noxious weed infestations are expected to increase under both action alternatives. Any 

past, present or foreseeable future activity that causes soil disturbance has the potential to 

introduce and increase the rate of spread of noxious weeds and other exotic plants. This 

can be detrimental to rangeland resources and SOLC and state listed plant species, as 

invasive species have the ability to out-compete desired native plants. The potential for 

noxious weed establishment is even greater in disturbed areas adjacent to existing weed 

populations. The movement of equipment in and out of these areas also facilitates weed 

establishment. Roads create a network of corridors through which seed dispersal can 

occur.

The herbicides used in noxious weed control can also be detrimental to SOLC and state 

listed species if the individuals are inadvertently exposed to the herbicides.

The grazing in the Briggs Spring project area will continue as identified in the Allotment 

Management Plans for the grazing allotments within the project area. Under both action 

alternatives, creation of transitory range would have a positive cumulative effect on those 

allotments by reducing the time livestock spend in riparian areas. Broadcast burning 

proposed under the action alternative would work against the cumulative effect of fire 

suppression by killing small trees and setting back succession, though it is expected to 

have limited effects on overstory canopy. All of the effects to rangeland resources 

presented here would be limited in intensity and duration. Any negative impacts would 
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be minimal and are directly related to livestock management in the short term as they are 

impacted by treatment activities.

All of the above uses are limited in intensity and duration and therefore when combined 

with the alternatives analyzed, including the no action alternative, do not result in adverse 

cumulative impacts to the state listed species, SOLC, R2 sensitive species or their habitat.

Minerals and Geologic Resources

Affected Environment

The regional geology and mineral resource potential of the Briggs Spring project area is 

described in U.S. Geological Survey Bulletin 1580 (Dewitt et al., 1986). Geologic 

mapping is available for the Briggs Spring project area in the Geologic Map of the Black 

Hills Area, South Dakota and Wyoming: Geological Survey Miscellaneous Investigations 

Series Map I-1910, scale 1:250,000 (DeWitt et al., 1989).

Mineral resources on National Forest System lands can be divided into three categories. 

These categories are Locatable Mineral Resources, Salable Mineral Resources, and 

Leasable Mineral Resources.

Locatable minerals are minerals or mineral materials subject to claim and development 

under the General Mining Law of 1872, as amended. As set forth in this law, all

locatable minerals on public domain lands such as the Briggs Spring project are open to 

location, discovery and mining. The Forest Service has only limited authority to restrict 

and regulate locatable mineral activities on public domain lands (USDA Forest Service, 

2006c). High-calcium limestone is a potential locatable mineral resource that could be 

present within the Briggs Spring project area.

Salable minerals are a group of mineral commodities such as common variety sand, 

gravel, and stone that are salable under the Materials Act of 1947. The Forest Service has 

discretionary authority over production of these commodities from National Forest 

system lands (USDA Forest Service, 2006c).

Oil and gas are leasable minerals under the Mineral Leasing Act of 1920. This act 

provides authority to the Bureau of Land Management to lease oil and gas deposits on 

public domain National Forest system lands. Significant oil and gas production is 

occurring along the western and southwestern margins of the Black Hills, although no oil 

and gas production or exploration activities are known in the direct vicinity of the Briggs 

Spring project area. Dewitt et al. (1986) does classify a majority of the Briggs Spring 

project area with a low potential for discovery of small oil and gas deposits. The very 

western edge of the project area may be in the moderate potential area for discovery of 

large oil and gas deposits (stratigraphic traps) as described by Dewitt et al. (1986).

No current mineral exploration or production activities are known within the Briggs 

Spring project area. No notice of intents for mineral activities have been filed with Black 

Hills National Forest and a search of the Bureau of Land Management Geographic Claim 

Index shows that there are no active mining claims in the area.
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There are no known abandoned mines in the Briggs Spring project area (Webb et al., 

1998; DeWitt et al., 1986). This concurs with the identification of a limited potential for 

mineral resource development as discussed above. The closest abandoned mine is 

approximately three-miles east of the project area (Davis et al., 1998).

The Pahasapa Limestone hosts the vast majority of caves within the Black Hills including 

Jewel and Wind Caves, the second and fourth longest caves in the world respectively. 

Currently, there are no known caves in the project area. The Pahasapa Limestone does 

have the potential to host cave systems. This potential is indicated by the occurrence of 

caves along the outcrop of the Pahasapa Limestone south of the Briggs Spring project 

area which contains at least ten (10) caves three-miles or less from the project area. The 

closest known caves are less than one-mile from the project area.

The rocks within the Briggs Spring project area host Paleozoic invertebrate fossils. In 

addition, in very rare occasions, deposits of Pleistocene vertebrate fossils such as camels 

and mammoths are found within sediment-filled sinkholes in the Pahasapa Limestone. 

Examples of Pleistocene vertebrate fossil deposits include the Hot Springs mammoth site 

in the southern Black Hills and the Richmond Hill site in the northern Black Hills. The 

Pleistocene deposits are very difficult to identify and are often only discovered by chance 

in some type of excavation.

Potential mineral recreational opportunities include fossil collecting and exploration for 

undiscovered caves. No permits have been issued for the collection of rocks or fossils in 

the project area.

Environmental Consequences

Direct, Indirect Effects and Cumulative Effects for All Alternatives

Current transportation conditions within the project area are adequate to facilitate 

activities related to exploration and development for either locatable minerals or oil and 

gas. However, it is not considered likely that these activities will occur in the near future.

The Briggs Spring project would not cause direct or indirect effects to mineral resources 

under any alternative, therefore there would not be any cumulative effects to mineral 

resources under either Alternatives 1, 2, or 3. Cumulative effects to cave resources are 

also unlikely under the three alternatives; design criteria is included to protect any caves 

discovered during project implementation. 

Lands and Special Uses

Affected Environment

There are 4,368 acres of private land within the Briggs Spring project area. The private 

in-holdings are mostly large Homestead Entry Surveys that are surrounded by federal 

land administered by the Forest Service. Most of the private parcels are raw land

primarily used for grazing or recreation with only a few year round residents. Access to 

private land is provided through system and/or non-system, NU-new unauthorized forest 

roads and private roads. Lands special uses are very minimal within the project area and 
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therefore do not pose any concerns or issues. Black Hills Power has submitted an 

application and project proposal for a very extensive new 230kV Transmission overhead 

power line that would cross both private and National Forest System (NFS) land within 

the Briggs Spring project area.

There are no special use permits and only one issued easement within the Briggs Spring 

project area. Easements have not been issued to landowners in this part of the district due 

to the fact that the private in-holdings are predominantly raw land and landowners have 

not historically performed any road maintenance, reconstruction or snow removal to 

access the parcels. As private land increasingly becomes subdivided for either year 

around residential, single family homes or seasonal cabins, we may see an influx of 

applications for easements to obtain perpetual legal access.

Environmental Consequences

Alternative 1 – No Action

There would be no project activities implemented under this alternative. 

Direct and Indirect Effects

This alternative would not have any short-term effect on the lands resource. There is a 

potential for untreated NFS lands to have an increased threat of wildfires due to higher 

stocking densities. This could pose a risk of fire spread to private property. This would 

also eliminate the ability to reduce potential mountain pine beetle spread onto private 

land and subsequent tree mortality by not thinning dense timber stands on NFS lands. 

Any land use proposals, including the 230 kV overhead transmission line corridor 

application, would continue to be considered through the Lands and Special Uses 

programs. Other uses such as Small Tracts Act applications, special use permit 

applications, other utility requests, easement applications and opportunities to acquire 

right-of-ways would continue within the project area.

Common to All Action Alternatives

Direct and Indirect Effects

These alternatives would not have any long term effects on the lands resource. The 

minimal special uses and right-of-ways within the project area would not conflict with 

any action alternative provided roads are kept open for access to the public. Short term 

effects of proposed activities would include dust and noise from increased traffic during 

harvest operations. Increased log hauling traffic could impact roads that the public 

utilizes to access their private property. Smoke from prescribed burning and slash pile 

disposal operations may impact some adjacent landowners. Reduction in stand density 

could reduce fire intensities, should a fire start on forest and endanger private property. 

Social impacts include private landowners’ receptivity to more aggressive silvicultural 

prescriptions and its relationship to land values. No needs have been identified for 

acquiring right-of-ways for implementation of either action alternative.

Cumulative Effects

The Briggs Spring project area boundary, land exchanges within the last 30 years and 

special uses within the last 10 years were used to evaluate cumulative effects. Activities 

proposed under the action alternatives would not have any effect on the current lands and 
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special uses, nor would they affect any foreseeable future lands and/or special uses 

proposals.

Heritage Resources

Affected Environment

Prehistoric Context

The Black Hills are part of the greater culture area of the Northwestern Plains with 

human occupation of dating to 11,000 B.P. (Frison, 1991:7,13). Over this vast period of 

human occupation, the ecology, subsistence patterns, technology, and the cultures of 

Black Hills inhabitants have witnessed notable changes (Frison, 1991:24). These 

changes are grouped into phases of occupation, which are held in the archaeological 

record. The Black Hills National Forest Cultural Resources Overview identifies cultural 

sites that represent all of these prehistoric phases of occupation in the Black Hills (Rom, 

et al. eds., 1996). Identifiable tribal groups living within the Black Hills area during the 

Protohistoric period include the Kiowa, Crow, Arapaho, Cheyenne, and Sioux.

Many Native Americans consider the entire Black Hills sacred land. Their belief system 

links specific locations in and around the Black Hills to star constellations (Rom, et.al. 

eds., 1996). These spiritually significant locations include but are not limited to: Devil’s 

Tower, Old Baldy Mountain, Hot Springs, Buffalo Gap, Reynolds Prairie, the spearfish 

formation “race track” that surrounds the Black Hills, and Harney Peak (Goodman, 

1992). Ceremonies are performed at these sacred locations during specific periods on the 

celestial calendar or weather events (Goodman, 1992: 12).

Historic Context

Although influenced by Euro-American culture through the introduction of horses, guns, 

and disease as early as the 17th century, sporadic use of the Black Hills by EuroAmericans largely began in the early 1800’s and consisted mainly of fur trappers and 

traders (Sundstrom, 1989). The western half of South Dakota, including the Black Hills, 

portions of southern North Dakota, and nearly the entire area of the Powder River Basin 

in Wyoming and Montana was recognized as unceded Indian Territory by the 1868 treaty 

between the United States and the Sioux and Arapaho. More intense Euro-American 

occupation in the Black Hills began shortly after gold was discovered in the Black Hills 

in 1874. It was this discovery that brought a full scale influx of Euro-American 

prospectors and miners to the Black Hills.

Historic settlement in the Black Hills by Euro-Americans is generally auxiliary to this 

history of the mining industry. Homestead patents are common from the late 1800’s 

through the 1920’s. Industries such as the ranching and logging industry became 

common in the early 1900’s. However, much of the land was not patented and remains 

public land. During the Great Depression/New Deal Period (1920-1941), public works 

projects became common across the Black Hills landscape. The Civilian Conservation 

Corp (CCC) and the Works Progress Administration (WPA) organized groups of men in 

camps to construct lookouts, roads, trails, dams, and wells throughout the area.
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Within the Briggs Spring project area there are 25 known cultural resources determined 

eligible for listing on the National Register of Historic Places (NRHP). The majority of 

sites are considered prehistoric and range in age from 7,000 to 250 years before present. 

They include rock shelters, lithic procurement sites, quarries, and village sites. The 

historic sites include remnants of various CCC developments linked to the Great 

Depression and New Deal time period in addition to past remnants of logging and 

homesteading.

Field Surveys

Sections of the Level III cultural resource inventory were first contracted to Niwot 

Archaeological Consultants in 2006 and 2008. A Level III Heritage Resource Inventory, 

Monitoring, and Evaluation: Redbank Unit of the Briggs Analysis Area by Brad Noisat 

(BKF # R2006020300133) resulted in the survey of 5,141 acres. Level III Heritage 

Resource Inventory: Moon Unit of the Briggs Analysis Area by Brad Noisat (BKF # 

R2008020300104) resulted in the survey of 1,197 acres in 2008. The two contract 

inventories consisted of new survey and the evaluation of newly discovered sites.

The Forest Service conducted an in-house cultural resource survey of the remaining 

2,626 acres distributed across the 24,548 acre Heritage area to protect (APE). Newly 

recorded and previously recorded unevaluated sites were evaluated for eligibility to the 

NRHP. All eligible sites were monitored and evaluated for effects from all project 

alternatives.

Environmental Consequences

Alternative 1 – No Action

There would be no project activities implemented under this alternative. 

Direct and Indirect Effects

If there is no federal action, then there is no undertaking, as defined in 36 CFR Part 

800.16(y), for Section 106 of the National Historic Preservation Act (16 U.S.C. 470f). 

However, no action may result in the destruction of cultural resources due to the 

increased fuel loading and tree mortality from overgrowth--both of which increase the 

risk of fire and subsequent ground disturbance and erosion. Many of the eligible sites in 

the Briggs Spring analysis area are eligible for listing on the NRHP due to the presence of 

intact subsurface cultural deposits or standing architectural features. As such, any 

processes that disturb the soil/sediment matrices of an archaeological site (including 

erosion) or increase the intensity and probability of catastrophic wildfire, adversely 

impact the site’s eligibility.

Common to All Action Alternatives

Direct and Indirect Effects

Within the Briggs Spring project area there are 25 known cultural resources determined 

eligible for listing on the National Register of Historic Places. The Forest Service 

developed site specific recommendations for these eligible cultural resources to avoid 

adverse effects from all action alternatives. These recommendations were submitted 

within the Section 106 report for the Briggs Spring project. The South Dakota SHPO 

concurs with these determinations. Furthermore, SHPO concurs with a finding of No 
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Adverse Effect, provided that these cultural resources are avoided by all ground 

disturbing activities during project implementation. If during the course of any ground 

disturbance related to this project, any bones, artifacts, foundations, or other indications 

of past human occupation of the area are uncovered, all operations will cease within a 

100-meter radius of the site location and a district archaeologist notified immediately. 

The SHPO and regional Tribal Historic Preservation Offices (THPOs) will be notified of 

the discovery and provided an opportunity to comment. Any cultural resources located 

during project implementation will be protected based on the recommendations of the 

district archaeologist and the SHPO.

Adherence to the design criteria would result in no direct or indirect effects to cultural 

resources from Alternative 2.

Cumulative Effects

The nature of the cultural resources and the foreseeable actions in the project area dictate 

that the cumulative effects area should match the physical site boundaries. Therefore, the 

cumulative effects area is defined as the known archaeological sites in the identified burn, 

thinning units, and access roads to and from the project area. The timing limit for the 

cumulative effects analysis is 20 years; ten years prior to present and ten years in the 

future.

No adverse effects are expected to occur as a result of any alternative provided that the 

design criteria are followed and the site specific recommendations are implemented. 

Because there will be no direct or indirect effect to cultural resources, there will be no 

cumulative effects associated with the Briggs Spring project.

Scenery

Affected Environment

Existing Scenic Integrity represents the current status of a landscape. It is determined 

on the basis of visual changes that detract from the scenic quality of the area. Direct 

human alterations may be included if they have become accepted over time as positive 

landscape character values. Existing scenic integrity is the current visual state, which is 

measured in degrees of deviation from the natural appearance of the landscape character 

type. These ratings give an indication of the present level of visual quality and visual 

evidence of management activities. The frame of reference for measuring achievement of 

scenic integrity levels is the valued attributes of the existing landscape character unit 

being viewed. In natural or natural appearing character, this is limited to natural or 

natural appearing vegetative patterns, features of water and rock, and landforms.

The Briggs Spring project area is noted for conifer stands in gently rolling terrain, 

meadows that follow streams and intermittent streams, and pockets of aspen and other 

hardwood trees. Forested areas are predominantly populated by ponderosa pine 

communities, but spruce communities can be found in most streams and wet areas. 

Water features are limited to low-flow streams. Apparent human alterations in the form 

of roads, have generally been accepted over time as part of the positive cultural landscape 
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character attributes – when they do not dominate the landscape in appearance or quantity, 

and are limited around non-motorized areas or recreation facilities. Vegetation 

alterations in the form of fuel treatments (small trees removed), noncommercial thinning, 

commercial thinning, seed tree cuts, and overstory removals are scattered, and only 

readily apparent when adjacent to a main road. Pine and spruce stands are expanding into 

meadows and hardwood stands.

There are isolated foreground views along Sensitivity Level 2 Roads (County and Major 

Forest Development Roads & Trails) where past vegetative treatments are evident; 

however in the middleground views (away from the main roads) vegetative treatments are 

not readily apparent due to the relatively flat terrain. Mountain pine beetle activity is 

evident in this area in the form of red-needle trees that were recently killed; however it is 

generally isolated in small pockets. Trees that are under attack have clumps of pitch that 

are evident on the trunk, when viewed up close, and the color of the needles is a lighter 

hue which is generally not apparent from a distance. Unless an individual walks through 

the forest looking at each tree, the scope of the mountain pine beetle spread is not 

apparent.

In the surrounding landscape, outside this planning area, past vegetation treatments are 

evident in the foreground and middleground views. Areas to the west are generally 

natural appearing. Vegetation management has been very active in the north & east, and 

these areas tend to have a more managed appearance. The Jasper Fire occurred in the 

summer of 2000 (approximately 83,510 acres), burning through the landscape south of 

the planning area and killing the majority of trees. Today the Jasper Fire area is a large 

open grass area. As a result of wildfire and vegetation management, the areas 

surrounding the planning area have a variety of appearances – resulting in a Moderate 

Existing Scenic Integrity condition.

Scenic Integrity Objectives (SIOs) are management objectives for forest scenic resources. 

Within the Briggs Spring project area there is 0% High SIO, 31% Moderate SIO, and 

69% Low SIO.

Environmental Consequences

Alternative 1 – No Action

There would be no project activities implemented under this alternative. 

Direct and Indirect Effects

Existing conditions and natural processes of trees growing and regenerating would

continue. The existing MPB activity would be expected to continue for several years, 

pockets of MPB killed trees could expand in size and spread. 

Common to All Action Alternatives

Direct and Indirect Effects

Vegetative treatments would result in the removal of trees within a stand. How well 

these treatments blend into the characteristic landscape, and meet the SIO, is based upon 

the slope, aspect, and vegetation remaining on the site. Thinning trees to an even spacing 

can result in a managed, un-natural appearance.
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This project maintains a large tree component across the majority of the planning area, 

with only a few units removing the entire overstory. The result would be a multi-storied, 

or multi-aged, forest – although with a reduced density of trees. This lower population of 

trees would reduce the susceptibility to mortality from wildfire and MPB, and a forested 

appearance in the long term. By treating these areas through the action alternatives the 

visually desirable large tree characteristics (SS 4A) - though widely spaced, would have a 

greater potential to remain as a feature in the planning area, more so than the no action 

alternative. In addition, the vegetation treatments would enhance the large tree 

component, when present, by reducing competition for nutrients around them. A variety 

of vegetation structure would be maintained – both large & small trees (Form, Line & 

Texture), and an increase in hardwoods, grasses and shrubs (Color, Texture, Seasonal 

Variety) within the planning area would result. Overall, the variety of vegetation that 

would be enhanced at the stand level would be a very positive feature from a scenery 

standpoint.

Impacts to the scenery resource would also occur from or be influenced by related actions 

such as roads, prescribed burning, slash treatments, logging systems, and landing 

locations. These elements can impact the overall scenery quality by changing the form, 

color, and texture of landscapes as viewed from foreground, middleground, and 

background views.

Alternative 2 – Proposed Alternative

Direct and Indirect Effects

Alternative 2 would modify the vegetation across the landscape - this management 

activity would occur quickly over the span of a few years. The variety of treatments 

would also create a variety of textural patterns and improve opportunities to view 

hardwoods and wildlife. Overstory removal treatments generally do not meet the High or 

Moderate SIO. However, due to the limited size and scattered location of these units in 

this landscape, the rolling hills and ridges would reduce the visibility of these types of 

treatments, so they would be less evident in this landscape. Restoration treatments to 

increase hardwood sprouting, and thinning treatments to decrease potential for MPB to 

attack forest stands, would meet the assigned SIO. These various treatments would move 

the vegetation in this landscape to being less dense and more open, closer to conditions 

that emulate the effect of natural fire interval in this ecosystem. Hardwoods and 

meadows would be more evident and provide seasonal color and textural variety in the 

landscape, than currently exists. The reduction in trees, slash, and small trees, would 

open views into the forest, and returning to an appearance that could be similar to a 15 to 

30 year fire interval that created the ‘natural appearance’ for this ecosystem. This 

alternative would meet the assigned SIOs for this planning area.

“New Moon” OHV Recreation Campground Facility – The proposed campground 

location is in an area with a Low SIO assigned under the Forest Plan. Views toward the 

campground from private land (0.1 miles southwest) would be partially-screened by 

vegetation immediately surrounding the campground. Campground facilities would be 

visible, though color and size of the buildings should help them blend into the landscape 

and vegetation. Other facility features such as tables, bulletin board, and fire rings would 

be visible from the surrounding area, though less evident due to size, distance, color, and 

the position of the campground on higher flat terrain. Recreation vehicles in the 
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campground would be the most visible elements in the landscape. The trailhead would 

be closest to the private land. A bulletin board in this location would be evident, though 

vehicles parked here would be the most visible. Construction of a limited capacity, and 

lower Development Level, campground, and a trailhead, in this location would meet the 

assigned LOW SIO.

Alternative 3

Direct and Indirect Effects

The effects of this alternative are similar to Alternative 2 except in two ways. 

First, the group shelterwood treatment would occur on essentially double the acres as in 

Alternative 2. This increase in areas treated with this prescription would reduce the acres 

of dense vegetation, moving the vegetation toward more open forest stands. Hardwoods 

would be more evident across the landscape, providing a contrast in color throughout the 

year, particularly adjacent to meadows and in drainages. Rock formations will be readily 

apparent as well. The diversity of vegetation structure, created for wildlife, will be 

visible in all distance zones. This change in treatment prescriptions would result in less 

areas of dense vegetation.

Alternative 3 would modify the vegetation across the landscape - this management 

activity would occur at a similar pace as Alternative 2, though over a wider area. Aside 

from the increase in group shelterwood treatments, the effects would be the same as 

Alternative 2. The reduction in trees, slash, and small trees, would open views into the 

forest, and returning to an appearance that could be similar to a 15 to 30 year fire interval 

that created the ‘natural appearance’ for this ecosystem, but on a larger area than 

Alternative 2. This alternative would meet the assigned SIOs for this planning area.

Cumulative Effects

The boundary on the ground for analyzing cumulative effects is primarily that of the 

planning area. This identified area is the landscape that is evident in the foreground and 

middle ground from the main travel routes, with particular attention to recreation 

facilities.

The time boundary for this analysis extends from 1980 (when the start of recent 

vegetation management activities took place) to 2050 [completion of management 

activities (2020), followed by 5 years for pine seedlings to become established, and 

approximately 25 years for trees to grow up and visually ‘fill’ open areas]. This time 

period includes known management activities, and activities that are planned but have yet 

to be accomplished.

Fire suppression over the past century has played a role in the increased density of the 

vegetation on the forest. Likewise, much of the Forest was pre-commercially thinned by 

the Civilian Conservation Corp in the 1930’s and 1940s, however we do not know if that 

effort included any or all of this planning area. The areas were these treatments occurred 

do not standout, but blend in with the surrounding vegetation.

Although the planning area is relatively free of fire scars, a large wildfire occurred along 

the southern boundary of the planning area. The Jasper Fire (2000) burned intensely, 

killing the majority of all trees within the fire perimeter. As a result, ten years later, the 
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area is a large grass covered area, approximately 85,000 acres in size. The large size has 

limited seed dispersion from ponderosa pine trees around the perimeter of the fire.

Past vegetation treatments are not readily apparent on the ground, as trees have grown up, 

the topography is gently rolling, and treatments areas did not form ‘hard edges’ between 

treated and non-treated locations. The action alternatives would treat the vegetation in a 

manner that would be apparent to most observers; however those treatments should not 

dominate the landscape. In areas that are treated, it will take approximately 5-15 years to 

get new trees and shrubs established in the understory and move these treated areas to the 

point where they start to appear different – moving toward a more natural appearance.

Alternative 2 – Proposed Action

Under this alternative, trees of all sizes would be selected for harvest. The resulting 

appearance of vegetation treatments would change little for the first 10 years after the 

treatments are completed. Any treatments would result in fewer trees across the 

landscape, reducing the risk of MPB infestation and reducing fire hazard.

Effects of MPB activity are most evident when trees have been killed and the green

needles have turned red in color. As the trees decay and fall, openings would be created. 

These openings would change the character from a uniform appearing landscape 

‘carpeted’ with pine trees to a complex matrix of openings, decaying dead trees, residual 

pine trees, and expanding areas of hardwood trees.

Hardwoods would be more evident as well. Panoramic views are limited within this 

planning area due to the gently rolling nature of the topography. Roads accessing 

landings would be evident until the road template no longer exists. The greatest visual 

effects in the immediate foreground would be from roads and landings, as they will take 

the longest time to heal.

The variety of treatments would produce a natural appearing forest, but one that has 

fewer trees, as if fire had continued to play its natural room all along. Due to the insect 

activity and fuel treatments adjacent to private land, the current view of the forest from 

these locations would likely change from their current condition. Views of these 

treatments would be limited from Sensitivity Level 1 or 2 roads outside the planning area, 

due to the topography surrounding the planning area.

Alternative 2 would modify the vegetation across the landscape. Management activities 

would be more evident. The variety of treatments would create a variety of vegetation 

patterns, colors, and improve opportunities to view hardwoods and wildlife. Restoration 

treatments to increase hardwoods and meadows may take time to appear natural, but long 

term they would improve the visual diversity in the landscape. Prescribed burning, piling 

and burning, would reduce fuel levels to natural levels, which is a positive ecological & 

scenic characteristic of frequent fires in a pine ecosystem. Prescribed burning treatments 

would meet a Moderate to High Scenic Integrity one year after being completed.

Alternative 3

Under this alternative, cumulative effects are similar to Alternative 2, with the differences 

noted below.
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Alternative 3 management activities would modify the vegetation across the landscape on 

a larger area as noted in the effects section. Treatments should meet a Moderate to High 

Scenic Integrity one year after being completed.

Transportation

Affected Environment

The existing transportation system was inventoried in the summer of 2007 and 2008, and 

reviewed in 2010. During the 2010 review additional road condition surveys were 

conducted to capture any change in road conditions. The existing transportation system 

was assessed for maintenance needs and for roads that could be needed in order to 

support commercial timber harvest and other resource needs in the project area. 

Approximately 12.8 miles of National Forest System Road within the Briggs Spring 

project area were designated for Off Highway Vehicle (OHV) trail system as indicated in 

the March 22, 2010 Record of Decision and later depicted on the December 1, 2010 

Motor Vehicle Use Map.

To summarize, the transportation system within the Briggs Spring project area is 

comprised of approximately 121.7 miles of existing roads and OHV trails. The 

breakdown of the existing transportation system is listed below in Table 33.

Table 33. Existing roads and OHV trails within the Briggs Spring project area

Roads and Trails by System

System Classification Length in Miles Road Density 

(Miles/Square Mile)

National Forest System Roads 108.9 2.8

OHV Trail System 12.8 0.1

 Total 121.7 2.9

The Briggs Spring planning area is located in a snowmobile use area which affects the 

seasonal availability of some roads. Additionally, past management decisions have closed 

roads on a yearlong basis for resource protection. The travel management designation of 

the National Forest System Roads (FSRs) within the project area and road density (miles 

of road per square mile) is depicted in Table 34. Likewise, Table 35 indicates OHV trail 

miles and trail density. Maps 9-11 in Appendix A show transportation for Alternatives 1-

3. 
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Table 34. Travel Management – NFSRs in miles and road density

Travel Management Designation Length in 

Miles

Road Density 

(Miles/Square 

Mile)

Roads Closed to All, Yearlong 7.9 0.2

Roads Open to All, Seasonal (May 15 to Dec. 15) 11.2 0.3

Roads Open to All, Yearlong 14.3 0.4

Roads Open to Highway Legal Vehicles Only, 

Seasonal (May 15 to Dec 15) 5 0.1

Roads Open to Highway Legal Vehicles Only, 

Yearlong 70.4 1.9

Total 108.9 2.9

There may be further change in the travel management of roads in the next few years as 

the Forest implements the Travel Management Plan for the Black Hills National Forest.

Table 35. Travel Management – National Forest System (NFS) OHV trails in miles 

and trail density 

Travel Management Designation Length 

in Miles

OHV Trail Density 

(Miles/Square Mile)

Trails Open to All Vehicles, Yearlong 4.6 0.1

Trails Open to All Vehicles, Seasonal 

(May 15 to Dec. 15) 8.2 0.2

Total 12.8 0.3

Environmental Consequences

Alternative 1 – No Action

There would be no project activities implemented under this alternative. 

Direct and Indirect Effects

Under Alternative 1 there would be no effects from a proposed action. There would be no 

change in the transportation system due to a proposed action. Scheduled annual and grid 

maintenance would continue as it has in the past. Road densities would remain the same 

under this alternative.

Common to All Action Alternatives

Direct and Indirect Effects

The action alternatives propose additional maintenance, reconstruction, route conversion 

(0.8 miles). Potential direct adverse effects from these proposed activities would be short 

term vegetation loss, vegetation removal, soil disturbance and compaction, an increase of 

mixed traffic and traffic delays during project implementation. Short term increases of 

noise and dust would occur.

Within the Briggs Spring project area the majority of the NFSRs would require minimum 

maintenance or reconstruction to facilitate the extraction of timber and other resource 

access.
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Project implementation would be accomplished by utilizing a majority of the existing 

NFSRs, reconstructing selected existing NFSRs to the standard in which they were 

designed, and reclassifying selected unauthorized roads for conversion to system roads. 

Road reconstruction may include but is not limited to structural improvements, such as 

rolling dips or culverts, surface reconditioning or realignment. Select system roads 

would be closed to protect and prevent damage to resources. Conversion of unauthorized 

roads to NFSRs may require the reconstruction the existing road template include but not 

limited to structural improvements, such as, rolling dips and culverts, aggregate 

placement or centerline adjustments. Temporary roads would be closed after use as part 

of the timber operations unless identified as motorized routes in the Black Hills National 

Forest (BHNF) Travel Management Plan.

Use of the transportation system would vary somewhat between the action alternatives. 

Reconstruction activity would bring road standards up to the minimum necessary to 

accommodate commercial timber hauling, while protecting soil and water resources. In a 

similar manner, reconstruction of existing unauthorized roads (NFSR conversion) would 

also bring roads up to minimum road standards necessary for commercial haul while 

protecting soil and water resources. All temporary roads may also be used to access 

portions of proposed treatments units. All temporary roads would be closed or 

decommissioned during post resource management activities. 

Roads utilized under the action alternatives would be reconstructed, constructed and 

maintained in accordance to the Engineering Design Guidelines and Best Management 

Practices Compliance. 

Alternative 2 – Proposed Action

Direct and Indirect Effects

The transportation system under Alternative 2 proposes to maintain 75.9 miles, 

reconstruct 31.9 miles and add 0.8 miles of existing unauthorized road to National Forest 

System Roads (NFSR). The 0.8 miles of converted road would be closed to public use 

after treatment activities, no change to open road density would occur. All unneeded 

unauthorized roads, approximately 35.3 miles, have been administratively closed to 

public traffic under the Black Hills National Forest Travel Management decision, as 

shown on the Motor Vehicle Use Map (MVUM). It should be noted that many of these 

unauthorized roads may be used for temporary access during timber harvest operations. 

No new road construction would occur under this alternative.

Alternative 3

Direct and Indirect Effects

The transportation system under Alternative 3 proposes to maintain 77.3 miles and to 

reconstruct 35.3 miles of National Forest System Road. Like Alternative 2, Alternative 3 

would convert 0.8 miles of unauthorized road to National Forest System Road which 

would be closed following treatment activities, no change to open road density would 

occur. All unneeded unauthorized roads, approximately 35.3 miles, have been 

administratively closed to public traffic under the Black Hills National Forest Travel 

Management decision, as shown on the Motor Vehicle Use Map (MVUM). It should be 

noted that many of these unauthorized roads may be used for temporary access during 

timber harvest operations. No new road construction would occur under this alternative.
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Cumulative Effects

Alternative 1 – No Action

Alternative 1 would have no direct or indirect effects, therefore no cumulative effects 

would occur. 

Common to All Action Alternatives

The action alternatives would not increase open road density for the project area. 

Therefore, no negative cumulative effects to open road density would occur.

These activities along with the Briggs Spring project have the potential for the following 

cumulative effects on the transportation system:

• Annual maintenance on Maintenance Level 3 and 4 roads would have a positive 

effect on the transportation system. These routes would only require minimal 

maintenance to support timber harvest activities barring no significant or 

catastrophic weather events occur. Grid maintenance activities in 2008-2009 

would have most roads in a state that would require minimal maintenance to 

support timber harvest activities.

Road maintenance, reconstruction, and construction within the Briggs Spring project, 

combined with annual and grid maintenance activities, would have cumulative effects on 

ground disturbance, vegetation loss, dust/noise increases and sediment movement for 

short durations and in scattered areas within the analysis area.

Recreation

Affected Environment

Recreation is an approved use in this management area and this area is designated as a 

Roaded Natural area in the Recreation Opportunity Spectrum (ROS). Numerous open 

roads provide commercial access and roaded recreation opportunities, while closed roads 

provide non-motorized recreation opportunities. Activities such as hunting, hiking, and 

biking occur on roads closed to motorized vehicle traffic. Some roads are open yearround while others are open seasonally; some motorized vehicle use restrictions may be 

for management area purposes.

The Briggs Spring project area is ideal for recreational activities on the Black Hills 

National Forest. It provides mostly un-fragmented and undeveloped public lands for 

recreating in a forested setting. There are no paved roads, no commanding new custom 

homes or sub-divisions, and very limited commercial services. Terrain in the interior of 

the project area is a limestone plateau, which is flat or rolling and park-like with broad 

open meadows interspersed with aspen and pine stands. There are few inspiring rock 

formations but the outer edges of the area are steep and mountainous mainly to the north 

and east with steep limestone canyons that drop off to the drier south. The northern twothirds of the project area experiences heavy winter snowfall. This makes it excellent for 

winter recreation but limits passenger vehicle access and may limit timber harvest 

activities during the winter season. This area offers the best consistent conditions for a 
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groomed snowmobile trail system on the district. It is relatively easy to experience a 

sense of solitude in this primarily motorized area. There is evidence of historic and 

continuing management actions, mainly timber harvesting and cattle grazing, which 

blend with the natural setting.

Primary recreational use of this area is dispersed in nature and includes hunting, 

horseback riding, OHV (off highway vehicle) use (mainly ATV riding and 

snowmobiling) and camping, primarily associated with a vehicle.

Developed Recreation

There is one developed recreation campground in the project area, Redbank Spring 

Campground. Redbank Spring Campground is a fee-required Forest Service operated 

campground. It consists of four campsites and offers two vault toilets, campfire rings and 

picnic tables. There is no potable water at the Redbank Spring Campground. The 

campground is considered to be in a quality location being at the end of the campground 

service road, FSR 294.2A, and surrounded by open native grass fields with scattered 

timber stands.

The Forest Service operated Moon Campground, which was located on the western 

boundary of the project area, was decommissioned in October 2008 and the area 

rehabilitated back to a forested setting. This campground had three campsites with picnic 

tables, campfire rings, and a vault toilet. It was decommissioned as part of a Forest 

Service Recreation Facility Analysis (RFA) planning effort. The RFA determined which 

recreation facilities on a forest wide basis were most important to maintain or improve to 

meet the needs of current and future users of the National Forest as well as which ones to 

decommission or modify. Moon Campground was in need of replacement of all 

improvements due to their poor condition. Considering its size at three sites, low volume 

and occupancy, its proximity adjacent to a private residence, and a busy timber haul road 

(FSR 117), it was decided to decommission the campground.

The RFA also recommended that Redbank Spring Campground be modified to provide 

increased camping capacity to accommodate campers from the closed Moon 

Campground. Recommended improvements are to be designed for OHV users who 

would be overnight camping. Design of an OHV specialized campground includes group 

camping sites, roads, pull-throughs, and camping spurs designed for large radius turn 

vehicles with trailers, information kiosk(s) for posting maps and tread lightly OHV 

education information, and a day use equipment trailer parking area.

From fee receipts it has been determined that Redbank Spring Campground has a 40% 

occupancy rate, considered moderate, during the main Memorial Day-Labor Day season 

of operation. Fall season of use from Labor Day to the end of October primarily serves 

hunters and is more minimal. The majority of use is from Wyoming residents. This 

campground is “off the beaten path” compared to most Black Hills National Forest 

campgrounds and is accessed only by many miles of gravel roads. It provides more of a 

roaded-natural setting for camping due to its remoteness. From Forest Service personnel 

observations, many campers are also hauling OHV’s on trailers to ride on the Forest. A 

two or three person size group of OHV campers is common and they rent most of the 

campsites typically on weekends. The Forest Service added a two trailer overflow 

parking area in the campground in 2007 to help accommodate this use. Deep winter 
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snows typically preclude any early spring or late fall campground use and the access 

roads are closed to wheeled vehicle travel (insert dates closed) for use as groomed 

snowmobile trails.

Dispersed Recreation Use and Trails

The project area is popular with fall big game hunters and fall/spring turkey hunters. On 

the weekends, hunters typically camp overnight at Redbank Spring Campground or along 

roadsides. Approximately 50% of the time spring turkey hunting is not possible in the 

project area due to late season deep snows. From personal observations of the project 

area there are usually 2-3 weekend horse camp outings each summer. These are small 2 

to 4 person horse riding groups, camping beside the road, who ride the roads during the 

daytime. Mountain bike riders have been observed riding during the day on the multitude 

of roads within the Jasper Fire burn area, in the project area, 2-3 times per year. It 

appears they are using one car to begin their day ride to travel in one direction and then 

use another car at the end of the ride to travel back to the first car. Open fires are banned 

year-round throughout the Black Hills National Forest, unless in an approved and 

permitted campfire ring. Dispersed camping sites should not include campfires and 

associated fire scars, trash and impacted soils and vegetation.

The project area includes OHV trails and snowmobile trails. Table 36 shows 

approximate mileages and type of system trails in the project area. The snowmobile trail 

system is operational and closed by regulation to wheeled traffic from December 15th to 

March 30th annually. The OHV trails in the project area are either open to vehicles less 

than 62 inches in width or open to full size vehicle widths. There are no non-motorized 

system trails in the project area.

Table 36. Approximate mileages of system trails in the 

project area

OHV >62” Width OHV Full Size Snowmobile Trail

6.2 mi. 5.0 mi. 13.7 mi.

Overall, the Briggs Spring project area is part of an important dispersed recreation area in 

all seasons, whether it is summer OHV use, fall big game hunting, winter snowmobiling, 

or spring turkey hunting. Some developed recreation camping occurs at the Redbank 

Spring Campground to a moderate level of use. The well-roaded nature of the area lends 

itself to recreation in a motorized setting. The limestone canyons, located in the southern 

section of the project area, offer a higher degree of solitude and quality for non-motorized 

recreational pursuits not found in the rest of the Briggs Spring project area.

Recreation Special Uses

According to the Forest Service Special Use Data System (SUDS) there are no outfitter 

guiding permits issued for the project area. There was a group recreation event permit 

issued in 2006 within the project area for a weekend-long dispersed group camping and 

horse riding event.
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Environmental Consequences

Alternative 1 – No Action

Direct and Indirect Effects

The No Action alternative would have no effect on recreation resources in the project 

area. No changes to existing developed sites or dispersed recreation activities would 

occur.

Common to All Action Alternatives

Direct and Indirect Effects

Short term direct effects (3-5 year time period) would be attributable to increased noise, 

smoke, dust and logging traffic from nearby harvest and post-harvest activities. These 

effects would occur to motorized and snowmobile trail users, dispersed recreation users, 

and developed campground users. Prescribed burning and winter slash pile burning 

would create smoke in the project area which may cause temporary adverse effects to 

system trail and campground users. Increased noise, smoke and dust from project 

activities may temporarily decrease the quality of a recreational users’ experience.

Redbank Spring Campground would not be open to the public when vegetation activities 

would be occurring within the site itself. Design criteria would be in place to restrict 

harvest activities during the full operation period of the facility, which is May 15th

through October 15th annually. Short duration smoke and noise from post-sale activities 

such as pile burning and prescribed fire burning may decrease the quality of a camping 

experience. However burning activities normally would occur outside of the full 

operation period of the campground.

The dispersed activity of driving for pleasure on forest roads would be affected 

particularly by increased dust and traffic from logging traffic.

Sections of motorized trails and snowmobile trails may be temporarily closed to the 

public during timber harvesting and hauling for safety reasons. It would be possible that 

some trails may be closed temporarily with no alternative trail routes except by utilizing 

system roads which would require OHV drivers to have a state driver license and 

registration. Snowmobile trail users may have some disruption to system trails. This 

could include increased safety signing due to harvest and post-harvest vegetation 

activities that would occur in the winter. Affected trails would need to be closed and 

brought back to trail standards during proposed post-harvest operations.

These short term effects could occur during all seasons of the year with the likelihood of 

effecting the highest dispersed recreation use period and activity of fall big game hunting.

Long term (beyond a five year time period) direct effects concern visual changes of 

recreation sites and adjoining areas to campground users (see Scenery section). The 

appearance of the area would be from a denser forested setting to a more open one until 

the vegetation regenerates. This more open forested appearance would create more 

opportunities for recreational wildlife viewing.

The Redbank Spring Campground would be expected to have less hazardous tree 

maintenance work in the long term as thinning would remove high risk trees and reduce 

the chance of beetle infestation of the stand.
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Snowmobile system trails may experience more drifting of snow from a more open forest 

in windy areas; however the trails may also experience increased snow depth from a more 

open forest canopy. Trails, overall, would benefit from harvest activities because 

typically harvested stands would result in healthier trees and less high-risk trees, resulting 

in fewer dead trees falling across trails, ultimately requiring less maintenance and 

increased user safety in the long term.

Alternative 2 – Proposed Action

Direct and Indirect Effects

Short term direct effects to action Alternative 2 would include short duration dust, noise 

and other disturbances to the public and adjacent private land owners of the area 

identified for new construction of the “New Moon” OHV campground.

Long term indirect effects to this alternative would be increased recreation traffic and 

noise to adjacent private landowners and forest visitors caused by the presence of a 

developed recreation campground at the identified location. Other effects would include 

an enhanced campground experience by visitors due to the modernized and disabled 

person accessible facilities. This would include a training lot and new furnishings such 

as picnic tables, fire rings, and new vault toilets designed for wheelchair access. Traffic 

flow and parking would be designed for safety and ease of visitors with features such as 

pull-through design camp spurs and larger turning radius corner turns.

Alternative 3

Direct and Indirect Effects

There would be no new recreation facilities created, therefore no change to existing 

recreation opportunities. OHV campers will continue to use existing campgrounds; 

Redbank Spring campground is within the project area and Beaver Creek and Ditch 

Creek campgrounds which are near by the project area. 

Cumulative Effects

The cumulative impact area for this analysis is the Briggs Spring project area. The time 

boundary for the cumulative effects analysis is 10 years in the past, present, and 10 years 

to the future. Past, present and future activities within the Briggs Spring project area 

boundary include timber harvests, grazing, road maintenance, OHV trail maintenance, 

noxious weed control, wildlife habitat improvement projects, and recreation use.

The No Action alternative would have no cumulative effect on recreation because it does 

not have direct or indirect effects.

Alternative 2 would represent a small developed recreation program for the project area 

with negligible negative effects of increased noise from recreation connected traffic. 

Both action alternatives would have minimal direct and indirect effects on recreation, 

some positive, some negative, depending upon the specific use being considered. There 

would be no adverse long-term cumulative effects to the recreation resource as a result of 

implementing any of the alternatives, including the no action.
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Soils and Water Resources

Affected Environment

Soils

The objective of soil resource management is to improve or maintain long-term soil 

productivity. Soil productivity is the inherent capacity of a soil to support the growth of 

specified plants, plant communities, or a sequence of plant communities. In order to 

improve or maintain long-term soil productivity, soil disturbance should be minimal and 

adequate measures taken to protect the surface soil, keep the soil in place, reduce 

compaction, and maintain nutrient and organic matter levels (USDA Forest Service, 

1996). 

There are 12 soil map units within the Briggs Spring project area. Five soil map units 

(with symbols, JhD, ReC, SybC, SycE, and VcE) comprise 95% of the project area and 

the other seven soil map units occupy 5% or less (see Table 37 below and Map 8 in 

Appendix A). 

Table 37. Soil Map Units in the Briggs Spring project area and respective percentage of the 

project area 

Map Unit 

Symbol(s) Map Unit Name

Acres 

in 

Project

Percent 

of 

Project

BsB Bullflat-Cordeston silt loams, 2 to 9 percent slopes 491 2%

CkC Citadel-Vanocker complex, 2 to 12 percent slopes 179 0.6%

JhD Judy-Heath-Paunsaugunt variant complex, 2 to 25 percent 

l

2,531 9%

PbD Paunsaugunt-Gurney complex, 2 to 15 percent slopes 89 0.3%

ReC Redbird-Heath silt loams, 2 to 9 percent slopes 1,666 6%

SyaC Stovho silt loam, 2 to 15 percent slopes 306 1%

SybC Stovho-Lail-Trebor complex, 2 to 12 percent slopes 11,725 41%

SycE Stovho-Trebor complex, 10 to 40 percent slopes 9,587 33%

TuG Trebor-Rock outcrop complex, 40 to 80 percent slopes 112 0.4%

VcE Vanocker-Citadel complex, 10 to 40 percent slopes 1,840 6%

VkE Vanocker-Lakoa complex, 10 to 40 percent slopes 174 0.6%

VoG Vanocker-Sawdust-Rock outcrop complex, 40 to 80 percent 

l

225 1%

Soil Health Assessment

Results of field inspections conducted within the Briggs Spring project area during 2007-

2008 indicate that in some cases there were residual impacts from past logging activities 

in the form of landings, compression tracks, and some minor compaction in highlytraveled areas (skid trails and landing areas). These were generally associated with more 

recent management activities, while sites with management that occurred some time ago 

exhibited few if any residual impacts. However, no previously disturbed sites within the 
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Briggs Spring project area were found to be degraded and existing soil conditions 

indicate overall soil health, productivity, and function.

Soil Erosion

Soil erosion is defined as the movement of individual soil particles by a force, and is 

initiated by the planar removal of material from the soil surface (sheet erosion) or by 

concentrated removal of material in a downslope direction (rill erosion). Surface erosion 

is a function of four factors: (1) susceptibility of the soil to detachment; (2) magnitude of 

external forces (raindrop impact or overland flow); (3) the amount of protection available 

by material that reduces the magnitude of the external force (soil cover); and (4) the 

management of the soil that makes it less susceptible to erosion (Foster, 1982; Megahan, 

1986).

Although erosion is a natural process occurring on the landscape, management activities 

can increase the amount of material transported offsite, as well as accelerate the rate at 

which it is removed. Severe erosion can impair long-term soil productivity if soils are 

heavily disturbed on shallow or highly erodible soils. Erosion potential is the relative 

susceptibility to sheet and rill erosion when surface cover is completely removed from 

the site. Ground vegetation, downed debris, root masses, and duff help stabilize soil. 

When soil is disturbed by management practices, it can be exposed to runoff. When this 

happens, sheet and rill erosion occur. Erosion hazard is therefore an indication of the risk 

of soil loss associated with disturbance. Soil erosion is discussed in terms of rutting and 

displacement, erosion hazard for activities occurring off roads and trails, soil suitability 

for natural surface roads and trails, erosion hazard associated with natural surface roads 

and trails, and windthrow potential.

Soil Rutting Hazard and Displacement

Concentration of runoff, accelerated erosion, sediment delivery to surface waters, and 

damage to roads and trails can result from soil rutting. Soil rutting hazard ratings are an 

indication of how easily surface ruts can form through the operation of forestland 

equipment (USDA NRCS, 2009). Nearly all of the soils within the Briggs Spring project 

area are rated as “severe” for rutting potential and thus are very easily rutted.

Soil displacement and puddling (soil deformation and compaction) may occur 

simultaneously with rutting. Displacement can occur when the productive, upper layer of 

soil is removed or mixed with underlying, less productive layers during harvest or site 

preparation. The most common causes of displacement are side-casting of soils during 

road or fire-line construction, skidding logs, and landing construction and rehabilitation.

Soil Erosion Hazard (Off-Road, Off-Trail)

Erosion hazard is an indication of the risk of soil loss in a managed forest stand. The 

ratings in this interpretation indicate the hazard of soil loss from off-road and off-trail 

disturbance activities that remove most or all of the protective ground cover and expose 

the soil surface (USDA NRCS, 2009). Approximately 9,900 acres (34%) have soils rated 

as “severe” for erosion potential from off-road and off-trail disturbances and indicates 

that intensive management or special equipment and methods are needed to prevent 

excessive soil loss (Table 38). These areas correspond to hill side slopes throughout the 

project area. Approximately 2,000 acres (7%) are rated as “moderate” for erosion 

potential from off-road and off-trail disturbances. This indicates that the expected soil 
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122

loss is small and generally, no special measures are needed. These areas correspond to 

the Virkula soils found in the southern portion of the project. The remaining area (16,990 

acres or 59%) is rated as “slight” and corresponds to stringer drainage bottoms and broad, 

flat ridgetops.

Table 38. Soil Map Units in the Briggs Spring project with elevated risk of 

erosion

Erosion 

Rating Soil Map Units included in rating

Acres 

in 

Project

Percent 

of 

Project

Very 

Severe None None None

Severe

SycE – Stovo-Trebor complex

TuG – Trebor-Rock outcrop complex

VoG – Vanocker-Sawdust-Rock outcrop

9,920 34%

Moderate VcE – Vanocker-Citadel complex

VkE – Vanocker-Lakoa complex 2,015 7%

Slight

BsB – Bullflat-Cordeston

CkC – Citadel-Vanocker

JhD – Judy-Heath-Paunsaugunt variant complex

PbD – Paunsaugunt-Gurney complex

ReC – Redbird-Heath

SyaC – Stovho

SybC – Stovho-Lail-Trebor

16,990 59%

Three soil map units within the Briggs Spring project area are prone to wind throw. 

These include the Stovho-Lail-Trebor (SybC), Stovho-Trebor (SycE), and Trebor-Rock 

outcrop (TuG) map units, which total 21,424 acres or 74% of the project area. These 

units are located throughout the project area, especially on exposed ridgelines.

Soil Heating and Damage by Fire

Most soils within the Briggs Spring Project Area are rated low for potential for damage 

by fire with the exception of some isolated segments in the vicinity of White Spring and 

the upper end of Redbird Canyon, and the Virkula soils found in the southern portion of 

the project.

Only 408 acres of the 4,740 acres of previously burned soils from the Jasper Fire within 

the Briggs Spring project were mapped as high soil burn severity; 2,529 as moderate; and 

1,802 as low within the previously burned portions of the project.

Current fire research points to the fact that soils tend to recover within 3-5 years 

following wildfires as vegetation is established (Neary et al., 2005). These particular 

areas have had approximately 10 years to recover, thus any fire-induced water repellency 

has long-since dissipated with the annual freeze-thaw cycles and effective ground cover 

has increased significantly.
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Soil Compaction

Soil compaction results from a packing together of soil particles due to increased pressure 

on the soil surface, as by equipment or large animals. Compaction can occur on all soils 

particularly if soil moisture conditions are too wet; if excessive equipment passes are 

made; or exceptionally heavy equipment is used (i.e. pressure applied per unit area). 

Compaction impairs water infiltration, root growth, and soil biota, all of which contribute 

to increased runoff and erosion. Compaction also affects plant production, plant 

composition, and organisms living within the soil – all of which contribute to overall site 

productivity. There are six soil map units in the project area which are more susceptible 

to compaction that the other soil map units. These six soil map units (with symbols CkC, 

SyaC, SybC, SycE, VcE, and Vke) comprise approximately 82% of the project area. 

Forest Plan monitoring of soil compaction has occurred across the Black Hills since 1999 

(USDA Forest Service, 2007a). There is evidence that Black Hills soils can compact 

when timber harvest occurs on moist or wet soils, and that harvesting when soils are dry 

can prevent or limit compaction. 

Organic Matter and Nutrients

In the Briggs Spring project area there are three soil map units (with symbols JhD, SybC, 

and VkE) which may contain soil organic matter of less than 2% (Forest Plan Standard 

1102). The three map units comprise approximately 50% of the project area. These soil 

groups contain two to three different soils that are lumped into one overall unit and it is 

usually only one soil that exhibits low organic matter. Within the area occupied by these 

soil map units, it is estimated that approximately 3,800-5,400 acres or 13-19% of the 

Briggs Spring project area truly contains areas limited by low amounts of topsoil organic 

matter.

Forest Plan Objective 212 prescribes an average of 5-10 tons per acre of coarse, woody 

debris (CWD) for conifer stands, to be provided at least once during stand rotation 

(approximately 100 years), and provided that a conflict with fire or pest management 

objectives does not exist (USDA Forest Service, 2006). Distribution of CWD throughout 

a treated area is also more desirable than isolated concentrations. Current CWD levels of 

sites surveyed during field investigations appear to meet or exceed 5-10 tons per acre. 

Geologic Hazards

The Limestone Plateau is generally considered to be stable, five soil map units in the 

Briggs Spring project area are rated as having mass movement potential. These soil map 

units occupy a total of approximately 11,940 acres (41%) and include the Stovho-Trebor 

(SycE), Trebor-Rock outcrop (TuG), Vanocker-Citadel (VcE), Vanocker-Lakoa (VkE), 

and Vanocker-Sawdust-Rock outcrop (VoG) soil map units (USDA SCS, 1990). 

However since most of the Briggs Spring project area has slopes that are less than 40%, 

the actual risk of mass movement is relatively low. Only 83 acres (0.3%) within the 

project boundary have slopes that exceed 40%. These steep areas coincide with canyon 

walls associated with the southern portion of Redbird Canyon. In fact, most of the area 

(92%) has slopes of 20% or less, thus making the area very well-suited to ground-based, 

mechanical operations. There are no roads or trails currently located on hill slopes with 

slope or soil stability concerns within the Briggs Spring project area, regardless of 

ownership. No slope failures were identified during field reviews, with the exception of 

small, isolated talus and rock slide areas on canyon side walls.
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Environmental Consequences

Effects to soil resources were analyzed for the time period beginning in the year 2000 and 

extending through the year 2026. The year 2000 was chosen as a starting point for 

effects analysis because the Jasper Fire occurred in this year within part of the Briggs 

Spring Project Area and post-fire runoff events caused some soil adjustments. The year 

2026 was chosen as an ending point in time because project activities would not begin to 

be implemented until 2011, with proposed prescribed burning and harvest activities 

taking place over the course of the next 10 years through the year 2021. Scientific 

research has found that most burned areas tend to recover within 3-5 years following a 

fire (Neary et al., 2005), so a buffer of 5 additional years was added to allow for recovery 

of the landscape following any prescribed burning activities that would be implemented 

as late as the year 2026. 

The analysis area for soils includes only the proposed activity units because impacts to 

soils occur on the site and do not accumulate outside of the activity area (USDA Forest 

Service, 1992). An activity area is “An area of land impacted by a management activity 

ranging from a few acres to an entire watershed depending on the type of monitoring 

being conducted; it is commonly a timber sale cutting unit, a prescribed fire burn unit or 

an allotment pasture” (USDA Forest Service, 1992). Effects to soil resources in units 

outside of the proposed Briggs Spring project area are outside the scope of this project. 

Tree harvest, grazing, and other various activities on non-federal lands are also outside of 

the soil analysis area. 

Alternative 1 – No Action

Direct and Indirect Effects

Soil Erosion

There would be no direct effects to soil productivity resulting from soil erosion with 

Alternative 1 because no new management activities are proposed. Existing soil 

disturbances and erosion would continue at current rates, or may get worse without 

corrective actions. Most erosion problems in the Briggs Spring project area are roadrelated. Correcting problem areas would occur more slowly compared to both action 

alternatives, depending on when and how much appropriated funding is made available. 

A large-scale, high intensity wildfire event has the greatest potential of exposing and 

altering soil conditions and indirectly contributing to increased soil erosion. Ultimately, 

erosion rates would depend on the timing, duration, and intensity of rainfall following the 

fire, as well as the recovery of plant communities. 

Soil Heating and Damage by Fire

There would be no direct effect to soil productivity from soil heating with this alternative 

because no burning would occur. If a wildfire were to occur, the soils could be adversely 

affected. 

Soil Compaction

This alternative would not have any new activities occurring within the project area so 

soil compaction would not be affected. There would be no direct or indirect effects 

would occur to soil productivity from soil compaction with this alternative because no 

new activities are planned. 
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Organic Matter and Nutrients

Alternative 1 would have no direct effect on soil organic matter or nutrient cycling 

because no new activities are proposed. A large-scale, high-intensity wildfire would 

indirectly affect the amount of organic material and nutrient cycling. Some nutrients 

would be lost through wind and water erosion, while others would remain onsite for use 

by vegetation. 

Geologic Hazards

There would be no direct effects to slope stability or unstable soils associated with 

Alternative 1 because no new activities are proposed. Hill slopes would continue to 

adjust in response to natural weathering processes such as freezing and thawing. A largescale, high-intensity wildfire may indirectly increase the rate and size of hill slope 

adjustments. Hill slope adjustments following a wildfire would continue to occur until 

vegetation has recovered and slopes have reached equilibrium (generally within 3-5 years 

following the wildfire). 

Common to All Action Alternatives

Direct and Indirect Effects

Soil Erosion

The alternatives vary in potential for soil erosion by the extent of vegetation treatments 

on soils with severe erosion hazard rating where slopes are greater than 40%. 

Alternatives 2 and 3 would implement mechanical treatments on soils with a severe 

erosion hazard rating on 7,866 acres (27% of project area) for Alternative 2 and 9,000 

acres (31% of project area) for Alternative 3. Prescribed fire is not expected to impact 

soil productivity from soil erosion because the organic layer of soils would not be burned 

off and would remain to protect soils from erosion. Implementation of Forest Plan 

standards and guidelines, which include WCPs and BMPs would minimize the potential 

for erosion in any alternative. 

Past monitoring and field investigations within the project area found that most existing 

erosion problems are related to roads and their effects on streams (USDA Forest Service, 

2010).

Although some wind-throw of trees would continue to occur, large areas of wind-thrown 

trees are not expected to result following project implementation due to the consideration 

of wind-throw potential when proposed silvicultural prescriptions were developed for the 

project area.

Alternative 2 does not propose any new road or trail construction and therefore no new 

construction would take place on soils with elevated erosion risk. Approximately 76 

miles of road maintenance and 33 miles of road reconstruction are proposed this would 

correct existing road runoff and erosion issues.

The “New Moon” OHV campground proposed by Alternative 2 is an ideal location based 

on the inherent soil properties found at this site. The NRCS provides soil interpretations 

specifically tailored to recreation developments, including suitability for camp and picnic 

areas, off-road motorcycle/ATV trails, and human foot paths and trails (USDA NRCS, 

2009). Soils at the proposed location are rated “somewhat limited” for overall 

campground development. This indicates that soils are generally suited for campground 

development but may require some additional measures or considerations to address 
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126

limitations posed by specific soil properties. Fair performance and low-to-moderate 

levels of maintenance will be required to maintain vegetative cover and prevent rutting 

and soil loss due to erosion. Furthermore, soils in the proposed campground area are 

rated “slight” for erosion from off-road and off-trail disturbance in general. Soils in this 

location are not limited for human foot paths and trails or off-road motorcycle/ATV 

trails.

Based on the acres of mechanical treatments proposed on soils with severe erosion hazard 

rating and proposed campgrounds in each alternative, Alternative 3 has the greatest 

potential for soil erosion than Alternative 2. Although the alternatives would vary in the 

potential for effects, no detrimental erosion would be expected due to design criteria, 

including Forest Plan direction. 

Soil Heating and Damage by Fire

Effects to soils from heating from management actions can come from two sources; 

burning slash piles and prescribed fire. 

Burning slash piles may result in detrimental soil disturbance due to the high intensity 

fire, high temperatures, and long duration of burning needed to completely burn these 

larger piles. However, design criteria have been included to minimize the amount of 

detrimental soil disturbance associated with burned slash piles (Appendix B). Burning of 

hand piles can also result in severely burned soils but these piles are much smaller in size 

and therefore do not produce the same degree or extent of soil damage. Design criteria 

pertaining to slash treatment and hand piles has also been included to minimize potential 

effects to soils (Appendix B). These measures include specifications for pile locations 

and size, soil and duff moisture requirements, and rehabilitation where necessary.

Prescribed fire is proposed on approximately 6,295 acres (Alternative 2) and 7,009 acres 

(Alternative 3). Prescribed burning associated with Alternatives 2 and 3 are not expected 

to result in severely burned soils within proposed activity areas. Prescribed broadcastburn prescriptions would be designed to provide only the fire intensity needed to achieve 

vegetation and fuel management objectives. Design criteria have also been included to 

protect soils during prescribed burning operations (Appendix B). These measures include 

specifications for soil and duff moisture requirements, fire intensity, appropriate ignition 

techniques, ground cover requirements following burning, and rehabilitation measures. 

Soil heating and associated effects to physical, chemical, biological, and hydrologic soil 

functions are expected to be minimal because fire intensities are expected to be primarily 

low to moderate.

Soil Compaction

Thinning, mechanical fuels treatment, and prescribed burning activities associated with 

either of the action alternatives are not expected to directly or indirectly result in 

detrimental levels of soil compaction. Much of the project area contains rock 

outcroppings and extensive surface rock within the soil which helps to protect soils in 

these areas from compaction. Activities would be limited to dry or frozen conditions. By 

controlling the season, location, and intensity of equipment operations, harvest activities 

can take place on soils with a higher susceptibility to compaction, without causing 

significant detrimental disturbance.

Treatment methods that avoid ground-based equipment operations within aspen stands 

such as hand felling, yarding from outside the aspen clone, or leaving felled pine in place, 
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127

would protect these moist soils and conserve soil characteristics. Equipment operations 

over snow and/or frozen soil conditions in these areas surrounding the aspen should 

provide adequate soil protection as well as meet operational needs. Design criteria for 

management of aspen stands have been included in the Briggs Spring project to protect 

these sensitive soils. 

The construction of an OHV campground under Alternative 2 would directly cause soil 

compaction in the development area. However this activity is exempt from inclusion in 

detrimental soil disturbance calculations per FSM and FSH direction because it is 

associated with administrative sites, facilities, and infrastructure.

Management activities associated with both action alternatives have been designed to 

minimize soil compaction through the use of design criteria (Appendix B) which includes 

USFS Watershed Conservation Practices (WCPs) and South Dakota Best Management 

Practices (BMPs). These practices include but are not limited to the use of designated 

and existing skid trails in sensitive areas, soil moisture limitations, and seasonal 

restrictions. 

Acres of proposed treatments on soils subject to compaction are:

• Alternative 2 = 18,920 acres (65% of project area)

• Alternative 3 = 21,454 (74% of project area)

Based on these acres, Alternative 3 has the greatest potential for soil compaction, 

followed by Alternative 2. Very little soil compaction would be expected to occur due to 

the inclusion of design criteria. Based on previous monitoring, any minor compaction 

would be expected to be a short term impact, alleviated by natural freeze-thaw cycles. 

Forest Plan monitoring has shown “there is evidence that conditions were such that 

within one geographic area, on at least one soil type, and to the depth sampled, that the 

mean soil bulk density decreased from levels above the threshold classified as 

‘detrimental compaction’ to levels below the threshold within the time period of one 

year” (USDA Forest Service, 2009). 

Organic Matter and Nutrients

Long term soil productivity associated with organic matter and nutrient cycling is not 

expected to be negatively affected directly or indirectly by management activities 

proposed under either action alternative, but rather to trend towards a net improvement 

following project implementation. 

The difference between Alternatives 2 and 3 regarding impacts to the soil resource from 

nutrient removal are based on acres of mechanical treatment proposed on soils that could 

have low organic matter. Prescribed fire would affect surface litter layer by partially or 

entirely consuming organic matter. Prescribed burning also affects the duff layer where 

topsoil organic matter resides. The degree of impact depends on fire intensity and 

burning duration and moisture content of the duff layer. Design criteria have been 

included to limit fire intensity through soil and duff moisture requirements, seasonal 

timing of burning, slash pre-treatment where necessary, and ignition techniques. 

Therefore the effects of prescribed burning on topsoil organic matter are expected to be 

minimal due to the inclusion of design criteria and the inherent nature of lower-intensity 

prescribed burning
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It is estimated that 4,165 acres (Alternative 2) and 7,744 acres (Alternative 3) of 

shelterwood treatment are located on soils that could potentially have low topsoil organic 

matter. Other treatments are proposed on soils with low topsoil organic matter, including 

various thinning. These other treatments would retain sufficient residual material in the 

stand to meet Forest Plan Guidelines and Standard 1102. 

The Forest Plan requires the maintenance or improvement of long-term levels of organic 

matter and nutrients on all lands (Standard 1102). Guideline 1102a provides the 

following direction to achieve this standard for areas where topsoil is thinner than 1 inch, 

topsoil organic matter is less than 2%, or the effective rooting depth is less than 15 

inches:

• Consider the existing and projected levels of fine slash; and

• Retain 90% or more of the fine logging slash (less than 3 inches in diameter) in 

the stand after each clearcut and seed-tree harvest; and

• Retain 50% or more of the fine slash in these stands after each shelterwood and 

group selection harvest.

Implementing Forest Plan requirements and design criteria pertaining to these soils is 

expected to maintain long term nutrient levels and contribute to the topsoil organic 

matter, and thus ensures compliance with Forest Plan Standards 1102 and 1112 

pertaining to the retention of organic matter for soil productivity.

Geologic Hazards

Approximately 40 acres out of the total vegetation management activities proposed under 

Alternative 2 include areas where slopes are greater than 40% and soil have the potential 

for mass movement. Alternative 3 has approximately 68 acres out of the total vegetation 

management activities. However, these are isolated areas within larger treatment units 

and are often associated with steep, rocky outcrops and canyon walls. 

The project has been designed so that all proposed ground-based mechanical treatments 

under both action alternatives would generally avoid slopes exceeding 40%. Therefore, 

any soils prone to movement on these slopes would also be avoided. Ground-based 

equipment operations are excluded from these areas, except to cross, short, isolated 

segments as part of project design criteria that includes WCPs and BMPs in order to 

minimize the risk of initiating a slope failure during or following harvest activities in 

these areas. Implementing design criteria would minimize or eliminate the risk of mass 

movement. 

Cumulative Effects to Soils

The cumulative effects area for the soils resource is the proposed activity units in the 

project area. The effects of the alternatives on the soils resource would be contained 

within the units. The timeframes used to consider effects of past, present, and future 

activities are from 2000 to 2026. This time frame would include impacts from the Jasper 

Fire (2000) and impacts from past timber sales, and through completion of proposed 

activities in this project. The past, present, and future activities considered in this 

analysis are presented in Appendix F. 

Forest Plan standards and guidelines, as well as site specific design criteria would be 

implemented in all alternatives. When implemented as described, no adverse cumulative 

effects to soils are expected to occur. Past monitoring shows that when Forest Plan 
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standards and guidelines are implemented on similar projects, this standard is met 

(USDA Forest Service, 2008). It is further expected that the compacted, eroded, or 

displaced condition would be less than 15%, as described in Standard 1103. The 

following discussion considers the cumulative effects of potential disturbances to longterm soil productivity in accordance with Forest Plan Standard 1101. 

Soil Erosion

Past, currently ongoing, and reasonably foreseeable actions listed in Appendix F were 

considered along with proposed activities for cumulative effects to soil erosion and 

displacement. Any soil erosion that may occur related to implementation of the Briggs 

Spring project is expected to be localized, minor in both severity and extent, and thus 

well below levels that would be considered detrimental. This expectation also applies to 

other forest management activities and uses. Design criteria and appropriate WCP/BMP 

measures apply to all forest management activities and uses. These measures are 

designed to control runoff and erosion for a 10 year storm event (USDA Forest Service, 

2006b). Therefore the risk of cumulative detrimental soil erosion is mitigated for typical 

storm events observed in the Black Hills for all forest management activities.

Past monitoring and field investigations within the project area found that most existing 

erosion problems are related to roads and their effects on streams (USDA Forest Service, 

2010). 

Grazing management throughout the project area is not expected to cause extensive soil 

erosion. Dispersed recreation activities generally do not cause excessive soil erosion 

issues due to the lack of concentrated use. Concentrated recreation sites are purposely 

located in flatter terrain which minimizes the potential for soil erosion and employs 

management strategies to guide concentrated uses where measures are in place (i.e. 

WCPs/BMPs) to minimize soil erosion.

Any soil erosion would be expected to be minimal and would be within the limits of 

Forest Plan Standard 1103 for the action alternatives. There would be no cumulative 

effects to soil erosion resulting from the no action alternative. 

Soil Heating and Damage by Fire

Events that could cause negative effects of soil heating are wildfires and, to a lesser 

degree, prescribed burning. Prescribed burning within the project area would be 

implemented in a manner designed to reduce the potential for adverse soil heating 

impacts. Prescribed burning would have beneficial effects by reducing long-term fire 

hazard and the potential for large-scale, high intensity wildfire that could have soil 

heating effects. Therefore, no adverse cumulative effects would be expected under any 

action alternative. 

Soil Compaction

Past, currently ongoing, and reasonably foreseeable actions in the Briggs Spring project 

area were considered along with proposed activities for cumulative effects to soil 

compaction. Any soil compaction that may occur related to implementation of the Briggs 

Spring project is expected to be localized and well below levels that would be considered 

detrimental. This expectation also applies to other forest management activities and uses. 

Design criteria and appropriate WCP/BMP measures apply to all forest management 
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activities and uses. Therefore the risk of cumulative detrimental soil compaction is 

minimized. 

Grazing management throughout the project area is not expected to cause detrimental 

levels of soil compaction due to where livestock naturally tend to roam and the presence 

of rock fragments in most of the soils within the project area. Dispersed recreation 

activities also do not tend to cause detrimental soil compaction due to the lack of 

concentrated use for this type of recreation. 

Minimal cumulative impacts to the soil from compaction are expected and would be 

within the limits set by Forest Plan Standard 1103. No cumulative effects from the no 

action alternative would occur. 

Organic Matter and Nutrients

There would be no adverse cumulative impacts to soil organic matter and nutrients from 

any alternative within the project area because sufficient residual material and trees 

would be left on site for nutrient recycling after project implementation. 

Geologic Hazards

There is little potential for mass movement of soils in this project area. Actions that 

influence mass movement of soils include timber harvesting and road building. There 

would be no cumulative impact to mass movement of soils from any alternative. The 

action alternatives include design criteria to minimize and reduce the risk of landslides 

within the treatment area. 

Water Resources 

Affected Environment

The Briggs Spring project boundary overlaps portions of three 6th level watersheds. 

These watersheds include Redbird Canyon, Gillette Canyon, and a very small portion of 

the Stockade Beaver Creek watershed (Table 39). Since the project area does not 

coincide exactly with watershed boundaries, the water resources analysis area differs 

from the project area boundary. Although a small portion of the Stockade Beaver Creek 

watershed is included in the Briggs Spring project boundary, it is privately owned land 

and thus no federal land management activities would take place. For this reason, the 

Stockade Beaver Creek watershed was excluded from the watershed analysis area. 

Watershed Condition

Watershed boundaries and HUC codes were obtained from the National Hydrography 

Dataset developed and maintained by the USDA Service Center and USGS (USGS, 

2008).
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Table 39. 6th Level Watersheds (HUC 12) associated with the Briggs Spring 

project

6th Level 

(HUC 12) 

Watershed

6th Level (HUC 12) 

Watershed Name

Total 

Watershed 

Acres

Acres of 

Watershed 

in Project

Percent of 

Watershed 

in Project

101201070404 Stockade-Beaver Creek 37,643 129 0.3%

101201070405 Gillette Canyon 51,464 2,679 5%

101201070406 Redbird Canyon 52,135 26,021 50%

Watershed Condition Classes were assessed during the 1997 Forest Plan Revision, but 

watershed boundaries have changed since that time due to the development of the 

nationwide National Hydrography Dataset (USGS, 2008). Watershed boundaries used in 

the 1997 Forest Plan correspond well to the analysis watersheds for this area and all three 

watersheds are rated as Condition Class 2 – Moderate Concern. According to the Forest 

Plan (1997), “Class 2 watersheds are those which may have streams and soils in 

disequilibrium; a change in the rate or nature of management activity, stricter 

implementation of Watershed Conservation Practices and BMPs, or minor structural 

projects should be able to return these watersheds to a Class 1 condition; some upland 

restoration may be necessary.”

Redbird Canyon (HUC 101201070406)

The overall Redbird Canyon watershed encompasses 52,049 acres (about 81 square 

miles). Only the upper portion of the watershed is included in the Briggs watershed 

analysis area (Map 6, Appendix A), totaling 32,054 acres or 62% of the overall 

watershed. Seeps and springs are abundant throughout the watershed. Stream channels 

are ephemeral to intermittent in nature, as most precipitation is lost to aquifer recharge. 

Most of the watershed is National Forest lands managed for timber production and 

grazing. Privately owned lands comprise 4,638 acres and are a combination of scattered 

homestead and mining claims, generally occupying wider valley bottoms and grassy 

meadows. 

Gillette Canyon (HUC 101201070405)

The Gillette Canyon watershed encompasses 51,072 acres (about 80 square miles). Only 

the upper portion of the watershed is included in the Briggs water resources analysis area 

(Map 6, Appendix A), totaling 18,768 acres or 37% of the overall HUC 6 watershed. 

Elevations range from approximately 5,800 feet at the outlet of Wolf Draw in the south 

over 6,900 feet on the northeastern watershed divide with Spring Creek. Seeps and 

springs are abundant throughout this watershed as well. Stream channels are ephemeral 

to intermittent in nature, as most precipitation is lost to aquifer recharge. Most of this 

watershed is also National Forest lands managed for timber production and livestock 

grazing. Portions of the watershed that experienced high tree mortality resulting from the 

Jasper Fire are now primarily managed for grazing and wildlife. Privately owned lands 

comprise 406 acres of this portion of the Gillette Canyon watershed. Private lands are a 

combination of scattered homestead and mining claims, generally occupying wider valley 

bottoms and grassy meadows.
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Floodplains

A floodplain is the flat area on either side of a stream or river that is susceptible to 

inundation by floodwaters. Floodplains slow flood velocities and decrease erosion 

because they are by nature wide and flat, thus allowing for shallower and slower water. 

Thus, floodplains provide for flood moderation, water quality protection, ground water 

recharge, and wildlife habitat, among other benefits. The Federal Emergency 

Management Agency (FEMA) has mapped 100-year floodplains across the nation 

(FEMA, 1998).

There are approximately 345 acres of mapped 100-year floodplains within the project 

area. Mapped 100-year floodplains are located along the following streams and drainage 

ways: Redbird Draw, isolated segments of Redbird Canyon, and Gillette Canyon.

Wetlands and Riparian Areas

There are approximately 27 acres of wetlands mapped by the NWI within the Briggs 

Spring project area (Table 40). These are associated with 69 different wetland areas, 

many of which are associated with impoundments used primarily for stock watering. All 

of the NWI wetlands within the project boundary are classified as Palustrine and 

generally less than one acre in size. Additionally, there are 31 miles of mapped linear 

wetlands within the project boundary (Table 40), located in Redbird Draw and Redbird 

Canyon. Additionally, there are approximately 30 acres, associated with another 96 

wetlands, which were identified during field reviews and GIS analysis that were not 

identified by NWI mapping. Thirty-five acres are located on Forest Service managed 

lands and the remaining 22 acres are located on privately owned lands.

Table 40. Wetlands within Briggs Spring project area

Wetland 

Classification Wetland Type(s)

Wetland 

Areas 

(Acres)

Linear 

Wetlands 

(miles)

Lacustrine Lakes None None

Palustrine Marshes, swamps, floodplains, fens, bogs, 

wet meadows, etc. 27 31

Riverine Adjacent to rivers, streams and includes ox 

bows, freshwater marshes, etc. None None

To Be 

Determined Field identified and GIS digitized wetlands 30 None

Total 57 acres 31 miles

There are 24 known springs located within the Briggs Spring project area, all of which 

are in the Redbird Canyon watershed. Nineteen springs are located on USFS lands and 

include Baseline Spring, Beef Pasture Spring, Bert Howey Spring, Briggs Spring, Cabin 

Spring, Cigarette Spring, Herrin Spring/WPA Well, Howell Spring, Johnson Spring, 

Lower Antelope Spring, Multiplex Springs, North Cigarette Spring, Old Camp Spring, 

Redbank Spring, Redbird Spring, Rogers Spring, Upper Antelope Spring, White Spring, 

and Willow Spring. The remaining five springs are located on privately-owned lands. 

Most of these springs also have associated wetlands surrounding the spring source. The 

wetlands associated with Willow Springs Complex, Redbank Spring, and Upper and 
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Lower Antelope Springs have been identified as peat-forming wetlands, and maybe fens 

if sufficient peat depths are present. 

Stream Flow Regime

The Briggs Spring project area does not contain any perennial streams with sustained 

lengths, but does have a few, very short segments in which surface water can be found,

but each segment is generally a few hundred feet in length or less, and supported by 

springs. These segments add up to less than one mile in length. The area is dominated 

by intermittent and ephemeral streams. There are approximately 58 miles of intermittent 

streams and 27 miles of ephemeral streams within the project boundary (Table 41). Due 

the highly dissected nature of the Black Hills, numerous ephemeral drainages are also 

present. These channels generally do not have a defined channel and are often swales, 

and carry water only in response to larger storm events or snowmelt. Ephemeral 

drainages/swales are not specifically mapped.

Table 41. Miles of perennial, intermittent, and ephemeral streams in the Briggs 

Spring project area

Stream Flow Regime Stream 

Miles

Acres Associated 

w/Protected 

Streams (WIZ)

Perennial – defined channel and generally flows 

year-round. 0.7 17

Intermittent – defined channel but flows for only 

part of the year; includes loss zones where 

streamflow goes underground into ground water 

aquifers. For the Briggs Spring Project Area, these 

also include Karst Streams.

58 1,415

Ephemeral – defined channel or flow path, but 

carries water only in response to larger storm events 

or snowmelt. For the Briggs Spring Project Area, 

these include Karst Streams and Water Courses, 

which are protected water courses.

27 655

The drainages in the Briggs Spring watershed analysis area are in a stream flow regime 

dominated by runoff resulting from both snowmelt and intense summer thunderstorms 

(Sando, 1998).

Due to the unique underlying geology of the Briggs Spring project area, it is generally 

considered a ground water recharge zone (Carter et al., 2002; 2003). Prior to the Jasper 

Fire of 2000, surface runoff and flow in stream channels was a rare occurrence in this 

region, often occurring only in response to very high intensity thunderstorms of a “cloud 

burst” nature. Although short, isolated sections of spring-fed streams exist, stream 

channels are generally ephemeral and intermittent, carrying water only in response to 

such intense rainfall events or rapid, seasonal snowmelt. Waterways are often well 

vegetated with no defined flow channel and many times have ponderosa pine trees 

growing within the channels. 
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No active stream discharge gauges are present in the area (USGS, 2008a). One USGS 

crest-stage gauge is located near the outlet of Redbird Canyon and used to indirectly 

measure occasional high flows.

Stream flows have been altered from historic conditions by various human-related 

disturbances. Historic accounts by the Custer and Dodge Expeditions in 1874 and 1875 

noted more perennially-flowing streams, more abundant and lush riparian zones, and 

more wetlands in low-gradient valley bottoms than conditions today (Grafe & Horsted, 

2002; Horsted, 2006; Shepperd & Battaglia, 2002). Subsequent post-settlement timber 

harvesting, mining, livestock grazing, and beaver trapping changed the water yield as 

described previously and thus also affected streamflow (Shepperd & Battaglia, 2002). 

These changes damaged the riparian zones and led to an increase in peak flows and the 

intensity of flash floods, and a decrease in the perennial flow of some streams (Parrish et 

al., 1996).

Stream Health

Streams within the Briggs Spring project area have not yet been rigorously surveyed and 

evaluated for stream stability. However, general stream health assessments have been 

completed in accordance with Region 2 and Forest Plan guidance. Most stream channels 

within the Briggs Spring project area are currently stable and rated as “robust”. Some 

segments of channel instability exist in the southern portion of the project area as a result 

of post-fire flooding after the Jasper Fire. Post-fire floods scoured material out of 

channels and stream banks, depositing this material in flatter stream segments where 

flood waters slowed, particularly at culverts (Gould, 2003). Scour and transport of debris 

has slowed significantly as the burned area recovered and very little occurs now, and only 

in response to the occasional runoff created by very high-intensity summer 

thunderstorms. Overall, stream channels appear to be recovering well based on field 

investigations.

Connected Disturbed Areas (CDAs) are disturbed sites that have a continuous surface 

flow path into streams and other water bodies (USDA Forest Service, 1999). Sediment 

delivery to and transport in streams is a natural process, but roads and other disturbed 

sites can act as channels that multiply sediment loads to the stream network during runoff 

events. CDAs include roads, ditches, compacted soils, bare soils, mine spoils, and areas 

of severely burned soils that are directly connected to the stream network. Ground 

disturbing activities located within the water influence zone are also considered 

connected unless site-specific actions are taken to disconnect them from streams (USDA 

Forest Service, 2006b).

CDAs in the Briggs Spring project area are primarily associated with livestock 

concentration in wet areas such as springs and wetlands that are not fenced or where 

fences are in disrepair. Some of the larger spring and wetland areas that are impacted 

include Briggs Spring, Willow Spring and wetland complex, Upper Antelope Spring, and 

White Spring

Water Quality

The SD DENR assigns water quality standards based on the beneficial uses of each water 

body. All streams in South Dakota are assigned the beneficial uses of irrigation, fish and 

wildlife propagation, recreation, and stock watering (SD DENR, 1999). None of the 
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streams within the Briggs Spring Project Area or water resources analysis area are listed 

specifically for other beneficial uses due to the lack of continuous surface water.

No water bodies within the Briggs Spring project area are currently listed as impaired 

(SD DENR, 2010), nor have they been listed on previous years reports (SD DENR, 1998; 

2002; 2004; 2006; 2008).

Environmental Consequences

Effects to water resources were analyzed for the same time period as soil resources, 

beginning in the year 2000 and extending through the year 2026, for the same reasons 

stated previously. Effects to water resources are also summarized in the context of short 

term effects (5 years or less) as well as long term effects (longer than 5 years).

The water resources analysis area encompasses the headwater portions of Redbird and 

Gillette Canyons, an area totaling approximately 50,820 acres (Appendix A, Map 6). The 

water resources analysis area includes land managed by both the Mystic and Hell Canyon 

Ranger Districts of the Black Hills National Forest, as well as private lands. 

Past, currently ongoing, and reasonably foreseeable actions listed in Appendix F were 

considered along with proposed activities for cumulative effects to water resources. 

Effects from known past actions were included in the analysis of existing resource 

conditions. Generally this includes activities that have occurred since the 1874 Custer 

Expedition to the Black Hills region. Proposed activities associated with each alternative 

were considered in the analysis of direct and indirect effects. Past and present land use 

and activities within the analysis watersheds, which encompasses the Briggs Spring 

project boundary, include timber harvest, wild and prescribed fire, livestock grazing, 

private land ownership, roads and off road vehicles, mines and quarries, various types of 

recreation, and forest product gathering. All of these activities or events individually 

have some level of impact on the watershed, which results in cumulative effects to 

watershed and water resources conditions and processes.

Alternative 1 – No Action

Direct and Indirect Effects

Floodplains, Wetlands and Riparian Areas

This alternative would not have any new activities within the project area so there would 

be no direct or indirect effects on floodplains, wetlands and riparian ecosystems. 

Stream Flow Regime

Alternative 1 would not have any new activities within the project area. Therefore, no 

direct effects to flow regime would occur. Indirect effects include a potential for increase 

in biomass over time, which would generally reduce the amount of water available for 

streamflow. This alternative could also have potential for a large stand replacing event 

which would impact stream flow regime. 

Stream Health and Water Quality

This alternative would have no new activities within the project area. Current conditions 

of temperature/oxygen, sediment, water purity, aquatic life, and bed and bank stability 

would be expected to remain unchanged. No change to existing stream health ratings 

would occur. However, this alternative has potential for a large scale disturbance, such as 
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a large-scale, high intensity fire, to occur and this could impact water quality and stream 

health. 

Common to All Action Alternatives

Direct and Indirect Effects

Floodplains, Wetlands and Riparian Areas

No measureable, negative direct or indirect effects to stream channels and floodplains in 

the project area are expected as a result of changes in annual water yield or runoff 

magnitudes resulting from either action alternative.

The location for an OHV campground proposed by Alternative 2 is located well away 

from stream channels and floodplains and therefore would not affect these resources. 

Short-term impacts may occur to stream channels and floodplains under both action 

alternatives in areas where vegetative and fuels treatments and road work is proposed 

within riparian corridors and adjacent to streams. However, design criteria and 

WCPs/BMPs (Appendix B) are included to protect stream courses and minimize 

floodplain and riparian impacts during management activities. Forest Plan Standards 

1301, 1302, 1306 and Guideline 1115 also stipulate the use of buffers for streams and 

riparian areas (USDA Forest Service, 2006). 

Roads that cross riparian areas would have design criteria and WCPs/BMPs associated 

with them. Management activities would be expected to result in an overall improvement 

in wetland and riparian conditions once protective measures around these areas are 

installed (i.e. fencing or natural barriers) and road improvements are made.

Design criteria have been included in the project to protect these areas during 

management activities. Buffers provide protection for these areas, so no negative effects 

to wetland and riparian areas are anticipated for proposed activities. Therefore this 

project would comply with all water-quality related Forest Plan Standards and Guidelines 

and all State and National water quality regulations, and also complies with floodplain 

and wetland regulations.

The proposed OHV campground associated with Alternative 2 is not located near 

wetlands, riparian areas, or GDEs and would therefore have no direct or indirect impact 

to these resources.

Stream Flow Regime

Stream flow is not anticipated to be negatively affected by implementation of project 

activities associated with either action alternative. 

Intermittent and ephemeral streams and drainages occasionally flow in response to very 

intense summer thunderstorms currently and would continue to do so. In these events, 

the amount and rate of rainfall is the driving force behind streamflow being produced and

carried throughout the drainage network. Therefore proposed vegetation treatments, 

prescribed fire, fuels treatments, and OHV campground areas are not expected to 

measurably alter this current response. WCP/BMP measures are included in the project 

design. These measures are designed to control runoff damage from at least a 10-year 

storm of any duration (USDA Forest Service, 2006b). Therefore, for typical precipitation 

events observed in the Black Hills area, storm runoff is not expected to cause damages to 

soil or water resources. 
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Stream Health and Water Quality

Proposed timber and fuels management, and prescribed burning activities associated with 

both action alternatives are not expected to degrade water quality or exceed state 

specified thresholds for the various water quality parameters associated with each 

beneficial use. Commercial and non-commercial thinning and prescribed burning 

activities associated with Alternative 2 and 3 are not expected to result in detrimental 

levels of soil erosion as explained previously in the soil erosion discussion, and therefore 

no substantial increase in sediment transport to streams and water bodies is anticipated. 

Measures have been included in the project to protect the quality of ground water as 

required by Forest Service Manual 2880 – Geologic Resources, Hazards, and Services 

(USDA Forest Service, 2008). Applicable WCPs found in FSH 2509.25 (USDA Forest 

Service, 2006), along with SD BMPs (SDSU et al., 2003), are used to prevent 

degradation of both surface and ground water quality. These measures include stream 

and riparian buffers, avoidance of sensitive areas, seasonal operations, drainage features, 

and restrictions on harvest, road activities, and fire ignition in and immediately adjacent 

to water resources.

Vegetative buffers would remain in place to filter any incoming sediment or chemical 

pollutants, provide stream bank stability, minimize bank erosion, and provide necessary 

shading to maintain cooler water temperatures necessary for coldwater fisheries. All 

water bodies including but not limited to lakes, ponds, wetlands, springs, perennial and 

intermittent streams, and water courses have 100-foot WIZ vegetative buffers as required 

by agreement with the SD DENR (USDA Forest Service, 2006b; 2009a) and Forest Plan 

Standards 1301, 1302, 1306 and Guideline 1115 (USDA Forest Service, 2006).

WIZ buffers would be avoided by ground-based equipment except at designated crossing 

points, to perform road work, to end-yard any cut trees out of the WIZ, or where sitespecifically approved. Forest management activities such as tree harvest and prescribed 

fire can take place within the 100-ft WIZ buffer along streams if desired for silvicultural 

reasons and done so cautiously, with a “tread lightly” approach. Design criteria has been 

included to protect vegetation within 50 feet of each stream bank for stream-side areas 

where vegetation management may be desired. Within this 50 foot stream-side buffer, 

willows, aspen, spruce, or other trees and shrubs providing physical bank stabilization or 

shade to the stream would not be removed unless site specifically approved otherwise.

Approximately 76 miles of road maintenance activities are proposed under Alternative 2

and approximately 33 miles of road reconstruction is proposed. Approximately 77 miles 

of road maintenance activities are proposed under Alternative 3 and approximately 34

miles of road reconstruction is proposed. Road maintenance and reconstruction activities 

would reduce potential impacts to water quality. Road problems and CDAs would be 

corrected as part of the commercial timber harvest and road package, thus reducing 

sediment to the streams. Harvest activities would have a positive effect on stream 

temperature for those short segments that carry surface water flow. 

Alternatives 2 and 3 could result in localized, short term sediment delivery to water 

resources from road-related activities adjacent to streams or at stream crossings. In the 

long term, roads would produce less sediment as a result of the implementation of the 

road work in these alternatives (road work associated with timber sale areas).
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The proposed OHV campground associated with Alternative 2 is not located near streams 

or other water bodies and will therefore have no direct or indirect impact to these 

resources. 

Cumulative Effects

Floodplains, Wetlands and Riparian Areas

Cumulatively, all activities are expected to maintain current conditions of wetlands, 

riparian areas, and/or ground water dependent ecosystems through implementation of 

design criteria and WCPs/BMPs (Appendix B). Some improvements in condition may 

occur where road-related problems are addressed through commercial timber harvest road 

work. In general, wetland, riparian, and GDE sites are expected to remain in their current 

condition, regardless of which alternative is chosen. 

Stream Flow Regime

Under Alternative 1, current stream flow conditions would likely persist. Cumulative 

impacts could occur from MPB killing enough trees across watersheds, or a large-scale, 

high intensity wildfire occurs, both of which could cumulatively result in increased 

stream flows in the short term. Timber management associated with the action 

alternatives may cumulatively make more soil moisture available throughout the 

watersheds to sustain slightly higher water levels in springs, wetlands, and stream 

channels downstream of these areas. Prescribed fire, fuels treatment, and an OHV 

campground would not have any measureable effect on stream flows, regardless of the 

alternative chosen.

Stream Health and Water Quality

Cumulatively, stable stream channels throughout the area are expected to remain in their 

current conditions until a natural disturbance such as wildfire occurs, which would likely 

cause instability. Conversely, already unstable stream channels would continue to 

degrade, causing impacts to ripple throughout their tributary networks as well. Design 

criteria and WCPs/BMPs have been included in both action alternatives to protect 

streams and floodplains during harvest activities. Road work associated with both action 

alternatives would lead to improved flood passage and channel stability at improved 

stream crossings.

Cumulatively, all activities are expected to maintain current water quality levels through 

the proper implementation and adherence to required design criteria and WCPs/BMPs 

(Appendix B). The OHV campground associated with Alternative 3 would require more 

extensive engineering design and WCP/BMP measures than Alternative 2 to prevent 

impacts to water quality. However, specified design criteria, including proper 

implementation and maintenance of WCP/BMP measures, would ensure protection of 

water quality at Redbank Spring. Vegetation management, prescribed fire, and road 

activities, including design criteria and WCP/BMP measures, would not be expected to 

have a negative, measurable change in overall water quality in any of the streams or 

water bodies due to activities associated with either action alternative. Implementation of 

either action alternative may cumulatively result in decreased sediment delivery and 

improved water quality through road improvement work. 
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Routine maintenance of trails, developed recreation facilities, and dispersed campsites or 

the operations of outfitters and guides would not involve activities which would increase 

sedimentation or affect water quality. Public recreational uses would have no measurable 

effect on sediment yields in the project area, due to the fact that disturbance created by 

these activities would be small, if any and dispersed across the landscape. Routine road 

maintenance is likely to occur as needed on existing roads in the project area.

For Alternative 1, existing CDAs would be corrected as funding and project 

authorizations allow (i.e. grazing allotment improvements, annual road maintenance, 

stream or wetland improvement projects, etc). For both action alternatives, existing roadrelated CDAs could be corrected as part of contracted road work associated with timber 

sales. Both action alternatives would have the potential to create new disturbed sites 

related to the creation or expansion of existing campground facilities for concentrated 

OHV recreational use. However, the OHV campground proposed under Alternative 2 is 

located well away from any surface waters and thus is not likely to result in a connection 

to surface water bodies. 

Best Management Practices (BMP) Effectiveness 

Best Management Practices (BMPs) are measures and practices used to reduce or 

eliminate the introduction of pollutants into water resources and to meet non-point source 

pollution control related to the Clean Water Act. BMPs include structural and 

nonstructural controls, as well as operational and maintenance procedures that are applied 

before, during and after ground-disturbing activities. An agreement between the USFS 

and the State of South Dakota stipulates that USFS Region 2 Watershed Conservation 

Practices (WCPs) will be used above and beyond South Dakota Forestry BMPs to 

comply with State and Federal water quality regulations related to the Clean Water Act 

(USDA Forest Service, 2009).

These practices have been proven effective in preventing runoff, erosion, sediment 

delivery, and chemical pollution of water resources when implemented properly (Lee, 

2001; Lee and Everett, 2001; Everett, 2004; Thomas, 2008; Hoxie and Engelskirger, 

2009; USDA Forest Service, 2003, 2006a, 2010). All management activities have been 

designed to meet Forest Plan Standards and Guidelines through the inclusion of project 

Design Criteria and specified WCP/BMP measures. These measures also help to ensure 

compliance with the Clean Water Act and all State and National water quality 

regulations. Strict adherence to project Design Criteria and WCP/BMP measures, 

including proper implementation and maintenance, would ensure that no substantial or 

long-lasting effects to surface or ground water quality occur. 

WCP/BMP monitoring of previously logged areas in the Briggs Spring Project Area has 

taken place between 2002 and 2009 and includes the Redbank, Dumbuk, Thumb, 

Stateline, Run, and Cattle Salvage Timber Sales. Monitoring results indicate that 

although there are some residual impacts from past logging activities, BMP/WCP 

measures are being implemented and are effective at controlling non-point source 

pollution. Additional BMP/WCP monitoring has been completed across the Hell Canyon 

Ranger District between 2002 and the present. The monitoring summary report indicates 

that logging operations across the district routinely implement BMP/WCP measures; 

these measures are effective; and logging practices comply with the requirements of the 

Clean Water Act and SD water quality regulations (Thomas, 2008).
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CHAPTER 4: CONSULTATION AND 

COORDINATION

The Forest Service consulted the following individuals, Federal, State, and local 

agencies, tribes and non-Forest Service persons during the development of this 

environmental assessment:

Interdisciplinary Team Members:

Lynn Kolund District Ranger – Bachelor of Science, Forest Biology, 

Colorado State University, 1978. Thirty-one years of Forest 

Service experience in timber, silviculture, recreation, 

wilderness, fire and lands. Worked on seven districts and two 

Supervisor’s offices on six National Forests in Wyoming, 

Colorado, Alaska and South Dakota.

Kelly Honors District NEPA Coordinator – Bachelor of Science, Forestry, 

State University of New York, College of Environmental 

Science and Forestry, 1985. Twenty six years of Forest 

Service experience at the district level in timber and planning; 

twenty-three of those years on the Black Hills National Forest. 

Twenty-two years experience in writing NEPA documents.

Wendy Steuerwald IDT Leader – Assistant NEPA Coordinator – Bachelor of 

Science, Wildlife Management, University of WisconsinStevens Point, 2003. Thirteen years of Forest Service 

experience at the district level on the Black Hills National 

Forest, twelve years experience in timber and one year in 

planning. 

Nancy Bayne Silviculturalist – Bachelor of Science, Forest Resources with 

an emphasis in Silviculture, University of Minnesota, 1986. 

Twenty-one years of Forest Service experience in timber at the 

district level on the Black Hills National Forest. Six years in 

current silviculturalist position.

Gwen Lipp Fire/Fuels Planner – Bachelor of Science, Environmental 

Engineering, South Dakota School of Mines and Technology, 

2004. Ten years of Forest Service experience at the district 

and national level in fire operations, fuels, timber, prescribed 

fire and planning. Current qualifications include: Incident 

Commander Type 4, Dozer Boss, Engine Boss, Prescribed Fire 

Effects Monitor, Prescribed Fire Ignition Specialist, Resource 

Unit Leader, Situation Unit Leader, Task Force Leader trainee, 

Burn Boss Type 2 trainee and Planning Section Chief trainee.
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141

Tracy Clark Wildlife Biologist – Bachelor of Science, Wildlife 

Management with Minor in Environmental Law Enforcement, 

University of Wisconsin-Stevens Point, 1990. Eight seasons 

(1989-1994, 2000-2001) of wildlife experience as a Biological 

Technician with the Forest Service, Park Service and BLM in 

South Dakota, Idaho and Oregon. From 1994-1996 worked as 

a private consultant with the Minnesota DNR writing land 

stewardship plans and performing forest inventory. From 

1996-2001 worked as a contractor performing stand exam on 

the Black Hills National Forest. Have been a Wildlife 

Biologist on the Black Hills National Forest since January of 

2002.

Jessica Gould Hydrologist – Bachelor of Science (2000) and Master of 

Science (2004) in Civil Engineering, focusing on water 

resources, from the South Dakota School of Mines and 

Technology (SDSM&T). Master’s thesis conducted on the 

Black Hills NF, studying post-fire watershed responses after 

the Jasper Fire of 2000. PhD candidate in Geology & 

Geological Engineering, focusing on hydrogeology 

(groundwater), also from SDSM&T. Doctoral research 

focuses on identification and characterization of peat-forming, 

groundwater-dependent wetlands called fens in the Black Hills. 

Fourteen years of experience with the Forest Service at the 

district and SO levels, eleven in soil and water resources 

management, and 10 years working on the Black Hills NF. 

Nationally Registered and State licensed EMT-Intermediate 

and volunteer fire fighter with Hill City Fire and Ambulance 

Services. Hydrologist on the DOI National Interagency 

Burned Area Emergency Response (BAER) Team since 2003, 

lead Hydrologist since 2007. Assessed post-fire watershed 

conditions on over 5 million acres associated with fires in SD, 

WY, MT, ID, NV, and CA.

Lucas Bindel Rangeland Management Specialist – Bachelor of Science –

Rangeland Ecology and Watershed Management; MinorReclamation and Restoration Ecology. University of 

Wyoming, 2009. Two years experience as Rangeland 

Management Specialist for Forest Service. 

Matthew Scott Botanist – Bachelor of Science – Rangeland Ecology and 

Watershed Management; Minor, Reclamation and Restoration 

Ecology; Extensive coursework in soils and botanical sciences, 

2006. Three years experience fuels, wildland and prescribed 

fire management. Four years experience as a Natural Resource 

Specialist for Laramie Rivers Conservation District focused in 

rangeland management, vegetation monitoring, and wildlife 
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142

habitat management. Qualified for OPM 430 Series (Botanist) 

in 2010. Six months experience as Botanist on the Black Hills 

National Forest.

Matthew Padilla Archaeologist – Master of Arts in Anthropology and Minor in 

GIS from New Mexico State University, 2006. Bachelor of 

Arts in Anthropology from Kansas State University, 2003. 

Three field seasons as an Archaeological Technician for the 

Black Hills National Forest (2002, 2004, 2005). One year as a 

SCEP archaeologist on the Plumas National Forest (2006). 

Four years of Forest Service experience as an Archaeologist at 

the district level, six years as a fire archaeologist, and five 

years as a BAER archaeologist. USFS experience in 

California and South Dakota.

Donald Weiand Civil Engineering Technician – Bachelor of Science in 

Industrial Technology from Black Hills State University, 1996. 

Associate of Science in Drafting from Black Hills State 

University, 1994. Fourteen years of Forest Service experience 

at the district and Forest level in transportation planning, road 

design, contract preparation & administration, and 

environmental analysis. Certified in roads, administration of 

timber sales, and public works under the Forest Service 

National Construction Certification Program. Eighteen years 

as an Army Engineer with experience in route reconnaissance 

and roads planning and road construction operations. 

Dave Pickford Recreation – Bachelor of Arts in Outdoor Recreation from 

Eastern Washington University, 1984. Eighteen years of 

Forest Service experience as the District level in timber, 

firefighting, trails, recreation and wilderness on the Ottawa and 

Black Hills National Forests. USFS, NPS and USFWS field 

experience in Washington, Idaho, Wyoming, Colorado, UP 

Michigan as well as NH State Parks. Former USAF Survival 

Specialist and USAF (civilian) Outdoor Adventure Program 

Staff.

Meagan Buehler Lands Specialists – Bachelor of Science, Forestry, minor in 

Wildlife & Fisheries Biology, University of MassachusettsAmherst, 1997. Eleven years experience with the Forest 

Service at the district level for the Black Hills National Forest 

currently as District Lands Specialist. One season experience 

with the BLM in Oregon as a forester-stand exams and timber 

sale preparation.

Gary Haag Geologist/Minerals Specialist: Bachelor of Arts, Geology, 

Rutgers University, 1979 & Master of Science, Geology, 

Rutgers University, 1982. New Jersey Department of 
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143

Environmental Protection 1884-1989, ground water discharge 

permit program. South Dakota Department of Environment 

and Natural Resources 1989-2010, ground water discharge 

permit program. February 2010 to present on BHNF-Hell 

Canyon Ranger District as a geologist working on locatable 

and mineral material projects and mineral potential reports for 

mineral withdrawals and timber sales.

Stephen Keegan Forest Landscape Architect - Bachelor of Science, Landscape 

Architecture & Environmental Studies, State University of 

New York (SUNY) - College of Environmental Science and 

Forestry, 1980; Bachelor of Science, Syracuse University 

1980; Associates of Arts, Humanities, SUNY - Onondaga 

Community College, 1978. Twenty-eight years of Forest

Service experience at the Forest and Zone level on the Helena, 

Clearwater, Malheur & Black Hills National Forests. Of which 

twenty-one years have been as a Landscape Architect 

conducting Scenic Resource Assessments for: vegetation and 

fuels management, watershed analysis, utility & facility 

construction, wild & scenic rivers, scenic byways, and burned 

area emergency rehabilitation.

Margaret Farrell GIS/Database Management Specialist – Bachelor of Science, 

Geology, University of Wyoming, 1985. Eighteen years of 

Forest Service experience in database management, including 

fourteen years experience in ESRI GIS products.

Federal, State, and Local Agencies:

Jewel Cave National Monument

U.S. Fish and Wildlife Service

The Honorable John Thune, United States Senate

The Honorable Tim Johnson, United States Senate

The Honorable Stephanie Herseth-Sandlin, House of Representatives

Governor Mike Rounds, South Dakota Governor’s Office

South Dakota Department of Environment and Natural Resources

South Dakota State Department of Game, Fish, and Parks

Shelly Deisch

Shannon Percy

South Dakota Division of Forestry

State of South Dakota Department of Transportation

South Dakota Department of Forestry

Custer County Commissioners
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144

Custer County Highway Department

Pennington County Commissioners

Pennington County Planning Department

Tribes:

Cheyenne River Sioux Tribe

Cheyenne-Arapaho Tribes of Oklahoma

Crow Creek Sioux Tribe

Eastern Shoshone Tribe

Flandreau Santee Sioux Tribe

Kiowa Ethnographic Endeavor for 

Preservation

Lower Brule Sioux Tribe

Mandan, Hidatsa and Arikara Nation

Northern Arapaho Tribe

Oglala Sioux Tribe

Rosebud Sioux Tribe

Santee Sioux Tribe

Sicangu Lakota Treaty Council Office

Sisseton-Wahpeton Sioux Tribe

Spirit Lake Sioux Tribe

Standing Rock Sioux Tribe

Yankton Sioux Tribe

Organizations, Groups, and Businesses:

Barton Banks

Betty Baldwin Family Trust

Biodiversity Conservation Alliance

Black Hills 4-Wheelers

Black Hills Electric Cooperative

Black Hills Forest Resource Association

Black Hills Group Sierra Club

Black Hills Power and Light

Dakota Territory Cruisers

Double Triangle Ranch

Geddes Grazing Association

Howell Ranch, Inc.

Kay Linton Trust

Long Shot Ranch

Marquiss Family Trust

Mies, Inc. 

National Wild Turkey Federation

Native Ecosystems Council

Papcke Family Trust

Prairie Hills Audubon Society

R.E. Linde Sawmills, Inc.

Rocky Mountain Elk Foundation

Rushmore Forest Products

SD Association of Professional 

Archeologists

SD Chapter of the Sierra Club

Sky Vue Motel Corp., Inc.

Spearfish Forest Products

The Nature Conservancy

True Ranches, Inc.

Others:

Alexander, Kelsey

Anderson, Garner

Artley, Dick

Baldwin, Roberta & Gene

Baldwin, Gene

Brademeyer, Brian

Compton, Wayne

Couture, Alvin

Davis, Russell D. & Lorraine

Driscoll, Jesse

Gould, Robert

Kloss, Bob
Briggs Spring Environmental Assessment Chapter 4

145

Kuck, Thomas & Peggy

Marty, Les, Shirley & Zane

Morrison, Michael

Orsborn, Paul & Terry

Patton, Dennis

Perino, Janet

Perino, Matt & Donna

Rawhouser, Frank

Rogers, James & Laura

Sorensen, David

Stewart, Cody & Donna

Stuen, Ron

Terry, Blue

Tysdal, Garrett

Tysdal, Harold & Dana

Whitley, David
Briggs Spring Environmental Assessment Chapter 5

146

CHAPTER 5: LITERATURE CITED and GLOSSARY

Literature Cited

Allen, Kurt K. 2003. Evaluation of MPB Activity on the Black Hills National Forest. 

Forest Health Evaluation R2-04-02. Rapid City Service Center, Rapid City, SD.

Beason, J., K. Hutton, A. Panjabi, R. Sparks, and D. Hanni. 2006. Monitoring the Birds 

of the Black Hills: 2005 Field Season Report. Tech. Rep. M-MBBH05-01. 

Rocky Mountain Bird Observatory, Brighton, CO, 113 pp.

Bildstein, K.L., and K. Meyer. 2000. Sharp-shinned hawk (Accipiter striatus). No. 482, 

In: The Birds of North America. A. Poole and F. Gill, eds. The Birds of North 

America, Inc., Philadelphia, Pennsylvania.

Carter, J.M., D.G. Driscoll, J.E. Williamson, and V.A. Lindquist. 2002. Atlas of Water 

Resources in the Black Hills Area, South Dakota. Hydrologic Investigations 

Atlas HA-747. U.S. Geological Survey: Reston, VA. 130 p. Online: 

http://pubs.usgs.gov/ha/ha747/#pdf.

Carter, J.M., D.G. Driscoll, and J.F. Sawyer. 2003. “Ground-Water Resources in the 

Black Hills Area, South Dakota.” Water Resources Investigation Report 03-4049. 

U.S. Geological Survey: Rapid City, SD. 41 p. Online: 

http://pubs.usgs.gov/wri/wri034049/ .

Clark, T.W., and M.R. Stromberg. 1987. Mammals in Wyoming. Museum of Natural 

History. University of Kansas, Lawrence, Kansas. 314 pp.

Cryan, P., M. Bogan, and G. Yanega. 2001. Roosting habits of four bat species in the 

Black Hills of South Dakota. Acta Chiropterologica. 3:43-52.

Davis, A.D., C.J. Webb, and C.J. Paterson. 1998. Comprehensive Inventory of Known 

Abandoned Mine Lands in the Black Hills of South Dakota. South Dakota School 

of Mines and Technology.

DeGraaf, R.M., V.E. Scott, R.H. Hamre, L. Ernst, and S.H. Anderson. 1991. Forest and 

rangeland birds of the United States, Natural History and Habitat Use. USDA 

Forest Service-Agriculture Handbook 688. 625 pp.

Dewitt, E., J.A. Redden, A.B. Wilson, D. Busher, and J.S. Dersch. 1986. U.S. Geological 

Survey Bulletin 1580, Mineral Resource Potential and Geology of the Black Hills 

National Forest, South Dakota and Wyoming. Washington D.C.

DeWitt, E., J.A. Redden, D. Busher, and A.B. Wilson. 1989. Geologic map of the Black 

Hills Area, South Dakota and Wyoming. U.S. Geological Survey Miscellaneous 

Investigations Series Map I-1910, scale 1:250,000.

Drilling, Nancy E. 2010. 2009 Black Hills owl surveys. Technical Report M-SDBBA2-

03. Rocky Mountain Bird Observatory, Brighton, CO, 13 pp.
Briggs Spring Environmental Assessment Chapter 5

147

Duckwitz, J.J. 2001. Small mammal survey of Wind Cave National Park. Masters 

Thesis, South Dakota State University, Brookings. 95 p.

Everett, A.M. 2004. 2004 Field Audit Report: implementation monitoring and 

evaluation of South Dakota forestry best management practices. Black Hills 

National Forest Resource Association. Rapid City, SD. 33p. 

Farrar, Don. 2004. Personal communication with Deanna Reyher. Professor of Botany, 

Iowa State University, expert in Botrychium systematics. January 20, 2004.

Fauna West Wildlife Consultants. 2003. 2003 survey results for small forest owls, the 

northern goshawk and other raptors of interest in the Black Hills, South Dakota. 

Report prepared for South Dakota Department of Game, Fish and Parks, Pierre, 

South Dakota.

FEMA (Federal Emergency Management Agency). 1998. National Flood Insurance 

Program, Q3 Flood Data. GIS data on CD-ROM for South Dakota. Online: 

http://www.fema.gov/plan/prevent/fhm/dfm_ptd.shtm.

Flake, L.D., C.P. Lehman, A.P. Leif, M.A. Rumble, and D.J. Thompson. 2006. The wild 

turkey in South Dakota. South Dakota Department of Game, Fish and Parks, 

Pierre, and South Dakota Agricultural Experiment Station, Brookings. SDAES 

B747. 

Foster, G.R. 1982. Modeling the erosion process. In: Haan, C.T., Johnson, H.P., 

Brakensiek, D.L., eds. Hydrologic Modeling of Small Watersheds. St. Joseph, MI. 

American Society of Agricultural Engineers. Chapter 8, p 295-380.

Frest, T. J., and E.J. Johannes. 2002. Land snail survey of the Black Hills National 

Forest, South Dakota and Wyoming summary Report, 1991-2001. USDA Forest 

Service. Black Hills National Forest, Custer, South Dakota. 127 pp.

Frison, George C. 1991 Prehistoric Hunters of the High Plains. Academic Press, New 

York.

Ghalambor, C. 2003. Conservation assessment of the pygmy nuthatch in the Black Hills 

National Forest, South Dakota and Wyoming. USDA, Forest Service, Rocky 

Mountain Region, Black Hills National Forest. Custer, South Dakota. 

http://www.fs.fed.us/r2/blackhills/projects/planning/assessments/pygmy_nuthatch

.pdf .

Giroir G., C.White and R. Sparks. 2007. Monitoring the birds of the Black Hills, 2007 

field season report. Technical Report M-MBBH07-01. Rocky Mountain Bird 

Observatory, Brighton, CO, 81 pp.

Goodman, Ronald. 1992. Lakota Star Knowledge: Studies in Lakota stellar theology. 

Second ed. Siŋte Gleska University, Mission, South Dakota.

Gould, J.J. 2003. Hydrologic modeling of high-intensity, short-duration rainfall on 

burned ponderosa pine forested watersheds existing in highly permeable geology 

within the Black Hills of South Dakota. M.S. Thesis. South Dakota School of 

Mines and Technology: Rapid City, SD. 121 p.

Grafe, E. and P. Horsted. 2002. Exploring with Custer: The 1874 Black Hills 

Expedition. Golden Valley Press: Custer, SD. 300 p.
Briggs Spring Environmental Assessment Chapter 5

148

Graham, Russell T., Sarah McCaffrey, Theresa B. Jain. 2004 Science basis for changing 

forest structure to modify wildfire behavior and severity, Gen. Tech. Rep. RMRSGTR-120. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, 

Rocky Mountain Research Station. Online: 

http://www.fs.fed.us/rm/pubs/rmrs_gtr120.pdf .

Griffin, S.L., L.A. Rice, C.S. DePerno, and J.A. Jenks. 1999. Seasonal movements and 

home ranges of white-tailed deer in the central Black Hills, South Dakota and 

Wyoming, 1993-97. South Dakota Department of Game, Fish and Parks, 

Pittman-Robertson Game Rep., W-75-R-34, Pierre, South Dakota.

Hann, Wendel, D. Havlina, A. Shlisky, et al. 2003. Interagency and The Nature 

Conservancy fire regime condition class website. USDA Forest Service, US 

Department of the Interior, The Nature Conservancy, and Systems for 

Environmental Management. Online:

http://frames.nbii.gov/portal/server.pt?open=512&objID=309&&PageID=1397&

mode=2&in_hi_userid=2&cached=true .

Higgins, K.F., E.D. Stukel, J.M. Goulet, and D.C. Backlund. 2000. Wild mammals of 

South Dakota. South Dakota Department of Game, Fish and Parks, Pierre, South 

Dakota. 278 pp.

Horsted, Paul. 2006. The Black Hills: Yesterday & Today. Golden Valley Press: Custer, 

SD. 304 p.

Hoxie, J. and C. Engelskirger. 2009. 2009 Field Audit Report: implementation 

monitoring and evaluation of South Dakota forestry best management practices. 

Black Hills Forest Resource Association, South Dakota Department of 

Environment and Natural Resources, Lawrence County Conservation District. 

Rapid City, SD. 18p. 

Huffman, David W. and Margaret M. Moore. March 2004. Responses of Fendler 

ceanothus to overstory thinning, prescribed fire, and drought in an Arizona 

ponderosa pine forest. Forest Ecology and Management. Pg 105-115.

Huxoll, C. 2008. 2007 Annual report: Big game harvest projections. South Dakota 

Game Report No, 2008-02. South Dakota Dept. of Game, Fish and Parks, Pierre, 

South Dakota. 72 pp.

Huxoll, C. 2009. 2008 Annual report: Big game harvest projections. South Dakota 

Game Report No, 2009-03. South Dakota Dept. of Game, Fish and Parks, Pierre, 

South Dakota. 75 pp.

Huxoll, C. 2010. 2009 Annual report: Big game harvest projections. South Dakota 

Game Report No, 2010-01. South Dakota Dept. of Game, Fish and Parks, Pierre, 

South Dakota. 83 pp.

Johnson, A.S., and S.H. Anderson. 2003. Conservation assessment for the northern sawwhet owl in the Black Hills National Forest, South Dakota and Wyoming. 

USDA, Forest Service, Rocky Mountain Region, Black Hills National Forest. 

Custer, South Dakota. 27pp. Online: 

http://www.fs.fed.us/r2/blackhills/projects/planning/assessments/northern_saw_w

het_owl.pdf . 
Briggs Spring Environmental Assessment Chapter 5

149

Lee, W.K. 2001. Wyoming Silviculture Best Management Practices Field Audit: 

Implementation, Monitoring, and Evaluation. Wyoming Timber Industry 

Association and Wyoming Department of Environmental Quality. Saratoga, 

Wyoming. 17 p.

Lee, W.K. and Everett, A.M. 2001. South Dakota Silviculture Best Management 

Practices Audit Project Final Report: Implementation Monitoring and Evaluation. 

Black Hills Forest Resource Association and South Dakota Department of 

Environment and Natural Resources. Rapid City, SD. 48 p.

Luce, B., A. Cerovski, B. Oakleaf, J. Priday, and L.Van Fleet. 1999. Atlas of birds, 

mammals, reptiles, and amphibians in Wyoming. Wyoming Game and Fish 

Department, Wildlife Division, Biological Services Section, Lander, Wyoming.

Marriot, H., and D. Faber-Langendoen. 2000. The Black Hills community inventory, 

volume 2: Plant community descriptions. The Nature Conservancy, Midwest 

Conservation Science Center and Association for Biodiversity Information.

Minneapolis, Minnesota. 326 pp.

Marrone, G.M. 2002. Field guide to butterflies of South Dakota. South Dakota 

Department of Game, Fish and Parks, Pierre, South Dakota. 478 pp.

McCallum, D.A. 1994. Review of technical knowledge: flammulated owl. Pages 14-46 

in Hayward G.D. and J. Verner technical editors. Flammulated, boreal, and great 

gray owls in the United States: A technical conservation assessment. Gen. Tech. 

Rep. RM-253. U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Forest and Range Experiment Station, Fort Collins, Colorado. 214 pp. 

Megahan, W.F. 1986. Recent studies on erosion and its control on forest lands in the 

United States. In: Richard, F. ed. Range basin sediment delivery: Proceedings, 

1986, August. Albuquerque, NM. IAHS Publication 159, Wallingford, Oxon, 

United Kingdom:178-189.

Mehl, S.M. 1992. Growth descriptions for the major cover types in the Rocky Mountain 

Region. In: USDA Forest Service GTR-RM-213, Old-growth forests in the 

Southwest & Rocky Mountain regions, proceedings of a workshop. 

Mohren, S. 2002. Habitat evaluation and density estimates for the black-backed 

woodpecker (Picoides arcticus) and northern three-toed woodpecker (Picoides 

tridactylus) in the Black Hills National Forest. M.Sc. Thesis, University of 

Wyoming, Laramie, Wyoming. 110pp.

NatureServe. 2009. NatureServe Explorer: An online encyclopedia of life 

[webapplication]. Version 7.1. Arlington, Virginia. Online: 

http://www.natureserve.org/explorer . (Accessed August 11, 2010).

Neary, D.G., K.C. Ryan, and L.F. DeBano eds. 2005. Wildland Fire in ecosystems: 

effects of fire on soils and water. Gen. Tech. Rep. RMRS-GTR-42-vol.4. Ogden, 

UT: USDA Forest Service, Rocky Mountain Research Station. 250p.

Padilla, Matthew J. and Ami L. Schlosser. 2011. A Level III Cultural Resource 

Inventory of the Briggs Spring Analysis Project, Pennington County, South 

Dakota. Black Hills National Forest, Hell Canyon Ranger District. BKF # 
Briggs Spring Environmental Assessment Chapter 5

150

R2008020300114. Section 106 Report on file at the Black Hills National Forest 

Supervisor’s Office.

Panjabi, Arvind. 2001. Monitoring birds of the Black Hills: Year 1. Final Report. 

Rocky Mountain Bird Observatory, Fort Collins, Colorado. 96 pp.

Panjabi, Arvind. 2003. Monitoring birds of the Black Hills: Year 2. Final Report. 

Rocky Mountain Bird Observatory. Fort Collins, Colorado. 125 pp.

Panjabi, A. 2004. Monitoring the birds of the Black Hills: Year 3. Annual Report 

submitted to Black Hills National Forest. Rocky Mountain Bird Observatory, 

Brighton, Colorado. 58 pp.

Panjabi, A. 2005. Monitoring the birds of the Black Hills: Year 4. Annual Report 

submitted to Black Hills National Forest. Rocky Mountain Bird Observatory, 

Brighton, Colorado. 67 pp.

Parrish, J.B.; Herman, D.J.; Reyher, D. J. 1996. A century of change in Black Hills forest 

and riparian ecosystems. B 722. Brookings, SD: U.S. Department of Agriculture, 

Forest Service, Agriculture Experiment Station, South Dakota State University. 

20 p.

Peterson, R.A. 1995. The South Dakota breeding bird atlas. South Dakota 

Ornithologists’ Union. Northern Prairie Wildlife Research Center web home 

page. Jamestown, North Dakota. Online: 

http://www.npwrc.usgs.gov/resource/distr/birds/sdatlas/sdatlas.htm .

Powder River Eagle Studies. 2000. Northern Black Hills broad-winged hawk occurrence 

and distribution study. Phase Two Conclusion: Nest Search & Summary of Nest 

Site Characteristics. Submitted to: Wharf Resources Partnership, HC 37, Box 

811, Lead, South Dakota.

Rabe, M., T. Morrell, H. Green, J. DeVos Jr., and C. Miller. 1998. Characteristics of 

ponderosa pine snag roosts used by reproductive bats in Northern Arizona. 

Journal of Wildlife Management. 62(2):612-621.

Rom, Lance, Tim Church and Michele Church. 1996. Black Hills National Forest 

Cultural Resources Overview. Ms. on file at the Black Hills National Forest, 

Supervisor’s Office.

Royer, R.A., and G.M. Marrone. 1992. Conservation status of the regal fritillary 

(Speyeria idalia) in North and South Dakota. Rep. to the U.S. Department of 

Interior, Fish and Wildlife Service, Denver, Colorado. 44 pp.

Rumble, M.A., L. Benkobi and R.S. Gamo. 2005. Elk responses to humans in a densely 

roaded area. Intermountain Journal of Sciences. Vol. 11, No.102:10-24.

Saab, V.A. and K.T. Vierling. 2001. Reproductive success of Lewis’s woodpecker in 

burned pine and cottonwood riparian forests. The Cooper Ornithological Society. 

The Condor 103: 491-501.

Sando, S.K. 1998. Techniques for estimating peak-flow magnitude and frequency 

relations for South Dakota streams. USGS Water-Resources Investigations 

Report 98-4055. 52p.
Briggs Spring Environmental Assessment Chapter 5

151

Sandrini, J. 2007. 2006 job completion report, elk. Casper Region, Herd Unit 740. 

Wyoming Game and Fish Department. Newcastle.

Sauer, J.R., J.E. Hines, and J. Fallon. 2005. The North American breeding bird survey, 

results and analysis 1966-2005. Version 6.2.2006. USGS Patuxent Wildlife 

Research Center, Laurel, MD. Online: http://www.mbrpwrc.usgs.gov/bbs/bbs.html . 

Schaupp, Willis C. Jr. 2011. Aerial overview detection survey in 2010, Black Hills of 

South Dakota and Wyoming, Service Trip Report RCSC-03-11. 6p. February 02, 

2011.

Schmidt, C.A. 2003a. Conservation assessment for the northern myotis in the Black 

Hills National Forest, South Dakota and Wyoming. USDA, Forest Service, 

Rocky Mountain Region, Black Hills National Forest. Custer, South Dakota. 

Online: 

http://www.fs.fed.us/r2/blackhills/projects/planning/assessments/northern_myotis.

pdf . 

Schmidt, C.A. 2003b. Conservation assessment for the small-footed myotis in the Black 

Hills National Forest, South Dakota and Wyoming. USDA, Forest Service, 

Rocky Mountain Region, Black Hills National Forest. Custer, South Dakota. 

Online: 

http://www.fs.fed.us/r2/blackhills/projects/planning/assessments/small_footed_ba

t.pdf .

Schmidt, C.A. 2003c. Conservation assessment for the long-eared myotis in the Black 

Hills National Forest, South Dakota and Wyoming. USDA, Forest Service, 

Rocky Mountain Region, Black Hills National Forest. Custer, South Dakota. 

Online: 

http://www.fs.fed.us/r2/blackhills/projects/planning/assessments/long_ear_bat.pdf

Schmidt, C.A. 2003d. Conservation assessment for the long-legged myotis in the Black 

Hills National Forest, South Dakota and Wyoming. USDA, Forest Service, 

Rocky Mountain Region, Black Hills National Forest. Custer, South Dakota. 

Online: 

http://www.fs.fed.us/r2/blackhills/projects/planning/assessments/long_legged_bat.

pdf .

SD DENR (South Dakota Department of Environment and Natural Resources). 1998. 

The 1998 South Dakota 303(d) waterbody list and supporting documentation. 109

p. Online: http://denr.sd.gov/des/sw/IntegratedReports.aspx . 

SD DENR (South Dakota Department of Environment and Natural Resources). 1999. 

Article 74:51. The administrative rules of South Dakota (ARSD 74:51:01,:02, 

and :03). South Dakota's Surface Water Quality Standards.

SD DENR (South Dakota Department of Environment and Natural Resources). 2002. 

South Dakota total maximum daily load waterbody list 2002. 67 p. Online: 

http://denr.sd.gov/des/sw/IntegratedReports.aspx . 
Briggs Spring Environmental Assessment Chapter 5

152

SD DENR (South Dakota Department of Environment and Natural Resources). 2004. 

The 2004 South Dakota integrated report for surface water quality assessment. 

230 p. Online: http://denr.sd.gov/des/sw/IntegratedReports.aspx .

SD DENR (South Dakota Department of Environment and Natural Resources). 2006. 

The 2006 South Dakota integrated report for surface water quality assessment. 

211 p. Online: http://denr.sd.gov/des/sw/IntegratedReports.aspx . 

SD DENR (South Dakota Department of Environment and Natural Resources). 2008. 

The 2008 South Dakota integrated report for surface water quality assessment. 

262 p. Online: http://denr.sd.gov/des/sw/IntegratedReports.aspx .

SD DENR (South Dakota Department of Environment and Natural Resources). 2010. 

The 2010 South Dakota integrated report for surface water quality assessment. 

272 p. Online: http://denr.sd.gov/des/sw/IntegratedReports.aspx . 

SDGFP (South Dakota Game, Fish and Parks). 2010a. Eagle awareness: Where to see 

eagles in South Dakota. South Dakota Game, Fish and Parks. Online: 

http://gfp.sd.gov/outdoor-learning/bald-eagle-awareness-days/range.aspx .

SDGFP (South Dakota Game, Fish and Parks). 20010b. Eagle awareness: Midwinter 

survey results. South Dakota Game, Fish and Parks. Online:

http://gfp.sd.gov/outdoor-learning/bald-eagle-awareness-days/midwinter.aspx .

SDGFP (South Dakota Game, Fish and Parks). 2010c. South Dakota snakes: Redbelly 

snake. South Dakota Game, Fish and Parks. Online: 

http://gfp.sd.gov/wildlife/critters/amphibians-reptiles/snakes/bLack-hills-redbellysnake.aspx . 

SDNHP (South Dakota Natural Heritage Program). 2006. Rare, threatened or 

endangered animals tracked by the South Dakota Natural Heritage Program. 

South Dakota Natural Heritage Program. Online: 

http://www.sdgfp.info/Wildlife/Diversity/RareAnimal.htm . 

SDSU (South Dakota State University), South Dakota Cooperative Extension Service, 

U.S. Environmental Protection Agency, South Dakota Department of 

Environment and Natural Resources and South Dakota Department of 

Agriculture. 2003. Forestry Best Management Practices for South Dakota. 39 p.

Sheppard, Wayne D. and Lance A. Asherin. 2004. Assessment of aspen clonal 

conditions on the Black Hills National Forest. USDA-Rocky Mountain Research 

Station, Ft. Collins, CO. October 25, 2004.

Sheppard, Wayne D. and Michael A. Battaglia. 2002. Ecology, silviculture, and 

management of Black Hills ponderosa pine. Gen. Tech. Rep. RMRS-GTR-97. 

Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky 

Mountain Research Station. 112p.

Smith, B.E. 2003. Conservation assessment of the northern leopard frog in the Black 

Hills National Forest, South Dakota and Wyoming. U.S. Department of 

Agriculture, Forest Service, Black Hills National Forest, Custer, South Dakota. 

78pp.
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153

Stefanich, M.R. 2001. Draft conservation assessment for the tawny crescent in the Black 

Hills National Forest of South Dakota and Wyoming. Black Hills National 

Forest. March 2001.

Stephens, R.M. and S.H. Anderson. 2002. Conservation assessment for the Cooper’s 

hawk and sharp-shinned hawk in the Black Hills National Forest, South Dakota 

and Wyoming. USDA, Forest Service, Rocky Mountain Region, Black Hills 

National Forest. Custer, South Dakota. Online: 

http://www.fs.fed.us/r2/blackhills/projects/assessments/coopers_ss_hawk.pdf . 

Sundstrom, Linea. 1989. Culture history of the Black Hills with reference to adjacent 

areas of the Northern Great Plains. J & L Reprint Company, Lincoln, NE.

Tallman, D.A., D.L. Swanson, and J.S. Palmer. 2002. Birds of South Dakota. Third 

Edition. Midstates/Quality Quick Print, Aberdeen, South Dakota. 441 pp.

Thomas, S. 2008. Best Management Practices and Watershed Conservation Practices: 

Summary Report 2002-2007, Hell Canyon Ranger District. Black Hill National 

Forest. Rapid City, South Dakota. 53 p.

Tigner, J. and E. Stukel. 2003. Bats of the Black Hills: A description of status and 

conservation needs. South Dakota Department of Game, Fish, and Parks Wildlife 

Division Report 2003-05. 94 pp.

Turner, R.W. 1974. Mammals of the Black Hills of South Dakota and Wyoming. 

University of Kansas. Museum of Natural History. Miscellaneous Publication 

60:1-178.

USDA Forest Service. 1996. Final environmental impact statement for the revised land 

and resources management plan for the Black Hills National Forest. U.S. 

Department of Agriculture, Forest Service, Black Hills National Forest. Custer, 

South Dakota. December 1996. Online: 

http://www.fs.fed.us/r2/blackhills/projects/planning/index.shtml .

USDA Forest Service. 1999. Indicators for analysis of water/road interactions, Appendix 

2. In: Roads analysis, informing decisions about managing the National Forest 

transportation system. Miscellaneous Report FS-643. USDA Forest Service, 

Washington Office.

USDA Forest Service. 2000. Expert interview summary for the Black Hills National 

Forest Land and Resource Management Plan Amendment. Unpublished Rep. 

U.S. Department of Agriculture, Forest Service, Black Hills National Forest, 

Custer, South Dakota. Online: 

http://fsweb.blackhills.r2.fs.fed.us/int_dir/00_10_25_ExpertInterviewSum.pdf .

USDA Forest Service. 2003. Fire and Archaeology: A workshop addressing fire 

behavior, the federal fire policy, and managing risks to cultural resources. 

prepared by Region 5, Forest Service, Vallejo, California.

USDA Forest Service. 2003a. Black Hills National Forest, Forest Plan Best 

Management Practices Evaluation. Custer, SD.
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154

USDA Forest Service. 2004. Black Hills National Forest 2002 monitoring and five-year 

evaluation report. U.S. Department of Agriculture, Forest Service, Black Hills 

National Forest, Custer, South Dakota.

USDA Forest Service. 2004a. FY2003 monitoring and evaluation report. U.S. Dept. of 

Agriculture, Forest Service, Black Hills National Forest, Custer, South Dakota.

USDA Forest Service. 2005. Final Environmental Impact Statement for the Phase II 

Amendment to the 1997 Revised Land and Resource Management Plan for the 

Black Hills National Forest. US Department of Agriculture-Forest Service, 

Black Hills National Forest. Custer, South Dakota. October, 2005. Online: 

http://www.fs.fed.us/r2/blackhills/projects/planning/index.shtml . 

USDA Forest Service. 2005a. Forest Service Manual, Black Hills National Forest. FSM 

2600 – wildife, fish and sensitive plant habitat management. Chapter 20 –habitat 

planning and evaluation. Supplement number: r2_bh_2600-2005-7. Online: 

http://fsweb/directives/fsm/2600/bh_supp_2600-2005-1.doc . 

USDA-Forest Service. 2006. 1997 Revised Land and Resource Management Plan for the 

Black Hills National Forest, as amended by the Phase II Amendment. United 

States Department of Agriculture-Forest Service, Black Hills National Forest, 

Custer, South Dakota. March, 2006.

USDA Forest Service. 2006a. FY2005 monitoring and evaluation report. U.S. Dept. of 

Agriculture, Forest Service, Black Hills National Forest, Custer, South Dakota.

USDA Forest Service. 2006b. Forest Service handbook, Region 2 supplement, 2509.25 –

Watershed Conservation Practices Handbook. Rocky Mountain Region, Ft. 

Collins, Colorado. 58 p.

USDA Forest Service. 2006c. Forest Service minerals and geology program handbook 

FSH 2809.15. United States Department of Agriculture-Forest Service.

USDA Forest Service. 2007. FY2006 monitoring and evaluation report. U.S. Dept. of 

Agriculture, Forest Service, Black Hills National Forest, Custer, South Dakota.

USDA Forest Service. 2007a. Ground Water Technical Guide. Washington Office,

Washington DC. 295 p.

USDA Forest Service. 2008. FY2007 monitoring and evaluation report. U.S. Dept. of 

Agriculture, Forest Service, Black Hills National Forest, Custer, South Dakota.

USDA Forest Service. 2008a. Forest Service Manual 2880 - Geologic resources, hazards, 

and services. Washington Office, Washington DC. 18 p.

USDA Forest Service. 2008b. Best Management Practices and Watershed Conservation 

Practice, Summary Report 2002-2007. Black Hills National Forest, Hell Canyon 

Ranger District. 

USDA Forest Service. 2009. FY2008 monitoring and evaluation report. U.S. Dept. of 

Agriculture, Forest Service, Black Hills National Forest, Custer, South Dakota.

USDA Forest Service. 2009a. Memorandum of understanding between USDA Forest 

Service, Rocky Mountain Region and Northern Region and South Dakota 
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Department of Environment and Natural Resources. Forest Service Agreement 

#09-MU-11020000-014. 8 p.

USDA Forest Service. 2010. FY2009 monitoring and evaluation report. U.S. Dept. of 

Agriculture, Forest Service, Black Hills National Forest, Custer, South Dakota.

USDA Forest Service. 2010a. Region 2, Threatened, Endangered and Sensitive Species 

homepage. U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Region, Golden, Colorado. Online: 

http://fsweb.r2.fs.fed.us/rr/R2_TES_Site_2007/sensitive.html .

USDA NRCS (Natural Resources Conservation Service). 2009. Soil data mart, 

Geospatial data for soil survey area SD604 – Custer and Pennington Counties, 

Black Hills Parts, South Dakota. Online: http://soildatamart.nrcs.usda.gov/ .

Accessed August 30, 2010.

USFWS (U.S. Fish and Wildlife Service). 2008. Birds of conservation concern 2008. 

Division of Migratory Bird Management, Arlington, Virginia. 93pp. Online: 

http://www.fws.gov/migratorybirds/reports/BCC2008/BCC2008m.pdf . 

USFWS (U.S. Fish and Wildlife Service). 2010. Species account – Bald eagle. U.S. 

Fish and Wildlife Service, South Dakota Ecological Services Field Office. 

Online: http://www.fws.gov/southdakotafieldoffice/EAGLE.htm .

USFWS (U.S. Fish and Wildlife Service. 2010a. Federal endangered and threatened 

species list by county for South Dakota. September 14, 2010. Online: 

http://southdakotafieldoffice.fws.gov/endsppbycounty.htm

USFWS (U.S. Fish and Wildlife Service). 2011. Federal endangered and threatened 

species list by county for South Dakota. U.S. Fish and Wildlife Service, South 

Dakota Ecological Services Field Office. Online: 

http://www.fws.gov/southdakotafieldoffice/endsppbycounty.htm . 

USGS (US Geological Survey). 2008. National hydrography dataset, watershed boundary 

dataset. Online: http://nhd.usgs.gov/data.html . Accessed April 21, 2010.

USGS (US Geological Survey). 2008a. National water information system (NWIS). 

streamflow statistics for selected stations on Redbird Canyon. Online: 

http://waterdata.usgs.gov/sd/nwis . Accessed November 13, 2008.

Vonhof, M.J., and R.M. Barclay. 1997. Use of tree stumps as roosts by the western 

long-eared bat. Journal of Wildlife Management. 61(3):674-684.

Webb, C., P. Rahn, and A. Davis. 1998. Abandoned and inactive mine inventory in the 

Black Hills National Forest of South Dakota. South Dakota School of Mines and 

Technology.

Wells-Gosling, N., and L.R. Heaney. 1984. Glaucomys sabrinus. Mammalian species 

no. 229, The American Society of Mammalogists.

Whitaker, J.O. Jr. 1972. Zapus hudsonius. Mammalian species no. 11. The American 

Society of Mammalogists.
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White, C. and G. Giroir. 2009. Monitoring the birds of the Black Hills, 2008 field season 

report. Tech. Rep. M-MBBH-USFS08, SDDGF08. Rocky Mountain Bird 

Observatory, Brighton, CO, 57 pp.

WYNDD (Wyoming Natural Diversity Database). 2002. Species abstracts, element 

occurrence records and township/range list. Species of Special Concern, Black 

Hills National Forest. June 2002.

Glossary

Activity Fuels 

Fuels resulting from or altered by mechanical treatments, such as tiimber harvest 

or thinning, as opposed to naturally created fuels. 

Age Class 

Groups of trees approximately the same age. 

Allotment 

A designated area of land available for livestock grazing upon which a specified 

number and kind of livestock may be grazed under a range allotment management 

plan. It is the basic land unit used to facilitate management of the range resource 

on National Forest lands. 

Area of Potential Effects 

The geographic area or areas within which an undertaking may cause changes in 

the character or use of historic properties, if any such properties exist. 

Arterial Road 

Provides service to large land areas and usually connects with public highways or 

other Forest arterial roads to form an integrated network of primary travel routes. 

The location and standard are often determined by a demand for maximum 

mobility and travel efficiency rather than specific resource management service. 

It is usually developed and operated for long-term land and resource management 

purposes and constant service. 

At-Risk-Community (ARC)

An area (A) that is comprised of —(i) an interface community as defined in the 

notice entitled “Wildland Urban Interface Communities Within the Vicinity of 

Federal Lands That Are At High Risk From Wildfire” issued by the Secretary of 

Agriculture and the Secretary of the Interior in accordance with Title IV of the 

Department of the Interior and Related Agencies Appropriations Act, 2001 (114 

Stat. 1009) (updated 66 Fed. Reg. 43384, August 17, 2001); or (ii) a group of 

homes and other structures with basic infrastructure and services (such as utilities 

and collectively maintained transportation routes) within or adjacent to Federal 

land; (B) in which conditions are conducive to a large-scale wildland fire 

disturbance event; and (C) for which a significant threat to human life or property 

exists as a result of a wildland fire disturbance event.” 
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Available Fuel 

The total mass of ground, surface and canopy fuel per unit area consumed by a 

fire, including fuels consumed in postfrontal combustion of duff, organic soils, 

and large woody fuels.

Basal Area 

The cross-sectional area of a stand of trees measured at 4 feet 6 inches from the 

ground. The area is expressed in square feet per acre.

Best Management Practices (BMPs) 

Are methods, measures, or practices selected by an agency to meet its nonpoint 

source control needs. BMPs include but are not limited to structural and 

nonstructural controls, and operation and maintenance procedures. BMPs can be 

applied before, during and after pollution-producing activities to reduce or 

eliminate the introduction of pollutants into receiving waters (40 CRF 130.2(m)). 

An agreement between the USFS and the State of South Dakota stipulates that 

USFS Region 2 Watershed Conservation Practices (WCPs) will be used above 

and beyond South Dakota BMPs to comply with state and federal water quality 

regulations related to the Clean Water Act. 

Big Game 

Certain wildlife that may be hunted for sport under state laws and regulations. In 

the Black Hills, these animals include deer, elk, turkey, mountain goats, and 

bighorn sheep.

Biological Evaluations 

As defined by FSM 2670.5, a biological evaluation is a documented Forest 

Service review of Forest Service programs or activities in sufficient detail to 

determine how an action or proposed action may affect any threatened, 

endangered, proposed, or sensitive species. 

BMPs 

(See "Best Management Practices.")

Board Foot 

timber measurement equaling the amount of wood contained in a board one-inch 

thick, 12-inches long, and 12-inches wide.

Broadcast Burning 

A management ignited fire, allowed to burn under specific conditions 

(prescriptions) and within established boundaries to achieve some landmanagement objective.

Browse 

Twigs, leaves and young shoots of trees and shrubs on which animals feed. 

Canopy

The cover by vegetation and/or branches. Often but not always restricted to the 

tree layer or greater than six feet tall.
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Canopy Closure/Cover

The percentage of the ground and/or sky covered by vegetation and/or branches. 

These are perceived from a human point of view perpendicular to flat ground.

Canopy Fuels

The live and dead foliage, live and dead branches, and lichen of trees and tall 

shrubs that lie above the surface fuels. (See also Available Canopy Fuel)

Clearcut 

The harvesting (removal) in one cut of all trees in an area. The area harvested 

may be a patch (zero-to-ten acres), stand (not more than 40 acrea), or strip.

Coarse Woody Debris (CWD)

Woody material greater than 3 inches in diameter, that is derived from tree limbs, 

boles, and roots (excluding stumps) in various stages of decay. 

Collector Road

Serves smaller land areas than a Forest arterial road and is usually connected to a 

Forest arterial or public highway. Collects traffic from Forest local roads and/or 

terminal facilities. The location and standard are influenced by both long-term 

multi-resource service needs, as well as travel efficiency. May be operated for 

either constant or intermittent service depending on land use and resource 

management objectives for the area served by the facility.

CMAI 

(See "Culmination Mean Annual Increment.”)

Compaction 

The packing together of soil particles by forces exerted at the soil surface, 

resulting in increased soil density. 

Conifer 

A group of cone-bearing trees, mostly evergreen, such as the pine and spruce. 

Council on Environmental Quality (CEQ) 

An advisory council to the President established by the National Environmental 

Policy Act (NEPA) of 1969.

Cover Type 

The vegetative species that dominates a site. Cover types are named for one plant

species or non-vegetated condition presently (not potentially) dominant, using 

canopy or foliage cover as the measure of dominance. 

Crown 

The upper part of a tree or other woody plant carrying the main branch system 

and foliage and surmounting at the crown base a more or less clean stem.

Crown Fire 

Any fire that burns in canopy fuels.

Crown Fire Hazard 

A physical situation (fuels, weather, and topography) with potential for causing 

harm or damage as a result of crown fire.
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Cubic Foot 

A unit of measure usually referring to wood volume (1 foot wide by 1 foot long 

by 1 foot thick).

Culmination Mean Annual Increment (CMAI) 

The point at which a tree or stand achieves its greatest average growth, based on 

expected growth, according to the management systems and utilization standards 

assumed in the Forest Plan.

Cultural Resources 

(See "Heritage Resources.”)

Cumulative Effects 

Collective results of past, present, and reasonably foreseeable future actions, 

regardless of which agency or person undertakes the actions.

DBH 

(See "Diameter at Breast Height.”)

Dead Fuels

Fuels with no living tissue within which moisture content is governed almost 

entirely by solar radiation.

Decision Documents 

Documents that provide the criteria and information used in the

formulation and evaluation of alternatives and the preferred alternative.

Design Criteria 

Management measures included in the design of a project to avoid or minimize 

potential resource impacts. 

Diameter at Breast Height (DBH) 

The diameter of a standing tree at a point 4 feet, 6 inches from ground level.

Ecosystem 

A community of living plants and animals interacting with each other and with 

their physical environment. A geographic area where it is meaningful to address 

the interrelationships with human social systems, sources of energy, and the 

ecological processes that shape change over time.

Eligible (Heritage Resources)

Indicates a specific heritage resource qualifies for or is already listed in the 

National Register of Historic Places.

Endangered Species 

Any species of animal or plant in danger of extinction throughout all or a

significant portion of its range and so designated by the Secretary of Interior in 

accordance with the 1973 Endangered Species Act.

Ephemeral Streams 

A stream or portion of a stream that has flowing water only in direct response to 

precipitation in the immediate locality (watershed or catchment basin), and only 

flows during and for a short duration after the precipitation event. Runoff from 

rainfall or snowmelt is the primary source of water for stream flow. Groundwater 
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is not a source of water for the stream and thus the stream bed is at all times above 

the water table. 

Erosion 

The wearing away of the land surface by running water, wind, ice, gravity, or 

other geological activities.

Erosion Hazard Rating 

The probability of soil loss from off-road and off-trail disturbance activities that 

remove most or all of the protective ground cover and expose the soil surface. 

Erosion hazard ratings are developed by the Natural Resource Conservation 

Service (NRCS) based on forest soil properties. 

Fire Hazard

A fuel complex, defined by volume, type, condition, arrangement and location, 

that determines the ease of ignition and the resistance to control. 

Fire Incidence 

The average number of fires in a specified area during a specified time period.

Fire Occurrence 

Number of fires per unit time in a specified area (synonym for fire frequency).

Fire Regime Condition Class (FRCC) 

A tool developed to evaluate current against natural landscape characteristics with 

respect to vegetation-fuel composition and structure, fire frequency, fire severity, and 

other disturbances. Fire Regime Condition Class characterizes the degree of 

departure from natural fire, vegetation, and fuel regimes.

• Fire Regime Condition Class I - Fire regimes are within natural range, and risk 

of losing key ecosystem components is low. Vegetation attributes (species 

composition and structure) are intact and functioning within historical range.

• Fire Regime Condition Class II - Fire regimes have been moderately altered 

from their natural range. The risk of losing key ecosystem components is 

moderate. Fire frequencies have departed from natural frequencies by one or 

more return intervals. Vegetation attributes have been moderately altered.

• Fire Regime Condition Class III - Fire regimes have been significantly altered 

from their natural range. The risk of losing key ecosystem components is high. 

Fire frequencies have departed from natural frequencies by several return 

intervals. Vegetation attributes have been significantly altered.

Fire Risk 

The chance of a fire starting, as affected by the nature and incidence of causative

agents, including lightning, people, and industry. Three risk scales are used: high, 

moderate, and low. High-risk areas include locations where lightning, people, or 

industry have commonly caused fire in the past; moderate-risk areas include 

locations where lightning, people, or industry have periodically caused fire in the 

past; and low-risk areas include locations where lightning, people, or industry 

have infrequently caused fire in the past.
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Fire Suppression 

All the work and activities connected with fire-extinguishing operations

beginning with discovery and continuing until the fire is completely extinguished.

Fire Suppression Objective 

To suppress wildfires at minimum costs consistent with land and resource 

management objectives and fire-management direction as determined by National 

Fire Management Analysis System (NFMAS). This includes all work and 

activities associated with fire-extinguishing operations beginning with discovery 

and continuing until the fire is completely extinguished. 

Fireline Intensity 

The rate of heat energy released per unit time per unit length of a fire front.

Numerically, it is the product of the heat combustion, quality of fuel consumed 

per unit area in the fire front, and the rate of spread of a fire as measured in BTUs 

per second per foot of the fire front.

Floodplain

The lowland and relatively flat areas adjacent to streams and standing bodies of 

water and coastal waters, including debris cones and flood-prone areas of offshore 

islands. 100-year floodplains include, at a minimum, the area subject to a 1% 

chance of flooding in any given year. 

Forage 

Vegetation used for food by wildlife, particularly ungulate wildlife and domestic

livestock.

Forbs 

Any herbaceous plant other than those in the grass, sedge, and rush families. For 

example, any non-grass-like plant that has little or no woody material.

Forest System Roads 

Roads that are part of the Forest Development Transportation System that

includes all existing and planned roads as well as other special and terminal 

facilities designated as part of the Forest Development Transportation System.

Fuel Breaks 

Generally wide strips of land 100-300 feet in width on which native vegetation

has been modified so that fires burning into them can be more readily controlled. 

Some fuel breaks contain fire lines such as roads or hand lines that can be 

widened.

Fuel Complex

The combination of ground, surface, and canopy fuel strata.

Fuel Loading 

The volume of the available or burnable fuels in a specified area, usually

expressed in tons per acre.

Fuel Model

A set of surface fuel bed characteristics (load and surface-area-to-volume-ratio by 

size class, heat content, and depth) organized for input to a fire model. Standard 
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fuel models (Anderson 1982) have been stylized to represent specific fuel 

conditions. 

Fuel Treatment 

Any manipulation or removal of fuels to reduce the likelihood of ignition and/or 

to lessen potential damage and resistance to control, including lopping, chipping, 

crushing, piling, and burning (synonym for fuel modification).

Fuels 

The organic materials that will support the start and spread of a fire: duff, litter, 

grass, weeds, forbs, brush, trees, and dead woody materials.

Goal 

Broad, general statement that encompasses the desired future conditions that the 

U.S. Forest Service seeks to attain.

Grass/Forb, Grass/Forb Stage (Structural Stage 1) (See Structural Stages - Structural 

Stage 1)

Guideline 

Preferred or advisable courses of action; deviations from guidelines are 

permissible, but the responsible official must document the reasons for the 

deviation.

Hardwood 

Pertains to broadleaf trees.

Herbicide 

A chemical substance used for killing or suppressing plants.

Heritage Resources 

The physical remains (including but not limited to artifacts, structures, landscape 

modifications, rock art, trails, or roads) and conceptual content or context (as a 

setting for legendary, historic, or prehistoric events, such as a sacred area for 

native peoples) of an area.

Ignition (Fire Management) 

The initiation of combustion.

Infrastructure 

The facilities, utilities, and transportation systems needed to meet public and 

administrative needs.

Insect Epidemic 

High population levels of insect pests that cause substantial injury to plant or 

animal hosts. Used synonymously with “Outbreak”. 

Intensity (Fire Management) 

How hot a fire is. Specifically, a measure (in BTUs per foot per second) of the 

energy released per unit of time in an area of actively burning fire. The amount of 

heat released per foot of fire front per second.

Interdisciplinary Team (IDT) 

A group of individuals with different specialized training assembled to solve a 

problem or perform a task. The team is assembled out of recognition that no one 
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discipline is sufficiently broad to adequately solve the problem. Through 

interaction, participants bring different points of view and a broader range of 

expertise to bear on the problem.

Intermittent Stream

A stream or portion of a stream that flows, in its natural condition, only during 

certain times of the year when ground water provides water for streamflow. 

During dry periods intermittent streams may not have flowing water. Runoff from 

rainfall or snowmelt is a supplemental source of flow. 

Landscape Character 

Particular attributes, qualities, and traits of a landscape that give it an image and 

make it identifiable or unique. Valued landscape character creates a "sense of 

place" and describes the image of an area. The landscape character provides a 

reference for defining the inherent scenic attractiveness classes.

Late Succession 

Ecosystems distinguished by old trees and related structural features (Mehl,

1992). This term encompasses the later stages of stand development that typically 

differ from earlier stages in structure, composition, function, and other attributes. 

There are two types of late-successional ponderosa pine defined for the Black 

Hills. The first type, open-canopy late-successional ponderosa pine, occurs where 

periodic, low-intensity fires have been part of the ecosystem. These latesuccessional stands would consist of clumps or groups of trees with grasses in the 

openings between the clumps. They would contain large old trees with open 

branches, irregular, and flattened crowns. The clumps or groups of trees would 

contain little down dead material and few small trees. The second type, closedcanopy late-successional ponderosa pine occurs where periodic, low intensity 

high-frequency fires have not been a significant part of the ecosystem. These 

stands would contain large old trees with open branches and irregular crowns. The 

stands would have multiple canopy layers made up of various-aged trees. They 

would be well stocked with trees and contain standing dead and down trees.

Lopping and Scattering 

Lopping logging debris and spreading it more or less evenly on the ground.

Management Indicators Species (MIS)

Plant or animal species selected in a planning process that are used to monitor the 

effects of planned management activities on populations of wildlife and fish, 

including those that are socially or economically important.

Meadow 

An area of perennial, herbaceous vegetation, usually grass or grass-like. A natural

opening in a forest, generally at higher elevations, that produces exceptional 

levels of herbaceous plants. 

Mechanical (treatment, activity)

Vegetation management activitives which are implemented with the use of 

mechanized equipment (i.e chainsaws, etc.).
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Monitoring 

The sample collection and analysis of information regarding Forest Plan and 

project level management practices to determine how well objectives have been 

met as well as the effects of those management activities on the land and 

environment.

Multi-storied Stands (Vegetation) 

Plant communities having two or more recognizable canopy layers or height 

levels.

National Environmental Policy Act of 1969 (NEPA) 

An act declaring a national policy to encourage productive harmony between 

people and their environment; to promote efforts that will prevent or eliminate 

damage to the environment and the biosphere and simulate the health and welfare 

of people; to enrich the understanding of the ecological systems and natural

resources important to the nation; and to establish a Council on Environmental 

Quality.

National Fire Management Analysis System (NFMAS) 

A broad umbrella process to help fire managers identify the most efficient fire 

program meeting the direction in the Forest Plan. This includes information for 

the planning record on program composition, annual programmed costs,

emergency firefighting costs, expected resource impacts, and net value change.

National Forest Management Act (NFMA) 

A law passed in 1976 amending the Forest and Rangeland Renewable Resources 

Planning Act that requires the preparation of Regional and Forest Plans and the 

preparation of regulations to guide that development.

National Register of Historic Places (NRHP) 

A list of heritage resources that have local, state, or national significance. The list 

is maintained by the Secretary of the Interior.

Natural Regeneration 

The renewal of a tree crop by natural means without seeding or planting done by 

people. The new crop is grown from self-sown seed or by vegetative means, such 

as root suckers.

Non-motorized Activities 

Activities that do not incorporate the use of a motor, engine, or other non-living 

power source. Non-motorized activities exclude such machines as aircraft, 

hovercraft, motorboats, automobiles, motor bikes, snowmobiles, bulldozers, 

chainsaws, rock drills, and generators.

Noxious Weeds 

Those plant species designated as weeds by federal or state laws. Noxious weeds 

generally possess one or more of the following characteristics: aggressive and 

difficult to manage; poisonous; toxic; parasitic; a carrier or host for serious insects 

or diseases; and generally non-native.
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Objective 

Concise statement of desired measurable results intended to promote achievement 

of specific goals. Attainment of objectives is limited by the application of 

standards and guidelines.

Outbreak

See insect epidemic. 

Overstory 

The portion of vegetation in a forest forming the uppermost foliage layer.

Perennial Stream

A stream or portion of a stream that has flowing water year-round, during a 

typical year. Groundwater is the primary source sustaining base stream flow, with 

rainfall or snowmelt providing supplemental stream flow. The water table is 

located above the stream bed for most of the year. 

Piling and Burning 

Piling slash resulting from logging and subsequently burning individual piles.

Plant Communities 

Assemblage of plant species living in an area. It is an organized unit to the extent 

that it has characteristics in addition to the individuals and populations and 

functions as a unit.

Products Other than Logs (POL)

Products such as posts, poles, and fiber from trees or parts of trees less than 

sawlog size. POL usually includes trees greater than 5 inches diameter breast 

height (DBH) (4.5 feet from ground level) and less than 7.9 inches diameter 

breast (DBH), with tops of trees greater than 4 inches to less than 6 inches in 

diameter.

Prescribed Burning/Fire

Controlled application of fire to wildland fuels in either their natural or modified 

state under specified environmental conditions that allows the fire to be confined 

to a predetermined area and at the same time produce the fireline intensity and 

rate of spread required to attain planned resource management objectives 

(synonym for controlled burning).

Prescription (Fire Management) 

A written statement defining objectives to be attained, as well as temperature; 

humidity; wind direction and wind speed; fuel-moisture content; and soil 

moisture, under which the fire will be allowed to burn, generally expressed as 

acceptable ranges of the various indices, and the limit of the geographic area to be 

covered.

Ranger District 

Administrative subdivisions of the Forest supervised by a District Ranger who

reports to the Forest Supervisor.

Raptor Nests

Any nest of eagles, hawks, falcons, or owls.
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Regeneration (Silviculture)

The renewal of vegetation whether by natural or artificial means. Also, the new 

growth itself.

Responsible Official 

The Forest Service employee who has the delegated authority to make a specific 

decision.

Riparian Area 

(See "Riparian Ecosystem.”)

Riparian Communities 

Repeating, classified, defined, and recognizable assemblages of plantor-animal 

communities associated with riparian areas.

Riparian Ecosystem 

The moist transition zone between the aquatic ecosystem and the relatively drier, 

more upland, terrestrial ecosystem(s). This transition zone can extend both 

laterally and longitudinally away from aquatic ecosystems, sometimes into 

headwater swales that have no defined stream channel. The riparian ecosystem is 

the area whose soil is relatively more moist than the adjacent upland and whose 

vegetation growth reflects the greater accumulation of available water.

Roads 

A general term denoting a way with at least two-wheel tracks for purposes of 

travel by vehicles greater than 50 inches in width.

Sawtimber 

Trees suitable in size and quality for producing logs that can be processed into 

lumber. For planning purposes, trees with an 8-inch diameter or more are 

classified as sawtimber.

Scarify 

To abrade, scratch, or modify the surface of the ground to expose mineral soil (as 

in site preparation) or to break up compacted soil layers (as during road 

decommissioning or landing rehabilitation). 

Scenery 

The composition of basic terrain, geologic features, water features, vegetative 

patterns, and landrise effects that typify a land unit and influence the visual appeal 

the unit may have for visitors.

Scenic Class 

Scenic classes measure the relative importance or value of discrete landscape 

areas having similar characteristics of scenic attractiveness and landscape 

visibility. Scenic classes are used during forest planning to compare the value of

scenery with the value of other resources, such as timber, wildlife, late succession, 

or minerals. The higher the scenic class, the more important it is to maintain the 

highest scenic value. Scenic classes are determined and mapped by combining the 

three classes of scenic attractiveness with the distance zones and concern levels of 

landscape visibility. A numerical value of 1 to 7 is assigned to Forest lands. 
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Generally, scenic classes 1-2 have high public value; classes 3-5 have moderate 

value; and classes 6 and 7 have low value.

Scenic Integrity (Existing or Objective) 

State of naturalness or conversely the state of disturbance created by human 

activities or alteration. Integrity is stated in degrees of deviation from the existing 

landscape character in a national forest. It is the measure of the degree to which a 

landscape is visually perceived to be complete. The highest scenic integrity 

ratings are given to those landscapes that have little or no deviation from the 

character valued by constituents for its aesthetic appeal. Scenic integrity is used to 

describe an existing situation, standard for management, or desired future 

conditions.

Very High: A scenic integrity level that generally provides for ecological change 

only.

High: A scenic integrity level meaning human activities are not visually evident. 

In high scenic integrity areas, activities may only repeat attributes of form, line, 

color, and texture found in the existing landscape character.

Moderate: A scenic integrity level that refers to landscapes where the valued 

landscape character "appears slightly altered.” Noticeable deviations must remain 

visually subordinate to the landscape character being viewed.

Low: A scenic integrity referring to the landscapes where the valued landscape 

character "appears moderately altered." Deviations begin to dominate the valued ,

being viewed, but they borrow valued attributes such as size, shape, effect, and 

pattern of natural opening, vegetative type changes, or architectural styles within 

or outside the landscape being viewed. They should not only appear as valued 

character outside the landscape being viewed but compatible or complimentary to 

the character within.

Very Low: A scenic integrity level that refers to landscapes where the valued 

landscape character "appears heavily altered.” Deviations may strongly dominate 

the valued landscape character. They may not borrow from valued attributes such 

as size, shape, edge effect, and pattern of natural openings, vegetative type 

changes, or architectural styles within or outside the landscape being viewed. 

However, deviations must be shaped and blended with the natural terrain so that 

elements such as unnatural edges, roads, landings, and structures do not dominate 

the composition.

Unacceptable Low: A scenic integrity level that refers to landscapes where the 

valued landscape character being viewed appears extremely altered. Deviations 

are extremely dominant and borrow little if any line, form, color, texture, pattern, 

or scale from the landscape character. Landscapes at this level of integrity need 

rehabilitation. This level should only be used to inventory existing integrity. It 

must not be used as a management objective.

Sediment 

Displaced soil material suspended in water or that has been deposited in streams 

and lakes.
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Sensitive Species 

Those plant and animal species identified by the Regional Forester for which

population viability is a concern, as evidenced by significant current or predicted 

downward trends in population numbers or density; or significant current or 

predicted downward trends in habitat capability that would reduce a species' 

existing distribution.

Severely Burned Soil 

A condition in which most woody debris and the entire forest floor is consumed 

down to bare mineral soil. Soil may have turned red due to extreme heat. Also, 

fine roots and organic matter are charred in the upper one-half inch of mineral 

soil.

SHPO 

(See "State Historic Preservation Officer.”)

Silvicultural System 

A management process that tends, harvests, and replaces forests, resulting in a 

forest of distinctive form with a desired condition.

Silviculture 

Generally, the science and art of tree management, based on the study of the life 

history and general characteristics of forest trees and stands, with particular 

reference to local factors; more particularly, the theory and practice of controlling 

the establishment, composition, constitution, and growth of forests for desired 

conditions.

Site 

An area considered in terms of its physical and/or biological environment; for 

example, a riparian zone, a homogenous stand of vegetation, or a campground.

Skid Trail 

Any way, more or less prepared, over which logs are dragged. Any road or trail 

leading from stump to landing.

Skidding 

Moving logs from the stump to a collecting point.

Slash 

The residue left on the ground after harvesting, sanitation operations, windstorm, 

or fire. It includes such material as unutilized logs, uprooted stumps, broken or 

uprooted stems, tops, branches, and leaves.

Snag 

Standing dead tree or standing portion from which at least the leaves and smaller 

branches have fallen; often called a stub if it is less than 20 feet tall.

Soil Productivity 

The inherent capacity of a soil to support the growth of specified plants, plant 

communities, or a sequence of plant communities. Soil productivity may be 

expressed in terms of volume or weight/unit area/year, percent plant cover, or 

other measures of biomass accumulation.
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Standard 

Mandatory courses of action; any deviation from standards requires amendment 

of the LRMP.

Stand 

A community, particulary of trees, possessing sufficient uniformity as regards to 

vegetation type, age class, risk class, vigor, size class, and stocking class that

distinguishes it from adjacent communities and thus forms a management or 

silvicultural unity. Within a stand, a dominant or primary species and age class is 

identifiable, but there may be inclusions or clusters of different species or ages. 

R2 RIS stands are typically greater than 10 acres. IRI stands are typically greater 

than 5 acres.

Stand-replacing Fire 

A fire that kills all or most living overstory trees in a forest and initiates

secondary succession or regrowth.

State Historic Preservation Officer (SHPO) 

A person appointed by a state's governor to administer the State Historic 

Preservation Program.

Stream Health 

The condition of a stream relative to robust health for that stream type and 

landscape, considering indicators such as channel pattern; slope; particle size; 

pool frequency and depth; bank vegetation; and woody debris that reflect the 

stability and habitat quality of the stream.

Stream Level

A classification of the relative position of streams in a channel network. Firstlevel streams drain into the ocean. Second-level streams are tributaries to the 

first-level streams. For example, the Mississippi is a first-level stream; the 

Missouri is a second-level stream.

Structural Stages (Vegetation) 

Any of several developmental stages of tree stands described in terms of tree size 

and the extent of canopy closure they create. They include:

• Structural Stage 1 (Grass/Forb): An early forest successional stage during 

which grasses and forbs are the dominant vegetation. This stage is dominated by 

grasses and forbs lasting until tree seedlings become established. 

• Structural Stage 2 (Shrubs/Seedlings): Developmental stage dominated by tree 

seedlings (less than one inch dbh) and shrub species. This stage consists of shrubs 

and seedlings. This stage remains until seedlings reach 1 inch diameter at breast height 

(DBH).

• Structural Stage 3 (Sapling/Pole): Developmental stage dominated by young 

trees 1 to 9 inches dbh, 10 to 50 feet tall, and usually less than 50 years old. This 

stage is subdivided into three canopy closure classes: SS3A Sapling/Pole stage 

with less than 40% canopy cover

o SS3B Sapling/Pole stage with 40-70% canopy cover

o SS3C Sapling/Pole stage greater than 70% canopy cover
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• Structural Stage 4 (Mature): Consists of trees larger and older than structural 

stage 3. This stage contains trees which are at least 9” DBH. 

o SS4A Mature stage with less than 40% canopy cover

o SS4B Mature stage with 40-70% canopy cover

o SS4C Mature stage greater than 70% canopy cover

• Structural Stage 5 (Late Succession): This stage is characterized by very large 

trees (16+ inches DBH). Trees are at least 160 years in age. Late succession 

ponderosa pine may occur in dense stands but may also grow in the open or in 

“park-like” stands. 

Successional Stages (Seral Stages) 

The relatively transitory communities that replace one another during 

development toward a potential natural community.

Temporary Roads

A road developed and operated for a limited period of time that will cease to exist 

as a transportation facility after the purpose for which it was constructed is 

completed and the occupied land is reclaimed and managed for natural resource 

purposes.

Thinning 

The practice of removing some of the trees in a stand to meet desired conditions. 

Two types of thinning may be done:

Pre-commercial, Non-commercial: Removing trees that are too small to make a 

merchantable product.

Commercial: Removing trees that have reached sufficient size to be 

manufactured into a product and to improve tree spacing and promote more rapid 

growth.

Threatened Species 

Any species likely to become endangered within the foreseeable future throughout 

all or a significant portion of its range and that has been designated in the Federal 

Register by the Secretary of Interior as such.

Trail 

A general term denoting a way usually less than 50 inches wide for purposes of 

travel by foot, stock, or trail vehicle.

Transportation System 

All roads needed to manage and administer Forest resources. A road network.

Travel Corridor 

A strip of land that includes up to a maximum of 1,000 feet for major roads

(500 feet either side of the road's centerline) or 500 feet for major trails (250 feet 

either side of the trail's centerline); travel corridors form a passageway that allows 

travelers to experience and interact with the quality and character of the 

landscape.

Travel Management 

Travel management is the movement of people and products to and
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through national forests and grasslands. It connects many different varieties of 

users and multiple uses on National Forest System (NFS) lands.

Understory 

The lowest layer of vegetation in a forest or shrub community composed of grass, 

forbs, shrubs, and trees less than 10 feet tall. Vegetation growing under the tree 

canopy.

Values, Values at Risk (Fire Management) 

Any or all natural resources, improvements, or other values that may be

jeopardized if a fire occurs. 

Water Influence Zone (WIZ) 

The land next to water bodies where vegetation plays a major role in sustaining 

long-term integrity of aquatic systems. It includes the geomorphic floodplain 

(valley bottom), riparian ecosystem, and inner gorge. Its minimum horizontal 

width (from top of each bank) is 100 feet or the mean height of mature dominant 

late-seral vegetation, whichever is most. 

Watershed 

The area of land bounded by a divide that drains water, sediment, and dissolved

materials to a common outlet at some point along a stream channel or to a lake, 

reservoir, or other body of water. Also called a drainage basin or catchment.

Watershed Conservation Practices (WCPs)

Are stewardship actions based upon scientific principles and legal requirements to 

protect soil, aquatic and riparian resources. Each watershed conservation practice 

consists of a management measure, a set of design criteria used to achieve the 

management measure, and guidance for monitoring and restoration. 

Watershed Level 

The number assigned to an entire drainage basin contributing to the stream

segment of a given level and bearing an identical designation; for example, a firstlevel watershed contains all the drainage area of a first-level stream (See “Stream 

Level.”)

Waters of the United States 

“include essentially all surface waters such as navigable waters and their 

tributaries, all interstate waters and their tributaries, all wetlands adjacent to these 

waters, and all impoundments of these waters”. “Waters of the United States 

include perennial and intermittent streams, lakes, wetlands, and their tributaries.” 

Refer to 40 CFR 230.3 for the full definition. 

Wetlands 

As defined jointly by the Corps of Engineers (33 CFR 328.3) and Environmental 

Protection Agency (40 CFR 230.3), wetlands are those areas that are inundated or 

saturated by surface or ground water at a frequency and duration sufficient to 

support, and that under normal circumstances do support, a prevalence of 

vegetation typically adapted for life in saturated soil conditions. Wetlands 

generally include swamps, marshes, bogs, and similar areas. Wetlands are a 

subset of the “Waters of the United States” subject to regulation under Section 

404 of the Clean Water Act. 
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Wildfire 

Any wildland fire not designated and managed as a prescribed fire within an 

approved prescription. All wildfires will be given an appropriate suppression 

action. 
Appendix A:

MAPS

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Appendix B:

DESIGN CRITERIA

Briggs Spring Environmental Assessment Appendix B

B-1

Introduction

The following design criteria are listed by resource area and do not suggest any particular 

order of priority. All activities proposed in this project would require implementation of 

these design criteria.

Heritage

 All eligible sites will be avoided during project activities. There are 25 known 

cultural resources determined eligible for listing on the National Register of 

Historic Places.

 If during the course of any ground disturbance related to this project, any bones, 

artifacts, foundations, or other indications of past human occupation of the area 

are uncovered, all operations will cease within a 100-meter radius of the site 

location and a District Archaeologist notified immediately. The SHPO and 

regional THPOs will be notified of the discovery and provided an opportunity to 

comment. Any cultural resources located during project implementation will be 

protected based on the recommendations of the District Archaeologist and the 

SHPO.

 Mechanical Treatments: the following design criteria must be implemented to

protect the known sites in the project area from adverse effects of mechanical 

treatments.

o All cultural resources that have the potential to be affected by project 

activities will be flagged or otherwise posted for avoidance.

o No burn piles will be placed within the boundaries of eligible or 

unevaluated sites.

o All vehicles, timber harvesting equipment, or other machinery must not be 

stored or parked within the boundaries of the above eligible or 

unevaluated sites. Vehicles would be confined to existing and marked 

Forest Service roads if and when traversing through cultural resources, 

unless travel through site boundaries is specifically not allowed as stated 

in the site specific recommendations. 

o No road maintenance, blading or modification of roads through eligible 

and unevaluated sites will be conducted without the specified clearance 

and on-site presence of a district archaeologist.

 Prescribed Fire Treatments: the following design criteria, developed through 

scientific studies of fire effects on cultural resources must be implemented to 

protect the known sites in the project area from the adverse effects of prescribed 

fire (USDA, 2003).

o All cultural resources that have the potential to be affected by project 

activities will be flagged or otherwise posted. In some cases, burning

through sites may be allowed, but specified features must be avoided by 
Briggs Spring Environmental Assessment Appendix B

B-2

ground disturbing effects (e.g. road cuts, dozer lines, handlines, staging 

areas, and mop-up).

o Wetline through cultural resources instead of using ground disturbing 

handlines.

o Fire retardant possesses a risk of damaging archaeological sites and is not 

allowed within site boundaries.

o Fire is allowed within the site boundaries of cultural resources provided 

that the following on-site fire behavior criteria are met: There are 8 

known sites that will burn under 400°C < 1 hour without any preparation 

and may be burned through. There are 17 cultural resource sites that 

contain material which is easily destroyed by fire or would burn greater 

than 400° > 1 hour, and were preparation is not feasible due to the amount 

of fuel loading. These 17 sites cannot be burned through and must be 

avoided during implementation of all prescribed burning. Consult with 

heritage resource specialist prior to any burning.

Fire/Fuels

 All prescribed burn treatments will meet with the provisions of the Clean Air Act. 

District personnel would monitor burn conditions, and the SASEM (Smoke 

Model) or equivalent program would be used to assure provisions are met. The 

impacts of burning on metropolitan areas such as Rapid City would be assessed at 

the time of burning.

 Smoke impacts would be minimized utilizing the following design criteria and are 

incorporated into the burn plan as appropriate:

o Limit treatment area size.

o Specify wind directions and speed.

o Specify minimum mixing heights to ensure dispersal of emissions.

o Stagger ignitions.

 Whole tree yarding would be required in the harvest units listed in Table B-1 

where prescribed burning is planned.

Table B-1. Sites where whole tree yarding is required

Location Site

040701 10, 16, 32, 45

040702 3-6, 12, 13, 17, 19, 20-22, 31, 37, 42-45, 74

040704 10, 16-20, 26-28

040802 7-10, 17-22, 27, 28, 37-43, 45, 49, 50

040803 104, 108-110, 115, 126

040804 104, 108, 109, 115, 119, 120, 122-124, 130, 131

040805 135, 137, 139, 142, 151, 152
Briggs Spring Environmental Assessment Appendix B

B-3

040806 131, 137, 144

040807 105, 111, 118, 151

 Revegetation of prescribed burned areas will be promoted by:

o Following broadcast burning, seed to initiate revegetation if ground cover 

is 60 percent or less and slopes are 30 percent or more.

o If piled and burned fuel creates ash piles deeper than three inches, scatter 

the ash, scarify and mix it with mineral soil, or bury it. Guideline 4106

 Prescribed burn plans will identify acceptable levels of tree mortality for 

seedlings/saplings, poles and sawtimber; burning prescriptions will be estimated 

to meet these levels. Guideline 4108

 Slash piles that are scheduled for burning should be located outside of meadows 

that contribute to Waters of the United States. Use a buffer distance designed to 

keep sediment, ash and debris out of channels. Guideline 4111

 Activity fuels would be treated along forest collector roads and forest 

development trails to meet the adopted Scenic Integrity Objectives (SIO). Along 

arterial roads, remove 70-90 percent of activity fuels up to 300 feet from roads 

edge. Debris piles would be burned as soon as practical after remaining on-site 

for at least 2 years. Where mechanical treatment and prescribed burning is 

proposed within the same site, mechanical treatments would be completed prior to 

burning.

 The threat of wildfire to public and private developments will be reduced by 

following the standards in the National Fire Protection Association Publication 

1144, “Protection of Life and Property from Wildfire” and reduce the fuel loading 

from habitat improvement treatments to acceptable standards.

Minerals

 Although there is a potential for cave resources in the project area, no caves have 

been identified to date which require management as set forth in the Forest Plan. 

In the event that cave resources are identified during the course of the Briggs 

Spring project, the location will be reported to the wildlife biologist, archeologist 

and geologist for recommendation on resource protection measures, according to 

the Forest Plan.

Botany/Rangeland/Weeds

 Known noxious weed infestations would be treated with herbicides and/or 

biological controls after treatments to reduce infestations and allow native 

vegetation to compete with non-natives. Areas would be retreated as necessary.

 Areas infested with noxious weeds may be treated with herbicide prior to 

disturbance to help reduce seed dispersal from existing plants.

 Disturbed areas such as skid trails, burned slash piles and temporary roads would 

be seeded with certified weed-free seed. Standard 1110
Briggs Spring Environmental Assessment Appendix B

B-4

 When possible, avoid disturbances to grassland and meadows with activities such 

as large slash piling, skidding, and temporary road construction.

 Restore or rebuild all fences damaged during project activities.

 When temporary roads and skid trails are to be constructed, locate beside existing 

fences, if possible. Such clearing will help with the maintenance of those 

improvements.

 All livestock gates would remain shut from June 1st – October 15th.

 Defer prescribed burned areas from livestock grazing for a portion or all of the 

following growing season to ensure regrowth of forage species. Guideline 4107

 Deck piles and landings should be no closer than 200’ from any spring with 

exclosure fences. Heavy equipment would not be allowed to operate within wet 

areas to prevent noxious weed growth near existing springs.

Recreation

 Use of system trails needed for project implementation would be coordinated with 

recreation specialist. 

 All system trail signs and markers would be protected during harvest activities.

 Exclude snowmobile trails from harvest activities from December 15-March 31, 

annually. Note that snowmobile trail #13 includes a portion located on Six Mile 

Road (FSR 301); this portion can be located either on the road bed, if the road is 

not plowed or being used for logging traffic, or it can be located on the road edge 

if the road is plowed.

 Signing of harvest activities would be placed at trailheads, bulletin boards and 

trail intersections to ensure public safety.

 Any logging slash should be removed from recreational sites, such as 

campgrounds prior to the opening date of May 15, annually.

 Protect the Redbank Spring campground improvements from vegetation 

management activities during its full operational period from May 15th to October 

15th annually. Protect campground facilities and improvements during all periods 

of vegetation management occurring in the campground.

 Avoid piling slash or placing landing piles in campgrounds or on trails (4 feet 

each side of the centerline of trails). Slash or logs would be removed and any 

disturbed ground recontoured and seeded prior to the start of the primary use 

recreation season on May 15th annually.

Scenery

 For all overstory removals and shelterwood seed cut treatments, transition 

(‘feather’) the vegetation edge from dense canopy (in the adjacent non-treated 

areas) into this unit.

 In all harvest units along FSRs: 117 (Boles Canyon), 294 (South Castle Creek), 

301 (Six Mile), 296 (Redbird-Gillette Canyon), 284 (Custer-Limestone), and 
Briggs Spring Environmental Assessment Appendix B

B-5

294.2A (Redbank Spring Campground access), within 300 feet of these routes, 

and around campgrounds, the following design criteria should be used: 

o Where possible along roads and trails, remaining vegetation should be in a 

variety of sizes and spacing to maintain a more natural appearance.

o Log decks within 300 feet of campgrounds and travel corridors would be 

returned to original contours, scarify to eliminate compaction (as 

necessary), and reseeded with native grass seed.

o Slash would be cleaned up to natural levels within 300 feet of 

campgrounds and travel corridors. This could be accomplished by 

scattering and burning, piling and burning, or chipping) after harvesting.

o Slash needs to be treated in accordance with Forest Plan Guideline 5606. 

o When thinning dense stands, avoid creating a residual forested stand with 

evenly spaced trees if possible.

o All temporary roads and skid trails within 1⁄4 mile of developed recreation 

areas should be returned to a natural appearance by eliminating the cut/fill 

slope to match the adjacent contours. Re-seed and place natural levels of 

down debris across these routes.

 In the Redbank Spring & New Moon developed recreation areas and for 300 feet 

around them, maintain some of the largest trees to ensure long-term large 

diameter trees, and their character will be present.

 Fuel treatments along private land boundaries would transition into the 

surrounding forest. These areas are essential shaded fuel breaks. Avoid creating 

‘corridors’ of cleared understory areas by laying out the outer (forest side) of the 

unit in a curvilinear layout.

Transportation

 After project implementation any temporary roads would have slash dropped or 

spread over the road to prevent future unauthorized use. Boulders and berms may 

also be used to close these roads.

Wildlife

 The sites in Table B-2 would have slash lopped and scattered within 200’ of the 

site edge in the direction of the nearby pond/spring; if proposed for prescribed 

burning, do not burn down woody material, juniper and regeneration within 200’

of the site edge:

Table B-2. Sites requiring lop and scatter within 200’ of adjacent pond or 

spring

Location Site

040702

40 - (Briggs Spring) – extend the 200’ wide lop and scatter treatment 

for the length of the west side of site 40 adjacent to site 23. Proposed 

for commercial and non-commercial vegetative treatments in 

Alternatives 2 and 3.

040702 52, 56, 57 - (White Spring) – lop and scatter 200’ radius from spring 
Briggs Spring Environmental Assessment Appendix B

B-6

exclosure fence into these 3 sites. Proposed for commercial and noncommercial vegetative treatments in Alternatives 2 and 3.

040703

14 - (beef pasture spring, north side, along private land) – lop and 

scatter 200’ radius from spring. Site proposed for mechanical fuels in 

Alternatives 2 and 3. Commercial treatment is proposed in Alternative 

3.

040704

2 - (Redbird Spring) – lop and scatter 200’ radius from spring 

exclosure fence near upper pond. Site proposed for commercial 

treatment in Alternative 3.

040705

134 - (Multiplex Spring) – extend the 200’ wide lop and scatter 

treatment for the length of the west side of site. Proposed for 

commercial and non-commercial vegetative treatments in Alternatives 

2 and 3.

040705

156 - (Redbank Spring Reservoir) – extend the 200’ wide lop and 

scatter treatment for the length of the north side of the site. Proposed 

for commercial and non-commercial vegetative treatments in 

Alternatives 2 and 3.

040807

105, 110, 111 - (Park Spring) – sites 105 and 111 are proposed for 

sanitation if needed and prescribed burning in Alternatives 2 and 3. 

Site 110 is deferred in Alternative 2 but is proposed for commercial 

treatment in Alternative 3. If sites 105 and 111 are sanitized, lop and 

scatter the south tips of the sites to a depth of 200’. If site 110 is 

treated than lop and scatter the south tip of the site from Park Spring 

south.

 When prescribed burning in sites 040702-23, 040705-132 and 040802-44 protect 

the existing fences around Willow Spring, Briggs Spring, Multiplex Spring, Junes 

Pools and Herrin Wildlife Ponds. No burning would occur within the fences in 

order to maintain residual grass cover for amphibians.

 No snags will be cut unless deemed a safety hazard. Snags determined to be a 

safety hazard should be felled and left in place, where feasible. Existing snags 

and down woody material (>10” diameter) will be protected during prescribed 

burning where feasibility and safety permits. Standards 2301, 2304, 2305, 2308,

and Objectives 211, 212

 Retain existing large woody debris in mechanically treated sites including the 

sites proposed for whole tree yarding. Do not pull existing logs out of the site 

while removing recently cut trees. Guideline 2307

 If piles are created while accomplishing mechanical vegetation treatments, 

including mechanical fuel treatments, leave 1 pile per 2 acres for small mammal 

habitat. Piles do not need to be any particular size; as a pile size guideline, aim 

for approximately 10’ x 10’ and 6’ in height. This will benefit small mammal 

predatory species by creating near-ground structure for prey species. Standard 

3117

 Screening cover for big game will be retained within 200’ of the road in the 

following areas proposed for non-commercial treatments (Guideline 3203). Any 

planned burning should have a mortality limit of 0-5% of seedlings and saplings 

within these areas. Mechanical thinning should not occur within 200’ of the road 
Briggs Spring Environmental Assessment Appendix B

B-7

in these areas. Sites proposed for non-commercial treatments that need screening 

cover (seedlings/saplings) retained within 200’ of the arterial or collector road are 

shown in Table B-3.

Table B-3. Sites where screening cover adjacent to roads must be 

maintained

Location Site Road Proposed treatment

040701 10 117.1 Mechanical thin and prescribed fire

040701 18 117.1 Mechanical thin

040701 20 117.1 Mechanical thin

040701 23 117.1 Mechanical thin

040701 38 301 Mechanical thin

040702 50 301 Mechanical thin

040702 54 301 Mechanical thin

040702 55 301 Mechanical thin

040702 56 301 Mechanical thin

040705 126 294 Mechanical thin

040801 8 284.5D Mechanical fuels

040801 9 117.1 Mechanical thin

040801 10 284.5D Mechanical thin

040802 47 284.5D Mechanical fuels and prescribed fire

040803 101 301 Mechanical thin

040805 151 284 Prescribed fire

040806 142- east 

end

284 Mechanical fuels and prescribed fire

040806 120 284.5D Mechanical thin

040808 109 284 Mechanical thin

 Allow only 0-5% mortality of pine regeneration in site 040702-73 when 

prescribed burning.

 To allow for hiding cover in sites listed in Table B-4, do not thin pine 

regeneration during timber stand improvement (post sale) treatments along 

specified roads.

Table B-4. Sites where hiding 

cover is to be retained

Location Site Road

040802 30, 31

296.2D

301.2D

301.2E

 If new raptor nests are found apply recommended spatial and activity time 

restrictions for the nest area. Restrictions would be dependent on raptor species 

and if the nest area is active. Standards 3115 and 3204

 Known raptor nests will be protected (Standard 3204).
Briggs Spring Environmental Assessment Appendix B

B-8

 “From April 1 through August 15, minimize additional human-caused noise and 

disruption beyond that occurring at the time of nest initiation (e.g., road traffic, 

timber harvests, construction activities) within one-half mile of all active goshawk 

nests up until the nest has failed or fledglings have dispersed” (Standard 3111).

Prior to starting any activities in the sites listed in Table B-5, consult with a 

district biologist. A biologist will check the known raptor nests for any indication 

of use. If no use is detected the treatment activities may be allowed to proceed.

Table B-5: Sites proposed for treatment within a 1⁄2 mile of northern goshawk nest 

territories requiring protection

Location Site

Alternatives 

proposing 

treatment

Treatments 

proposed Territory Comments*

040802 11 2 and 3 Commercial and noncommercial thinning Herrin-Miller Buffer: 0.5 miles 

April 1- August 15

040802 22 2 and 3 Hardwood release and 

prescribed burning Herrin-Miller

040802 23, 24,

32, 33 2 and 3 Sanitation if needed Herrin-Miller

040802 23, 24,

32, 33 3 Non-commercial thinning Herrin-Miller

040802 30 2 and 3

Commercial (south 1/3) 

and non-commercial 

thinning; sanitation if 

needed

Herrin-Miller

040802 15 2 and 3 Non-commercial 

thinning Herrin-Miller

040802 12, 15 3 Commercial thinning Herrin-Miller

040802 31 2 and 3

Sanitation if needed and 

non-commercial 

thinning

Herrin-Miller

040802 42, 43,

45 2 and 3

Commercial and noncommercial thinning; 

prescribed fire

Herrin-Miller

040802 44 2 and 3

Pine encroachment 

treatment and 

prescribed fire

Herrin-Miller

040802 51 2 and 3 Commercial and noncommercial thinning Herrin-Miller

040804 117 2 and 3 Sanitation if needed Dumbuk Buffer: 0.5 miles 

April 1- August 15

040805

101,

102,

103,

104,

153

2 and 3 Sanitation if needed Dumbuk

040805 107 2 and 3 Pine encroachment and 

prescribed fire

Dumbuk

040805 141 2 and 3 Mechanical fuels and 

prescribed fire

Dumbuk

040805 142 2 and 3 Sanitation if needed and 

prescribed fire

Dumbuk

040805 149 2 and 3 Mechanical fuels and 

prescribed fire

Dumbuk
Briggs Spring Environmental Assessment Appendix B

B-9

040805 149 3 Commercial thinning Dumbuk

040806 132 2 and 3 Commercial thinning Dumbuk

040806 137 2 and 3

Commercial and noncommercial thinning; 

prescribed fire

Dumbuk

040806

138,

139,

145

2 and 3 Sanitation if needed Dumbuk

040806 140,

142 2 and 3 Mechanical fuels and prescribed fire

Dumbuk

040806 140,

142 3 Commercial thinning Dumbuk

040806 141 2 Sanitation, mechanical 

fuels and prescribed fire

Dumbuk

040806 141 3

Commercial thinning, 

mechanical fuels and 

prescribed fire

Dumbuk

040806 144 2 and 3 Pine encroachment and 

prescribed fire

Dumbuk

*The spatial buffer of 0.5 miles has a corresponding time period buffer when activity, such as commercial, 

non-commercial and fuels treatments including prescribed burning, is not to take place.

 In addition to the sites listed in the table above, there would be time restrictions

(April 1-August 15, annually) for new activity related to project implementation 

on roads adjacent to the two goshawk territories.

o If the Herrin-Miller territory is active then FSR 301.2D (the entire length) 

and FSR 296.2D (within 1⁄2 mile of the junction with 301.2D) will have 

new use timing restrictions in place, for activities related to timber harvest.

o If the Dumbuk territory is active then FSR 284.5E (the entire length), FSR 

296.2B (between FSR 284.5D and U220036), and FSR 289.1A (from the 

junction with FSR 296.2B south to U220036), U220035 and U220036 will 

have new use timing restrictions in place, for activities related to timber 

harvest. A portion of FSR 284.5D is located within 1⁄2 mile of the 

goshawk nests in the Dumbuk territory. The timing restriction is not being 

recommended on this road. Other roads discussed above will have the 

timing restriction in place which will minimize additional disturbance 

within the territory. Standard 3111. Use of this road is also required to 

implement the proposed projects during the summer months.

 If R2 sensitive species or species of local concern is found after a contract or 

permit is issued, consult with the district wildlife biologist to coordinate 

mitigation measures. Standard 3115

 If northern leopard frogs are observed in the project area during any project 

activities, consultation with a district wildlife biologist would occur before any 

project activities are implemented.

 If, during any activities in the project area, red-bellied snakes are observed or 

potential hibernacula are found, consult with a district wildlife biologist. If a 

hibernacula/breeding site is found a spatial restriction may be established around 

the riparian area and the hibernacula.
Briggs Spring Environmental Assessment Appendix B

B-10

 Retain all spruce trees within 600 feet of the spring near the border of sites 

040705-103 and 040705-106 for wildlife cover as well as enhanced vegetative 

diversity for forest birds.

 Retain a denser canopy (> 60 BA) in the northern 1/3 of site 040802-51 within 

200 feet of the meadow site 040802-44. The denser canopy will allow for more 

moisture on the ground in the site as well as provide some hiding cover for big 

game. This site may be used as upland habitat for sensitive northern leopard frogs 

if present in the Herrin wildlife ponds within site 44.

 Within site 040705-126 retain a denser canopy (> 60 BA) and lop and scatter 

slash within 200’ of the springs in site 040705-135.

 Ten percent of the SS4 ponderosa pine acreage in the management area will have 

an average tree size of “very large”. Objective 5.1-204. In the sites listed in 

Table B-6, retain very large tree size (16” DBH and greater) of ponderosa pine 

trees:

Table B-6. Sites with large tree retention needs

Location Site

040701 10

040802 7, 8, 9

040803 110 (east end)

040808 108 (only if large pine trees are not 

producing regeneration within the meadow)

 There is one Frest site present in the project area that showed presence of a 

species of local concern snail. The Frest site is in 040701-36 along Road 117.1. 

No vegetative commercial treatment is planned in Alternative 2, however a POL 

treatment (post sale) is proposed. In Alternative 3 the site is proposed for group 

shelterwood commercial harvest with a POL treatment. The Frest site 

(approximately 1⁄4 acre) needs to be avoided during mechanical treatments under 

either alternative. A district biologist can flag the site boundary prior to any 

vegetative treatments. Standard 3103

 Where it is not a concern for fuels and/or the silviculturist, leave slashed tops 

from commercially harvested pine trees within aspen clones and within 100 feet 

of the clone. This will help provide barriers to inhibit ungulate browsing on 

regenerating aspen.

 Broadcast prescribed burning in structural stage 3B or 4B sites should be designed 

to limit mortality in all size classes to less than 10%.

 Within the hardwood stands listed in Table B-7, hinging of remaining noncommercial conifers would occur to protect aspen regeneration from browsing.
Briggs Spring Environmental Assessment Appendix B

B-11

Table B-7. Aspen sites which require hinging of non-commercial 

sized trees

Location Site

040401 118

040502 18-28, 39, 40, 45, 51, 52, 63, 64

040704 24

040705 121, 129-132, 137, 138, 146, 147, 172

040802 7-10, 17-22, 27, 28, 37-43, 45, 49, 50

040803 104, 108-110, 115, 126

040804 104, 108, 109, 115, 119, 120, 122-124, 130, 

131

040805 135, 137, 139, 142, 151, 152

040806 131, 137, 144

040807 105, 111, 118, 151

Silviculture

 Activity fuel should be removed, lopped, scattered or piled for later burning. 

Slash piles, other than those left for wildlife habitat (Standard 3117), should be 

burned within one year. This will reduce the risk of Ips beetle caused mortality.

 Prescribe burning mortality limits in ponderosa pine – The percentages listed in 

Table B-8 are not a target to strive for but rather a range in which to operate 

during a prescribe burn. Before prescribed burning, the silviculturist would check 

sites for regeneration. In areas with seedlings less than 4.5’ in height, exclude 

area from burn if possible, if it can’t be excluded, follow mortality limits 

according to Table B-8. Broadcast prescribe burning should be designed to limit 

mortality in the following tree diameter sizes:

Table B-8. Allowable mortality due to prescribed burning in pine sites

Ponderosa Pine Percent Mortality

> 16.0” DBH < 5%

9.0” – 16.0” DBH < 15%

5.0” – 8.9” DBH < 20%

1.0” – 4.9” DBH < 30%

> 500 seedlings/acre < 50%

300 – 500 seedlings/acre < 25%

100 – 300 seedlings/acre < 10%

No Rx burning within pine plantations.

 Prescribe burning mortality limits in aspen – The percentages listed in Table B-9

are not a target to strive for but rather a range a maximum allowable mortality that 

would occur due to a prescribe burn. Broadcast prescribe burning should be 

designed to limit mortality in the following tree diameter sizes:

Table B-9. Allowable mortality due to prescribed burning in aspen sites

Aspen Percent Mortality

> 3.0” DBH

(All age classes) ≤ 10%

< 3.0” DBH

(All seedlings & saplings) ≤ 5%
Briggs Spring Environmental Assessment Appendix B

B-12

 The most current Black Hills NF “Visual Marking Guides” would be followed for 

tree marking within distance of arterial and collector roads and private land with 

dwellings.

 The practices outlined in “Best Management Practices for the control of NonPoint Pollution from Silvicultural and Related Road Activities” will be followed.

 Within harvest units, conifer trees identified as insect infested would be removed 

in order to reduce the potential for future infestations.

 Aspen stands should be whole tree harvested when removing commercial sized 

conifers to insure conifers can be removed without excess damage to remaining 

aspen. This will also eliminate shading of the ground by logging slash. If conifer 

slash is to be piled and burned, piles need to be placed at least one (aspen) tree 

height away from the edge of the aspen to avoid damage to the roots from the 

intense fire (Sheppard, 10-2004).

 Conifers within one aspen tree height (approximately 50 feet) surrounding aspen 

inclusions within pine sites would be removed.

 Remove all conifers from designated aspen clones within conifer harvest units. 

Conifers less than 9-inches DBH shall be removed post harvest or hinged to 

provide protection to aspen suckers. Standard 2205

Soils and Hydrology

 Include all USFS Region 2 Watershed Conservation Practices (WCPs), Forest 

Plan standards and guidelines, South Dakota Best Management Practices (BMPs), 

and industry standard methods for protecting geologic, soil and water resources. 

 Use existing roads and trails to the extent practical. Minimize construction of 

new trails or temporary roads.

 Rehabilitate and close temporary roads as soon as possible after activities are 

completed. Rehabilitation will include scarification, seeding and physical barriers 

of slash or rock to block access. 

 All roads and trails will have drainage control structures installed as needed, and 

be regularly maintained prior to, during and following operations, including 

seasonal shutdowns. Drainage structure spacing should use the following 

guidelines shown in Table B-10.

Table B-10. Drainage structure spacing guidelines for roads 

and trails

Road or Trail Grade Maximum Spacing 

between Structures

2% 250 feet

5% 135 feet

10% 80 feet

15% 60 feet

20% 45 feet
Briggs Spring Environmental Assessment Appendix B

B-13

 If winter road use occurs – maintain roads as needed to keep the road surface 

drained during thaw and breakup periods; do not use riparian areas, wetlands or 

streams for snow storage or disposal; minimize use of sand, salt or other de-icing 

substances (i.e. Mag-Chloride).

Protected Stream Courses and Springs: 

 Protected stream courses within the project area include all or portions of the 

following streams; Antelope Draw, Gillette Canyon, Jenks Draw, Redbird 

Canyon, and Redbird Draw (see Map 7 in Appendix A).

 Avoid crossing protected stream courses to the extent practical. If a stream 

crossing is absolutely necessary, consult a hydrologist to identify a stable crossing 

location and any site-specific needs.

 Protected springs within the project area include:

Table B-11. Protected springs in the Briggs Spring project area 

Spring Name Location Site(s)

Cabin Spring 040502 23

Upper Antelope Spring Complex 040701 8

Lower Antelope Spring Complex 040701 8

Willow Spring Complex 040702 23

Briggs Spring/Pond 040702 23

White Spring/Ponds 040702 52

Beef Pasture Spring 040703 14

Old Camp Spring Complex 040703 26

Redbird Spring Complex 040704 2

North Cigarette Spring/Pond 040704 9

Cigarette Spring/Pond 040704 21, 22

Multiplex Springs Complex 040705 132, 133

Baseline Spring/Pond 040705 137

Redbank Spring Complex 040705 145, 170

Herrin Spring/WPA Well and Pond 040802 44

Bert Howey Spring 040806 103

Howell Spring 040806 116, 118

Rogers Spring/Pond 040806 132, 138

 Within the 100 foot Water Influence Zone (WIZ), either side of a protected stream 

course or spring/wetland, the following will apply: 

o Management activities within the WIZ must be done in such as manner as 

to limit damage to riparian vegetation, soil disturbance rutting, and 

sediment delivery. 

o Avoid ground based equipment operations within WIZ to the extent 

possible, except at designated crossings or where otherwise approved by a 

hydrologist. 
Briggs Spring Environmental Assessment Appendix B

B-14

o Approved equipment operations within the WIZ will be during dry or 

frozen soil conditions, unless otherwise approved by a hydrologist. 

o Do not place temporary roads or skid trails within WIZ except at 

designated crossings or if otherwise approved by a hydrologist. 

o Do not locate landings or other slash piles within the WIZ. 

o Ensure one-end log suspension within the WIZ. 

o Do not ignite prescribed fire within the WIZ. Prescribed burning may 

occur within a WIZ, but must not be initiated in the WIZ. 

o Protected stream courses, ponds or wetlands, and other wet areas within 

the WIZ should not be used as natural barriers for firelines unless a 

hydrologist approves this on a site specific basis. 

o Manage prescribed fire in the WIZ to achieve a low intensity burn to 

protect soils.

 Remove slash and debris that inadvertently enters stream courses

 Protected stream courses and known spring/wetlands requiring protection will be 

identified on the sale area map. 

 Do not store or locatae refueling sites within 150 feet of streams, wetlands, 

springs or ephemeral streams. Inspect equipment for leaks and remedy leaks right 

away. Any leaks or spills should be cleaned up immediately. 

 Conduct water drafting for prescribed fire operations at locations which minimize 

adverse effects to water quality.

100-Year Floodplains: 

 There are 100 year floodplains associated with Redbird draw, Redbird Canyon 

and Gillette Canyon see Table B-2 and Floodplain map in project file. The

following applies to activities within the 100-year floodplain: 

o Do not locate landings and piles within the 100-year floodplain so as not 

to restrict any potential flood flows or damage floodplain processes. 

o Any vegetation felled and left in place should not restrict potential flood 

flows or create a debris-dam. 

 Avoid locating staging areas or other concentrated uses within 100-year 

floodplains.

Table B-12. 100-Year floodplains in the Briggs Spring project area

Floodplain Area Acres Location Site(s)

Redbird Draw

35 40701 44

77 40702 22, 23, 36, 52, 57, 70, 75

51 40801 12, 13, 19

42 40802 7, 46, 47, 53, 57

36 40806 115, 118, 149
Briggs Spring Environmental Assessment Appendix B

B-15

Redbird Canyon

6 40803 127

46 40807 129, 139, 142, 143, 148

Gillette Canyon

10 40804 105, 109, 116, 129, 134

4 40805 107, 121, 125, 148

Soils: 

 Restrict roads, landings, skid trails and concentrated-use sites to designated sites 

to limit additional soil disturbance. 

 All off-road, ground-based equipment operations should be minimized as 

possible, and should take place during dry or frozen conditions to limit soil 

compaction, rutting and soil erosion. 

 Avoid soil disturbing actions during periods of heavy rain or wet soils to prevent 

rutting, compaction, erosion and sediment delivery to streams. 

 Avoid ground-based harvest and skidding equipment operations on sustained 

slopes steeper than 40%. 

 Avoid placing temporary roads and skid trails within ephemeral drainages to

prevent soil rutting and compaction. 

 When machine piling of slash occurs, leave topsoil in place and avoid displacing 

soils into piles or windrows. 

 Rehabilitate landings and burned slash piles by scarifying and seeding these areas. 

Rehabilitate other disturbed sites, such as firelines, staging areas, and safety 

zones. 

 During vegetation management activities on ponderosa pine sites, retain an 

average of at least 50 linear feet per acre of coarse woody debris with a minimum 

diameter of 10 inches. (standard 2308s)

 Shelterwood harvest on the following sites should retain 50% or more of fine

(consists of leaves, needles, branches and limbs less than 3 inches in diameter)

logging slash (guideline 1102a). Fine slash should be evenly distributed through 

the unit. See Table B-13. 

Table B-13. Stand locations and sites that contain soil components low in topsoil organic matter within the 

Briggs Spring project area

Stand 

Location Site(s)

Acres 

within 

Stand 

Location

Percent of Stand 

Location (within 

the Project 

Area)

040401 118 10 100%

040502 18-28, 39-41, 45, 49, 51, 52, 59-61, 63-65 847 80%

040601 75 0.2 100%

040701 1, 2, 4-16, 18-21, 23-26, 28, 30-33, 35-45 1,360 54%

040702 1-24, 26-37, 39-77, 79, 80 2,265 55%

040703 1, 2, 4-9, 11-21, 23, 24, 26, 30, 32-36, 38, 

40, 42, 43 908 77%
Briggs Spring Environmental Assessment Appendix B

B-16

040704 1-36 1,445 76%

040705 101-107, 109, 111, 113-132, 137-160, 

162-172, 174-178 1,637 48%

040801 1-19 596 56%

040802 1-15, 17-28, 30-43, 45-57 1,869 62%

040803 101-115, 117-137, 140-143 821 38%

040804 101-108, 110-113, 117, 119, 120, 123-

125, 130, 137 188 16%

040805 101-104, 107, 109, 125-129, 132, 133, 

135, 136, 138-142, 147, 149, 151-154 449 38%

040806 101-113, 115-117, 119-126, 128-134, 

137-145, 147, 149 825 34%

040807

101-103, 105-107, 109-112, 114, 115, 

118-121, 123, 124, 130-133, 140-142, 

144-150, 152, 153

970 39%

040808 101-107, 109, 110, 112 234 46%

 Skidding through hardwood stands should be minimized to protect the moist soils 

in these areas and to prevent soil compaction and rutting. 

 Avoid locating landings and piles scheduled for burning within hardwood stands 

to protect soils. 

 Ground based operations occurring within and directly adjacent to hardwood 

stands should occur when soils are frozen. 

 Conduct prescribed fire operations within hardwood stands with the minimum fire 

intensity necessary to achieve objectives. 

 Conduct prescribed fires and pile burning when soil and humus are moist to 

minimize fire intensity and soil heating. 

 Use low intensity prescribed fire on steep slopes or highly erodible soils. 

 Locate and construct fire control lines to the minimum size and standard 

necessary to contain the fire and meet overall objectives. 
Appendix C:

MONITORING PLAN

Briggs Spring Environmental Assessment Appendix C

C-1

Monitoring Plan for the Briggs Spring Project

Introduction

The Forest Plan identifies specific items to be monitored, and the Monitoring 

Implementation Guide (USDA Forest Service, 2005) describes monitoring protocols that 

have been established for numerous resources, as directed by the Forest Plan. The 

Monitoring Implementation Guide identifies frequency and methods of data collection, 

unit of measure, sampling design, expected precision and reliability, reporting frequency, 

data storage location, and costs for each monitoring item identified by the Forest Plan. 

This guide is subject to periodic adjustments. For additional information, refer to the 

Forest Plan (Chapter 4), and the Monitoring Implementation Guide.

The ID Team for the Briggs Spring project compiled additional monitoring 

objectives/items, which are summarized below. These items provide emphasis regarding 

particular resource monitoring needs in the project area. Monitoring would be prioritized 

by the responsible line officer if funding is unavailable to implement all items listed or 

referenced in this Monitoring Plan.

Soils and Hydrology

To ensure that soil and water resources are not impaired due to project activities, Best 

Management Practices (BMPs) are applied. BMP monitoring occurs during and after 

management activities. BMP implementation monitoring would occur during 

management activities, primarily through contract administration or oversight of Forest 

Service crew work.

Project specific design criteria for soil and water protection will be incorporated into any 

contracts or internal work orders used to implement the proposed activities. The 

effectiveness and implementation of these design criteria would be monitored as stated 

above for BMPs and during the annual Implementation and Effectiveness field review. 

Additional monitoring may occur based on needs as identified by the project hydrology 

and soils specialist.

Fuels

All fuels treatments would be recorded in the FACTS database. Prescribed fire surveys 

would be conducted following prescribed burning to ensure resource objectives are being 

met.

Monitoring of smoke conditions during burning operations would be done to comply with 

the provisions of the Clean Air Act. District personnel utilize the SASEM (Smoke 

Model), or an equivalent program to assure provisions are being met. The impacts on 

metropolitan areas such as Rapid City would be assessed at the time of burning.
Briggs Spring Environmental Assessment Appendix C

C-2

Noxious Weeds

Areas of weed infestation would be monitored and the effectiveness of the weed 

treatments measured. Areas should be re-treated as necessary.

Wildlife

Hell Canyon district biologist would monitor known goshawk nests every summer for 

activity and breeding success. The biologist would coordinate with implementation crews 

to ensure that timing restrictions are followed in active territories. Occurrences and 

sighting of wildlife species would be documented during field visits and monitoring trips.

Heritage

Post project site monitoring is a useful method for determining the effectiveness of 

avoidance measures. Twenty percent (20% rounded up to the nearest whole number) of 

eligible and unevaluated cultural resources in the vicinity of treatment areas will be 

revisited and monitored for effects from the Briggs Spring Project following 

implementation. The selection of sites to be monitored is at the discretion of a District 

Archaeologist, and results will be sent to SHPO in the form of a site monitoring report.
Appendix D:

TREATMENTS and

POST SALE ACTIVITIES BY SITE

Briggs Spring Environmental Assessment Appendix D

D-1

Alternative 2 Treatments and Post-Sale Activities

Alternative Prescription Abbreviations:

CTHIN – Commercial Thin

GRSH – Group Shelterwood

HDWC – Hardwood Conversion

HDWR – Hardwood Release

OSR – Overstory Removal

PE – Pine Encroachment

POL – POL Thinning

SWSC – Shelterwood Seed Cut

Cover Type Abbreviations:

TPP – Ponderosa Pine

TAA – Aspen

GRA – Grass, meadow

Location/Site Site Acres

Post Sale

Cover Type

Alternative 2

Prescription

Alternative 2

Post Sale 

Activities

Alternative 2

Prescribe 

Burning 

Acres

40401-118 10 TAA DEFER

40502-18 47 TPP HWDC HWDR

40502-19 49 TPP GRSH POL, HWDR

40502-20 30 TPP GRSH POL, HWDR

40502-21 33 TPP SANITATION

40502-22 27 TAA HWDR HWDR

40502-23 28 TPP HWDC HWDR, POL

40502-24 62 TPP DEFER FUELS

40502-25 37 TPP GRSH FUELS

40502-26 20 TAA HWDR HWDR

40502-27 48 TPP HWDC HWDR

40502-28 47 TAA HWDR HWDR

40502-39 40 TPP DEFER FUELS

40502-40 44 TPP GRSH POL

40502-41 55 TPP SANITATION FUELS

40502-45 45 GRA PE PE

40502-49 20 TPP DEFER FUELS

40502-51 37 GRA PE PE

40502-52 12 GRA PE PE

40502-63 20 TPP CTHIN POL

40502-64 27 TAA HWDR HWDR

40502-65 9 TPP SANITATION

40701-1 100 TPP GRSH POL

40701-2 95 TPP CTHIN POL

40701-4 54 TPP SANITATION

40701-5 81 TPP SANITATION

40701-6 11 GRA PE PE

40701-7 97 TPP GRSH POL

40701-8 58 GRA PE PE 17

40701-9 41 TPP SANITATION
Briggs Spring Environmental Assessment Appendix D

D-2

40701-10 94 TPP GRSH POL 94

40701-11 31 TPP DEFER FUELS 30

40701-12 35 TPP SANITATION POL 34

40701-13 83 TPP SANITATION POL 83

40701-14 32 TPP DEFER FUELS 31

40701-15 28 TPP SANITATION 28

40701-16 75 TPP GRSH POL 75

40701-17 15 TPP DEFER POL

40701-18 110 TPP GRSH POL

40701-19 93 TPP SANITATION POL 93

40701-20 35 TPP SANITATION POL

40701-21 71 TPP SANITATION

40701-23 73 TPP GRSH POL

40701-24 34 TPP SANITATION

40701-25 63 TPP SANITATION POL 63

40701-26 220 TPP GRSH POL

40701-28 64 TPP SANITATION 62

40701-30 72 TPP SANITATION

40701-31 65 TPP SANITATION HWDR 63

40701-32 51 TPP GRSH POL,HWDR 50

40701-33 63 TPP SANITATION POL

40701-35 25 GRA PE PE

40701-36 17 TPP DEFER POL

40701-37 45 TPP GRSH POL

40701-38 53 TPP GRSH POL

40701-39 67 TPP GRSH POL

40701-40 90 GRA PE PE 41

40701-41 35 GRA PE PE

40701-42 17 TPP DEFER 17

40701-43 4 GRA PE PE 4

40701-45 33 TPP GRSH POL 33

40702-1 131 TPP SANITATION

40702-2 85 TPP DEFER POL 83

40702-3 59 TPP SANITATION 59

40702-4 58 TPP SANITATION 58

40702-5 7 TPP GRSH

40702-6 17 TPP SANITATION

40702-7 50 TPP SWSC

40702-8 30 TPP SWSC

40702-9 68 TPP SWSC

40702-10 45 TPP SANITATION

40702-11 29 TPP SANITATION 20

40702-12 92 TPP GRSH POL 56

40702-13 68 TPP GRSH POL 68

40702-14 25 GRA PE PE

40702-15 81 TPP GRSH POL

40702-16 53 TPP DEFER POL 53

40702-17 78 TPP SANITATION 75

40702-18 22 GRA PE PE 22

40702-19 84 TPP GRSH POL 84

40702-20 56 TPP GRSH POL 56

40702-21 109 TPP GRSH POL 109

40702-22 22 TAA HWDR HWDR 22

40702-23 203 GRA PE PE 78
Briggs Spring Environmental Assessment Appendix D

D-3

40702-24 48 TPP GRSH POL

40702-25 9 TAA DEFER

40702-26 50 TPP SANITATION

40702-27 42 TPP SANITATION

40702-28 29 TPP DEFER

40702-29 40 TPP SANITATION

40702-30 24 TPP SANITATION

40702-31 50 TPP GRSH POL 44

40702-32 73 TPP GRSH POL

40702-33 52 GRA PE PE 5

40702-34 49 TPP CTHIN NO POL

40702-35 61 TPP CTHIN POL, HWDR

40702-36 24 GRA PE PE

40702-37 27 TPP GRSH POL, HWDR 27

40702-38 10 TPP SANITATION

40702-39 37 TPP SANITATION

40702-40 33 TPP GRSH POL

40702-41 56 TPP GRSH POL

40702-42 35 TPP GRSH POL

40702-43 28 TPP GRSH POL

40702-44 47 TPP GRSH POL 47

40702-45 74 TPP GRSH POL 74

40702-46 63 TPP GRSH POL

40702-47 23 TPP GRSH POL

40702-48 40 TPP GRSH POL

40702-49 55 TPP GRSH POL, HWDR

40702-50 82 TPP GRSH POL, HWDR

40702-51 49 TPP SANITATION

40702-52 76 TPP GRSH POL, HWDR

40702-53 62 TPP GRSH POL, HWDR

40702-54 32 TPP GRSH POL, HWDR

40702-55 47 TPP GRSH POL

40702-56 66 TPP CTHIN POL

40702-57 35 TPP GRSH FUELS

40702-58 16 TPP SANITATION

40702-59 58 TPP DEFER POL

40702-60 59 TPP DEFER POL

40702-61 7 GRA PE PE

40702-62 39 TPP DEFER POL

40702-63 58 TPP GRSH POL, HWDR

40702-64 57 TPP GRSH POL

40702-65 40 TPP GRSH POL

40702-66 55 TPP GRSH POL, HWDR

40702-67 58 TPP SWSC POL, HWDR

40702-68 68 TPP SANITATION

40702-69 36 TPP SANITATION

40702-70 82 GRA PE PE 5

40702-71 18 TPP SANITATION

40702-72 36 TPP DEFER

40702-73 22 TPP DEFER NO POL 20

40702-74 11 TPP GRSH POL 11

40702-77 25 TPP DEFER

40702-78 4 GRA PE PE

40702-79 18 TPP DEFER
Briggs Spring Environmental Assessment Appendix D

D-4

40702-80 50 TPP DEFER POL

40702-81 1 TAA HWDR HWDR

40702-82 5 TPP SANITATION

40703-1 32 TPP DEFER

40703-2 38 TPP SANITATION

40703-3 9 GRA PE PE

40703-4 41 TPP SANITATION POL

40703-5 12 TPP DEFER

40703-6 30 TPP SANITATION

40703-7 12 TPP DEFER POL

40703-8 32 TPP SANITATION POL

40703-9 19 TPP SANITATION

40703-10 29 TPP SANITATION

40703-11 50 TPP DEFER FUELS

40703-12 9 GRA PE PE

40703-13 69 TPP GRSH POL

40703-14 39 TPP DEFER FUELS

40703-15 43 TPP SANITATION FUELS

40703-16 44 TPP SANITATION

40703-17 51 TPP SANITATION

40703-18 68 TPP SANITATION

40703-19 37 TPP DEFER

40703-20 12 GRA PE PE

40703-21 20 TPP SANITATION FUELS

40703-22 24 TPP DEFER

40703-23 36 GRA PE PE

40703-24 36 TPP DEFER

40703-26 74 TPP SANITATION

40703-30 25 TPP SANITATION

40703-32 49 GRA PE PE

40703-33 18 TPP SANITATION FUELS

40703-34 56 TPP SANITATION FUELS

40703-35 68 TPP SANITATION FUELS

40703-36 14 TAA DEFER

40703-38 25 TPP SANITATION FUELS

40703-40 15 TAA DEFER

40704-1 64 TPP DEFER

40704-2 58 TPP DEFER

40704-3 18 GRA PE PE

40704-4 49 TPP SANITATION FUELS

40704-5 4 GRA PE PE

40704-6 64 TPP GRSH POL

40704-7 52 TPP SANITATION

40704-8 51 TPP SANITATION

40704-9 55 TPP GRSH POL

40704-10 69 TPP GRSH POL 68

40704-11 46 GRA PE PE 12

40704-12 60 TPP SANITATION

40704-13 53 TPP SANITATION

40704-14 30 TPP SANITATION

40704-15 23 GRA PE PE

40704-16 47 TPP GRSH POL 46

40704-17 51 TPP GRSH POL 50

40704-18 42 TPP GRSH POL 41
Briggs Spring Environmental Assessment Appendix D

D-5

40704-19 46 TPP GRSH POL 46

40704-20 51 TPP GRSH POL 50

40704-21 32 TPP SANITATION

40704-22 56 TPP GRSH POL

40704-23 40 TPP GRSH POL

40704-24 82 TPP DEFER FUELS

40704-25 35 GRA PE PE 10

40704-26 52 TPP GRSH POL 52

40704-27 56 TPP GRSH POL 55

40704-28 35 TPP GRSH 30

40704-29 9 GRA PE PE

40704-30 87 TPP GRSH POL

40704-31 44 TPP GRSH POL

40704-35 12 TPP SANITATION

40704-36 27 TPP DEFER POL

40705-101 15 GRA PE PE

40705-102 9 TAA DEFER

40705-103 109 TPP GRSH POL

40705-104 13 TPP DEFER

40705-105 69 GRA PE PE

40705-106 32 TPP GRSH POL

40705-107 41 TPP DEFER

40705-108 30 TPP DEFER

40705-109 12 TPP SANITATION FUELS

40705-110 46 TPP GRSH POL

40705-111 25 TPP DEFER

40705-112 56 TPP GRSH POL

40705-113 43 TPP GRSH POL

40705-114 58 TPP GRSH POL

40705-115 40 TPP GRSH POL

40705-116 38 GRA PE PE

40705-117 44 TPP GRSH POL

40705-118 71 TPP GRSH POL

40705-119 38 TPP GRSH POL

40705-120 63 TPP DEFER

40705-121 77 GRA PE PE

40705-122 46 TPP GRSH POL

40705-123 85 TPP GRSH POL

40705-124 79 TPP GRSH POL

40705-125 30 TPP GRSH POL

40705-126 78 TPP GRSH POL

40705-127 32 TPP GRSH POL

40705-128 16 TPP GRSH POL, HWDR

40705-129 33 TPP GRSH POL, HWDR

40705-130 91 TPP DEFER

40705-131 43 TPP DEFER

40705-132 58 GRA PE PE

40705-133 7 GRA PE PE

40705-134 21 TPP GRSH POL

40705-135 42 GRA PE PE

40705-136 17 TAA DEFER

40705-137 59 GRA PE PE

40705-138 17 TPP DEFER

40705-139 76 TPP SANITATION
Briggs Spring Environmental Assessment Appendix D

D-6

40705-140 63 TPP SANITATION

40705-141 80 TPP DEFER

40705-142 35 GRA PE PE

40705-143 59 TPP SANITATION

40705-144 54 TPP DEFER

40705-145 66 GRA PE PE

40705-146 53 GRA PE PE

40705-147 48 GRA PE PE

40705-148 67 TPP DEFER

40705-149 28 TPP DEFER

40705-150 56 TPP SANITATION

40705-151 78 TPP SANITATION

40705-152 45 TPP SANITATION

40705-153 54 TPP GRSH

40705-154 14 GRA PE PE 14

40705-155 33 TPP DEFER 31

40705-156 28 TPP GRSH POL, HWDR

40705-157 43 TPP DEFER

40705-158 56 GRA PE PE 35

40705-159 22 GRA PE PE

40705-160 54 TPP DEFER

40705-161 19 GRA PE PE

40705-162 35 TPP SANITATION

40705-163 42 TPP SANITATION

40705-164 31 TPP GRSH POL

40705-165 62 TPP GRSH POL

40705-166 32 TPP DEFER FUELS 32

40705-167 51 TPP DEFER FUELS 49

40705-168 69 TPP DEFER 67

40705-169 20 TPP DEFER FUELS 20

40705-170 3 TPP DEFER FUELS

40705-171 17 TPP SANITATION

40705-172 14 TPP DEFER

40705-173 10 GRA PE PE

40705-174 28 TPP SANITATION

40705-175 5 GRA PE PE 5

40705-176 24 TPP DEFER 24

40705-178 14 TPP GRSH HWDR

40801-1 10 TPP DEFER POL

40801-2 25 TPP SANITATION POL

40801-3 46 TPP DEFER

40801-4 70 TPP SANITATION

40801-5 19 TPP DEFER POL

40801-6 22 TPP SANITATION

40801-7 45 TPP SANITATION

40801-8 67 TPP SANITATION FUELS

40801-9 16 TPP DEFER POL

40801-10 53 TPP GRSH POL

40801-11 18 GRA PE PE

40801-12 58 GRA PE PE

40801-13 38 TPP GRSH POL

40801-14 10 GRA PE PE

40801-15 7 TPP DEFER

40801-16 6 GRA DEFER
Briggs Spring Environmental Assessment Appendix D

D-7

40802-1 47 TPP DEFER FUELS 47

40802-2 55 TPP DEFER 55

40802-3 35 TPP DEFER

40802-4 75 TPP SWSC

40802-5 59 TPP SWSC

40802-6 36 TPP SANITATION

40802-7 37 TPP CTHIN 29

40802-8 32 TPP GRSH 32

40802-9 42 TPP GRSH 42

40802-10 65 TPP GRSH POL, HWDR 65

40802-11 59 TPP GRSH POL

40802-12 51 TPP DEFER

40802-13 32 TPP SWSC

40802-14 29 TPP SANITATION

40802-15 65 TPP DEFER POL

40802-16 8 GRA PE PE

40802-17 41 TAA HWDR HWDR 27

40802-18 26 TPP SWSC 26

40802-19 44 TPP SANITATION 44

40802-20 52 TPP SANITATION 51

40802-21 74 TPP GRSH POL 70

40802-22 25 TAA HWDR HWDR 14

40802-23 52 TPP SANITATION

40802-24 62 TPP SANITATION

40802-25 31 TPP GRSH POL 5

40802-26 19 TPP GRSH POL

40802-27 74 TPP GRSH POL 74

40802-28 30 TPP GRSH POL 30

40802-29 20 GRA PE PE 14

40802-30 106 TPP SANITATION POL 40

40802-31 63 TPP SANITATION

40802-32 84 TPP SANITATION

40802-33 72 TPP SANITATION

40802-34 50 TPP DEFER FUELS 22

40802-35 26 TPP SANITATION FUELS

40802-36 17 TPP GRSH POL, HWDR

40802-37 23 TPP GRSH POL 23

40802-38 43 TPP GRSH POL 43

40802-39 41 TPP GRSH POL 41

40802-40 61 TPP GRSH POL 61

40802-41 72 TPP GRSH POL 72

40802-42 70 TPP GRSH POL 70

40802-43 53 TPP GRSH POL 52

40802-44 58 GRA PE PE 9

40802-45 74 TPP CTHIN POL 49

40802-46 91 GRA PE PE 69

40802-47 78 TPP SANITATION FUELS 77

40802-48 4 GRA PE PE 4

40802-49 41 TPP GRSH POL 41

40802-50 79 TPP CTHIN POL 79

40802-51 73 TPP CTHIN POL

40802-52 69 TPP SANITATION FUELS

40802-53 75 TPP DEFER FUELS

40802-54 53 TPP SANITATION
Briggs Spring Environmental Assessment Appendix D

D-8

40803-101 69 TPP GRSH POL

40803-102 119 TPP SANITATION

40803-103 54 TPP GRSH POL

40803-104 111 TPP GRSH POL 103

40803-105 33 TPP SANITATION

40803-106 102 TPP DEFER

40803-107 55 TPP GRSH POL

40803-108 69 TPP CTHIN POL 69

40803-109 50 TPP CTHIN POL 50

40803-110 100 TPP GRSH POL 100

40803-111 42 TPP SANITATION

40803-112 30 TPP CTHIN POL

40803-113 33 TPP SWSC HWDR

40803-114 36 TPP DEFER 32

40803-115 43 TPP CTHIN POL 32

40803-116 68 TPP DEFER FUELS

40803-117 24 TPP CTHIN POL

40803-118 49 TPP DEFER POL

40803-119 37 TPP DEFER

40803-120 30 TPP DEFER

40803-121 61 TPP CTHIN POL

40803-122 18 TPP SANITATION

40803-123 25 TPP SANITATION

40803-124 66 TPP DEFER POL

40803-125 100 TPP DEFER

40803-126 18 TPP CTHIN HWDR 18

40803-127 105 GRA PE PE 14

40803-128 52 GRA PE PE 21

40803-129 28 TPP OSR POL

40803-130 30 TPP SANITATION

40803-131 4 GRA PE PE

40803-132 31 TPP DEFER 31

40803-133 21 TPP CTHIN POL

40803-134 1 TPP SANITATION

40803-135 4 GRA PE PE

40803-143 8 TPP DEFER

40804-101 40 TPP CTHIN POL

40804-102 69 TPP SANITATION

40804-103 41 TPP CTHIN POL, HWDR

40804-104 28 TPP CTHIN POL 24

40804-105 25 GRA PE PE 25

40804-106 6 GRA PE PE 6

40804-107 19 TPP DEFER 17

40804-108 56 TPP GRSH POL, HWDR 56

40804-109 27 TPP CTHIN POL 26

40804-110 11 GRA PE PE

40804-111 10 TPP SANITATION

40804-112 47 TPP SANITATION

40804-113 44 GRA PE PE 12

40804-115 24 TPP GRSH POL, 

Deadfall 24

40804-116 28 GRA PE PE 24

40804-117 80 TPP SANITATION

40804-118 11 GRA PE PE
Briggs Spring Environmental Assessment Appendix D

D-9

40804-119 73 TPP CTHIN POL, 

Deadfall 10

40804-120 56 TPP CTHIN POL, 

Deadfall 3

40804-121 15 GRA PE PE 9

40804-122 11 TAA HWDR HWDR 6

40804-123 64 TPP CTHIN POL, 

Deadfall 15

40804-124 50 TPP SANITATION DEADFALL 10

40804-125 15 TAA HWDR HWDR 12

40804-126 12 TPP DEFER

40804-129 20 TPP DEFER DEADFALL 20

40804-130 44 TPP CTHIN POL, 

Deadfall

40804-131 3 TAA HWDR HWDR

40804-133 24 TPP DEFER 24

40804-134 47 TPP DEFER DEADFALL 45

40804-135 20 TPP DEFER 16

40804-136 22 TPP DEFER

40804-137 37 TPP DEFER DEADFALL 19

40804-140 125 TPP DEFER DEADFALL 123

40805-101 64 TPP SANITATION

40805-102 49 TPP SANITATION

40805-103 27 TPP SANITATION

40805-104 51 TPP SANITATION

40805-107 80 GRA PE PE 33

40805-109 27 TPP DEFER 27

40805-121 28 TPP DEFER Deadfall, 

HWDR

40805-125 77 TPP DEFER

40805-126 38 TPP DEFER DEADFALL

40805-127 18 TPP DEFER

40805-128 10 TPP DEFER 10

40805-129 23 TPP DEFER 23

40805-132 29 TPP DEFER DEADFALL 29

40805-133 34 TPP DEFER DEADFALL 34

40805-135 33 TPP SANITATION 33

40805-136 63 TPP DEFER 63

40805-137 6 TPP SANITATION 6

40805-138 29 TPP DEFER 29

40805-139 10 TAA HWDR HWDR 10

40805-140 7 TAA DEFER HWDR 7

40805-141 18 TPP DEFER DEADFALL 18

40805-142 56 TPP SANITATION 56

40805-143 18 TPP DEFER 7

40805-144 43 TPP GRSH POL

40805-145 29 TPP DEFER DEADFALL 15

40805-146 13 TPP DEFER

40805-147 44 TPP DEFER DEADFALL

40805-148 48 TPP DEFER DEADFALL

40805-149 110 TPP DEFER DEADFALL 100

40805-151 26 TPP OSR 26

40805-152 39 TPP CTHIN POL, deadfall 39

40805-153 28 TPP SANITATION
Briggs Spring Environmental Assessment Appendix D

D-10

40805-154 16 TPP DEFER DEADFALL 15

40806-101 35 TPP CTHIN POL

40806-102 84 TPP SANITATION

40806-103 96 TPP DEFER POL

40806-104 37 TPP DEFER DEADFALL

40806-105 55 TPP DEFER POL

40806-106 39 TPP DEFER

40806-107 41 TPP CTHIN POL

40806-108 62 TPP CTHIN POL

40806-109 74 TPP DEFER

40806-110 34 TPP DEFER

40806-111 48 TPP CTHIN POL

40806-112 20 TPP CTHIN POL

40806-113 5 GRA PE PE

40806-114 25 TPP CTHIN POL

40806-115 61 TPP DEFER

40806-116 72 TPP SANITATION DEADFALL

40806-117 18 TPP DEFER DEADFALL

40806-118 95 GRA PE PE

40806-119 15 TPP DEFER DEADFALL

40806-120 40 TPP CTHIN POL, HWDR

40806-121 45 TPP CTHIN HWDR

40806-122 49 TPP SANITATION

40806-123 26 TPP SANITATION

40806-124 18 TPP SANITATION

40806-125 37 TPP CTHIN HWDR

40806-126 66 TPP CTHIN POL

40806-127 21 TPP CTHIN POL

40806-128 52 TPP CTHIN POL

40806-129 34 TPP CTHIN POL

40806-130 30 TPP CTHIN POL

40806-131 70 TPP CTHIN POL 48

40806-132 106 TPP SWSC

40806-133 56 TPP DEFER POL

40806-134 84 TPP OSR POL

40806-135 26 TPP DEFER DEADFALL 26

40806-137 65 TPP CTHIN POL 59

40806-138 91 TPP SANITATION

40806-139 15 TPP SANITATION

40806-140 77 TPP DEFER DEADFALL 77

40806-141 53 TPP SANITATION DEADFALL 52

40806-142 112 TPP DEFER DEADFALL 110

40806-143 9 GRA PE DEFER 8

40806-144 38 GRA PE PE 35

40806-145 15 TPP SANITATION

40806-146 38 GRA PE PE

40806-147 10 TPP DEFER

40807-101 19 TPP DEFER

40807-102 16 TPP DEFER

40807-103 21 TPP DEFER

40807-104 14 GRA PE PE

40807-105 69 TPP SANITATION 67

40807-106 39 TPP SANITATION 20

40807-107 67 TPP DEFER
Briggs Spring Environmental Assessment Appendix D

D-11

40807-108 13 GRA PE PE

40807-109 74 TPP DEFER DEADFALL

40807-110 63 TPP DEFER

40807-111 21 TPP SANITATION 21

40807-112 94 TPP DEFER DEADFALL 79

40807-114 9 TPP DEFER 9

40807-115 40 TPP SANITATION DEADFALL 28

40807-116 32 GRA PE PE 9

40807-118 29 TPP SANITATION DEADFALL 29

40807-119 57 TPP DEFER

40807-120 38 TPP DEFER DEADFALL

40807-121 53 TPP DEFER

40807-123 21 GRA PE PE

40807-124 54 TPP DEFER DEADFALL

40807-126 102 TPP DEFER

40807-128 60 TPP DEFER DEADFALL

40807-129 29 TPP GRSH POL

40807-130 21 TPP SANITATION DEADFALL 17

40807-131 19 TPP DEFER

40807-132 24 TPP DEFER DEADFALL

40807-133 28 TPP DEFER

40807-134 44 TPP DEFER

40807-135 8 GRA DEFER DEFER

40807-136 80 TPP DEFER

40807-137 58 TPP DEFER

40807-138 36 TPP DEFER

40807-139 20 GRA PE PE

40807-140 22 TPP DEFER

40807-141 28 TPP DEFER DEADFALL

40807-142 38 TPP DEFER DEADFALL

40807-143 34 TPP DEFER

40807-144 53 TPP DEFER

40807-145 25 TPP DEFER

40807-151 7 TPP SANITATION 7

40807-152 38 TPP DEFER

40807-153 24 TPP DEFER DEADFALL 10

40808-101 29 TPP DEFER

40808-102 23 TPP CTHIN POL

40808-103 40 TPP CTHIN POL

40808-104 44 TPP CTHIN POL

40808-105 56 TPP SANITATION

40808-106 139 TPP SANITATION

40808-107 14 GRA PE PE

40808-108 34 GRA PE PE

40808-109 67 TPP CTHIN POL

40808-110 21 GRA PE PE

40808-111 5 TPP DEFER

40808-112 41 TPP DEFER DEADFALL

Total Acres 24,548 6,295
Briggs Spring Environmental Assessment Appendix D

D-12

Alternative 3 Treatments and Post-Sale Activities

Alternative Prescription Abbreviations:

CTHIN – Commercial Thin

GRSH – Group Shelterwood

HDWC – Hardwood Conversion

HDWR – Hardwood Release

OSR – Overstory Removal

PE – Pine Encroachment

POL – POL Thinning

SWSC – Shelterwood Seed Cut

Cover Type Abbreviations:

TPP – Ponderosa Pine

TAA – Aspen

GRA – Grass, meadow

Location/Site Site Acres

Post Sale

Cover Type

Alternative 2

Prescription

Alternative 2

Post Sale 

Activities

Alternative 2

Prescribe 

Burning 

Acres

40401-118 10 TAA DEFER

40502-18 47 TPP HWDC HWDR 47

40502-19 49 TPP GRSH POL, HWDR 19

40502-20 30 TPP GRSH POL, HWDR 17

40502-21 33 TPP SANITATION

40502-22 27 TAA HWDR HWDR 27

40502-23 28 TPP HWDC POL, HWDR 27

40502-24 62 TPP GRSH FUELS

40502-25 37 TPP GRSH FUELS 37

40502-26 20 TAA HWDR HWDR 20

40502-27 48 TAA HWDC HWDR 48

40502-28 47 TAA HWDR HWDR 47

40502-39 40 TPP GRSH FUELS 6

40502-40 44 TPP GRSH POL 9

40502-41 55 TPP GRSH FUELS

40502-45 45 GRA PE PE 45

40502-49 20 TPP GRSH FUELS

40502-51 37 GRA PE PE 37

40502-52 12 GRA PE PE 12

40502-63 20 TPP CTHIN POL 20

40502-64 27 TAA HWDR HWDR 27

40502-65 9 TPP SANITATION 9

40701-1 100 TPP GRSH FUELS

40701-2 95 TPP CTHIN POL

40701-4 54 TPP SANITATION

40701-5 81 TPP SANITATION

40701-6 11 GRA PE PE

40701-7 97 TPP GRSH POL

40701-8 58 GRA PE PE 17

40701-9 41 TPP SANITATION

40701-10 94 TPP GRSH POL 94

40701-11 31 TPP GRSH FUELS 30
Briggs Spring Environmental Assessment Appendix D

D-13

40701-12 35 TPP GRSH POL 34

40701-13 83 TPP GRSH POL 83

40701-14 32 TPP GRSH FUELS 31

40701-15 28 TPP GRSH 28

40701-16 75 TPP GRSH POL 75

40701-17 15 TPP GRSH POL

40701-18 110 TPP GRSH POL

40701-19 93 TPP GRSH POL 93

40701-20 35 TPP GRSH POL

40701-21 71 TPP GRSH

40701-23 73 TPP GRSH POL

40701-24 34 TPP GRSH

40701-25 63 TPP GRSH POL 63

40701-26 220 TPP GRSH POL

40701-28 64 TPP GRSH 62

40701-30 72 TPP GRSH

40701-31 65 TPP GRSH HWDR 63

40701-32 51 TPP GRSH POL, HWDR 50

40701-33 63 TPP GRSH POL

40701-35 25 GRA PE PE

40701-36 17 TPP GRSH POL

40701-37 45 TPP GRSH POL

40701-38 53 TPP GRSH POL

40701-39 67 TPP GRSH POL

40701-40 90 GRA PE PE 41

40701-41 35 GRA PE PE

40701-42 17 TPP GRSH 17

40701-43 4 GRA PE PE 4

40701-45 33 TPP GRSH POL 33

40702-1 131 TPP SANITATION

40702-2 85 TPP GRSH POL 83

40702-3 59 TPP SANITATION 59

40702-4 58 TPP SANITATION 58

40702-5 7 TPP GRSH

40702-6 17 TPP SANITATION

40702-7 50 TPP SWSC

40702-8 30 TPP SWSC

40702-9 68 TPP SWSC

40702-10 45 TPP GRSH

40702-11 29 TPP GRSH 20

40702-12 92 TPP GRSH POL 56

40702-13 68 TPP GRSH POL 68

40702-14 25 GRA PE PE

40702-15 81 TPP GRSH POL

40702-16 53 TPP GRSH POL 53

40702-17 78 TPP SANITATION 75

40702-18 22 GRA PE PE 22

40702-19 84 TPP GRSH POL 84

40702-20 56 TPP GRSH POL 56

40702-21 109 TPP GRSH POL 109

40702-22 22 TAA HWDR HWDR 22

40702-23 203 GRA PE PE 78

40702-24 48 TPP GRSH POL

40702-25 9 TAA DEFER
Briggs Spring Environmental Assessment Appendix D

D-14

40702-26 50 TPP SANITATION

40702-27 42 TPP SANITATION

40702-28 29 TPP GRSH

40702-29 40 TPP SANITATION

40702-30 24 TPP SANITATION

40702-31 50 TPP GRSH POL 44

40702-32 73 TPP GRSH POL

40702-33 52 GRA PE PE 5

40702-34 49 TPP CTHIN

40702-35 61 TPP CTHIN POL, HWDR

40702-36 24 GRA PE PE

40702-37 27 TPP GRSH POL, HWDR 27

40702-38 10 TPP SANITATION

40702-39 37 TPP SANITATION

40702-40 33 TPP GRSH POL

40702-41 56 TPP GRSH POL

40702-42 35 TPP GRSH POL

40702-43 28 TPP GRSH POL

40702-44 47 TPP GRSH POL 47

40702-45 74 TPP GRSH POL 74

40702-46 63 TPP GRSH POL

40702-47 23 TPP GRSH POL

40702-48 40 TPP GRSH POL

40702-49 55 TPP GRSH POL, HWDR

40702-50 82 TPP GRSH POL, HWDR

40702-51 49 TPP SANITATION

40702-52 76 TPP GRSH POL, HWDR

40702-53 62 TPP GRSH POL, HWDR

40702-54 32 TPP GRSH POL, HWDR

40702-55 47 TPP GRSH POL

40702-56 66 TPP CTHIN POL

40702-57 35 TPP GRSH FUELS

40702-58 16 TPP GRSH

40702-59 58 TPP GRSH POL

40702-60 59 TPP GRSH POL

40702-61 7 GRA PE PE

40702-62 39 TPP GRSH POL

40702-63 58 TPP GRSH POL, HWDR

40702-64 57 TPP GRSH POL

40702-65 40 TPP GRSH POL

40702-66 55 TPP GRSH POL, HWDR

40702-67 58 TPP SWSC POL, HWDR

40702-68 68 TPP SANITATION

40702-69 36 TPP SANITATION

40702-70 82 GRA PE PE 5

40702-71 18 TPP GRSH

40702-72 36 TPP GRSH

40702-73 22 TPP GRSH 20

40702-74 11 TPP GRSH POL 11

40702-77 25 TPP DEFER

40702-78 4 GRA PE PE

40702-79 18 TPP GRSH

40702-80 50 TPP GRSH POL

40702-81 1 TAA HWDR HWDR
Briggs Spring Environmental Assessment Appendix D

D-15

40702-82 5 TPP SANITATION

40703-1 32 TPP GRSH

40703-2 38 TPP GRSH

40703-3 9 GRA PE PE

40703-4 41 TPP GRSH POL

40703-5 12 TPP GRSH

40703-6 30 TPP GRSH

40703-7 12 TPP GRSH POL

40703-8 32 TPP GRSH POL

40703-9 19 TPP GRSH

40703-10 29 TPP SANITATION

40703-11 50 TPP GRSH FUELS

40703-12 9 GRA PE PE

40703-13 69 TPP GRSH POL

40703-14 39 TPP GRSH FUELS

40703-15 43 TPP GRSH FUELS

40703-16 44 TPP SANITATION

40703-17 51 TPP GRSH

40703-18 68 TPP SANITATION

40703-19 37 TPP GRSH

40703-20 12 GRA PE PE

40703-21 20 TPP GRSH FUELS

40703-22 24 TPP GRSH

40703-23 36 GRA PE PE

40703-24 36 TPP GRSH

40703-26 74 TPP GRSH

40703-30 25 TPP GRSH

40703-32 49 GRA PE PE

40703-33 18 TPP GRSH FUELS

40703-34 56 TPP GRSH FUELS

40703-35 68 TPP GRSH FUELS

40703-36 14 TAA DEFER

40703-38 25 TPP GRSH FUELS

40703-40 15 TAA DEFER

40704-1 64 TPP GRSH

40704-2 58 TPP GRSH

40704-3 18 GRA PE PE

40704-4 49 TPP SANITATION FUELS

40704-5 4 GRA PE PE

40704-6 64 TPP GRSH POL

40704-7 52 TPP GRSH

40704-8 51 TPP GRSH

40704-9 55 TPP GRSH POL

40704-10 69 TPP GRSH POL 68

40704-11 46 GRA PE PE 12

40704-12 60 TPP GRSH

40704-13 53 TPP GRSH

40704-14 30 TPP SANITATION

40704-15 23 GRA PE PE

40704-16 47 TPP GRSH POL 46

40704-17 51 TPP GRSH POL 50

40704-18 42 TPP GRSH POL 41

40704-19 46 TPP GRSH POL 46

40704-20 51 TPP GRSH POL 50
Briggs Spring Environmental Assessment Appendix D

D-16

40704-21 32 TPP GRSH

40704-22 56 TPP GRSH POL

40704-23 40 TPP GRSH POL

40704-24 82 TPP GRSH FUELS 19

40704-25 35 GRA PE PE 10

40704-26 52 TPP GRSH POL 52

40704-27 56 TPP GRSH POL 55

40704-28 35 TPP GRSH 30

40704-29 9 GRA PE PE

40704-30 87 TPP GRSH POL

40704-31 44 TPP GRSH POL

40704-35 12 TPP SANITATION

40704-36 27 TPP DEFER POL

40705-101 15 GRA PE PE

40705-102 9 TAA HWDR

40705-103 109 TPP GRSH POL

40705-104 13 TPP GRSH

40705-105 69 GRA PE PE

40705-106 32 TPP GRSH POL

40705-107 41 TPP GRSH

40705-108 30 TPP GRSH

40705-109 12 TPP GRSH FUELS

40705-110 46 TPP GRSH POL

40705-111 25 TPP GRSH

40705-112 56 TPP GRSH POL

40705-113 43 TPP GRSH POL

40705-114 58 TPP GRSH POL

40705-115 40 TPP GRSH POL

40705-116 38 GRA PE PE

40705-117 44 TPP GRSH POL

40705-118 71 TPP GRSH POL

40705-119 38 TPP GRSH POL

40705-120 63 TPP GRSH

40705-121 77 GRA PE PE 5

40705-122 46 TPP GRSH POL

40705-123 85 TPP GRSH POL

40705-124 79 TPP GRSH POL

40705-125 30 TPP GRSH POL

40705-126 78 TPP GRSH POL

40705-127 32 TPP GRSH POL

40705-128 16 TPP GRSH POL, HWDR

40705-129 33 TPP GRSH POL, HWDR 11

40705-130 91 TPP GRSH POL 29

40705-131 43 TPP GRSH POL 7

40705-132 58 GRA PE PE 23

40705-133 7 GRA PE PE

40705-134 21 TPP GRSH POL

40705-135 42 GRA PE PE

40705-136 17 TAA DEFER

40705-137 59 GRA PE PE 34

40705-138 17 TPP GRSH POL 17

40705-139 76 TPP SANITATION

40705-140 63 TPP SANITATION

40705-141 80 TPP GRSH
Briggs Spring Environmental Assessment Appendix D

D-17

40705-142 35 GRA PE PE

40705-143 59 TPP SANITATION

40705-144 54 TPP GRSH POL

40705-145 66 GRA PE PE

40705-146 53 GRA PE PE 52

40705-147 48 GRA PE PE 42

40705-148 67 TPP DEFER

40705-149 28 TPP DEFER

40705-150 56 TPP SANITATION

40705-151 78 TPP SANITATION

40705-152 45 TPP SANITATION

40705-153 54 TPP GRSH

40705-154 14 GRA PE PE 14

40705-155 33 TPP GRSH 31

40705-156 28 TPP GRSH POL, HWDR

40705-157 43 TPP GRSH

40705-158 56 GRA PE PE 35

40705-159 22 GRA PE PE

40705-160 54 TPP GRSH

40705-161 19 GRA PE PE

40705-162 35 TPP SANITATION

40705-163 42 TPP GRSH

40705-164 31 TPP GRSH POL

40705-165 62 TPP GRSH POL

40705-166 32 TPP GRSH FUELS 32

40705-167 51 TPP GRSH FUELS 49

40705-168 69 TPP GRSH 67

40705-169 20 TPP GRSH FUELS 20

40705-170 3 TPP GRSH FUELS

40705-171 17 TPP SANITATION

40705-172 14 TPP DEFER 14

40705-173 10 GRA PE PE

40705-174 28 TPP SANITATION

40705-175 5 GRA PE PE 5

40705-176 24 TPP GRSH 24

40705-178 14 TPP GRSH HWDR

40801-1 10 TPP GRSH POL

40801-2 25 TPP GRSH POL

40801-3 46 TPP GRSH

40801-4 70 TPP SANITATION

40801-5 19 TPP GRSH POL

40801-6 22 TPP GRSH

40801-7 45 TPP SANITATION

40801-8 67 TPP GRSH FUELS

40801-9 16 TPP GRSH POL

40801-10 53 TPP GRSH POL

40801-11 18 GRA PE PE

40801-12 58 GRA PE PE

40801-13 38 TPP GRSH POL

40801-14 10 GRA PE PE

40801-15 7 TPP DEFER

40801-16 6 GRA DEFER

40802-1 47 TPP GRSH FUELS 47

40802-2 55 TPP GRSH 55
Briggs Spring Environmental Assessment Appendix D

D-18

40802-3 35 TPP GRSH

40802-4 75 TPP SWSC

40802-5 59 TPP SWSC

40802-6 36 TPP SANITATION

40802-7 37 TPP CTHIN 29

40802-8 32 TPP GRSH 32

40802-9 42 TPP GRSH 42

40802-10 65 TPP GRSH POL, HWDR 65

40802-11 59 TPP GRSH POL

40802-12 51 TPP DEFER

40802-13 32 TPP SWSC

40802-14 29 TPP SANITATION

40802-15 65 TPP GRSH POL

40802-16 8 GRA PE PE

40802-17 41 TAA HWDR HWDR 27

40802-18 26 TPP SWSC 26

40802-19 44 TPP SANITATION 44

40802-20 52 TPP SANITATION 51

40802-21 74 TPP GRSH POL 70

40802-22 25 TAA HWDR HWDR 14

40802-23 52 TPP SANITATION POL

40802-24 62 TPP SANITATION POL

40802-25 31 TPP GRSH POL 5

40802-26 19 TPP GRSH POL

40802-27 74 TPP GRSH POL 74

40802-28 30 TPP GRSH POL 30

40802-29 20 GRA PE PE 14

40802-30 106 TPP SANITATION POL 40

40802-31 63 TPP SANITATION POL

40802-32 84 TPP SANITATION POL

40802-33 72 TPP SANITATION POL

40802-34 50 TPP GRSH FUELS 22

40802-35 26 TPP GRSH FUELS

40802-36 17 TPP GRSH POL, HWDR

40802-37 23 TPP GRSH POL 23

40802-38 43 TPP GRSH POL 43

40802-39 41 TPP GRSH POL 41

40802-40 61 TPP GRSH POL 61

40802-41 72 TPP GRSH POL 72

40802-42 70 TPP GRSH POL 70

40802-43 53 TPP GRSH POL 52

40802-44 58 GRA PE PE 9

40802-45 74 TPP CTHIN POL 49

40802-46 91 GRA PE PE 69

40802-47 78 TPP GRSH POL 77

40802-48 4 GRA PE PE 4

40802-49 41 TPP GRSH POL 41

40802-50 79 TPP CTHIN POL 79

40802-51 73 TPP CTHIN POL

40802-52 69 TPP SANITATION FUELS

40802-53 75 TPP GRSH FUELS

40802-54 53 TPP GRSH

40803-101 69 TPP GRSH POL

40803-102 119 TPP SANITATION
Briggs Spring Environmental Assessment Appendix D

D-19

40803-103 54 TPP GRSH POL

40803-104 111 TPP GRSH POL 103

40803-105 33 TPP SANITATION

40803-106 102 TPP GRSH

40803-107 55 TPP GRSH POL

40803-108 69 TPP CTHIN POL 69

40803-109 50 TPP CTHIN POL 50

40803-110 100 TPP GRSH POL 100

40803-111 42 TPP SANITATION

40803-112 30 TPP CTHIN POL

40803-113 33 TPP SWSC HWDR

40803-114 36 TPP GRSH 32

40803-115 43 TPP CTHIN POL 32

40803-116 68 TPP GRSH FUELS

40803-117 24 TPP CTHIN POL

40803-118 49 TPP GRSH POL

40803-119 37 TPP GRSH

40803-120 30 TPP GRSH

40803-121 61 TPP CTHIN POL

40803-122 18 TPP SANITATION

40803-123 25 TPP SANITATION

40803-124 66 TPP GRSH POL

40803-125 100 TPP GRSH

40803-126 18 TPP CTHIN HWDR 18

40803-127 105 GRA PE PE 14

40803-128 52 GRA PE PE 21

40803-129 28 TPP OSR POL

40803-130 30 TPP SANITATION

40803-131 4 GRA PE PE

40803-132 31 TPP GRSH 31

40803-133 21 TPP CTHIN POL

40803-134 1 TPP SANITATION

40803-135 4 GRA PE PE

40803-143 8 TPP GRSH

40804-101 40 TPP CTHIN POL

40804-102 69 TPP SANITATION

40804-103 41 TPP CTHIN POL, HWDR

40804-104 28 TPP CTHIN POL 24

40804-105 25 GRA PE PE 25

40804-106 6 GRA PE PE 6

40804-107 19 TPP GRSH 17

40804-108 56 TPP GRSH POL, HWDR 56

40804-109 27 TPP CTHIN POL 26

40804-110 11 GRA PE PE

40804-111 10 TPP SANITATION

40804-112 47 TPP SANITATION

40804-113 44 GRA PE PE 12

40804-115 24 TPP GRSH POL, 

Deadfall 24

40804-116 28 GRA PE PE 24

40804-117 80 TPP SANITATION

40804-118 11 GRA PE PE

40804-119 73 TPP CTHIN POL, 

Deadfall 10
Briggs Spring Environmental Assessment Appendix D

D-20

40804-120 56 TPP CTHIN POL, 

Deadfall 3

40804-121 15 GRA PE PE 9

40804-122 11 TAA HWDR HWDR 6

40804-123 64 TPP CTHIN POL, 

Deadfall 15

40804-124 50 TPP SANITATION DEADFALL 10

40804-125 15 TAA HWDR HWDR

40804-126 12 TPP DEFER 12

40804-129 20 TPP GRSH DEADFALL 20

40804-130 44 TPP CTHIN POL, 

Deadfall

40804-131 3 TAA HWDR HWDR

40804-133 24 TPP GRSH 24

40804-134 47 TPP DEFER DEADFALL 45

40804-135 20 TPP DEFER 16

40804-136 22 TPP DEFER

40804-137 37 TPP GRSH DEADFALL 19

40804-140 125 TPP GRSH DEADFALL 123

40805-101 64 TPP SANITATION

40805-102 49 TPP SANITATION

40805-103 27 TPP SANITATION

40805-104 51 TPP SANITATION

40805-107 80 GRA PE PE 33

40805-109 27 TPP DEFER 27

40805-121 28 TPP GRSH Deadfall, 

HWDR

40805-125 77 TPP GRSH

40805-126 38 TPP GRSH DEADFALL

40805-127 18 TPP DEFER

40805-128 10 TPP GRSH 10

40805-129 23 TPP DEFER 23

40805-132 29 TPP GRSH DEADFALL 29

40805-133 34 TPP DEFER DEADFALL 34

40805-135 33 TPP SANITATION 33

40805-136 63 TPP DEFER 63

40805-137 6 TPP SANITATION 6

40805-138 29 TPP GRSH 29

40805-139 10 TAA HWDR HWDR 10

40805-140 7 TAA DEFER HWDR 7

40805-141 18 TPP DEFER DEADFALL 18

40805-142 56 TPP SANITATION 56

40805-143 18 TPP DEFER 7

40805-144 43 TPP GRSH

40805-145 29 TPP DEFER DEADFALL 15

40805-146 13 TPP GRSH

40805-147 44 TPP DEFER DEADFALL

40805-148 48 TPP GRSH DEADFALL

40805-149 110 TPP GRSH DEADFALL 100

40805-151 26 TPP OSR 26

40805-152 39 TPP CTHIN POL, deadfall 39

40805-153 28 TPP SANITATION

40805-154 16 TPP GRSH DEADFALL 15

40806-101 35 TPP CTHIN POL
Briggs Spring Environmental Assessment Appendix D

D-21

40806-102 84 TPP SANITATION

40806-103 96 TPP GRSH POL

40806-104 37 TPP GRSH DEADFALL

40806-105 55 TPP GRSH POL

40806-106 39 TPP GRSH

40806-107 41 TPP CTHIN POL

40806-108 62 TPP CTHIN POL

40806-109 74 TPP GRSH

40806-110 34 TPP GRSH

40806-111 48 TPP CTHIN POL

40806-112 20 TPP CTHIN POL

40806-113 5 GRA PE PE

40806-114 25 TPP CTHIN POL

40806-115 61 TPP GRSH

40806-116 72 TPP GRSH DEADFALL

40806-117 18 TPP GRSH DEADFALL

40806-118 95 GRA PE PE

40806-119 15 TPP GRSH DEADFALL

40806-120 40 TPP CTHIN POL, HWDR

40806-121 45 TPP CTHIN HWDR

40806-122 49 TPP SANITATION

40806-123 26 TPP SANITATION

40806-124 18 TPP SANITATION

40806-125 37 TPP CTHIN HWDR

40806-126 66 TPP CTHIN POL

40806-127 21 TPP CTHIN POL

40806-128 52 TPP CTHIN POL

40806-129 34 TPP CTHIN POL

40806-130 30 TPP CTHIN POL

40806-131 70 TPP CTHIN POL 48

40806-132 106 TPP SWSC

40806-133 56 TPP GRSH POL

40806-134 84 TPP OSR POL

40806-135 26 TPP GRSH DEADFALL 26

40806-137 65 TPP CTHIN POL 59

40806-138 91 TPP SANITATION

40806-139 15 TPP SANITATION

40806-140 77 TPP GRSH DEADFALL 77

40806-141 53 TPP GRSH DEADFALL 52

40806-142 112 TPP GRSH DEADFALL 110

40806-143 9 GRA DEFER 8

40806-144 38 GRA PE PE 35

40806-145 15 TPP SANITATION

40806-146 38 GRA PE PE

40806-147 10 TPP DEFER

40807-101 19 TPP GRSH

40807-102 16 TPP GRSH

40807-103 21 TPP GRSH

40807-104 14 GRA PE PE

40807-105 69 TPP SANITATION 67

40807-106 39 TPP GRSH 20

40807-107 67 TPP GRSH

40807-108 13 GRA PE PE

40807-109 74 TPP DEFER DEADFALL
Briggs Spring Environmental Assessment Appendix D

D-22

40807-110 63 TPP GRSH

40807-111 21 TPP SANITATION 21

40807-112 94 TPP GRSH DEADFALL 78

40807-114 9 TPP GRSH 9

40807-115 40 TPP GRSH DEADFALL 28

40807-116 32 GRA PE PE 9

40807-118 29 TPP SANITATION DEADFALL 29

40807-119 57 TPP GRSH

40807-120 38 TPP GRSH DEADFALL

40807-121 53 TPP DEFER

40807-123 21 GRA PE PE

40807-124 54 TPP GRSH DEADFALL

40807-126 102 TPP DEFER

40807-128 60 TPP GRSH DEADFALL

40807-129 29 TPP GRSH POL

40807-130 21 TPP GRSH DEADFALL 17

40807-131 19 TPP GRSH

40807-132 24 TPP DEFER DEADFALL

40807-133 28 TPP DEFER

40807-134 44 TPP DEFER

40807-135 8 GRA DEFER

40807-136 80 TPP DEFER

40807-137 58 TPP DEFER

40807-138 36 TPP DEFER

40807-139 20 GRA PE PE

40807-140 22 TPP GRSH

40807-141 28 TPP DEFER DEADFALL

40807-142 38 TPP GRSH DEADFALL

40807-143 34 TPP GRSH

40807-144 53 TPP GRSH

40807-145 25 TPP DEFER

40807-151 7 TPP SANITATION 7

40807-152 38 TPP DEFER 10

40807-153 24 TPP GRSH DEADFALL

40808-101 29 TPP GRSH

40808-102 23 TPP CTHIN POL

40808-103 40 TPP CTHIN POL

40808-104 44 TPP CTHIN POL

40808-105 56 TPP SANITATION

40808-106 139 TPP SANITATION

40808-107 14 GRA PE PE

40808-108 34 GRA PE PE

40808-109 67 TPP CTHIN POL

40808-110 21 GRA PE PE

40808-111 5 TPP DEFER

40808-112 41 TPP GRSH DEADFALL

Total Acres 24,548 7,009
Briggs Spring Environmental Assessment Appendix D

D-23

Riparian Fencing/Protection

Buck and Pole Fence (6240- option A): Alternatives 2 and 3 

Construct buck and pole fence to protect water sources Redbank Spring (040705-145) 

and Willow Spring (040702-23).

FY 2011 estimated cost for 200 feet = $3,096

800 feet planned: 4 X $3,096 = $12,384

Install Elk Cable: Alternatives 2 and 3

Install a length of elk cable on existing riparian exclosure fences to prevent elk knocking 

down the fence at Willow Spring (040702-23) and Herrin Wildlife Ponds (040802-44).

2500 feet planned: 40 cents/foot for cable = $1,000; 

Additional supplies and labor = $1,500

Total estimate = $2,500

Shrubs

Willow Planting with Protective Cages (6080): Alternatives 2 and 3

Collect native willow cuttings and grow at Bessey Nursery. Plant 200 willows per acre 

split between Willow Spring (040702-23) and Herrin Wildlife Ponds (040802-44). One 

cage per 5 willows.

FY 2011 estimated cost per acre = $1,598.72

1 acre planned: 1 X $1,598.72 = $1,598.72

Habitat Access Management

Habitat Access Management- Berms (6240): Alternatives 2 and 3

Close with an earthen berm (or boulders) roads identified as non-essential, such as user 

created roads.

FY 2011 estimate per berm (closure) = $419.00

20 closures planned: 20 X $419.00 = $8,380.00

Habitat Access Management- Carsonite Posts: Alternatives 2 and 3

Place carsonite post where user created roads are to be closed in the action alternatives.

FY 2011 estimate per carsonite post = $40.00

50 carsonite posts planned: 50 X $40.00 = $2,000.00

Appendix E:

FINDINGS: SILVICULTURE
 
Briggs Spring Environmental Assessment Appendix E

E-1

Silvicultural Findings of Compliance with Laws, Regulations, and Policy

Briggs Spring EA

The following findings are made based on the environmental analysis and the 

silvicultural prescription:

Consistency with plans [16 U.S.C. 1604 (i)]:

1. 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. 

All areas to be harvested are in the 5.1 Management Area (MA) – Resource 

Production Emphasis. Theme: “These areas are managed for wood products, 

water yield, and forage production, while providing other commercial products, 

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

Numerous open roads provide commercial access and roaded recreation 

opportunities, while closed roads provide non-motorized recreation 

opportunities.”

Table E-1. Alternative 2 treatment acres in MA 

5.1

Treatment MA 5.1

Commercial Thinning 2,204

Overstory Removal 138

Shelterwood Seed Cut 479

Group Shelterwood 6,376

Hardwood Conversion 123

Hardwood Release 250

Sanitation 6,063

Pine Encroachment 2,674

Table E-2. Alternative 3 treatment acres in MA 

5.1

Treatment MA 5.1

Commercial Thinning 2,204

Overstory Removal 138

Shelterwood Seed Cut 479

Group Shelterwood 13,845

Hardwood Conversion 123

Hardwood Release 259
Briggs Spring Environmental Assessment Appendix E

E-2

Sanitation 3,678

Pine Encroachment 2,674

2. Silvicultural treatments are consistent with the Forest Plan.

Forest Plan Standard 2408, Phase II Amendment, page II-25, for acceptable 

silvicultural systems.

Timber Harvest [16 U.S.C. 1604 (g)(3)(E)]: 

1. Soil, slope, or other watershed conditions will not be irreversibly damaged; 

See the Briggs Spring Hydrology specialist report.

2. There is assurance that the lands can be adequately restocked within five years 

after final regeneration harvest. 

All stands within the project area that are to receive shelterwood removals can be 

adequately restocked within 5 years of harvest. The minimum tree stocking 

standards for Region 2 will be met. Region 2 minimum stocking standards are 

described in FSH 2409.26b Reforestation Handbook R2 Amendment No. 

2409.26b – 93-2. 

Regeneration surveys will be accomplished on all shelterwood seed cuts (3rd and 

5th years), and on all selection cuts (5th year) to assure the stands have regenerated 

properly. There will be no clearcutting in the Briggs project area.

3. 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 the Briggs Spring Hydrology specialist report.

4. The harvesting system to be used was not selected primarily because it will give 

the greatest dollar return or the greatest unit output of timber.

Even-aged Regeneration Harvests [16 U.S.C. 1604 (g)(3)(F)]: 

1. For clearcutting, it is the optimum method. 

Clearcutting will not be used in the Briggs Spring project area.

2. Clearcuts, coppice cuts, seed tree, and shelterwood regeneration harvests are 

appropriate to meeting the objectives and requirements of the Forest Plan. 

Forest Plan Standard 2408, Phase II Amendment, page II-25, for acceptable 

silvicultural systems.

3. 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. 
Briggs Spring Environmental Assessment Appendix E

E-3

See the Briggs Spring specialist reports.

4. Cut blocks, patches, or strips are shaped and blended to the extent practicable 

with the natural terrain. 

See the Briggs Spring Visual Quality specialist report.

5. Even-aged regeneration harvests made in one operation meet the 40-acre 

maximum size limit requirement. 

Forest Plan Standard 2101, Phase II Amendment, page II-17.

6. Harvest will be consistent with the protection of soil, watershed, fish, wildlife, 

recreation, esthetic resources, cultural and historic resources, and the regeneration 

of timber resources.

See: Briggs Spring Botany BE and specialist report

Briggs Spring Wildlife BE and specialist report

Briggs Spring Hydrology specialist report

Briggs Spring Heritage specialist report

Briggs Spring Recreation specialist report

Culmination of Mean Annual Increment [16 U.S.C. 1604 (m)]:

Stands of trees harvested have generally reached the culmination of mean annual 

increment of growth (CMAI).

Page II-26 of the Black Hills Forest Plan Guideline 2411. Regeneration 

harvests of even-aged timber stands should not be undertaken until the 

stands have generally reached (or surpassed 95% of the) culmination of the 

mean annual increment measured in cubic feet.

CMAI occurs when the periodic annual increment equals the mean annual 

increment (MAI). MAI is calculated by adding the current stand volume with any 

mortality or previous removal and then dividing by the stand age. 

Appendix F:

PAST, PRESENT, AND FUTURE

ACTIVITIES

Briggs Spring Environmental Assessment Appendix F

F-1

Past, Present, and Reasonably Foreseeable Future Activities

The following is a summary of activities within the Briggs Spring project area. 

Past History

The Briggs area has been commercially harvested many times in the past. Present day 

records (RIS database, old harvest atlas, and the thinning atlas) indicate commercial 

harvest activity from the 1970s to the present along with precommercial thinning, weed 

and release, and mechanical site prep. 

Redbank, Dumbuk, and Thumb are the most recent timber sales in the analysis area. 

Redbank and Dumbuk closed FY2004 and all post sale activities are to be completed by 

FY2012 and Thumb closed FY2007 and all post sale activities are to be completed by 

FY2012. Portions of the Stateline and Run timber sales and the Cattle Salvage sale were 

also within the Briggs area. The Cattle Salvage sale was sold in August 2004 to salvage 

mountain pine beetle infested timber and closed in 2005. Run closed in FY2005 and 

Stateline closed in FY2006. All post sale activities are to be completed by FY2010 in 

Run and FY2011 in Stateline. 

Precommerical thinning has been used a great deal in the analysis area during the 1980s 

and 1990s with weed and release only used within the last decade. Since the 1980s until 

present, more than 6700 acres have been treated by precommerical thinning methods 

throughout the analysis area.

The grasses in some of the locations grow to form a thick matt of grass, which prevents 

ponderosa pine seedlings from getting established. To provide a seedbed mechanical site 

prep was used to expose mineral soil in the area to encourage natural regeneration in the 

ponderosa pine. In the early 1990s, 636 acres were mechanically site prepped.

In 2000 the Jasper Fire burned the southern end of the Dumbuk timber sale. Some of the 

area was salvage logged after the fire.

Some of the private land has been logged in the past and a few parcels of private land 

burned in the Jasper Fire of 2000. Most of the private land is mostly used for grazing 

cattle. There are a few parcels that are used for summer residences and hunting.

Present

Current timber sales located with the project area are as follows:

The Thumb timber sale encompasses most of the northern half of the project area on the 

north side of the Six-mile Road (FDR 301). This sale closed in 2000 and post sale 

activities will be on going until 2000. The Redbank timber sale is also located in the 

northern half of the analysis area on the northwest end. Redbank sale closed fiscal year 

2004 and post sale activities will be ongoing until 2009. The Dumbuk timber sale is 

south of the Six-mile Road (FDR 301) and runs down to the Custer-Limestone Road 

(FDR 284). Dumbuk was completed in fiscal year 2005 and post sale activities will end 

in 2010. 
Briggs Spring Environmental Assessment Appendix F

F-2

The Stateline timber sale (west side) closed in the summer of 2006 and post sale activities 

will be ongoing until 2011. The Run timber (west side) sale closed in 2005 and a few 

post sale activities will continue until 2010. 

Current timber sales adjacent to the project areas are as follows:

The Nest timber sale, northeast of Briggs, closed in fiscal year 2008 and post sale 

activities will be on-going until 2013. West of the Briggs analysis area is the Nottingham 

timber sale that was recently sold in December 2008. Nottingham is in the Mallo area. 

South of Nottingham is the Friar Tuck timber sale. Friar Tuck is to sell fiscal year 2010. 

To the south of Friar Tuck is the Sherwood timber sale. Sherwood runs north from the 

Summit Ridge Road (FDR 265). The Coulsen timber sale is to the northeast of the 

project area. This sale closed in fiscal year 2009 and post sale activities will be on-going 

through 2014.

The private land is used for cattle grazing, residences, and hunting opportunities.

Reasonably Foreseeable

All the timber sales within the boundaries of the planning area have all completed any 

post sale vegetative treatments except for Run. In fiscal year 2009 Run will finished up 

with weed and release. All remaining timber activities from these sales will only include 

regeneration surveys.

In areas adjacent to the Briggs analysis area, the Nest and Coulsen timber sales will begin 

post sale activities. There will be no timber vegetative treatments in Nest only 

regeneration surveys. Coulsen will have weed and release, precommercial thinning, and 

aspen release. All commercial harvesting activities in Nottingham and Sherwood timber 

sales will continue and commercial harvesting will start up once Friar Tuck timber sale 

has been sold. 

The adjacent Pole Creek analysis area is on the Mystic District north of the Six-mile 

Road and is east of Briggs. This project would entail prescribe burning only and could be 

implemented as early as spring 2009 or fall 2009.

A Forest-wide MPB analysis would be completed. 

The private land will be used for grazing cattle, summer residences, and hunting.

Past Activities 

1980s -1999 Type of Activity Acres Associated Project

1980s Commercial 

Treatments 18,195

Cow Camp, Multiplex, Keller, 

Johnson, Redbird, Rogers-Gillette, 

Preacher Spring, Howell, Keller

Broadcast 

Burning 327 Rogers-Gillette

Precommercial 13,432 Elk Mt. Outside Sale, Redbird, Cow 

Camp, Rogers-Gillette, Multiplex, 
Briggs Spring Environmental Assessment Appendix F

F-3

Jenks, Keller, Johnson, Preacher 

Spring,

Wildlife Habitat 

Improvement 9,979

Elk Mt. Outside Sale, Redbird, 

Keller, Jenks, Cow Camp, 

Mulitplex, Rogers-Gillette, 

Preacher Spring, Johonson

Pesticide 

Application 35,410

Elk Mt. Outside Sale, Redbird, 

Thumb, Bear Canyon Parmlee, 

Cow Camp, Jenks, Multiplex, 

Keller, Preacher Spring, RogersGillette, Johnson, Howell

1990s Pile Burning 2,502 Howell, Johnson, Rogers-Gillette

Broadcast 

Burning 305 Johnson

Jackpot Burning 275 Preacher Spring

Commercial 

Treatments 351 Run

Pine 

Encroachment 59 Keller

Salvage 93 Mallo

Fuel Break 565 Johnson

Precommercial 2,945 Keller, Johnson, Howell

Overstory Comm 135 Run

Pesticide 

Application 8,992

Elk Mt. Outside Sale, Redbird, Cow 

Camp, Multiplex, Keller, Preacher 

Spring, Rogers-Gillette, Johnson, 

Howell, Mallo, Thumb, Jenks, 

Dumbuk, Redbank

Site Prep 1,596 Redbird, Keller, Dowell

Wildlife Habitat 

Improvement 3,540 Redbird, Keller, Dowell, Preacher Spring

Range Seeding 

and Planting 521 Howell, Thumb

Past Activities 

2000 -Present Type of Activity Acres Associated Project

2000s Pile Burning 4,829 Dumbuk, Thumb, Stateline, 

Redbank, Cattle Salvage

Broadcast 

Burning 807 Stateline, Thumb

Jackpot Burning 532 Thumb, Stateline

Commercial 

Treatments 14,573 Thumb, Nottingham, Dumbuk, Redbank, Mallo, Stateline

Fuel Break 358 Run, Dumbuk, Mallo, Nottingham

Fuels 2,257 Thumb, Mallo, Dumbuk, 
Briggs Spring Environmental Assessment Appendix F

F-4

Nottingham

Pesticide 

Application 121,320

Mallo, Run, Thumb, Stateline, Cow 

Camp, Dowell, Dumbuk, Barrel, 

Redbank

Tree Planting 362

Precommercial 676 Dumbuk, Thumb, Nottingham

Salvage 1,882 Dumbuk, Cattle Salvage

Site Prep 297 Thumb

Pine 

Encroachment 453 Mallo, Dumbuk, Thumb

Wildlife Habitat 

Improvement 2,624

Thumb, Dumbuk, Stateline, 

Redbank, Run, Mallo, Nest, 

Nottingham
Appendix G:

SUMMARY: BIOLOGICAL

ASSESSMENT and BIOLOGICAL

EVALUATION

Briggs Spring Environmental Assessment Appendix G

G-1

Summary of Botany and Wildlife 

Biological Assessment and Biological Evaluation

Introduction

This is a summary of the Briggs Spring project Biological Assessment/Biological 

Evaluations (BA/BEs), and is a review and analysis of actions proposed in the Briggs 

Spring Project Draft Environmental Assessment. The full BA/BEs are in the Briggs 

Spring project file. The purpose of a BA/BE is to determine how the proposed action and 

alternatives to the proposed action will affect federally listed species or sensitive species 

listed by the Rocky Mountain Region (FSM 2670, R2 Supplement No. 2600-2011-1, 

2672.11 – Exhibit 01 effective June 10, 2011). The Briggs Spring BA/BEs are prepared 

in accordance with legal requirements set forth under Section 7 of the Endangered 

Species Act of 1973 (19 U.S.C. 1536 (c)), and follow standards established in Forest 

Service Manual direction (2672.42) and the Code of Federal Regulations (50 CFR S402). 

The Briggs Spring BA/BEs tier directly to the EIS for the revised Black Hills National 

Forest Land and Resource Management Plan (Forest Plan) as amended, the BA/BE 

completed for the Forest Plan revision, and the BA/BE prepared for the Phase II 

Amendment (USDA Forest Service, 2006).

Pre-field Review and Field Reconnaissance

Botany

Federally Listed Plant Species

The U.S. Fish and Wildlife Service (USFWS) website list for Threatened and Endangered 

species was accessed on September 14, 2010 for the state of South Dakota. There are no 

threatened or endangered plant species habitat known to occur in the State of South 

Dakota, nor does habitat that could support threatened or endangered plant species 

known from adjacent states occur in the project area (USFWS, 2010a).

Region 2 Sensitive Plant Species

The Region 2 Forest Service sensitive species list was updated by the Regional Forester on June 

9, 2009 (USDA Forest Service, 2009). All R2 sensitive plant species potentially occurring in the 

Black Hills National Forest were considered in the evaluation. Based on the pre-field review, no 

Region 2 sensitive plant species or suitable habitat has been located within the 

project area. A pre-field review was conducted of available information to assemble 

occurrence records, describe habitat needs and ecological requirements, and determine 

whether field reconnaissance is needed to complete the analysis. Sources of information 

included botanical surveys, Forest Service records and files, local professional judgment, 

and published research.

Wildlife

Federally Listed Animal Species

There are no federally listed wildlife species in the Briggs Spring project area. A list of 

federally threatened, endangered and proposed species has been provided by the U.S. 

Fish and Wildlife Service (USFWS), South Dakota State Office, and was last updated on 
Briggs Spring Environmental Assessment Appendix G

G-2

December 21, 2010 (USFWS, 2011). The South Dakota State Office is the primary 

center for all of the Black Hills, including Wyoming. The USFWS lists the following 

endangered and/or threatened species for Pennington County, South Dakota: whooping 

crane, least tern and black-footed ferret.

The whooping crane and least tern have been removed from the list of species considered 

on the Black Hills National Forest under Section 7 consultation (letter of concurrence 

from D. Gober, Field Supervisor, USFWS, Pierre, South Dakota, dated August 8, 2003). 

Although the black-footed ferret is listed for Pennington County, it is an experimental 

population located in eastern Pennington County, where they have been re-introduced 

into Badlands National Park and the Conata Basin of Buffalo Gap National Grassland. 

Habitat for the black-footed ferret is not present in the project area. There are no prairie 

dog colonies present. It was determined that management activities on the Forest would 

have ‘no effect’ on these species since the Black Hills National Forest lacks suitable 

habitat.

Region 2 Sensitive Animal Species

The current sensitive species list for the Rocky Mountain Region (R2) was renewed on

June 10, 2011. Sensitive species for the Black Hills National Forest are listed on the R2 

threatened, endangered and sensitive species home page (USDA Forest Service, 2011). 

There are now 26 species on the Region 2 sensitive species list that could be present in 

the Black Hills.

The pre-field review of Region 2 Sensitive Species and Federally Endangered and 

Threatened and Proposed species was completed using survey results, district records, 

communication with District personnel, literature reviews, on-line databases and the 

South Dakota Natural Heritage Database. The following R2 sensitive species have been 

found within the project area: bald eagle, northern goshawk, northern harrier, blackbacked woodpecker, northern leopard frog and Black Hills redbelly snake.

The following table lists an endangered species (black-footed ferret) and Region 2 

sensitive species that may be present in the Black Hills. Of the 26 R2 sensitive species in 

the table, fourteen have suitable habitat in the Briggs Spring project area and may be 

impacted by the alternatives (Table G-1).

Table G-1. Expected occurrence of Endangered (XN) and R2 Sensitive (S) Species 

within Briggs Spring project area

Species Status1 Species

Present2

Habitat

Present/ 

Analysis 

Provided3

Habitat

Description

Black-footed ferret 

(Mustela nigripes) XN NO NO

Prairie dog towns (USFWS, 2011b). No 

reintroduction sites or other known 

occupied habitat in Black Hills.

Bald eagle

(Haliaeetus

leucocephalus) S YES YES

Winter resident in the Black Hills and 

spring/fall migrant. Usually found near 

unfrozen water or carrion in winter 

(Tallman et al., 2002).
Briggs Spring Environmental Assessment 

 G-3

 

Rocky Mountain 

bighorn sheep (Ovis 

canadensis 

canadensis)

S NO NO

Open habitats such as grasslands, talus 

slopes, and rock outcrops where forage 

plants are abundant and escape cover is 

nearby (Beecham et al., 2007).

Fringed myotis

(Myotis thysanodes) S NO YES

Forages on insects in a variety of habitats 

including grasslands and forested areas. 

Roosts in a variety of structures 

including caves, mines, and buildings 

(Schmidt, 2003a).

Townsend’s big-eared 

bat

(Corynorhinus

townsendii)

S NO YES

Forages on insects in a variety of habitats 

including forested and wet areas. Roosts 

in a variety of structures including caves, 

mines, and buildings (Schmidt, 2003b).

Hoary bat (Lasiurus 

cinereus) S NO YES

Forages on insects. Roosts within tree 

foliage in a variety of forested cover 

types (Shump & Shump, 1982). 

Black-tailed prairie 

dog

(Cynomys 

ludovicianus)

S NO NO Short-grass and mixed-grass prairies

(USFWS, 2011c).

American marten

(Martes americana) S NO NO

Spruce forests with complex near-ground

structure, extending into adjacent 

ponderosa pine stands (Buskirk, 2002).

Northern goshawk

(Accipiter gentilis) S YES YES

Forages in a variety of forested areas and 

small openings; nests primarily in dense 

mature conifer forests (Erickson, 1987).

Ferruginous hawk

(Buteo regalis) S NO NO

Unbroken semiarid grassland with 

elevated nesting sites available. Prefer 

areas with high densities of rodents and 

lagomorphs (Johnsgard, 1990).

American peregrine 

falcon (Falco 

peregrinus anatum) S NO NO

Tall cliffs and open areas near water 

(Johnsgard, 1990).

Northern harrier

(Circus cyaneus)

S YES YES Prairies, open fields and marshes 

(Tallman et al., 2002).

Yellow-billed cuckoo 

(Coccyzus americanus) S NO NO

Low elevation riparian areas and 

woodlands characterized with 

cottonwood-willow or bur oak (Panjabi, 

2003).

Burrowing owl

(Athene cunicularia) S NO NO

Dry grasslands and pastures, usually 

associated with prairie dogs or ground 

squirrels (Tallman et al., 2002).

Flammulated owl

(Otus flammeolus)

S NO YES Open ponderosa pine forests (McCallum, 

1994).

Lewis’s woodpecker

(Melanerpes lewis) S NO YES

Open burned areas with large snags; oak 

and cottonwood forests (Anderson, 2003; 

Panjabi, 2003).

Black-backed 

woodpecker

(Picoides arcticus) S YES YES

Burned areas with a high density of preburn snags; dense and/or mature forests 

with a high snag density (Anderson, 

2003; Panjabi, 2003).

Loggerhead shrike

(Lanius ludovicianus) S NO NO

Open country with scattered, low 

deciduous thickets (Tallman et al., 

2002).
Briggs Spring Environmental Assessment Appendix G

G-4

Grasshopper sparrow

(Ammodramus

savannarum) S NO YES

Found almost exclusively in native 

mixed-grass prairies (Panjabi, 2003).

Long-billed curlew

(Numenius 

americanus) S NO NO

Considered native prairie specialists 

requiring shortgrass or mixed-grass 

prairie habitat with nearly flat 

topography (Sedgwick, 2006).

Northern leopard frog

(Lithobates pipiens) S YES YES

Riparian and wetland areas for tadpoles, 

subadults, and breeding adults; upland 

habitats for foraging adults (Smith, 

2003).

Black Hills redbelly 

snake (Storeria 

occipitomaculata

pahasapae)

S YES YES

Wet meadows, woodlands, and forestmeadow edge habitat in the Black Hills 

(Smith and Stephans, 2003).

Lake chub

(Couesius plumbeus) S NO NO

Streams or lakes with clear, cool water 

and clean cobble/gravel substrate; only 

known population in Deerfield Reservoir 

(Isaak et al. 2003).

Finescale dace

(Phoxinus neogaeus) S NO NO

Small lakes and cool, boggy 

environments associated with springs or 

beaver dams; isolated to the Redwater 

Drainage – no documented occurrences 

in the South Dakota portion of the Black 

Hills National Forest (Isaak et al., 2003).

Mountain sucker 

(Catostomus

platyrhynchus) S NO NO

Large rivers, lakes, reservoirs, prairie 

streams but most often in cool, clear, 

moderately swift mountain streams with 

mud, cobble, or boulder substrate (Isaak 

et al., 2003).

Cooper’s mountain 

snail

(Oreohelix strigosa 

cooperi)

S NO YES

Lowland wooded or riparian areas on 

limestone soils (Frest and Johannes, 

2002).

Regal fritillary 

butterfly

(Speyeria idalia) S NO YES

Tall-grass prairie and extensive 

grasslands with violets (Royer and 

Marrone, 1992). 1 XN = Experimental Population, S = Sensitive

2 Confirmed records of species in area.

3 Suitable habitat known or suspected to occur. Species not present and with no habitat in the project area 

will not be further analyzed in this document because they would not be affected by the proposed project 

alternatives.

Determinations Summary – Fauna (Wildlife)

The determination of effects on federally listed animal species and Region 2 Sensitive 

Species in this BA/BE were made as the result of the information gathered in the prefield review, field reconnaissance, and effects analysis for all alternatives. Because 

analysis considered management activities of all alternatives and associated design 

criteria, only one determination is made for each species, which applies to all alternatives. 

The basis for these determinations was potential habitat, distribution, and effects from 

proposed activities. The determination language is set forth in Forest Service Manual 

2670 and by the USFWS.
Briggs Spring Environmental Assessment 

 G-5

 

The Phase II Forest Plan Amendment FEIS (USDA Forest Service 2005b) evaluated 

population viability, and determined that all federally listed and sensitive species are 

likely to persist on the Forest over the next 50 years if standards and guidelines are 

followed, and if conditions move toward Forest Plan objectives. All standards and 

guidelines will be followed in all action alternatives of the Briggs Spring project. 

Furthermore, all alternatives are consistent with Objective 221, which is to conserve or 

enhance habitat for sensitive species. Therefore, persistence of all R2 sensitive species 

would not be affected by any alternative of the Briggs Spring project.

With implementation of Forest Plan direction and project-specific design criteria, the 

following determinations are made for R2 Sensitive Species:

Species Alternative 1 

Determination

Alternatives 2 and 3 

Determination

Bald eagle NI NI

Fringed myotis MAII MAII

Townsend’s big-eared bat NI MAII

Hoary bat NI MAII

Northern goshawk NI MAII

Northern harrier NI MAII

Flammulated owl MAII MAII

Lewis’s woodpecker MAII MAII

Black-backed woodpecker MAII MAII

Grasshopper sparrow NI MAII

Northern leopard frog NI MAII

Black Hills redbelly snake NI MAII

Cooper’s mountain snail NI MAII

Regal fritillary butterfly NI MAII

NI = No impact

MAII = May adversely impact individuals, but not likely to result in a loss of viability 

in the Planning Area, nor cause a trend toward federal listing.

Appendix H:

Response to Comments

Briggs Spring Environmental Assessment Appendix H

H-1

Appendix H

Briggs Spring Project

Summary of Comments on the Draft EA

The Hell Canyon Ranger District received eight comments on the Briggs Spring project Draft EA from individuals, groups, and tribes. All original 

correspondence is stored within the project file. The following numbered list corresponds to the Comment/Response table below. 

1. Scott Gross – private citizen/Sky-Vue MotelCorp, Inc., Rapid City, SD – comments database (email).

2. Michael C. and Shawnda F. Morrison – private citizen, Newcastle, WY – hardcopy letter.

3. Dick Artley – private citizen, Grangeville, ID – comments database (email). 

4. Carson Engelskirger – Black Hills Forest Resource Association, Rapid City, SD – comments database (email).

5. Conrad Fisher – Northern Cheyenne Tribe, Tribal Historic Preservation Office, Lame Deer, MT – fax.

6. Nancy Hilding – private citizen and Prairie Hills Audubon Society, Black Hawk, SD – comments database (email). 

7. Duane Short –Biodiversity Conservation Alliance, Laramie, WY – comments database (email). 

8. Nancy Hilding –Prairie Hills Audubon Society, Black Hawk, SD – comments database (email). 

NOTE: Two comments were received outside of the comment period. These comments are in the project file. 

9. Nancy Hilding – Biodiversity Conservation Alliance, Laramie, WY – comments database (email). 

10. Josh Van Vlack – Rushmore Forest Products, Neiman Enterprises, Inc., Hill City, SD – comments database (email). 

Comment 

Number Name Comment Response

1a Scott Gross I am in receipt of the Draft Environmental Assessment for the Briggs 

Springs Project, and would like to make some comments in following 

with my past letter to you.

First, the EA is very comprehensive and I compliment you and your 

team for the in - depth study of the area and the proposed actions. Often 

times it is easy for all of us to discount and overlook the complexity of 

our environment, and rush to decisions which will most certainly affect 

living things that we all enjoy that really don’t have a say.

Thank you for your comments and interest in the Briggs Spring 

project. 

1b Secondly, while I agree that there may be an additional need for more 

camping spaces especially for off road users, I certainly don’t agree 

that the solution is to create a new campground as we already have 

Redbank Springs and Ditch Creek Campground within close proximity. 

Redbank Springs is for a variety of reasons the perfect setting for a 

campground and can easily accommodate additional spaces and 

amenities. The access is provided on a good all weather road; fire risk 

Alternative 3 in the EA does not include a new campground. 

The possibility of expanding the Redbank Spring Campground 

was considered. After further analysis of Heritage resources, it 

was determined that expanding the Redbank Spring 

campground would have significant impacts to Heritage 

resources. Therefore, this alternative was not considered in 

detail. However, the proposed campground in Alternative 2 
Briggs Spring Environmental Assessment Appendix H

H-2

is minimal; the campground is easily expandable; and it is far enough 

away from several summer cabins (Sky-Vue, Compton, Whispering 

Pines, Gould Cabin, etc...) where as not to create problems with noise, 

traffic, etc...

(New Moon Campground) remains as part of Alternative 2. 

Your comments are noted, thank you.

1c Finally, in this environment of austerity, the Forest Service does not 

have the resources to properly maintain its current assets, not to 

mention another asset such as a new campground. So as part of any 

responsible study the financial issues should be pararmount. And at the 

end of the day, as is the case with many issues of today, we many need 

and want certain things, but clearly we cannot afford them.

The New Moon campground was analyzed in this EA to 

determine potential environmental effects to resources. 

Financial funding for the Forest Service program of work occurs 

as an annual appropriation from Congress and is outside the 

scope of this project. 

2a Michael & 

Shawnda 

Morrison

This letter is in regard to the Briggs Springs Project. I meet with 

Wendy Steuerwald and Gwen Lipp in the Newcastle Forest Service 

Office on October 21,2010. I am attaching a copy of notes taken at that 

meeting.

Once again I am in favor of the Forest Service taking an active stand 

against the pine beetle along with prescribed burning and cutting 

timber. One thing that was not mentioned in the meeting is that there 

needs to be active management of weed control after the prescribed 

burning for Canada thistle and other weeds.

Thank you for your comments and interest in the Briggs Spring 

project. 

Thank you for your support of the vegetation treatments and 

prescribed burning. The EA includes weed treatment, see pages 

92, 97-98. 

2b As far as the proposed campground is concerned, I have several issues 

with it. Again I believe the campground proposal was hidden within the 

document to look like a timber and burning project when it should have 

been a separate project. As of today the Federal Government is cutting 

back on budgets to all its departments, and here we are discussing 

building a 17 acre campground with facilities at great cost. Is this being 

fiscally responsible to the taxpayer? I do not believe so.

See responses to comments 1b & 1c. 

2c After reviewing the three alternatives, I believe that alternative three 

would be the best choice. My reasoning is that it allows for active 

management of the timber resources and pine beetle infestation, as well 

as promoting the existing campground at Redbank Spring. There still is 

no cost estimate for the campground expansion in this assessment, it 

would be less than building an entirely new campground site.

I thank you for taking time to review my comments and keeping me 

informed. My family and myself have had a very good working 

relationship with the Forest Service for over 40 years and appreciate it.

Your support for Alternative 3 is noted, thank you. 

The proposed Redbank Spring Campground expansion is not 

part of Alternative 3. See response to 1b. 

3a Dick Artley I have reviewed the draft EA for the Briggs Springs project.

The draft EA at page 4 states:

 “The purpose of this project is to maintain forest health”

I will show below that this project will not “maintain forest health.” To 

Thank you for your comments and interest in the Briggs Spring 

project. 

Yes, “to maintain forest health” is a part of the purpose and 

need for action. 
Briggs Spring Environmental Assessment Appendix H

 H-3

 

the contrary ... the timber sale will create opportunities to spend tax 

dollars to restore forest health

It’s good to provide jobs and income to the local communities with 

commercial timber sales in national forests if the opportunity presents 

itself. The draft EA at page 4 states that one of the purposes of this 

timber sale is to:

 “sustainable supply of commercial timber”

Clearly placing wood project output goals in the P&N is not consistent 

with Forest Service policy. Volume output must be a byproduct of real, 

true, verifiable actions that improve the forest resources ... This means 

forest resources besides conifer trees

Supporting the local economy by providing jobs and income must be a 

secondary benefit of a timber sale proposed to enhance and restore 

damaged ecosystems ... not a purpose for the sale. The economic 

benefit of merchantable tree removal should be described in Chapter 3.

This benefit the “ecosystem should benefit first” policy has been in 

existence for several years:

This timber sale is inconsistent with 2003 statements 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. 

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 

Yes, “to provide for a sustainable supply of commercial timber” 

is part of the purpose and need for action. Pages 2-4 of the EA

describe Management Direction for this project. Management 

Direction includes Goal 3 of the Black Hills Forest Plan which 

states, Goal 3: “Provide for sustained commodity uses in an 

environmentally acceptable manner.” 

Economics is no longer required for Region 2. The 1996 R2 

supplement to FSM 1970 was removed in 2011. 

This speech discusses how values of natural resources have 

changed throughout America. It discusses what the Forest 

Service has learned over time. This is not Forest Service 

“direction”, it was a speech. 

This speech covers a short history of the Forest Service and its 

joint accomplishments with other agencies. It also discusses 

possibilities of future joint accomplishments with other agencies 
Briggs Spring Environmental Assessment Appendix H

H-4

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

Overcoming 'timber-itch'

Published in the Miami Herald

May 25, 2011

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

and cooperators. Again, this is not Forest Service “direction”, it 

was a speech. 

This is an article published in “The Olympian” on May 25, 

2011, by Jim Furnish, a former deputy chief of the USFS. This 

article is not Forest Service ‘direction’. 
Briggs Spring Environmental Assessment Appendix H

 H-5

 

In the final EA please include either 1) the new direction that replaces 

that shown above , or 2) provide the letter exempting this sale from the 

direction and explaining why it is exempted.

Not sure what “new direction” is being referred to here. The 

Briggs Spring project is in compliance with the Black Hills 

National Forest Land and Resource Management Plan Phase II 

Amendment, March 2006. 

3b The Draft EA Indicates that 32.7 Miles of Road will be 

Reconstructed as Part of this Timber Sale.

In spite of the large amount of scientific literature that clearly indicates 

that aquatic resource damage is caused by forest road construction, the 

Responsible Official proposes road construction to make log extraction 

possible.

We are loosing about 200 square miles of our public land to 

development each week.

There are over 400,000 miles of road in our national forests. That’s 

enough to reach the moon and half way back. Isn’t that enough? 

Shouldn’t there be some merchantable trees that will never be 

accessed?

Reconstruction work generates sediment which finds its way to the 

streams during precipitation events.

Roads Comment #1: Forest road drainage excavates gullies and cause 

landslides downslope on roads requiring full-bench construction. Will 

any of the roads (including temporary) for this project be constructing 

on slopes greater than 40%? If so, what will be done to eliminate such 

damage.

Roads Comment #2: Forest roads change the microclimate by altering 

temperature and moisture regimes. This adversely affects wildlife. How 

will this be mitigated? Please list the data and/or monitoring results 

showing the effectiveness of this mitigation.

Roads Comment #3: Compacted forest road surfaces generate 

overland flow, and much of this flow often enters the channel system, 

locally increasing peak flows. How will this be mitigated? Please list 

the data and/or monitoring results showing the effectiveness of this 

mitigation.

Roads Comment #4: Roads fragment wildlife habitat. Forest roads 

also alter animal behavior by causing changes in home ranges, 

movement, reproductive success, and escape response. Forest road 

The Briggs Spring EA, page 111, states 31.9 miles of 

reconstruction for Alternative 2 and 35.3 miles of reconstruction 

for Alternative 3. 

There is no new road construction proposed for the Briggs 

Spring project, see EA page 111. 

See the “Transportation” and “Soils and Hydrology” sections of 

the EA, pages 109-112 and 117-137 for effects of roads. 

There is no new road construction proposed for the Briggs 

Spring project. Temporary roads for harvest activities would 

follow design criteria listed in Appendix B of the Briggs Spring 

EA. 

Appendix B of the Briggs Spring EA provides design criteria to 

lessen impacts of project activities. Also, see the FY 2009 

Monitoring and Evaluation Report for the Black Hills National 

Forest. 

Appendix B of the Briggs Spring EA provides design criteria to 

lessen impacts of project activities. 

Appendix B of the Briggs Spring EA provides design criteria to 

lessen impacts of project activities. Also, see the “Wildlife” 

section of the Briggs Spring EA for project effects to wildlife 
Briggs Spring Environmental Assessment Appendix H

H-6

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. None of this can be mitigated

effectively be eliminating vehicles with gates. Apparently the

Responsible Official believe that timber harvest is more important than 

the well-being of wildlife species in the area. Please explain. The 

majority of American national forest visitors want to see healthy 

wildlife interacting with their natural habitat. They do not want to see 

stumps, skidtrails and landings.

Roads Comment #5: Forest roads (both temp and system) 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. Has this been considered? If so, why are 

the roads still planned knowing that this long term impact will occur?

Roads Comment #6: Roads are the major vector for weeds and 

disease. How will this be mitigated? Please list the data and/or 

monitoring results showing the effectiveness of this mitigation.

Roads Comment #7: Forest roads allow more human-caused fires to 

be ignited because they provide easier access for passenger vehicles 

and ATVs. How will this possibility be eliminated?

Roads Comment #8: Forest roads increase isolation of populations or 

species which cause adverse wildlife genetic effects (i.e. inbreeding, 

depressed fertility/fecundity, and increased natal mortality) and

decreased genetic diversity from genetic drift and bottlenecks. Please 

tell the public in the final EA why timber harvest so important that 

these adverse effects to wildlife are considered appropriate tradeoffs.

Roads Comment 9: Macropores, which provide soil drainage and 

infiltration, have been shown to significantly decrease in size as a result 

of road construction and use. Has this been considered? If so, why are 

the roads still planned knowing that this long term impact will occur?

Roads Comment #10: Forest roads provide increased opportunities for 

species and habitat. 

Appendix B of the Briggs Spring EA provides design criteria to 

lessen impacts of project activities. Also, see the “Soils and 

Hydrology” and “Transportation” sections of the Briggs Spring 

EA for effects of roads. 

Appendix B of the Briggs Spring EA provides design criteria 

related to noxious weeds. See the “Botany, Rangeland, and 

Noxious Weeds” section (pages 92-93 and 97-99 specifically for 

noxious weeds) of the EA. Also, see the FY 2009 Monitoring 

and Evaluation Report for the Black Hills National Forest.

The possibility of human-caused fires will always exist in the 

National Forest as long as humans exist, therefore the possibility 

could never be eliminated. 

See the Briggs Spring EA “Wildlife” section, pages 37-76, for 

effects to wildlife species and habitat from project activities. 

There is no new road construction proposed in the Briggs Spring 

project area. See the “Transportation” and “Soils and 

Hydrology” sections of the Briggs Spring EA. 

Your comment is noted. 
Briggs Spring Environmental Assessment Appendix H

 H-7

 

exploitation by humans, such as: poaching, overhunting, overfishing, 

and passive harassment of animals increased trapping pressures

increased likelihood that snags and logs that are important habitat for 

some wildlife species will be removed for fuel wood.

Please do not reconstruct any roads for this sale. Of course there will be 

trees that cannot be harvested. Reducing the sale volume is a tradeoff 

that should always be made if the wildlife and fish in the area will 

benefit.

Your comment is noted. 

3c The Draft EA Proposes to Harvest Timber on 18,307 Acres

The majority of the American public does not want 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.

Tree farms on private land supply more than enough wood fiber raw 

material to supply the domestic demand.

Harvest Comment #1: Logging landings, skid trails and skyline chutes 

are frequently a source of sediment during precipitation events. How 

will this highly likely ecosystem damage be eliminated?

Harvest Comment #2: Logging removes dead and dying material from 

the site and inhibits the recruitment of downed woody material as time 

progresses. Will the area be fertilized after the sale? How will the 

organic material hauled to the mill that will potentially become soil be 

replaced?

Harvest Comment #3: A large body of scientific evidence indicates 

that increased edge effect and increased sunlight into stands, resulting 

from reduced canopy cover associated with timber harvest, 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). How will this be mitigated?

Your comment is noted. 

The Briggs Spring project does not claim there is a “timber 

famine”. 

There are no skyline chutes proposed in the Briggs Spring 

project. For effects to resources from logging landings and skid 

trails, see the “Wildlife, Botany”, “Soils & Hydrology”, and 

“Transportation” sections of the EA.

The Briggs Spring project does not propose to remove any dead 

material during harvest activities. ‘Green’ mountain pine beetle 

infested trees would be removed through sanitation efforts. 

There is no proposal to fertilize the project area. 

The analysis for the Briggs Spring project included literature 

that is specific to the Black Hills. See: 

Allen, K. 2003. Evaluation of MPB activity on the Black Hills 

National Forest. Forest Health Evaluation R2-04-02. Rapid 

City Service Center, Rapid City, SD. 

Schaupp, Willis C. Jr. 2011. Aerial overview detection survey in 

2010, Black Hills of South Dakota and Wyoming, Service Trip 

Report RCSC-03-11. 6p. February 02, 2011. 

Sheppard, Wayne D. and Michael A. Battaglia. 2002. Ecology, 
Briggs Spring Environmental Assessment Appendix H

H-8

Harvest Comment #4: The Forest Service lost $2 billion on its 

logging program from 1992 to 1997, according to the General 

Accounting Office. It spends more on building roads and preparing 

sales than it gets back in timber receipts. Is this expected to return more 

money to the treasury than it cost to plan and prepare the sale?

Harvest Comment #5: Logging reduces the organic parent material 

(duff and woody residues) available for soil-formation processes. How 

will this be replaced?

Harvest Comment #6: Congress finds that commercial logging harms 

to the recreation and tourism industries. The Briggs Springs area is 

popular with recreationists. Will they be educated about the changes to 

their recreation area?

Harvest Comment #7: Logging adversely affects hydrologic processes 

by reducing canopy interception and evapotranspiration. Please explain 

how this might affect the sale area in the final EA.

Harvest Comment #8: Logging decreases hydraulic conductivity and 

increases bulk density in forest soils after harvest. How will this soil 

density be reduced without an activity that causes erosion.

Harvest Comment #9: The spotted salamander is most likely to be 

affected adversely by the logging as this species of salamander relies on 

dense forests with full canopies. (Harding, 1997) Is this species present 

in the sale area?

Harvest Comment #10: Logging increases water temperature by 

altering available sunlight, conductivity by changing the amount of 

silviculture, and management of Black Hills ponderosa pine. 

Gen. Tech. Rep. RMRS-GTR-97. Fort Collins, CO: U.S. Dept. 

of Agriculture, Forest Service, Rocky Mountain Research 

Station. 112 p.

The cited references in the comment do not provide enough 

information to locate the literature. 

The issue of financing is outside the scope of this project. 

Please refer to the “Soils” section of the Briggs Spring EA, 

pages 117-127, specifically “Organic Matter and Nutrients” 

pages 120-121 and 125, 127. 

Please refer to the “Recreation” section of the Briggs Spring 

EA, pages 112-117 and design criteria in Appendix B page B-4.

Please refer to the “Soils & Hydrology” section of the Briggs 

Spring EA pages 117-137. Also see the “Geologic, Soil, and 

Water Resources” specialist report in the Briggs Spring project 

record. 

Please refer to the “Soils & Hydrology” section of the Briggs 

Spring EA pages 117-137. Also see the “Geologic, Soil, and 

Water Resources” specialist report in the Briggs Spring project 

record.

The spotted salamander is not present in the project area, nor is 

it found in the Black Hills. The literature citation provided does 

not give enough information to locate the literature. 

 

Please refer to the hydrology section of the “Soils and 

Hydrology” section of the EA, pages 127-137, for effects of 
Briggs Spring Environmental Assessment Appendix H

 H-9

 

organic matter that collects in the vernal ponds, or pH if the logging 

process deposits foreign residues to the area. Also heavy equipment 

used to harvest the timber has the potential to alter the terrain. This has 

a major negative effect on aquatic species. How will this damage be 

eliminated?

Harvest Comment #11: Logging 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. Please tell the public about this damage in the final 

EA.

Harvest Comment #12: Logging removes mature and maturing trees 

which conserve essential elements, whereas the area containing new 

very young planted trees following logging are susceptible to erosion 

and essential element loss. Will this occur?

Harvest Comment #13: Logging removes tree parts that would have 

created and maintained diversity in forest communities. What will be 

done to artificially enhance this diversity?

Harvest Comment #14: Widespread removal of dead and dying trees 

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) This effect is cumulative. 

Please explain how it will be reduced.

Harvest Comment #15: Logging removes biomass critical to future 

soil productivity of the forest. Activities taken on public forests should 

maximize growth potential and productivity. Why is this goal not 

important here?

Harvest Comment #16: Logging collapses some of the subsurface 

pipes, increasing local pore water pressure and the chance of landslides. 

(Sidle, 1986) How will this be mitigated?

Harvest Comment #17: Logging damages recreational opportunities 

and harms visual quality. Please see attachment #13 which shows 17 

statistically significant nationwide polls showing the public’s dislike of 

project activities to water. Appendix B of the EA also includes 

design criteria to lessen impacts to water resources. 

The environmental effects to forest resources are discussed in 

Chapter 3 of the EA. 

The Briggs Spring project does not propose any planting after 

harvesting. Also see the soils section of the “Soils and 

Hydrology” section of the EA, pages 117-127. 

The environmental effects to forest resources are discussed in 

Chapter 3 of the EA. 

The literature citation provided does not give enough 

information to locate the literature. The Briggs Spring project 

does not propose any removal of dead trees, except where 

considered a safety hazard. Any dying trees removed would be 

‘green’ mountain pine beetle hit trees through sanitation efforts. 

See the soils section of the “Soils and Hydrology” section of the 

EA, pages 117-127. Also see the “Geologic, Soil, and Water 

Resources” specialist report in the Briggs Spring project record. 

See response above to ‘Harvest Comment #15. The literature 

citation provided does not give enough information to locate the 

document. 

There was not an attachment to this comment letter. Please 

refer to the “Recreation” section of the EA, pages 112-117, and

the “Scenery” section of the EA pages 104-109. There are 
Briggs Spring Environmental Assessment Appendix H

H-10

logging on their land. Doesn’t it seem reasonable to manage according 

to the owner’s wishes?

design criteria included in the project to allow the project area to 

maintain its scenic integrity. See design criteria in Appendix B, 

pages B-4 – B-5. 

3d The Draft EA Indicates that Herbicides will be Applied to 

Eliminate and/or Control Non-Native Plants in the Project Area

The draft EA at page 97 states:

“It is critical that the proposed post harvest activity of using herbicides 

for noxious weed control be implemented to mitigate the spread of 

invasive plant species. Monitoring of the effectiveness of treatment, 

and retreatment as needed, is essential.”

In spite of Forest Service herbicide approval EISs there are new 

research findings that contradict earlier safety research. 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

This quote is actually on page 98 of the EA. 

The approval of herbicide EIS’s through the Forest Service as 

an agency is outside the scope of the Briggs Spring project. 
Briggs Spring Environmental Assessment Appendix H

 H-11

 

· 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

· 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®.

I have included an article describing recent research by unbiased, 

independent scientists below.

http://www.alternet.org/story/150733/why_is_damning_new_evidence

_about_monsanto%27s_most_widely_used_herbicide_being_silenced?

page=entire

This article was reviewed. It is not scientific literature, it is an 

article written for a website, www.alternet.org. 

3e Conclusion

After reading the information above describing the ecological harm 

caused by road construction and timber harvest, it should be clear that 

this sale might maintain or improve the health of the trees. However 

there are countless other important natural resources in the forest 

besides conifer tree species.

It is these other natural resources that will be harmed (some for the long 

term) by the Briggs Springs project.

Your comments have been noted. Thank you. 
Briggs Spring Environmental Assessment Appendix H

H-12

Please implement everything described in the Proposed Action except 

1) herbicide application, 2) timber harvest and 3) road construction.

Noxious weed spread is a massive problem on public land. They must 

be eradicated mechanical, hand and biological methods . . . this 

includes closing livestock allotments near infestation areas to prevent 

the spread of these weeds by livestock,

Please think of the health of our natural resources in the forest rather 

than the destructive, corporate-friendly, decades-old Forest

Service timber policy.

4a Carson 

Engelskirger

On behalf of the Black Hills Forest Resource Association and its 

members, we would like to submit comments on the Briggs Spring EA.

We agree with and support the Briggs Spring Purpose and Need and 

find it fitting. Overall, we are in support of Alternative 3, but with the 

following modifications and recommendations as listed below. We feel 

Alternative 3 best addresses Forest Plan Goal 10 and Objective 10-07 

by adding more stands to be included in commercial thinning. The 

current pine beetle epidemic continues to grow and there is a significant 

amount of activity within the project boundaries.

Thank you for your comments and interest in the Briggs Spring 

project. 

Your support for Alternative 3 is noted, thank you.

4b Sanitation

We feel sanitation is an important component to react in early 

infestations where there is the ability to reduce pockets from growing 

larger. Rather than having a limit on the amount of acres allowed for

sanitation (6,063ac) which appear to only be allowed in the unit 

boundaries, we recommend creating a clause that allows for response 

anywhere in the project boundaries. This will give the district and 

future purchasers, increased flexibility in mitigating early signs of 

infestation.

We agree that sanitation is an important component of reducing 

mountain pine beetle impacts. Therefore sanitation is included 

as a companion treatment in all commercial treatments, in both 

action alternatives. The EA has been edited to more clearly 

display that sanitation is included in all commercial treatments. 

The noted sanitation acres, 6,063 (page 9, EA), are where 

sanitation is the only proposed treatment in Alternative 2. 

Alternative 3 includes 3,678 acres where sanitation is the only 

treatment because additional commercial treatments are 

included in Alternative 3. There are 21,520 acres of pine sites 

in the project area. Alternatives 2 and 3 would treat 15,383 

acres (71%) and 20,467 acres (95%) of existing pine sites, 

respectively. In Alternative 3, the 5% of pine sites not included 

for treatment are those within the Jasper fire area and are 

structural stages 1, 2, and 3A, highly unlikely to be infested with 

MPB. Therefore, Alternative 3 does essentially include all pine 

sites with potential for beetle infestation. 
Briggs Spring Environmental Assessment Appendix H

 H-13

 

4c Current Info

We would encourage the district to use new flight information to be 

collected following the beetle flight, to adjust boundaries and 

prescriptions. This will allow for new pockets of infestation to be more 

accurately detected and mitigated.

The boundaries used for the project analysis cannot be adjusted. 

The Draft EA did include the following aerial survey in the 

analysis, Schaupp, Willis C., Jr. 2011. Aerial overview of 

detection survey in 2010, Black Hills of South Dakota and 

Wyoming, Service Trip Report RCSC-03-11. 6p. February 02, 

2011. 

Also see response to comment 4b. 

4d Commercial Treatments

We again support the increased thinning efforts mentioned in

Alternative 3. We do have some concerns regarding residual stand 

densities following treatment. Overall, we support efforts that treat the 

maximum number of acres possible in the project area. It has been 

observed over past year, that many stands, albeit infested with pine 

beetles, are being thinned down to a 40 BA. We support eliminating 

infestations in stands, but feel that some of the stands are being thinned 

too much. This creates abundant regen issues in the following years and 

also delays the next harvest far greater than if thinned to a higher 

residual stand density.

For example, if a stand is infested with pine beetles, and a prescription 

to thin to a 40 BA is applied, the result many times tends to be a 

residual stand that looks more like a 20BA after you account for the

original proposed thinning, green infested trees also removed, and 

pockets of dead trees from prior MPB mortality. In the following years, 

excessive wind throw can take place and the problem of abundant regen 

happen.

In these instances, we would recommend thinning these stands to a 60-

70BA. When that is done, a few things will happen: 1) all the bugs will 

be removed regardless of the prescription applied, 2) thinning to these 

levels will create areas that have sections that by result of removing 

green infested, create ‘40 BA’ sections, 3) the stand is still stocked at a 

reasonable level that allows adequate regeneration and also allows reentry sooner in to the stand, and 4) wind throw will be minimized and 

the residual stand will be more intact.

We understand the intent of thinning to a 40BA, but we have the ability 

to treat far more acres if we use a 60-70 BA. In the end it comes down 

to ‘thinning a few acres intensively v. thinning many acres

Your support of Alternative 3 is noted. 

The Briggs Spring project does not propose thinning to a 40 

basal area. Both alternatives in the Briggs Spring project 

propose commercial thinning to a 50-60 basal area, depending 

on MPB infestation. 

Your comments are noted. 

Thinning to a 60-70 BA was an alternative not considered in 

detail. Refer to Chapter 2 of the EA for more information. 
Briggs Spring Environmental Assessment Appendix H

H-14

extensively’. There still may be some mortality in residual stands, but 

populations will not be able to spiral out of control as they do in dense 

stands.

In the ‘commercial thin’ acres, we would support thinning efforts that 

focus more on 60BA regardless of infestations or not. In ‘group 

shelterwood’ we would also support a 60-70BA regardless of the 

beetles.

We also noticed the large extent of POL thinning proposed. We support 

POL sales, but caution including too much POL thinning in residual 

stands following commercial treatment. Some of these stands again are 

becoming too thin in the 20-40BA range. (ie - across from Crazy Horse 

Memorial)

We would also recommend shelving OR from being conducted in the 

near future. While we still believe they are important and necessary in 

the Black Hills, we need to focus on thinning more acres moderately, 

rather than a few acres intensively. Please still include them in the 

ROD.

The definition of POL thinning has been edited in the EA – see 

Table 2 and 4 in Chapter 2 of the EA. POL thinning will not be 

done to a predetermined spacing, but rather it will be done 

where necessary to achieve the overall target stand BA. 

Your request is noted and will be forwarded to the District 

Timber personnel. The timing of implementing OR treatments 

is outside the scope of this decision. The proposed OR are 

included in both alternatives and will be considered by the 

Decision maker. 

4e Prescribed Burning

We do not support any prescribed burning within the Jasper fire

footprint. This includes most of the proposed burn units in the southern 

part of the project. There are other places within the project area that 

deviate more from the historic fire regime than those recently burned in 

the Jasper fire. These areas are also regenerating suitable timber acres. 

What we do support regarding prescribed burning includes:

1.) Mortality limits of 10% or less of commercial timber 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 – what is the rationale in including burn units

within the Jasper burn?

4.) We strongly urge prescribed burning to be done in stands that have 

Your comments are noted. Appendix B of the EA includes 

design criteria for prescribed burning mortality limits based on 

DBH and/or number of seedlings per acre. Some clarification 

has been added to the design criteria, as follows: Before 

prescribed burning, the silviculturist would check sites for 

regeneration. In areas with seedlings less than 4.5’ in height, 

exclude area from burn if possible, if it can’t be excluded, 

follow mortality limits according to Table B-8. 

 

1) Some sites do include design criteria, Appendix B of the EA,

to limit burn mortality to less than 10%. The mortality limits 

vary depending on stand structures. 

2) The possibility of salvage logging was an alternative 

considered and deferred – see Chapter 2 of the EA.

3) Prescribed burning in these sites would reduce the buildup of 

fuels that have accumulated from the Jasper fire. 

4) Design criteria has been added to state mechanical treatments 
Briggs Spring Environmental Assessment Appendix H

 H-15

 

had mechanical treatments prior to burning.

5.) We caution the US Forest Service in burning following 

precommercial thinnings where the slash is left on the forest floor. We 

would recommend burning in this scenario only in cases where the 

slash is minimal or the stand densities are low enough that the residual 

stand will not be damaged and the prescribed burn will be of low

intensity.

would be implemented prior to prescribed burning. 

5) Prescribed burning in these areas would have mortality limits, 

depending on stand structure. 

Prescribe burning following POL thinning would have minimal 

slash on the ground as material 5-inches dbh and greater would 

be removed from the stand.

4f Design Criteria

B-1

• Regarding the 25 known cultural resources – how many of the 25 are 

currently unevaluated?

Why were any sites lacking evaluation, left unevaluated?

B-2

• Last bullet – we support proposing whole tree yarding in areas 

proposed for prescribed burning.

B-7

• Regarding Table B-3 and where screening cover is to be maintained, 

please define screening cover. We would not support the idea of 

screening cover if it results in dense stands along roads that are at 

increased risk for pine beetle infestation.

B-10, B-11

• We would recommend that mention of mortality limits on both pages 

reflect <10% in stands of commercial sized timber. We have enough 

‘holes’ and ‘openings’ in our canopy from pine beetles. We do not 

support proposed mortality limits in table B-8, regardless if that is a 

ceiling.

B-12

• First bullet – we agree with the need for sanitation clauses, but would 

support expanding this clause to be project-wide. If the purpose and 

need of the project involves reducing pine beetles, they why are there 

limiting factors and parameters regarding where you can and can’t react 

to pine beetles. Bottom line, if there are infestations popping up, we 

need to get them eliminated before they grow to cover large expanses, 

especially outside of unity boundaries which often times involves steep 

slopes. The BHNF has stated that the MPB is the number one priority 

All 25 sites on National Forest land in the project area have 

been evaluated. Design criteria in the EA has been clarified.

 

Your support of whole tree logging in areas to be burned is 

noted. 

Screening cover is defined as: being able to hide 90% of an 

adult deer or elk from human view at a distance of 200 feet or 

less (of the road). See Appendix B, pages B-6 – B-7 of the EA. 

Screening cover pertains to non-commercial sized trees, 

seedlings/saplings. 

Your comments are noted. Mortality limits of <15% for 

commercial sized timber (9.0” – 16.0”) was used because <10% 

is difficult to accomplish. If that mortality limit is 

accomplished, the reduction of fuels on the ground would be 

very minimal and it reduces the window of opportunity to 

accomplish the prescribed burn. 

Refer to response to comment 4b on sanitation. 
Briggs Spring Environmental Assessment Appendix H

H-16

on the forest, yet limiting sanitation efforts seems to contradict this 

statement.

B-13

• Fourth bullet – again, we agree with the concept, but feel sanitation 

should be allowed in sensitive areas such as the WIZ. In the end, if the 

removal is done carefully, it should enhance and maintain these areas 

from being destroyed.

B-16

• Third bullet – we would recommend including mention of ‘dry’ 

ground along with frozen.

This design criteria does not state that sanitation, or any other 

vegetation treatment, cannot be done within a WIZ. It states the 

design criteria to protect the WIZ during such operations. 

“Dry” conditions were purposely left out of this design criteria 

for hardwood treatments. This was recommended by the 

Hydrologist, due to the probability that the ground in hardwood 

stands being dry is very low. 

4g In conclusion, we support Alternative 3 with the above mentioned 

recommendations. Overall, we need to treat as many acres as possible 

to have the largest impact on the infestation. We support the increased 

efforts to thinning in Alternative 3 and applaud the district on this. We 

also feel that stands that have been deferred from treatment, that area at 

high risk to infestation, should be included in commercial treatments.

We thank you for the opportunity to comment on this project and look 

forward to the final EA.

Your support for Alternative 3 and your recommendations are 

noted. Thank you. 

5a Conrad Fisher No Comment. 

Exceptions: If archaeological materials or human remains are 

encountered during construction, the State Historic Preservation Office 

and applicable Native American Tribes will be notified.

Thank you. 

6a Nancy 

Hilding

Briggs Spring EA, comments, letter # 4

Please accept these comments in addition to those we have already 

submitted, with BCA/WWS and for PHAS,.

Wetlands,

Please improve discussion of wetlands, bogs and fens, including small 

areas not seen from the air, and thus may not show up on wetlands 

inventory. I don’t see a specific section on wetlands, but on page 133 of 

DEIS you talk about potential impacts to wetland near OHV camp. 

Please provide a map of wetlands, even small ones. Please keep roads 

and log landing out of wetlands, even the small ones.

Floodplains, wetlands and riparian areas are discussed in the EA 

on pages 129-130 and 132-137. GIS data of existing wetlands is 

located in the project record. 

There is design criteria for soils and hydrology in the EA,

Appendix B pages B-12 – B-16. 

6b Riparian Areas, Riparian 
Briggs Spring Environmental Assessment Appendix H

 H-17

 

You indicate there are no perennial riparian areas early in EA, but on 

page 130 talk about short perennial segments. Please disclose the places 

where springs or other sources release into waterways and thus where 

localized and small perennial stretches can be found. (Are all of these 

shown on the map # 7? You discuss karsts. Are there any “sink holes” 

where water can be seen disappearing into the ground, at least part of 

the year? Do the streams support fish and if not, where is the nearest 

perennial or intermittent stretch known to support fish (game or nongame)?

We are concerned that streams in the area have not been rigorously 

surveyed and evaluated for stream stability (DEIS at page 131).

There is less than one mile of perennial stream segments in the 

Briggs Spring project area, see page 130, Table 41 of the EA. 

Map 7 in Appendix A of the EA shows stream courses for the 

project area. There is karst terrain located in the project area, 

see the “Geologic, Soil, and Water Resources” specialist report 

for more information on karst terrain in the project record. 

There are not any known fisheries in the project area. 

The latest monitoring and evaluation reports were used during 

analysis of the project area. 

6c Mountain Lions

Please include a discussion of mountain lion habitat and effects of 

Project on lions. It should be considered a demand species or species of 

local concern.

Mountain lions were not discussed in this EA because they are 

not a Threatened, Endangered or Sensitive Species, a 

Management Indicator Species, a Species of Local Concern, or 

a Demand Species. The Forest Plan and FEIS Phase II 

Amendment designate species as Demand Species and Species 

of Local Concern, designation of species is outside the scope of 

the Briggs Spring EA. 

6d Elks,

Please improve the discussion of the impacts of roads and road density 

on elk. Please review the literature about such effects, especially the 

science produced locally.

See the “Wildlife” section of the EA, pages 37-76. The Wildlife 

specialist report in the Briggs Spring project record contains a 

list of references, including locally produced, used during 

analysis. 

6e Weeds,

Please provide for identifying areas with weed infestations and trying 

before the timber cutting/road building happens and further spreads. 

Weeds.

See the “Noxious Weeds” section of the EA, pages 92-93 and 

97-98. Design criteria to treat weeds is included in Appendix B. 

6f Scenery,

The SIO inventory done during the Forest Plan Revision was done in 3 

days on a computer, where the computer calculated beauty theoretically 

by assigning scenic values to mapped features. It is at best a guess. 

Even if it was correct, the area may have experienced major 

disturbance events since 1996. SIO are guidelines and thus can be 

changed by a NEPA document. Please review all SIO and ground truth 

them and update or change as needed.

How the SIO inventory was done during the Forest Plan 

Revision is outside the scope of this project. The scenery 

resource specialist has reviewed all SIO for the project area. 

Further details on scenery management can be found in the 

specialist report located in the project record. 

 

6g Log Landings

Please disclose all log landings and large slash pile locations in the EA. 

Please fully disclose how slash and slash piles will be situated and then 

how slash piles burned and slash pile detritus removed.

Appendix B of the EA contains design criteria for slash piles 

and landing sites. 
Briggs Spring Environmental Assessment Appendix H

H-18

6h Recreation

Please include nature study and bird and other wildlife watching as a 

recreational use.

Wildlife and bird watching is an activity that may occur 

throughout the National Forest, not specificly to this project 

area. 

6i Maps:

Please include a fire history map for the area.. Please include a beetle 

history map, which shows beetle activity in the area and nearby areas 

over time. Please include a topographic map. Please include a before 

and after pine structural stage map. Please provide a before and after 

cover type map. Please provide a map of the understory. Please provide 

a map of the SIO. Please disclose the dates and locations of all past 

timber sales in the area. Please provide a map of all stands that have 

been treated in the last 40 years or as far back as you have records.

Pages 79-80 of the EA discuss “Fire Risk” of the Briggs Spring 

project area. Page 79, Table 26 shows known fire history in the 

project area. Figure 5, page 80 shows the large fire history in 

and around the project area. 

Aerial overview detection surveys (2008-2010) of forest pest 

conditions were used during the analysis. The corresponding 

GIS data is in the project record.

The maps in Appendix A include topography lines. The GIS 

data in the project record includes a topography layer. 

Table 7, page 19-20 of the EA shows a comparison by 

alternative of cover types and structural stages. 

Understory is discussed in the “Forest Vegetation” section of 

the EA, pages 22-37. The commentor does not define exactly 

what understory component is of concern or the purpose of an 

understory map. 

SIOs are developed at the Forest level, which is outside the 

scope of this project.

See the EA, Appendix F, for past timber sales and treatments in 

the project area. 

6j Aspen,

Please discuss fire resistance of aspen and a strategy of converting from 

ponderosa pine to aspen/birch so as to reduce fire risk. Please discuss 

cutting pine trees away from the edge of aspen stands to as to accelerate 

the spread of aspen. However don’t remove very old large yellow barks 

from aspen.

See the EA “Forest Vegetation” section in Chapter 3 for 

quaking aspen, pages 32-33 and page 36. Appendix B of the 

EA includes design criteria for prescribed burning in the aspen 

stands, which includes mortality limits. Design criteria is 

included to remove all conifers from aspen sites, consistent with 

Forest Plan Standard 2205 and to remove conifers within one 

aspen tree height from the clone (~50 feet), Appendix B, page 

B-12. 

6k Mixed hardwoods with pine,

Please discuss the benefits to wildlife and birds from mixed cover type 

stands. Please provide for the retention of some mixed stands, 

especially if pine and aspen are at equilibrium. Please discuss if there 

are any areas where very large old pines occur next to aspen. Given 

how rare old pine are in the area, please don’t cut them any place. 

Please discuss the visual values of mixed stands.

The “Wildlife” section of the EA discusses habitat needs by 

species. The “Scenery” section in Chapter 3 of the EA 

discusses visual quality, pages 104-109. Also see response to 

comment 6j concerning aspen and very large trees. Appendix 

B, page B-10 of the EA, includes design criteria to retain very 

large trees, meeting Objective 5.1-204. 

6l Large old trees, The location of Moon Campground is outside of the Briggs 
Briggs Spring Environmental Assessment Appendix H

 H-19

 

There was a glorious old pine tree in a meadow near Moon 

Campground. I hope it is still there. Please identify and place a 

moratorium on the taking of large old pine trees in the area. Please 

provide charts that show data for tree diameters and tree ages for the 

project areas, both before and after. Which stands have the largest and 

oldest trees? Please show us. What are you doing with them. What is 

your plan to create SS 4C and 5, in the future? Which are the future SS 

4C and 5 stands. Why does the area fail to meet Forest Plan standards 

for the area, please disclose the cause of this past failure.

Spring project area. Appendix B of the EA, page B-10, includes 

design criteria to retain “very large” trees. The “Forest 

Vegetation” section of the EA, pages 23-25, discusses 

ponderosa pine age class distribution, structural stages, and 

Forest Plan objectives versus existing conditions. See response 

comments 6k pertaining to very large trees.

6m Fire Hazard ratings

On page 82 you discuss fire hazard ratings, without the qualification 

that this is the risk of catastrophic crown fires, not risk for all types of 

fire. Please be sure to always disclose the limits on which type of fire 

you are calibrating the risk for. Please discuss the relative risk of stands 

for other types of fire. (We believe that you can’t or never do). Please 

be honest about this.

Page 82 of the EA, discusses Fire Hazard, which includes the 

following statement, “The structural stage gives an indication of 

the current fire hazard and is a stand level rating of crown fire 

susceptibility.” Fire hazard ratings are not the risk of 

catastrophic crown fire. 

6n Road Densities.

Please provide an alternative that reduces the road densities.

A roads analysis process was completed for this project. 

Reducing road density was an alternative not considered in 

detail. 

6o Environmental Justice.

Is there an environmental justice section? If not please include. We 

believe that as the Black Hills is still claimed by Native Americans and 

ownership subject to dispute, thus they are impacted by projects on the 

BHNF, and thus -- how it is used is an environmental justice issue.

Executive Order 12898 directs Federal agencies to focus 

attention on human health and environmental conditions in 

minority communities and low-income communities. None of 

the counties in the study area contain low-income or minority 

populations as defined by Executive Order 12898. There would 

be no disproportionate negative effect on such communities 

under any of the alternatives. Public involvement efforts used 

for this project provided ample opportunity for participation in 

the analysis process. Eighteen tribes (33 individuals) were 

included in the scoping process and received the project scoping 

as well as the draft EA for this project. 

7a Duane Short Biodiversity Conservation Alliance, Prairie Hills Audubon Society, 

Nancy Hilding individually, Duane Short individually, and Western 

Watersheds Project submit these comments in response to the July 

2011 Draft Environmental Assessment for the Briggs Spring Project 

(hereafter, “BS Project”).

Comments on the DEA Project Summary (DEA Summary. p. i-ii)

Because, and according to the BS Project summary, “the Hell Canyon 

Ranger District of the Black Hills National Forest (hereafter Forest, 

Each resource in the EA includes direct, indirect, and 

cumulative effects – refer to Chapter 3 of the EA. 

The best available science was considered by the resource 

specialists who conducted the analysis for the Briggs Spring 

Project. Refer to the Literature Cited section of this EA and 

within specialist reports. In addition, all references provided in 

comment letters or during the scoping period have been 

reviewed by resource specialists. 
Briggs Spring Environmental Assessment Appendix H

H-20

Forest Service, or Service) proposes to implement multiple resource 

management actions, including commercial and non-commercial 

vegetation treatments, prescribed burning, and construction of a new 

campground within the Briggs Spring project area” (DEA Summary pg.

i) assessment of cumulative impacts, including the impacts of

connected, similar, cumulative including direct and indirect actions 

must be performed (National Environmental Policy Act(§1508.25, 

§1508.25 (a)(3)), §1508.7, 1508.25 (a)(2)).

When analyzing the proposal and alternatives, the Service must 

consider actions that result as a direct or indirect consequence - that is, 

connected, similar, and cumulative actions. These actions should be 

incorporated into the description of the proposal and alternatives as 

relevant.

Two Action Alternatives offer an insufficient number and variety of 

approaches for addressing management regimes that reflect best 

available science and public stakeholder concerns. Among and at the 

heart of the insufficiency is a failure to comprehensively address 

cumulative impacts associated with the BS Project and associated 

Additive and Interactive impacts.

CEQ Regulations §1508.7 Cumulative Impact

“Cumulative impact” is the impact on the environment which results 

from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person undertakes such actions.

Cumulative impacts can result from individually minor but collectively 

significant actions taking place over a period of time. Example: If, for 

example, the Service proposes to expand a campground in red-bellied 

snakes habitat, other activities that have a combined impact on the

red-bellied snake or its habitat must be included in the analysis. This 

would include other NFS projects that would occur in red-bellied snake 

habitat. It doesn't matter who takes the actions, or whether they took 

place in the past, are taking place in the present, or will take place in 

the foreseeable future.

Conservation Planning and Environmental Impact Analysis §4-5, G.6: 

“Cumulative impact information may be less exact than information on 

All public scoping comments were considered in identifying the 

key issues and alternatives to the proposed action. The Line 

Officer, Lynn Kolund, approved the issues and alternatives in a 

letter dated August 15, 2011, maintained in the project file. 

Documentation of how scoping comments were addresses is 

also maintained in the project file. 

NEPA does not require that a certain number of alternatives be 

analyzed in detail. CEQ regulations require that a No Action 

alternative and all reasonable alternatives be analyzed in detail 

(40 CFR 1502.14). For the Briggs Spring project, five 

alternatives were not considered in detail, see Chapter 2 for 

explanation of why these alternatives were eliminated from 

detailed study. 

The rest of this comment is from a National Park Service 

Director’s Order (specifically DO-12). National Park Service 
Briggs Spring Environmental Assessment Appendix H

 H-21

 

direct and indirect impacts of the alternatives, but a good faith effort to 

accurately and completely assess major sources of impact and their

contribution to resources affected by the proposed action or alternatives 

should be part of any EIS or EA.”

Cumulative Impacts = Additive and Interactive

Additive

These impacts accumulate in the same way as a “straw on a camel's 

back.” Straws keep adding weight until, finally, the camel's back is 

broken. One impact, causing occurrence, such as a single gas well, may 

be of little significance but one-hundred wells in the same area, 

however, may profoundly impact a given valued resource.

Interactive

These impacts accrue as a result of assorted similar or dissimilar 

actions being taken that tend to have similar impacts, relevant to the 

valued resource in question. Vegetation quality, diversity, density, and 

general health, for instance, could be affected by several actions. These 

actions could include unmitigated over-grazing by wildlife, cattle, plus 

motorcycle/off-road vehicle use, industrial development, logging and 

other vegetation treatments, and roads.

A. Connected actions (§1508.25)

Connected actions are those that are “closely related” to the proposal 

and alternatives. Connected actions automatically trigger other 

actions, they cannot or will not proceed unless other actions have been 

taken previously or simultaneously, or they are interdependent parts of 

a larger action and depend on the larger action for their justification. 

For instance, if your park proposes building housing for rangers on an

existing trailhead parking lot, and the trailhead lot must be relocated 

as a result, this is an action connected to the proposal of building the 

housing. The impacts of removing the existing parking lot, relocating 

the lot, and reducing visitor access to the trailhead must be analyzed in 

the same NEPA document as the housing.

B. Similar actions (§1508.25 (a)(3))

Similar actions are those that have similar geography, timing, purpose, 

or any other feature that provides a basis for evaluating their combined 

impacts in a single NEPA document. They can be the same as 

connected or cumulative actions. As an example, if in the future you 

D.O’s are outside the scope of this project. 
Briggs Spring Environmental Assessment Appendix H

H-22

intend to build a restaurant in association with the lodge on the north 

rim of the Grand Canyon, the restaurant and any parking, fencing, 

utilities, and so forth that are connected with it would be a similar 

action, which should be analyzed in the same NEPA document as the 

lodge itself.

C. Cumulative actions (§1508.7, §1508.25 (a)(2))

Cumulative actions are those that have additive impacts on a particular 

environmental resource. It is irrelevant who takes these actions (i.e., 

they are not confined to NPS or even federal activities), or whether they 

took place in the past, are taking place in the present, or will take place 

in the reasonably foreseeable future. As an example, if your park is 

proposing building a small sewage treatment plant and discharging 

treated wastewater into a river, other activities (i.e., cumulative

actions) that also have an additive impact on the river must be included 

in the analysis on water quality. These activities might include disposal 

of wastes from recreational vehicles in the park, cattle ranching 

upstream of the park on public land, or release of water from a 

reservoir on private property downstream of the park. If you are 

preparing a GMP or other broadscale plan, actions on land adjacent 

to, or even in the region of, the park unit may have combined impacts 

on resources inside the park boundaries and need to be included in the

cumulative impact analysis. One source of information about methods 

to analyze cumulative impacts is the CEQ’s January 1997 report, 

“Considering Cumulative Effects under the National Environmental 

Policy Act.”

7b Because the project area is entirely within Management Area (MA) 

5.1—Resource Production Emphasis—there is no mandate or impetus 

to log the entire area. A management prescription is a guideline, not an 

order. Multiple Use must also be a consideration with management for 

resource protection, wildlife viability (and not just deer, elk and other 

game species) within MA 5.1 a reasonable and responsible component. 

The Theme of MA 5.1 states, “These areas [MA 5.1] are managed for 

wood products, water yield, and forage production, while providing 

other commercial products, visual quality, diversity of wildlife and a 

variety of other goods and services....” (BHNF LRMP Phase II 

Amendment, Chapter 3. pg. III - 64)

Management Areas (MA) are identified in the Forest Planning 

process and include management direction for those areas. The 

MA theme is a short description of management direction. 

Species viability was analyzed for the Forest Plan Phase II 

Amendment. The Briggs Spring project is consistent with the 

Forest Plan. 

7c Comments on Background Information (DEA Background Ch. 1, p. 

1-2)

General George A. Custer’s 1874 photographs are exactly that—

The photographs and information from the Custer Expedition 

were simply used as a historical perspective. The EA does not 

state that Custer’s photographs are the standard for today’s 
Briggs Spring Environmental Assessment Appendix H

 H-23

 

photographs. These photographs are thought to be the first ever taken 

of the Black Hills. As such, these photographs are what they are—a 

snapshot in time—representing “only” (emphasis added) a temporal 

depiction of what the Black Hills forest ecosystem was like at the time 

of Custer’s expedition and thereafter. This truism might sound like 

heresy, but George A. Custer’s photographs do not set the scientific

standard for how the Black Hills forests must have appeared before his 

expedition or anytime thereafter. Ecosystems cannot be discussed or 

described in terms of snapshots in time. Best available science and 

common sense agree that ecosystems evolve constantly and that 

evolution is driven and shaped by the net effects of millions of years of 

significant pre-human environmental conditions and pressures. To set 

Custer’s photographs as the standard for today’s management goals (in 

terms of appearance) is most irresponsible in biological terms (see 

DEA Chapter 1 pg. 1-2).

No reliable information exists to account for the decades, centuries or 

millennia of natural events impacting and influencing the “appearance” 

of the forests encountered by General Custer. To claim, or to even 

infer, that General Custer’s photos somehow depict a “Desired 

Condition” is simply misleading to public stakeholders.

Lodgepole pine and ponderosa pine stands vary considerably in tree 

density, age composition, disease profile and many other characteristics 

over time and in response to or as a consequence of wildfire, disease, 

insect infestations, weather events and climate conditions as well as 

other less obvious environmental influences ranging from planetary 

(geologic) events to cosmic processes, cycles, and episodes. To 

highlight General Custer’s photographs as a reference for how today’s 

Black Hills forest should look is a most irresponsible and, frankly, 

naïve form of public information/education.

management goals, nor does the EA state that the Custer 

Expedition photographs “depict a Desired Condition”. 

Management direction comes from the Forest Plan, and the 

Briggs Spring project is consistent with the Forest Plan. 

7d The DEA states (DEA Chapter 1, pg 2) as if an undisputed scientific 

certainty that, “The proposed management actions within the action 

alternatives are designed to reduce the risk of MPB infestation and to 

provide a sustainable supply of commercial timber (consistent with 

Forest Plan direction). The action alternatives are also designed to 

reduce hazards related to large scale wildfire.”

The above claim literally flies in the face of the documented history 

As page 2 of the EA states, “The proposed management actions 

within the action alternatives are designed to reduce the risk of 

MPB infestation...” The EA does not claim to stop or control 

the MPB infestation, but to reduce the risk of susceptibility. 
Briggs Spring Environmental Assessment Appendix H

H-24

regarding the mountain pine beetle outbreak to which the statement 

refers. From British Columbia to New Mexico efforts have utterly 

failed to stop or even diminish the natural progress of the mountain 

pine beetle outbreak. A wave of spruce beetle and other insect 

infestations are following the mountain pine beetle outbreak. Will the 

BHNF management propose another round of logging, supposedly, to 

control insect infestations as well? I hope this point is well taken. The 

fact that the beetle infestation has reached the Black Hills is evidence 

that all efforts to control the mountain pine beetle have failed. Please 

acknowledge the logic of this irrefutable reality.

Fuel reduction treatments have an average effective life of about 20 

years. Fuel reduction treatments are meaningless until or unless 

wildfire actually visits the treatment area or unit. The Service has failed 

to acknowledge the calculable probability that it could take up to 700 

years for a wildfire to visit a given treated area.1

1

Jonathan J. Rhodes and William L. Baker. Fire Probability, Fuel 

Treatment Effectiveness and Ecological Tradeoffs in Western U.S. 

Public Forests. The Open Forest Science Journal, 2008, 1, 1-7 1874-

4208/08 2008 Bentham Science Publishers Ltd.

Regional Analysis of Ponderosa Pine

For ponderosa pine forests, the probability, q, of treated areas being 

affected within their window of effectiveness varies regionally from 

0.020 to 0.040 for high-severity fires and from 0.042 to 0.079 for highmoderate severity fires (Table 1). As expected, q in these forests is 

higher than for the West-wide analysis of all cover types. The highest

probabilities, as expected, are in the Southwest and in the Northern 

Rockies, with its dry summers (Table 1).

In these forests with more frequent fire, it is likely that fuel treatments 

can potentially reduce fire severity on a small fraction of treated areas. 

The results (Table 1) indicate that in 92.1-98.0% of treated areas, fuel 

treatment impacts on watershed processes are not likely to be 

counterbalanced by a reduction in higher-severity fire.

Across the six regions, treatments would have to be repeated every 20 

years for 340 to 700 years (17 to 35 times), on average, before it is 

This reference has been reviewed; it does not provide any new 

information. The Briggs Spring fire/fuels specialist used 

scientific literature specific to the Black Hills during analysis. 

The italicized text is from Rhodes and Baker.
Briggs Spring Environmental Assessment Appendix H

 H-25

 

expected that high-severity fire affects more than 50% of treated areas 

during periods of treatment effectiveness. Treatments would have to be 

repeated for 180 to 340 years (9 to 17 times) before more than 50% of

treated areas are expected to be affected by high-moderate severity 

fire. On average, these repeated treatments would affect watersheds 

and, potentially aquatic systems, depending on treatment practices, 

without providing reduction in fire severity on almost 50% of treated 

area.

An alternative method for estimating the risk of fire in the absence of 

fuel treatments is to use the fire rotation rather than mean annual 

probability of fire. The fire rotation indicates how long it takes, on 

average, for a particular area to burn one time and how often fire may 

return to a particular point in the landscape [23]. The fire rotation is

calculated by: B =1/p where B is the fire rotation for fire of a specific 

severity and p is, again, the mean annual probability of fire of a 

specific severity.

Based on our analysis, the mean annual probability, p, of high-severity 

fire in ponderosa pine forests West-wide is 0.0015 (Table 1), implying 

a fire rotation, B of about 667 years, varying from 500 to 1,000 years 

among individual regions. Based on the results in Table 1, the fire 

rotation for high-moderate severity fire is about 323 years in 

ponderosa pine forests West-wide, varying from 244 to 454 years in 

individual regions, based on data in Table 1. These results suggest that 

western ponderosa pine forests are not currently being rapidly burned 

by high or high-moderate severity fire, counter to other previous work

[37].

Carey and Schumann2 conclude, as follows:

“Although the assertion is frequently made that reducing tree density 

can reduce wildfire hazard, the scientific literature provides tenuous 

support for this hypothesis. This review indicates that the specifics of 

how prescriptions are to be carried out and the effectiveness of these 

treatments in changing wildfire behavior are not supported by a

significant consensus of scientific research at this point in time. This 

conclusion is supported by the work of other researchers.

Deeming (1990), suggested we do not know whether proposed 

The italicized text is from Carey and Schumann. This reference 

was also reviewed and does not provide any new information. 
Briggs Spring Environmental Assessment Appendix H

H-26

treatments will be effective in reducing the size, intensity, or severity of 

wildfires. A report prepared for Congress stated:

“We do not presume that there is a broad scientific consensus

surrounding appropriate methods or techniques for dealing with fuel 

build-up or agreement on the size of areas where, and the time frames 

when, such methods or techniques should be applied” (US GAO 

1999:56). A research report by Omi and Martinson (2002:1) stated: 

“Evidence of fuel treatment efficacy for reducing wildfire damages is 

largely restricted to anecdotal observations and simulations.”

The knowledge needed to carry out prescribed fire activities with any 

level of sophistication is severely limited because research has 

historically focused on fire suppression (Paysen et al. 15 1998). Other 

scientists acknowledged there is little objective data concerning 

effective combinations of prescribed fire and different silvicultural 

techniques (Harrington and Sackett 1990; van Wagtendonk 1996). Jim

McIver, a research scientist undertaking a five year study of alternative 

fuel treatment strategies stated: “At this point, information needed to 

answer this question is anecdotal or completely absent” (Sonner 2002). 

Omi and Martinson (2002:3), in a comprehensive overview of the 

literature concluded that only a “spattering” of studies published since

the 1950s report that fire severity was reduced in areas where fuels had 

been previously treated: “Very little work has been done that would fit 

into the scope of our research, i.e., wildfire severity variates measured 

and compared between untreated areas on noncommercial fuel 

reduction areas such that an hypothesis regarding treatment efficacy

may be statistically tested.”

Given the lack of scientific research, it is not surprising that forest 

managers also appear to lack adequate information concerning 

appropriate fuel reduction treatments. In a letter, a regional forest 

manager stated: “Regarding your question about different thinning 

prescriptions demonstrating relative effectiveness in reducing the 

intensity of spread of crown fire, I don’t know of any [studies]” 

(Personal Communication 2000).

In sum, the notion that mechanical thinning, or a combination of 

thinning and prescribed fire, reduces the incidence of catastrophic fire 

needs to be viewed as a working hypothesis and needs to be tested 
Briggs Spring Environmental Assessment Appendix H

 H-27

 

through experimentation and site specific evidence. The proposal that 

commercial logging can reduce the incidence of canopy fire appear 

completely untested in the scientific literature.”

2 Henry Carey and Martha Schumann. Modifying WildFire Behavior –The 

Effectiveness of Fuel Treatments: The Status of Our Knowledge. National 

Community Forestry Center. Southwest Region Working Paper. April 2003

At a time when short and long term financial considerations are 

paramount the Service should reevaluate the costs/benefits of its 

proposed fuels reduction activities and consider the probability that 

such treatments will, in actuality, do anything to prevent or reduce the 

risks of wildfire. In addition, the need to repeat fuels reduction 

exercises every two or so decades imposes repeated impacts to the 

forest ecosystem and its wildlife.

This reference has been reviewed and it does not provide any 

new information. 

Financial funding for the Forest Service program of work occurs 

as an annual appropriation from Congress.

Effects from fuels reduction activities were analyzed for this 

project. 

7e Comments on Management Direction (DEA Management Direction. 

Ch. 1, p. 2-4)

The Forest regarding the current condition of the project area compared 

with the desired conditions identified in the 2006 Forest Plan including 

applicable goals and objectives states, “Opportunities for improvement 

were identified” (DEA p. 2).

Phase II requires the Forest to manage for wildlife viability yet there is 

no mention of or reference to an opportunity to improve management to 

enhance wildlife viability. In fact, the only use of the word “viability” 

in the DEA is found in Chapters 3 and 5 and in Appendix G where each 

time the same blanket statement reads, “May adversely impact 

individuals, but not likely to result in a loss of viability in the Planning 

Area, nor cause a trend for federal listing.” Concerning the project’s 

impacts to the Iowa moonwort and narrowleaf grapefern the Forest

Service states, 

“Since both species occupy similar habitat the following determination 

is valid for both: May adversely impact individuals, but not likely to 

result in a loss of viability in the Planning Area, nor cause a trend for 

federal listing.”

The fact that two species share habitat is not sufficient scientific reason 

to assume no harm the viability of one and/or the other. Such 

The “Wildlife” section of the EA discusses the environmental 

consequences of project activities on wildlife species and 

wildlife habitat on pages 55-76. 

Viability of species is not considered at the project level. 

Species viability was analyzed for the Forest Plan Phase II 

Amendment. The Forest Plan provides management direction 

to insure species viability requirements are met. The Briggs 

Spring project is consistent with the Forest Plan. 

Page 90 of the EA states that neither Iowa moonwort or 

narrowleaf grapefern were found in the project area, therefore 
Briggs Spring Environmental Assessment Appendix H

H-28

statements appear to mock rather than embrace the use of Best 

Available Science. The above statement also reflects a lackadaisical, if 

any, concern for the viability of these and the numerous other sensitive 

species impacted by this project. Examples of failure to take advantage 

of Best Available Science and indifference toward wildlife viability are 

peppered throughout the DEA. As such we do not consider such 

flippant attention to the viability of sensitive species a step toward 

achieving desired conditions.

The Forest’s discussion of Management Direction, DEA pp 2-4 

elaborates on MA 5.1 Resource Production Emphasis by cherry 

picking Goals 2, 3, 4 & 10 none of which mention managing for 

wildlife viability. The Service demonstrates fastidiousness as it 

discusses the again, cherry-picked Objectives cited toward achieving 

Resource Production but fails to mention wildlife or species viability in 

this discussion.

Goal 2—which nearest addresses wildlife issues—is to:

“Provide for a variety of life through management of biologically 

diverse ecosystems.”

Goal 2, claims the Forest, is best achieved by seeking to satisfy 

Objective 201.

Objective 201: Manage for a minimum of 92,000 acres of aspen, and 

16,000 acres of bur oak during the life of the Plan. The highest priority 

for hardwood restoration is where conifers (e.g., spruce and pine) have 

out-competed aspen adjacent to riparian systems that once supported 

beaver.

only suitable habitat would be analyzed. Page 91, Table 31

discusses distribution and habitat of both species. 

Refer to response to comment 7a, on best available science. 

7f The focus and intent of the Service is clearly to manage the project area 

to produce the most and most marketable timber immediately. The 

intent is clearly to extract spruce and pine in the name of restoring 

aspen—a soft hardwood—which is typically softer than pinewood. The 

Forest has not considered Best Available Science, and has ignored a 

growing body of science that global warming is driving ecosystems to 

change at a pace faster than even the most scientists recognized just a 

decade ago. Of course, the compositions of forests are changing and 

quickly. Science does not support efforts to essentially lock or freeze 

any given forest’s composition into some arbitrary and somewhat 

Aspen restoration and increasing aspen acres is a Forest Plan 

objective (Objective 201). 

Refer to response to comment 7a, on best available science. 
Briggs Spring Environmental Assessment Appendix H

 H-29

 

capricious point in history. Even the Service recognizes that the project 

area is quickly changing in its statement,

“The highest priority for hardwood restoration is where conifers (e.g., 

spruce and pine) have out-competed aspen adjacent to riparian systems 

that once supported beaver.” Goal 2, Objective 20, p. 3.

The change referred to above is clearly recognized in the Phase II 

Amendment, 2006 Black Hills Forest Plan by the Plan’s authors (which 

are people now responsible for the Plan’s proper implementation).

7g The life expectancy of a given Forest Plan is about 15 years. No body 

of science would support efforts to thwart natural (or even man-made 

but uncontrollable) selection or competition among plants or animals. 

For example, if the now irrefutable accelerated climate change is 

deemed by the Service to be a natural phenomenon we ask, “Why 

impede nature?” If, on the other hand, the Service deems climate 

change to be man-made and not a natural phenomenon the fact remains

that nothing can be done to immediately reverse the warming trend 

seen worldwide. Again we ask, why should the Service waste money, 

time and human resources, in an attempt to combat the course of 

current and foreseeable environmental conditions arbitrarily and, 

perhaps, capriciously simply to lock or freeze the project area into a 

forest composition of a nostalgic view of yesteryear?”

Life expectancy of a Forest Plan is outside the scope of this 

project. 

Changing climate and warming caused by an increase in 

greenhouse gases can be relevant to Forest Service land 

management in two ways. These include assessing and 

reducing greenhouse gas emissions (mitigation); and, coping 

with the effects of climate change (adaptation). Mitigation 

reduces greenhouse gas emissions either directly on-site or by 

off-setting emissions generated elsewhere. Mitigation can 

include such activities as reducing the potential for deforestation 

or catastrophic loss, reforesting denuded lands, managing 

forests, to increase carbon uptake by trees, and utilizing biomass 

and wood products where carbon is sequestered. Management 

practices that reduce the likelihood of catastrophic fire and 

insect attack, and allow for utilization of forest products, can be 

characterized as mitigation techniques. 

Adaptation assesses ongoing or potential impacts to natural 

resources from changes in climate, and takes action to help plant 

and animal communities adapt to these changes. Proactive 

forest management anticipates certain long-term effects will 

result from changing climate based on research. It is important 

to recognize that there is a high degree of uncertainty in some 

current predictions. There are several possible approaches to 

adaptation, including promoting resilience in communities, and 

responding with changed management strategies. Management 

practices that promote diversity of species and reduce threats to 

forest health may also foster resilience in plant and animal 

communities, and can be characterized as adaptation techniques. 

These can often be carried out in current project planning. The 

need for changing management strategies may need to be 
Briggs Spring Environmental Assessment Appendix H

H-30

assessed in higher-level planning efforts such as RPA and forest 

planning. These efforts will rely on continuing scientific 

research. 

7h Goal 3, Objective 303 should be revisited as the Allowable Sale 

Quantity established in 2005 is being subjected to climate change but 

this climate change was not recognized by the Black Hills National 

forest at the time. The new National Forest Management Planning Rule 

is requiring ALL national forest units to incorporate climate change 

science into their own Forest Plans, planning and decision making 

exercises. To do less would be to violate the letter and spirit of the new 

Planning Rule which is due out in late 2011.

Revisiting the Allowable Sale Quantity in the Forest Plan is 

outside the scope of this project. 

See response to 7g pertaining to climate change. 

7i Goal 4, Objective 420b is more than met already. The Black Hills 

National Forest is one of the nation’s most heavily roaded forests. 

Existing roads are more than adequate to meet demand. Existing and 

foreseeable indicators are that long-distance tourism is on the decline in 

our nation and around the world due to ever-rising fuel costs. The 

Black Hills National Forest is located in one our nation’s most sparsely 

populated regions and will necessarily experience a pronounced decline 

in long-distance visitation. This unfortunate fact should be considered 

in terms of the Forest’s effort to meet Goal 4 via Objective 420b. The 

up side to the drop off in long-distance visitation is that the Forest’s 

claimed “demand” resulting in the ever-increasing fragmentation and 

roading of the Black Hills National Forest is declining.

The referenced objective states: “Provide recreation facilities, 

trailheads, trail crossings and other road corridor components to 

meet demand”. 

No new road construction is proposed with this project. 

7j Goal 10 and its associated Objectives are simply not based in Best 

Available Science that demonstrates the low probability of a given fuel 

reduction or other wildfire prevention exercise being subsequently 

visited by wildfire (Rhodes and Baker 2008). Even should a given 

wildfire prevention effort be subsequently visited by wildfire a growing 

body of science is developing that suggests the costs/benefits profile of 

such efforts, in terms of both economic and environmental 

considerations, is questionable at best (Carey and Schumann 2003).

Forest Planning is outside the scope of this project. 

The cited references have been reviewed, see 7d. 

Refer to response to comment 7a on best available science. 

7k The Forest fails to make scientific distinctions between terms 

flammable and combustible when discussing fuels—the former 

referring to the tendency of a material to produce a flame(s) and the 

latter referring to how strong or weak is that tendency. Deadfall for 

example, is both flammable and combustible. Combustion is measured 

with the help of calorimetry whereas flammability is calculated with 

the help of fire testing. All flammable substances are reliably

combustible, but all combustible substances are not essentially 

The Briggs Spring Draft EA does not use the words 

“flammable” or “combustible” anywhere in the document. 
Briggs Spring Environmental Assessment Appendix H

 H-31

 

flammable. Whether discussing combustibility or flammability, 

considerations for external conditions are paramount to a 

comprehensive understanding of fire. For example; even the liquid, 

gasoline, is non-combustible in the total absence of oxygen. Why, 

because even if liquid gasoline could burn in the absence of O2 it 

would release flame extinguishing CO2 instantly as a consequence of 

nature’s own negative feedback system. A negative feedback loop is a 

type of self-regulating system where increased output from the system 

inhibits future production by the system (no scientific citation 

necessary, right?).

The Forest fails to examine the roles of oxygen (O2) and carbon 

dioxide (CO2) as a flame accelerant and a flame retardant, respectively. 

Dead wood is not simply fuel as invariably the Forest Service depicts 

dead wood to its public audience. In fact wood both green and dead, 

wet and dry, or course and fine serves to both fuel an existing flame 

and to retard an existing flame. In the case of wildfire, observations 

focus on wood’s fueling role while wood’s retarding role is essentially 

ignored. Dead wood, such as jack-strawed deadfall not only inherently 

can serve as a fire break but can also harbor high levels of CO2 which 

is a potent flame retardant. Anyone having ever been around campfires, 

controlled brush fires, or who has study the physics of fire understand 

the dual roles played by dead wood or any other flammable material.

Thinning a forest to minimize the rate of spread and intensity of a 

hypothetical wildfire is like opening the windows of a house a house 

that is to hypothetically catch fire. Thinning a forest is like stoking a 

fire or lighting a brush or leaf pile by creating space for air to enter and 

or flow. The Forest Service itself (Gibson, Kegley and Bents 2009) has 

acknowledged that thinning increases wind (which is oxygen rich) and 

allows for dissipation of beetle pheromones which behave essential like 

gaseous materials including CO2.3

Silvicultural measures, such as thinning (Figure 15), have been shown 

to minimize mountain pine beetle-caused tree mortality in some 

lodgepole and ponderosa pine stands if performed prior to outbreak 

initiation. Opening the stand through thinning influences beetle 

populations by 1) changing microclimate and wind patterns within

the stand, 2) allowing beetle-produced pheromones to dissipate 

The cited reference (a leaflet) has been reviewed and does not 

offer any new information. 

The italicized text is from the Gibson, Kegley and Bentz 2009 

document. 
Briggs Spring Environmental Assessment Appendix H

H-32

through opened crowns, and 3) providing more growing space, 

nutrients, and water for remaining trees.

3

Ken Gibson, Sandy Kegley, and Barbara Bentz. Mountain Pine 

Beetle. Forest Insect & Disease Leaflet 2. Revised May 2009.

It is possible but not necessarily true that thinning may increase the 

amount of water available to remaining trees because any such increase 

is reduced significantly by several factors:

♦ Thinning allows more airflow though stands which in sunny, drier 

climates dries the entire thinned area including the forest duff layer.

♦ Thinning allows more sunlight and heat to penetrate to the forest 

floor, drying it more readily.

♦ Thinning, indeed, enhances the growth of the understory in terms of 

rate and volume thus necessitating more water uptake per plant 

compared to older plants past their peak growth rates.

♦ Increased growth rates of the understory plants and the remaining 

trees results in greater consumption of the subsurface water supply.

♦ Fewer and more widely spaced trees are less capable of retaining 

rainfall and snowmelt which means much of the water the Service 

claims is available for the remaining trees is lost to runoff.

7l “Patch-cutting in lodgepole pine landscapes creates a mosaic of age 

and size classes, which reduces acreage of lodgepole pine that will be 

highly susceptible to mountain pine beetle attack at any one time. 

Where clear- or patch-cutting is not an option, selective harvesting can 

help reduce beetle-related damage. Susceptible trees can be removed 

selectively in riparian zones, along roads, in campgrounds, and in 

scenic vistas.”

No science is offered to back up the above claim (in bold text) that 

thinning does anything to minimize the spread of beetles. The first 

phrase, in bold text, is incoherent. Of course, where there are fewer 

trees there will be a lower capacity for the remaining trees to support an 

insect that is largely dependent on that particular tree species for its 

survival. The extension of that logic however, is that to cut down all the 

trees would be the ‘solution’ to the beetle outbreak. Of course this 

‘solution’ is a preposterous notion. To thin trees, as a solution to the 

beetle outbreak, is simply a little less preposterous.

There is no lodgepole pine within the Briggs Spring project 

area. 

The italicized text is from Gibson, Kegley, and Bentz, 2009. 

See response to comment 7k above. 

The claims made in the leaflet authored by Gibson, Kegley and 

Bentz (2009) are outside the scope of the Briggs Spring project. 

7m We support removing clearly hazardous trees in high traffic, high use Trees that pose a safety hazard would be removed. Appendix B 
Briggs Spring Environmental Assessment Appendix H

 H-33

 

areas. Any proposed action to remove trees from riparian areas must be 

considered in terms of cost/benefit to the affected area—soil, water, 

aquatic life, wildlife and any potential introduction of invasive nonnative plant species.

of the EA contains design criteria to protect wetlands and 

riparian areas. 

7n Environmental consequences of both action alternative are states as 

follows. “Indirect effects would be the increased potential for noxious 

weed infestations in disturbed areas. This can be detrimental to state 

listed and SOLC plant species, as noxious weeds and invasive species 

have the ability to out-compete desired native plant species. The 

herbicides used in noxious weed control can also be detrimental to 

these species if the individuals are inadvertently exposed to the 

herbicides.” (DEA Chapter 3, pgs 93- 94). We restate here that 

herbicides can have adverse effects on aquatic life and amphibians.

The Briggs Spring EA recognizes the potential risk of using 

herbicides, EA pages 93-94, 98. The analysis concluded there 

would not be adverse cumulative impacts to any state listed, 

SOLC, R2 sensitive species or their habitat (EA page 99). Page 

71-72 of the EA also recognizes the potential effects of noxious 

weed treatment to the northern leopard frog. 

7o “Salvage can retrieve timber that would otherwise be lost, and if 

infested trees are removed and disposed of before beetles emerge, 

some reduction in beetle populations will be realized. However, 

salvage logging of infested trees, while a large outbreak is underway, 

is generally not effective for reducing subsequent levels of mountain 

pine beetle-caused tree mortality.”

We agree with the preceding comments in bold. Please explain then 

why thinning elsewhere in the DEA is stated and presumed to “improve 

the health of the forest.” The statement, “Salvage can retrieve timber 

that would otherwise be lost” appears to presume the idea that “No 

Tree be left behind” is without question or controversy. We ask the 

Service to consider that the Multiple Use sustained Yield Act 

(MUSYA) does not require that every tree in a MA 5.1 be cut and sent 

to market. Trees germinate from a seed and eventually die. The 

completion of this cycle is essential to the ever-changing ecology of 

any given forest. The presumption that a tree “is lost” if it is not 

harvested reveals the Service’s myopic vision, an abnormal vision we 

believe is the result of decades of catering to the timber industry to the 

near exclusion of other forest uses and benefits.

The italicized text is from Gibson, Kegley, and Bentz, 2009. 

See response to comments 7k and 7l. 

The claims made in the leaflet authored by Gibson, Kegley and 

Bentz (2009) are outside the scope of the Briggs Spring project.

The Briggs Spring project does not propose any salvage 

logging. The project does not propose that “every tree in MA 

5.1 be cut and sent to market”. 

7p “Additionally, beetle-infested trees and resultant snags and woody 

debris are important for many species of wildlife, nutrient recycling 

and tree regeneration.”

Again, we agree with the preceding comments in bold. And again, 

please explain why thinning elsewhere in the DEA is stated and 

The italicized text is from Gibson, Kegley, and Bentz, 2009.

The claims made in the leaflet authored by Gibson, Kegley and 

Bentz (2009) are outside the scope of the Briggs Spring project.
Briggs Spring Environmental Assessment Appendix H

H-34

presumed to necessary to “improve the health of the forest.”

7q

“Silvicultural strategies to reduce stand susceptibility to mountain 

pine beetle outbreaks in host species other than lodgepole and 

ponderosa pines have not been developed.”

We agree. We fully agree that the Forest Service has developed 

“strategies to reduce stand susceptibility to mountain pine beetle 

outbreaks in... [] lodgepole and ponderosa pines” but those strategies 

are subject to great controversy among independent scientists. More

compelling is the fact that both the U.S. Forest Service and the 

Canadian Ministry of Forests have been implementing the strategies to 

which the DEA refers with virtually no success. In the Medicine BowRoutt National Forest alone nearly 2 million acres of lodgepole pine or 

65% to 95% of all lodgepole pine have been killed by the mountain 

pine beetle. Similar statistics are common in lodgepole and ponderosa 

stands from British Columbia in Canada to New Mexico. No 

reasonable person would conclude that even the most frequently 

implemented and effective efforts (strategies) to combat the mountain 

pine beetle have been successful to any significant degree. This current 

beetle outbreak has been eloquently referred as a slow moving 

hurricane by University of Wyoming communication and journalism 

student Joshua King, a recipient of the Larsh Bristol Memorial Award 

in Journalism for 2009. King documented the spread of the Mountain 

Pine Beetle throughout southeastern and south– central Wyoming. He 

collected photographs, audio interviews, and correlating GPS data.

His photography exhibit, A Slow Hurricane, was featured in the 

Wyoming Union this past Fall. University Libraries has received more 

than 2,250 digital images, audio interviews, and corresponding GPS 

data from King’s research.

Slow or not, the beetle “hurricane” has not been deterred by any of the 

strategies implemented by the U.S. Forest Service. That the Black Hill 

NF is suggesting it can implement those same strategies and get a 

different result is again, preposterous if not somewhat insane.

The italicized text is from Gibson, Kegley, and Bentz, 2009.

The claims made in the leaflet authored by Gibson, Kegley and 

Bentz (2009) are outside the scope of the Briggs Spring project.

An online search for Joshua King’s document was done, it was 

not located. 

The Forest Service admits that it cannot definitely predict the 

outcome of the current beetle infestation. However, it is known 

through local research and expertise that on the Black Hills 

National Forest, reducing stand density has been shown to 

reduce the susceptibility of stands to mountain pine beetle 

caused mortality. See: 

Allen, K. 2003. Evaluation of MPB activity on the Black Hills 

National Forest. Forest Health Evaluation R2-04-02. Rapid 
Briggs Spring Environmental Assessment Appendix H

 H-35

 

City Service Center, Rapid City, SD. 

Schaupp, Willis C. Jr. 2011. Aerial overview detection survey in 

2010, Black Hills of South Dakota and Wyoming, Service Trip 

Report RCSC-03-11. 6p. February 02, 2011. 

7r Prescribed fire is an additional option for altering stand density to 

reduce overall susceptibility to mountain pine beetle attacks. 

However, sublethal heating of critical plant tissue during prescribed 

burns can stress residual trees, which then may become more 

susceptible to bark beetle attack.

The second (bold text) part of the first sentence above, “to reduce 

overall susceptibility to mountain pine beetle attacks” has absolutely 

no basis in science. This phrase is simply an unsupported Forest 

Service claim based on other unsupported Forest Service claims. The 

second sentence is certainly documented in science. Why, then, is 

Service proposing actions that are based on mere claims rather than 

properly accounting for the known science, which almost invariably 

suggests that the chance of doing harm to perfectly healthy trees is at 

least as great as doing good, creating a “zero sum” situation at best.

The italicized text is from Gibson, Kegley, and Bentz, 2009.

The claims made in the leaflet authored by Gibson, Kegley and 

Bentz (2009) are outside the scope of the Briggs Spring project.

Refer to response to comment 7a on best available science. 

7s Care should be taken to reduce fire-caused injury to desirable trees, 

especially in thin-barked species.

Both lodgepole and ponderosa ARE thin-barked tree species.

The italicized text is from Gibson, Kegley, and Bentz, 2009.

The claims made in the leaflet authored by Gibson, Kegley and 

Bentz (2009) are outside the scope of the Briggs Spring project.

There is no lodgepole pine in the Briggs Spring project area. 

According to the Colorado State Forest Service website, 

http://csfs.colostate.edu/pages/major-tree-species.html , 

lodgepole pine bark is described as “thin with many scales” and 

ponderosa pine bark is described as “nearly 3 inches thick”. 

7t Thinning lodgepole and/or ponderosa stands will not significantly 

reduce the mountain pine beetle outbreak and but would assuredly 

increase airflow making the thinned stands, if subjected to prescribed or 

wild fire, vulnerable to greater winds and flame accelerating oxygen. 

The bark of the remaining trees (those that survived the logging 

operation) would be at greater risk to “firecaused” injury.

A naturally thin (sparsely populated) or mechanically thinned forest is 

an oxygen rich forest—not in the sense of tree-produced oxygen but in 

The Briggs Spring project does not propose thinning lodgepole 

pine. The Briggs Spring project proposed vegetation treatments 

in order to reduce the risk of MPB infestation and to reduce the 

risk of large-scale, high intensity fires. 

The environmental effects of all alternatives are disclosed in 

Chapter 3 of the EA. 

Refer to response to comment 7a on best available science. 
Briggs Spring Environmental Assessment Appendix H

H-36

the fact that more oxygen-rich ambient air circulates among the trees. 

This added oxygen fuels (more than carbon-rich woody matter ever 

could) the spread of flames, i.e., fire. Exacerbating the spread and 

intensity of fire in a thinned forest is the fact that a thinned forest is 

much more susceptible to windy conditions that a naturally dense 

forest. Wind supplies oxygen at a ratio of 21% to 0.04% carbon dioxide 

(composition of ambient air). Thinned forests, in fact invite the potent 

fuel accelerant, oxygen, to fuel wildfire. In dense forests, while 

comprised of more woody “fuel” than the same forest that has been 

thinned, wind is minimized and the supply of oxygen is minimized (as 

opposed to maximized). Simultaneously the dense, wind resistant forest 

serves to harbor CO2 (a potent flame retardant). When carbon rich 

wood burns it released highly concentrated volumes of CO2. The 

released CO2 is most potent when harbored, as when deep layers of 

deadfall are present to still oxygen-rich air (especially near the ground) 

and to hold the CO2 in place rather than to allow it to dissipate in the 

wind and rise to a level above the canopy where it is no longer effective 

as a flame retardant. These facts are basic but they have been lost in the 

rise of wildfire technology where how to fight wildfire is the focus of 

inquiry rather than the basic scientific whys of wildfire.

I suggest the Black Hills National Forest organize an event where a 

trained firefighter throws a highly flammable blanket (fuel at its best) 

over a grass fire and it will be demonstrated, on a very simple level, 

every scientific fact presented above. The amount of fuel in the

presence of fire is one of the least concerns IF one understands the true 

determinants of the spread and intensity of fire.

Environmental conditions surrounding a given flame producing event 

are the true determinants of the characteristics of that event whether the 

event be the striking of a match or an ongoing raging wildfire. The 

simple measure of fuel is a truly secondary, tertiary or lesser concern. 

We ask then, “Why for so long has ‘fuel’ or ‘fuel load’ been the Forest 

Service’s tired old “soundbite” in its public discourse?” We suspect it is 

because removing trees “to save the forest from wildfire” win public 

approval which often translates into commercial logging projects. It’s 

just a hunch on our part.

The Forest Service has never, in my experience, discussed these 

Organizing such an event is outside the scope of the Briggs 

Spring project. 

Please refer to the “Fire and Fuels” section of Chapter 3 of the 

EA, for information on fire hazard and fire risk. 
Briggs Spring Environmental Assessment Appendix H

 H-37

 

scientific facts among its own personnel, much less before the general 

public. It is time wildfire issues including the scientifically baseless 

claims that thinning and other so-called wildfire prevention be 

addressed scientifically. The Black Hills National Forest management 

could earn the distinction of being the first national forest unit to enter 

into a 21st century understanding of the actual, not the merely

perceived, physics of fire. To do so would not eliminate the need to 

maintain fire protection measures and personnel. To do so would 

merely mean cessation of meaningless, yet very expensive and human 

life costing, exercises.

7u Comments on Purpose and Need for Action (DEA Purpose and Need 

for Action - Ch. 1, p. 4)

The NEPA requires the Service to produce a Purpose and Need for the 

Action(s) being proposed for any proposed project triggering the 

application of NEPA. This requirement comes with expectation far 

beyond the mere statement of Purpose and Need.

The purpose and need section in an EIS must clearly, and in plain 

language, explain why the proposed action, with its inherent costs and 

environmental impacts, is being pursued. If properly described, the 

Purpose and Need Statement also identifies the need for several 

alternatives and discusses the Service’s rationale for limiting the range 

of alternatives which may be considered reasonable, prudent, and 

practicable in compliance with the CEQ regulations, Section 4(f) the

Executive Orders on Wetlands and Floodplains, and the Section 

404(b)(1) guidelines. Further, it demonstrates the problems that will 

result if the project is not implemented. Implied is a reasonable 

consideration of the odds or probability that a given action(s) will be 

effective and how long the benefits, if any, of the proposed actions will 

endure.

The purpose and need section of an EIS should:

- justify why proposed action(s) must be implemented;

- be as comprehensive and specific as possible; and,

- be re-examined and updated as appropriate throughout the project 

development process.

Answering the following questions may assist in the evaluation of the 

need for the proposed action.

Sec. 1502.13 Purpose & Need 

“The statement shall briefly specify the underlying purpose and 

need to which the agency is responding in proposing the 

alternatives including the proposed action.”

The purpose and need for the Briggs Spring project is displayed 

in Chapter 1 of the EA. It does meet CEQ requirements. 
Briggs Spring Environmental Assessment Appendix H

H-38

How well is the proposed project supported, in terms of documented 

evidence of success, including similar actions taken, to date, by other 

agencies and governmental units, and how does the proposed project 

square with actions pending, existing project and program schedules, 

and etc?

System Linkage - Is the proposed project a "connecting link?" How 

does it fit in the Forest’s Schedule of Proposed Actions (SOPA)?

7v The stated “Purpose and Need” is as follows (inset in italics) and 

discussed point by point in normal text:

The purpose of this project is to maintain forest health, to manage 

ponderosa pine within this portion of MA 5.1 in order to provide for a 

sustainable supply of commercial timber, to manage fuels in order to 

reduce losses of timber and other desired forest habitat and the risk of 

large-scale, high intensity wildfire,...

While we recognize that this project may indeed produce the Service’s 

and the timber industry’s short-term goal to produce the most

marketable board feet in the least amount of time, we remind the 

Service that “the optimal timber harvest cycle is not coincident with the

optimal forest ecological cycle... not even close.” We assert that the 

Service’s disproportionate emphasis on timber harvest is harmful to the 

long-term health of the impacted area. The science of evolutionary 

biology has demonstrated time and time again and across a variety of 

plant and animal taxa that normal environmental pressures serve to

produce stronger, not weaker, individuals and populations of living 

organisms.

For example, over time trees that have survived unfavorable 

environmental conditions such as drought, disease, wildfire, insect 

infestations and any number of adverse conditions produce seeds or 

otherwise pass on genetic characteristics that generate stronger 

individuals. Coddling forests may indeed minimize immediate 

environmental stresses resulting in the “appearance” of improved 

health. Commercial tree farm operations over the past decades have 

indeed produced marketable timber at blinding speed but the grain and 

The quoted text provided in this comment is only a portion of 

the purpose and need as stated in Chapter 1 of the EA. 

Your disagreement with the purpose and need for action is 

noted. Scoping document sent out to the public, including 

Biodiversity Conservation Alliance, on October 14, 2011, 

included this same purpose and need for action. Scoping 

comments received from Biodiversity Conservation Alliance on 

November 11, 2011 did not mention any disagreement with the 

purpose and need for action.

Refer to response to comment 7a on best available science. 
Briggs Spring Environmental Assessment Appendix H

 H-39

 

overall quality of the resultant wood product is diminishing (common 

knowledge among older woodworkers and carpenters). In the simplest 

of terms, we inform the Service that coddling the Black Hills National 

forest is a recipe for long-term disaster. The wide array of feel good 

sounding names given to logging projects such as vegetation

treatments, stand replacement, “ecological restoration” and so on do 

nothing to improve forest health in a biological sense.

The fact that the manicured portions of the Black Hills National Forest 

are pleasing to the human eye is not scientific proof that the forest is 

healthy. Naturally healthy forests necessarily are comprised of deadfall, 

dead standing trees, insect infestations, windfall, various intensity 

wildfire events, disease and so on. These components often are not

pleasing to the human eye nor do they serve specifically human 

interests. However these components serve well the evolutionary 

processes that gave us our forests, wildlife, and the natural

benefits of water purification, carbon sink, oxygen production, 

temperature moderation, and so on.

We seriously encourage the Service to widen the aperture of its

myopic, anthropocentric view of “forest health.”

...and to provide a developed recreation campground facility which is 

designed for OHV recreational use, including large trailers, in support 

of the recently designated Travel Management OHV trail system within 

the Briggs Spring project area.

The above component of the Purpose and Need Statement certainly 

represents a purely anthropogenic focus toward forest management. No 

forest health benefits result from old or new motorized vehicle 

recreation. Roads and motorized trails serve to introduce and spread 

nonnative, aggressive invasive plant and animal species, such as leafy 

spurge (Euphorbia esula L.) and Canada thistle (Cirsium arvense [L.] 

Scop.). These “forest health” threatening plants are extremely difficult 

to control once introduced—typically by humans.4,5

4 Butler, Jack L.; Wacker, Stefanie D. 2010. Lack of native vegetation 

recovery following biological control of leafy spurge. Rangeland 

Ecology and Management. 63(5): 553-563.

The Forest Service does not claim that motorized recreation 

results in forest health benefits. 

The two provided references were reviewed and no new 

information is provided. 
Briggs Spring Environmental Assessment Appendix H

H-40

5 Wacker, Stefanie D.; Butler, Jack L. 2006. Potential impact of two 

Aphthona spp. on a native, nontarget Euphorbia species. Rangeland 

Ecology and Management. 59: 468-474.

7w This action is needed because: the current mountain pine beetle 

outbreak in forest stands within and near the Briggs Spring project 

area indicates there is opportunity to reduce potential mountain pine 

beetle caused mortality by thinning dense timber stands (Forest Plan, 

Goal 10 and Objective 10-07);

The current mountain pine beetle (MPB) outbreak may indeed, in an 

absolute sense, present an opportunity to “to reduce potential mountain 

pine beetle caused mortality by thinning dense timber stands.” We 

concede that trees cut and removed from the forest, if counted as trees 

saved, compute to reflect an absolute reduction in the beetle outbreak. 

However, in a rationale sense (here on planet earth), that idea is

preposterous. Not one tree of any kind has ever been saved by the 

cutting of it down to a stump. Because the MPB produces so many eggs 

and larva merely removing older trees from the forest has little to no 

significant role in the reduction of beetle offspring produced. In fact, 

removing a significant number of older, larger diameter trees in

counterproductive in that more emerging beetles per tree are forced to 

bore into smaller trees that may have otherwise been capable of

pitching (ejecting) a smaller number of beetles per tree. We find it 

troubling that Service fails to consider bodies of science that do not 

support its case for commercial logging. The bold text above is another 

example that suggests the Service believes it can reduce mountain pine 

beetle mortality simply because it says it can. Show us the science—

and by science we mean science generated via independent research 

and science that is not isolated science which conflicts with the

universal body of beetle-kill science.

The Briggs Spring project is using thinning treatments to reduce 

the risk of MPB susceptibility to the remaining stands of trees. 

Refer to response to comment 7a on best available science.

Refer to response to comment 7q on reducing mountain pine 

beetle susceptibility. 

7x ... there is opportunity to contribute to the Forest-wide objective 

(Forest Plan, Goal 3 and Objective 303) through timber harvest 

throughout the project area; there is opportunity to reduce fire hazard 

through fuels treatments (Forest Plan, Goal 10 and Objective 10-01 & 

10-04); and in light of the recently closed Moon Campground, which

is adjacent to the project area, the opportunity exists to create a 

recreation campground in support of the newly developed OHV trail 

system (Forest Plan, Goal 4 and Objective 420b).
Briggs Spring Environmental Assessment Appendix H

 H-41

 

We believe Forest Plan, Goal 3, Objective 303 must be reviewed and 

adjusted to reflect the current AND projected beetle-kill at least 

through the reasonably predictable term of the current Plan. Again, the 

Service is under no mandate to meet an ASQ for the sake of meeting

some arbitrary figure. When the free-market for lumber and wood 

products, in general, is at what may be an all-time low the Service must 

not simply give away our national forests to the highest bidding, 

taxpayer subsidized, timber extractor.

The revision and adjustment to Forest Plan Goal 3, Objective 

303 is outside the scope of this project. 

7y This action responds to the goals and objectives outlined in the Forest 

Plan and helps move the project area toward desired conditions

described in that plan.

Again, we remind the Service that best available science (independent 

science) fails to support the claim that thinning “treatments” reduce tree 

mortality. Black, Kulakowski, and DellaSala. 2010 concluded, “best 

available science indicates that such [thinning] treatments are not likely 

to reduce forest susceptibility to outbreaks or reduce the risk of fires, 

especially the risk of fires to communities.6

6 Black, S. H., D. Kulakowski, B.R. Noon, and D. DellaSala. 2010. 

Insects and Roadless Forests: A Scientific Review of Causes, 

Consequences and Management Alternatives. National Center for 

Conservation Science & Policy, Ashland OR.

In fact thinning exposes stands to more wind and therefore a greater 

potential for windfall which damages trees making them more

susceptible to insect infestations and disease.

The Purpose and Need Statement for this project is based on 

unsubstantiated Forest Service claims, claims that are refuted by the 

history of the beetle-outbreak itself and all the best efforts made by 

both the US Forest Service and the Canadian Ministry of Forests.

Refer to response to comment 7a on best available science. 

Refer to response to comment 7q on reducing mountain pine 

beetle susceptibility. 

The included reference was reviewed and does not provide any 

new information. 

7z Comments on Proposed Action (DEA Proposed Action Ch. 1, p. 4)

According the DEA,

“there are 24,548 acres of National Forest land and 4,368 acres of 

private owned land, totaling 28,916 acres included within the project 

area. This action is needed, because

♦ the current condition of forested stands does not meet Forest-wide 
Briggs Spring Environmental Assessment Appendix H

H-42

objectives for this management area;

♦ there is existing mountain pine beetle outbreak near the Briggs 

Spring project area and there is opportunity to reduce potential 

mountain pine beetle caused mortality by sanitation and thinning;

♦ there is an opportunity to reduce fire hazard through fuels 

treatments;

♦ and in support of the recently decided Black Hills Travel 

Management Plan there is opportunity to develop a new off highway 

vehicle (OHV) campground.”

Even though four reasons are given for the Proposed Action only two 

action alternatives are presented in the DEA. In the simplest analysis of 

the Proposed Action at least 16 alternatives could be, at least,

considered by the Forest Service. Has the Forest Service considered 16

alternatives? If yes, what were those alternatives? A No Action 

alternative is merely a default alternative. The Service has offered the 

public a minimum number of options from which to select actions. 

Given the large scope of the proposed project, two alternatives fails to 

satisfy the ‘hard look’ requirement established in the National 

Environmental Policy Act (NEPA) and fails to present the public an 

adequate array of management actions to evaluate.

See response to comment 7a on number of alternatives. 

7aa We have commented many times on other BHNF proposed projects 

numerous concerns over the significant adverse effects of excessive 

timber harvest, thinning (commercial and noncommercial) and 

associated activities (e.g. extensive road construction). For the purposes 

of these comments, we incorporate by reference all previous

submissions listed in the footnote below. 7

7 See e.g., Biodiversity Associates et al. Appeal of 1997 BHNF Revised 

Land and Resource Management Plan, Biodiversity Associates et al. 

Peak Project Appeal, Biodiversity Associates’ et al. comments on the 

Phase I Amendment to the BHNF Revised Land and Resource

Management Plan (“Phase I Amendment”), Biodiversity Associates’ et 

al. Appeal of the Phase I Amendment, and Biodiversity Associates’ et 

al. scoping comments for, and appeal of, the Phase II Amendment to 

the BHNF Revised Land and Resource Management Plan, Biodiversity

Conservation Alliance Scoping Comments West Rim Project, October 

10, 2007. For the purposes of these comments, we incorporate by 

reference these previous submissions and request all concerns,

Cumulative effects have been considered. Refer to Chapter 3 of 

the EA. 

Forest Plan direction is outside the scope of this project. The 

Briggs Spring project is consistent with the Forest Plan. 

Previous submissions to other projects are outside the scope of 

the Briggs Spring EA. 
Briggs Spring Environmental Assessment Appendix H

 H-43

 

questions, comments, and requests within these documents be fully 

considered in any and all environmental analysis completed for the

Briggs Spring project.

While we have many concerns over the BS project, we are convinced 

that the proposed so-called vegetation treatments do nothing nature

itself has not done for millennia to benefit biodiversity on the BHNF. 

The proposed project, instead, perpetuates and exacerbates humancaused ecological problems plaguing this unique ecosystem.

7bb Riparian areas (streamside habitat) and wetlands are particularly 

sensitive areas and are often home to many sensitive and dwindling 

native plant and animal species. This project does not address old 

growth shortages, fragmentation of late successional and dense mature 

forest habitat. The BS project will also exacerbate declines in habitat 

and populations of species dependent upon late successional and/or 

dense mature forest habitat. Several plant and animal species are

extremely sensitive to the impacts of logging and thinning on the 

BHNF. Therefore, we, again, request the Forest Service (“FS”) not log, 

thin, or implement any other vegetation management and instead focus 

on road decommissioning and closures to address the adverse impacts

associated with unreasonably high road densities, poorly designed 

stream crossings, erosion, and other ecological problems associated 

with roads.

The Briggs Spring EA contains design criteria to protect 

riparian areas and wetlands, see Appendix B. 

Clarification to the discussion of late succession has been added 

to the “Forest Vegetation” section of Chapter 3 of the EA. 

The EA includes effects to wildlife and plant species of project 

activities. See the “Wildlife” section, pages 37-76, and the 

“Botany, Rangeland, and Noxious Weeds” section, pages 89-99, 

of the EA. 

The Briggs Spring project is consistent with Forest Plan 

direction for plant and animal habitats. 

Refer to response to comment 6n on reducing roads.

The No Action alternative was analyzed in detail and would 

forego any vegetation management activities. 

7cc USDA Forest Service published a document titled, Threatened and 

Endangered & Sensitive Species Program” to explain the Service’s 

position.

“There are several factors that can lead to endangerment and 

extinction of species. The single-most important one--and the one the 

Forest Service has the greatest influence over--is the alteration and 

loss of habitats.”

We agree.

It is unclear what document is being referred to here. The 

italicized quoted text seems to be from the Regional Forester’s 

Sensitive Species List for Region 1. The Black Hills National 

Forest is in Region 2. 

7dd The Forest Service proposes to implement vegetation treatments with 

both commercial and non-commercial activities. Commercial

treatments include commercial thinning, group shelterwood, overstory 

The italicized text are a short description of the proposed action 

provided on page 4 of the EA. 
Briggs Spring Environmental Assessment Appendix H

H-44

removal, shelterwood seedcut, hardwood release or conversion, pine 

encroachment, and sanitation treatments. Commercial treatments 

would occur on approximately 12,224 acres with the potential to treat 

an additional 6,063 acres through sanitation treatment, if needed. Noncommercial treatments include hardwood release, pine encroachment, 

products other than logs (POL) thinning, deadfall, mechanical fuels 

treatments, and prescribed burning. Non-commercial treatments would

occur on approximately 22,305 acres, including 6,295 acres of 

prescribed burning. Some commercial and non-commercial treatments 

overlap each other within the same sites. A recreation campground 

facility (New Moon Campground) which is designed for OHV

recreational use, including both day use and overnight camping would 

be developed along the east boundary, within sites 040704-23 and 25, 

northeast of the junction of roads FSR 296.3A and FSR 296.2.

Only in the human mind is there a meaningful difference in noncommercial and commercial treatments which include commercial

thinning, group shelterwood, overstory removal, shelterwood seedcut, 

hardwood release or conversion, pine encroachment, and sanitation

treatments. 

In terms of habitat alternation and disturbance the latter most impacts 

the natural flow of wildlife behavior including reproduction, foraging, 

hunting, gathering, parturition, denning, nesting, burrowing and so on. 

Only when any of the above “treatments” includes clearcutting is the 

human distinction among treatments a distinction with a significant 

difference in the life of wildlife. Certainly overstory removal impacts 

different species in different ways but the point is that each of the socalled treatments listed above impacts to varying degree and in 

different ways every living organism in and even adjacent to the 

“treatment” area.

The project is area huge and the treatment areas are unusually large. 

Commercial treatments would occur on approximately 12,224 acres 

with the potential to treat an additional 6,063 acres through sanitation 

treatment, if needed (DEA Ch. 1, p.4). Additionally non-commercial

treatments would include hardwood release, pine encroachment, 

products other than logs (POL) thinning, deadfall, mechanical fuels 

treatments, and prescribed burning. Non-commercial treatments would 

occur on approximately 22,305 acres, including 6,295 acres of 

It is unclear what “the latter” is referring to, sanitation? 

The Briggs Spring project does not include “clearcutting”. The 

EA has analyzed the impacts and effects of the alternatives on 

wildlife as presented in Chapter 3 of the EA. 
Briggs Spring Environmental Assessment Appendix H

 H-45

 

prescribed burning. Some commercial and non-commercial treatments 

overlap each other within the same sites (DEA Ch 1, p4).

We strongly oppose the Proposed Action due to the Service’s

complete failure to cite independent science that supports its claims 

that these so-called treatments will result in improved forest health. 

Not one scientific reference is provided that points to research

offering data and conclusions that would support the specific 

effectiveness of any of the proposed treatments in preventing the 

spread and subsequent impacts of the mountain pine beetle.

Not one study cited in the DEA was conducted to test the

effectiveness of any of the “treatments” the Service claims, in the 

DEA, will reduce the spread or impact of the beetle outbreak... not 

one study.

In contrast, the DEA and the references cited offer many warnings 

of the negative impacts of each of treatments proposed including 

those negative impacts associated with prescribed burning of the 

forest understory. The Service appears arbitrarily and, in some 

cases, capriciously to exercise discretion to favor its own empty 

claims over the tried and true body of science that presents

warnings about the potential or probably negative impacts of its 

proposed treatments.

Your opposition to the proposed action is noted. 

Refer to response to comment 7a on best available science. 

Refer to response to comment 7q on mountain pine beetle 

susceptibility. 

7ee Comments on the Decision Framework (DEA Decision Framework 

Ch. 1, p. 5)

Given the purpose and need, the deciding official reviews the proposed 

action, the issues identified during scoping, the other alternatives, and 

the environmental consequences of implementing each alternative in 

order to make the following decisions:

(1) whether or not the information in this analysis is sufficient to make 

an informed decision;

(2) whether or not vegetation and fuels treatments should be

implemented and, if so, in what manner and in which locations;

(3) whether or not an OHV recreation campground should be

implemented and, if so, in what manner and in which locations.

Regarding Decision Framework component (1):

The decision framework has been edited in the EA. 

The Hell Canyon District Ranger is the project decision maker 

and is therefore, responsible for making the final project 

decision. 

Refer to response to comment 7a on best available science. 
Briggs Spring Environmental Assessment Appendix H

H-46

The Service could not possibly claim it possesses enough “best

available science” regarding whether or not the information in this 

analysis is sufficient to make an informed decision. The Service cited 

absolutely NO scientific information to support component (1) of the 

Decision Framework.

Regarding Decision Framework component (2):

We must assume component (2) is predicated upon component (1)

being satisfied. Component (1), as stated has not been satisfied.

Regarding Decision Framework component (3)

Again, we must assume component (3) is predicated upon component 

(1) being satisfied. Component (1), as stated has not been satisfied.

7ff Comments on Public Involvement (DEA Public Involvement Ch. 1, p 

5)

No comment at this time.

Noted.

7gg Comments on Issues (DEA Issues Ch.1, pg 5)

The Service states:

Comments received during the scoping process raised various issues in 

relation to management activities in the Briggs Spring project area. 

From these comments and other sources, the project interdisciplinary 

team identified two key issues that drove the development of the 

alternatives. A brief description of the issues follows.

The Forest Service identified two topics raised during scoping. These 

issues include:

Issue #1: Effects of Developing a New OHV Campground – Some 

commenters noted that the proposed action would result in two 

campgrounds located within close proximity of each other. It was 

suggested that expanding the existing Redbank Spring Campground

should be considered to meet the anticipated needs of OHV users,

rather than creating a new campground. Measures: Number of OHV 

recreational campgrounds and size. Number of acres of ground 

disturbance.

Issue #2: Susceptibility to Mountain Pine Beetle – Some commenters 

were concerned that the proposed action would not sufficiently reduce 
Briggs Spring Environmental Assessment Appendix H

 H-47

 

the potential for mountain pine beetle caused mortality throughout the 

area. Further sanitation and thinning was suggested. Measures: Acres 

of sanitation and thinning and level of insect risk rating area. Further 

sanitation and thinning was suggested. Measures: Acres of sanitation 

and thinning and level of insect risk rating.

The above discussion of the “Issues” raised during Scoping does not 

even mention that some commenters suggested that the project area is 

already too heavily roaded and that there is already motorized 

recreation overuse and that the beetle-kill condition of the Forest 

represents an opportunity to reduce (not increase) motorized recreation 

in the project area. No law exists that requires the Forest Service to 

meet motorized or any other recreation need if it can be met

elsewhere—on other National Forests or any other state or private 

lands. The Multiple Use Sustained Yield Act (MUSYA) is clear on this 

matter.8

One requirements of the Service is to provide for natural diversity. In 

36 CFR 219.27(g) it is required that "Management prescriptions, where 

appropriate and to the extent practicable, shall preserve and enhance the 

diversity of plant and animal communities, including endemic and

desirable naturalized plant and animal species, so that it is at least as 

great as that which would be expected in a natural forest and the 

diversity of tree species similar to that existing in the planning area. 

Reductions in diversity of plant and animal communities and tree 

species from that which would be expected in a natural forest, or from 

that similar to the existing diversity in the planning area, may be 

prescribed only where needed to meet overall multiple-use objectives...

A related regulation is found at 219.26, which requires that, "Forest 

planning shall provide for diversity of plant and animal communities 

and tree species consistent with the overall multipleuse objectives of 

the planning area. Such diversity shall be considered throughout the 

planning process. Inventories shall include quantitative data making 

possible the evaluation of diversity in terms of its prior and present 

condition. For each planning alternative, the interdisciplinary team

shall consider how diversity will be affected by various mixes of 

resource outputs and uses, including proposed management practices. 

(Refer to § 219.27(g).)

Refer to response to comment 7a on issues and alternatives. 

36 CFR 219.27(g) does not exist. 36 CFR 219.27 is in reference 

to “Special designations.” and includes subparts a-c. 

http://edocket.access.gpo.gov/cfr_2004/julqtr/pdf/36cfr219.27.p

df

36 CFR 219.26 Identifying and designating suitable uses.

The quoted text in the comment is not in the current version of 

36 CFR 219.26. 

http://edocket.access.gpo.gov/cfr_2004/julqtr/pdf/36cfr219.26.p

df
Briggs Spring Environmental Assessment Appendix H

H-48

For example, not every multiple use is required on every acre of

national forest. The Service must prepare a relative value analysis. That 

is, the Service must make a reasoned consideration of what uses may or 

may not be appropriate on a localized area of forest. This includes a

consideration of what can be provided by private land nationally (not 

just locally) in determining what use may be given weight to the 

exclusion of other uses on a given area.

Finally, the above discussion of the “Issues” raised during Scoping 

does not even mention that some commenters suggested that sanitation 

and thinning were essentially “ineffective” and provided scientific 

references to support this suggestion. Please explain, in detail, why the

discussion of the “Issues” fails to include this fact.

8 SEC. 4. [16 U.S.C. 531] As used in this Act, the following terms shall 

have the following meanings: (a) ‘‘Multiple use’’ means: The 

management of all the various renewable surface resources of the 

national forests so that they are utilized in the combination that will 

best meet the needs of the American people; making the most judicious 

use of the land for some or all of these resources or related services

over areas large enough to provide sufficient latitude for periodic 

adjustments in use to conform to changing needs and conditions; that 

some land will be used for less than all of the resources; and

harmonious and other, without impairment of the productivity of the 

land, with consideration being given to the relative values of the

various resources, and not necessarily the combination of uses that 

will give the greatest dollar return or the greatest unit output.

(b) ‘‘Sustained yield of the several products and services’’ means the 

achievement and maintenance in perpetuity of a high level annual or 

regular periodic output of the various renewable resources of the

national forests without impairment of the productivity of the land.

This is text from the Multiple Use Sustained Yield Act. 

7hh Comments on the Comparison of Alternatives Including the 

Proposed Action (DEA Comparison of Alternatives Including the 

Proposed Action Ch. 2 pg. 7)

Comments on Alternative 2

Alternative 2 proposes 18,307 acres of commercial logging and 22,305 As stated in the EA, Tables 1 & 2, on pages 8-11, commercial 
Briggs Spring Environmental Assessment Appendix H

 H-49

 

acres of non-commercial logging for a total of 40,612 acres of logging 

in a project area of only 24,548 acres. Another 6,295 acres of

prescribed burns are proposed. Such an assault on a parcel of land is 

essentially unprecedented. This project will produce impacts somewhat 

like those produced by an inland hurricane followed by a 6,295 acre 

wildfire (assuming the prescribed burn would not burn out of control). 

Wildlife impacts, water retention profiles, ecological systems and

physical characteristics of the impacted forest are independent of the 

labels the Service assigns its logging projects. Service fails miserably in 

its responsibility to address the impacts of logging over 40,000 acres 

and burning over 6,000 acres of the 24,548 acre Briggs Spring project 

area.

Alternative 2 would produce approximately 30,127 hundred cubic feet 

(CCF) of commercial sawlog volume and approximately 8,075 CCF of 

POL as a byproduct of the mechanical treatments. In addition, 75.9 

miles of roads would be maintained, 31.9 miles would be 

reconstructed, and 0.8 miles of an existing unauthorized road would be

reconstructed and converted to a Forest system road, as part of the 

mechanical treatments proposed in this alternative. Figure 1 shows the 

entire project area, however Appendix A has more detailed maps. 

Please refer to Map 2-Tiles 1-3, Appendix A, for a detailed view of 

Alternative 2 treatment areas.

It is inconceivable that beetle-kill can somehow be mitigated stopped or 

even slowed by the actions described above. The Service’s assertion 

that 40,000+ acres of logging, road construction and more motorized 

recreation on the project will spare the project area injury (whether

beetlekill or some other form of injury) is nothing short of laughable. 

But this is not a laughing matter.

treatments and non-commercial treatments would occur on the 

same acres. The 22,305 acres of non-commercial treatments are 

not strictly logging; non-commercial treatments include pine 

encroachment, POL thinning, hardwood releases, deadfall, 

prescribed burning (acres are included in the 22,305) and 

mechanical fuels treatments (EA pages 10-11). 

Prescribed burns would not have the same effects as a wildfire. 

Prescribed burns are controlled, low intensity fires. The effects 

of prescribed fire can be controlled in location and intensity; 

whereas a wildfire is not controlled therefore its effects are not 

controlled. 

The Briggs Spring project is not proposing to log over 40,000 

acres. See the EA, Tables 1 & 2, on pages 8-11. 

This project does not propose to stop ‘beetle-kill’. 

Again, Alternative 2 does not propose logging over 40,000 

acres, it does not propose any new road construction, and it is 

not proposing new motorized recreation. 

Refer to response to comment 7q on mountain pine beetle 

susceptibility. 

7ii Comments on Alternative 3

Alternative 3 proposes 23,400 acres of commercial logging and 23,452 

acres of non-commercial logging for a total of 46,852 acres of logging 

in a project area of only 24,548 acres. Another 6,295 acres of

prescribed burns are proposed. Such an assault on a parcel of land is 

essentially unprecedented. This project will produce impacts somewhat 

As stated in the EA, Tables 3 & 4, on pages 13-15, commercial 

treatments and non-commercial treatments would occur on the 

same acres. The 23,452 acres of non-commercial treatments are 

not strictly logging; non-commercial treatments include pine 

encroachment, POL thinning, hardwood releases, deadfall, 
Briggs Spring Environmental Assessment Appendix H

H-50

like those produced by an inland hurricane followed by a 7,009 acre 

wildfire (assuming the prescribed burn would not burn out of control). 

Wildlife impacts, water retention profiles, ecological systems and 

physical characteristics of the impacted forest are independent of the 

labels the Service assigns its logging projects. Service fails miserably in 

its responsibility to address the impacts of logging over 46,000 acres 

and burning over 7,000 acres of the 24,548 acre Briggs Spring project 

area.

This alternative was developed to address the issues identified during 

scoping: 1) effects of developing a new OHV campground; 2) 

susceptibility to mountain pine beetles.

To address issue #1, Alternative 3 eliminates the development of a new 

OHV campground and proposes to expand the existing Redbank Spring 

Campground to accommodate OHV recreationists. To address issue 

#2, Alternative 3 proposes additional group shelterwood and sanitation 

treatments in more ponderosa pine stands to further reduce MPB

susceptibility.

An expansion at the existing Redbank Spring Campground would be a 

Roaded Natural ROS Design, located within sites 040705-144 & 170 

(see Map 4-Tiles 1-2, Appendix A). The expanded OHV campground 

would include a connector trail to link the campground to the existing 

OHV trail system. The connector trail would be approximately 0.8 

miles in length and be designed for OHVs of 62” in width or less. The 

facility design features are the same as those proposed for Alternative 

2, except Alternative 3 would not include a training lot.

Vegetation treatments for Alternative 3 include both commercial (see 

Table 3) and noncommercial (see Table 4) treatments.

Alternative 3 would produce approximately 41,531 hundred cubic feet 

(CCF) of commercial sawlog volume and approximately 9,931 CCF of 

POL as a byproduct of the mechanical treatments. In addition, 77.3 

miles of roads would be maintained, 33.4 miles would be

reconstructed, and 0.8 miles of an existing unauthorized road would be

reconstructed and converted to a Forest system road as part of the 

mechanical treatments proposed in this alternative. This alternative 

prescribed burning (acres are included in the 23,452) and 

mechanical fuels treatments (EA pages 14-15). 

Prescribed burns would not have the same effects as a wildfire. 

Prescribed burns are controlled, low intensity fires. The effects 

of prescribed fire can be controlled in location and intensity; 

whereas a wildfire is not controlled therefore its effects are not 

controlled. 

The Briggs Spring project is not proposing to log over 46,000 

acres. See the EA, Tables 1 & 2, on pages 8-11.
Briggs Spring Environmental Assessment Appendix H

 H-51

 

also proposes to add approximately 0.8 miles of OHV trail to connect 

the Redbank Spring Campground to the existing OHV trail system. 

Figure 2 shows the entire project area, however Appendix A has more 

detailed maps. Please refer to Map 4-Tiles 1-3, Appendix A, for a 

detailed view of Alternative 3 treatment areas.

Because the Service did not include Alternatives that adequately 

question the ineffectiveness and negative direct, indirect and 

cumulative impacts of each treatment modality proposed in the DEA

we consider Chapter 2 to be without merit and therefore have no further 

comment except to request that the Service reconsider it responsibilities 

and either offer Alternatives to the public that provide an opportunity 

for reasonable discourse or that the Service abandon this project in its

entirety. In other words, the Service is saying to the public “take it or 

leave it” regarding its proposed huge, high impact logging project. 

Alternatives 2 and 3 are not significantly different in size, scope, and 

impact. Not one alternative is offered that considers significantly 

smaller sized “treatments” or alternatives to motorized recreation and 

road building. The Service even at this relatively early stage in the 

administrative process fails to offer the public room for negotiation.

This is perceived by many as an abuse of power. This is not how a 

democratic government is supposed to behave.

Refer to response to comment 7a on range of alternatives. 

Chapter 3 of the EA discloses the direct, indirect and cumulative 

effects of all alternatives considered in detail, including the no 

action alternative. 

7jj Comments on Affected Environment and Environmental 

Consequences (DEA Affected environment and environmental

consequences Ch 3, pg. 22)

This section summarizes the environment of the affected project area 

and the potential changes to those environments due to implementation 

of the alternatives. It also presents the scientific and analytical basis 

for comparison of alternatives presented in Chapter 2. For the 

purposes of this analysis and under federal regulations, “impacts” and 

“effects” are assumed to have the same meaning and are

interchangeable.

The Service falsely claims this Section of the DEA “presents the

scientific and analytical basis for comparison of alternatives presented 

in Chapter 2” (DEA Ch. 3 p. 22). An examination of Chapter 3 

produces no scientific and analytical basis for comparison of 

alternatives presented in Chapter 2. An further examination of the 

Refer to response to comment 7a on best available science. 

Refer to Chapter 4 for a listing of Interdisciplinary Team 

members and their qualifications. 

Resource specialist reports are available in the project file. 
Briggs Spring Environmental Assessment Appendix H

H-52

scientific references provided for the DEA substantiates that no 

scientific and analytical basis for comparison of alternatives presented 

in Chapter 3.

The information presented here is based on analysis prepared by 

resource specialists from the interdisciplinary team (IDT).

The IDT team provides no scientific and analytical basis for

comparison of alternatives presented in Chapter 3.

Analysis was accomplished by field observations and surveys, past 

experience and professional recommendations, aerial photography, 

resource modeling, literature review, information obtained through 

monitoring, Forest Plan direction and associated analysis, and public 

participation. The specialist reports are included in the project file, 

which is located at the Black Hills National Forest, Hell Canyon 

Ranger District, 330 Mount Rushmore Road, Custer, South Dakota. All 

resource specialists used the best available science in completing their 

analysis, in accordance with Forest Service Manual (FSM) 1920.

The above statement that “resource specialist used best available

science” is merely a claim and is not supported by the DEA.

7kk Past, Present, and Reasonably Foreseeable Actions

Analysis of cumulative effects include past, present, and reasonably 

foreseeable future activities that could affect the biological or social 

environments. See Appendix F for a listing of past, present, and future 

activities considered in the Briggs Spring project cumulative effects 

analysis. The project area boundary was used to address cumulative

impacts, unless otherwise noted in the resource discussions. Rationale 

for cumulative effects boundaries is noted in the cumulative effects 

discussions by resource.

The Service makes note of fact that the BS project area has no SS4A,B 

or C (Mature) or SS5 (late successional) stands of ponderosa pine occur 

in the project area. The Service merely states these facts but appear not 

to consider this a problem other than to state the Desired Condition is

5% of each structural type for a total of 10% mature to late successional 

trees. Obvious in Fig. 3 of Chapter 3 pg. 24 is that the forest has been 

It is unclear where this information is taken from. See the Draft 

EA, page 23, Table 14. Table 14 shows existing structural 

stages (SS) by cover type within the project area, which 

includes 12,725 acres of SS4A, 7,590 acres of SS4B and 0 acres 

of SS4C and 0 acres of SS5. 
Briggs Spring Environmental Assessment Appendix H

 H-53

 

managed to maintain almost 80% of the project area to accommodate 

the singular use of timer production. We contend that even in an MA 

5.1 management area that such heavy emphasis on one use, timber 

production, is not compatible with Phase II in terms of maintaining 

wildlife viability.

Given the 5.1 MA prescription and the actual (on-the-ground) age class 

distribution of ponderosa pine provided in Chapter 3, Fig. 3 of the DEA 

it is clear that the project are has been commercially and noncommercially treated in previous decades. The DEA Ch.3, pg. 35 

explains the extent of logging, including pre-commercial thinning 

occurring in the BS project area over the last decade. While the

Service, later in the DEA bemoans the “potential adverse cumulative

effects to ponderosa pine with the no action alternative” it virtually 

ignores the cumulative impacts of logging in the project area.

Much of the Briggs Spring analysis area has been harvested in the 

past. At least 19 timber sales have taken place since 1980. The effect 

of past treatments has been an increase of merchantable volume 

growth and improvement in the quality of timber. There has also been 

an improvement in the quality of timber through removal of damaged,

diseased, and poorly formed trees. Precommercial thinning has

occurred and improved stand health by removing damaged, diseased, 

and poor quality trees.

Future treatments for the area might be further thinning or

regeneration cuts. Any treatments for growth and yield purposes would 

not occur until stands became overstocked again or regeneration cuts 

were prescribed at culmination of mean annual increment or when 

more even-aged treatments were desired.

Refer to response to comment 7e on species viablility. 

Cumulative impacts concerning ponderosa pine are discussed in 

Chapter 3 of the EA. 

7ll Comments about CMAI

Culmination of Mean Annual Increment [16 U.S.C. 1604 (m)]:

Stands of trees harvested have generally reached the culmination of 

mean annual increment of growth (CMAI). Page II-26 of the Black 

Hills Forest Plan Guideline 2411. Regeneration harvests of evenaged timber stands should not be undertaken until the stands have 

generally reached (or surpassed 95% of the) culmination of the mean

annual increment measured in cubic feet.
Briggs Spring Environmental Assessment Appendix H

H-54

CMAI occurs when the periodic annual increment equals the mean 

annual increment (MAI). MAI is calculated by adding the current stand 

volume with any mortality or previous removal and then dividing by the 

stand age.

Our concern about the application of CMAI is that once an area has 

been logged the values from which subsequent CMAI are derived tend 

to be reduced. We suggest the the flawed premise of the CMAI 

explains, at least in part, why the BS project area consists of 0.0% SS4 

and SS5 ponderosa pine.

The Black Hills, including the Briggs Spring analysis area, had been in 

an on-going drought condition the last 10 years. While MPB does not 

depend on drought conditions for the insect to continuously increase 

their population, the drought aided the MPB by increasing stress in 

healthy trees thus making the trees more vulnerable to a successful

MPB attack.

We are not certain why the Service chose to discuss drought in this 

particular section of the DEA but the word-smithing exercised to 

diminish the role that drought plays in the spread of the mountain pine 

beetle is noted. Other climate related conditions such as global

warming are not mentioned here as a factor in the spread of the

mountain pine beetle. The cumulative conditions of drought and other 

climate related factors, far more than stand density, are the primary 

drivers of this current mountain pine beetle outbreak.9

To summarize our concern here, we ask the Service to explain, in

detail, why the prior rather ubiquitous thinning of the BS project area 

has not protected the area from the current beetle infestation.

The DEA states in Chapter 3 pg. 25:

Generally, stands are considered to be most susceptible to infestation if 

75% of the stand is in the 7-13 inch diameter range and the stand 

density is over 120 ft2/ac of basal area (Allen, 2003).

Yet throughout the remainder of the DEA the Service proposes to 

reduce to 50ft2 to 60ft2/acre. In no instance does the Service disclose 

The CMAI requirement is not discretionary. 

See response to 7kk pertaining to SS4 within the project area. 

Refer to silvicultural finding in Appendix E of the EA. 

The quoted text (in italics) is from the cumulative effects to 

ponderosa pine section of the Forest Vegetation section of the 

Draft EA (page 35). The drought conditions are discussed as a 

past event and included in consideration of cumulative effects 

for ponderosa pine. 

 

Refer to response to comment 7g on climate change. 

Reducing stand densities will reduce susceptibility to mountain 

pine beetle. However, forest stands are not static and therefore 

will grow and increase in density over time. 

The quoted text is correct. These particular stand conditions are 

most susceptible to infestation. Stands with these conditions 

would be considered to have the highest risk of beetle 

infestation. However, any dense, mature stand is at risk for 

beetle caused mortality. The project proposes to reduce stand 

densities to 50-60 ft2

/acre which results in a reduction of stand 

susceptibility to mountain pine beetle. Allen, 2003, states, “In 
Briggs Spring Environmental Assessment Appendix H

 H-55

 

whether or not 75% of the trees in the stands subject to be logged are 7-

13 inches in diameter or if the stand density is over 120 ft2/acre of 

basal area.

It is interesting to note that in Chapter 3 pg. 35 & 36 the DEA states:

Ponderosa pine trees with an average DBH of 7 inches or greater and 

basal areas over 80ft2/ac leave the stands susceptible to MPB

infestation.

Note: In this instance (for the statement above) no scientific citation is 

given and no explanation is offered for the Service’s decision to reduce 

stand density to, in some instances, less than twice the stand density 

stated by the Service itself as the density at which ponderosa stands are 

most susceptible.

9 Kenneth F. Raffa, Brian H. Aukema, Barbara J. Bentz, Allan L. 

Carroll, Jeffrey A. Hicke, Monica G. Turner, and William H. Romme 

.Cross-Scale Drivers Of Natural Disturbances Prone To Anthropogenic

Amplification: The Dynamics Of Bark Beetle Eruptions Bioscience • 

June 2008 / Vol. 58 No. 6

the Black Hills, stands that are less than 80ft2 of basal area per 

acre with average stand diameters below 7 inches are at the 

lowest risk. In areas where there are ongoing beetle outbreaks, 

lowering stand densities even further, such as to 40ft2 of basal 

area per acre would be advised.” In the Briggs Spring project 

area, outbreak conditions are not occurring at this time. The 

thinning of these stands would reduce the potential for an 

outbreak to occur. Page 19 of the EA defines structural stages, 

which includes general diameter sizes and canopy cover. 

The reference used as the footnote, Raffa et al., 2008, was 

reviewed and provides no new information.

7mm Overall, 35% of the analysis area is at high risk for MPB and 60% is at 

medium risk. Most of these stands would have been harvested before 

the MPB epidemic, leaving stands at a higher density than considered 

today.

Please explain the statement above (DEA Ch. 3, pg. 35 & 36).

The current epidemic has not shown signs of slowing down but 

continuously increasing in numbers. In 2010 the mapped acreage

affected by MPB doubled, as compared with acres attributed to MPB 

during each of the previous three years, representing significant new 

pine mortality (Schaupp, 2011). From the mapping of the 2010 Aerial 

Overview Detection Survey, areas of MPB mortality have increased in 

the Briggs Spring analysis area.

Again, we ask the Service, “Why has not the thinning (logging) of prior 

decades been effective in protecting the BS project area from the 

current beetle infestation?” Please explain in detail.

The cumulative effects section has been edited in the EA. 

Schaupp, 2011, is a Forest-wide aerial detection survey. It was 

noted in this survey that the general area of Briggs Spring has 

increased mountain pine beetle mortality. 

Refer to response to 7ll on past treatments and beetle 

susceptibility. 
Briggs Spring Environmental Assessment Appendix H

H-56

7nn There would be potential adverse cumulative effects to ponderosa pine 

with the no action alternative. Lack of vegetation treatment within 

ponderosa pine sites would amplify the potential for beetle populations 

to increase throughout the project area. Not harvesting ponderosa pine 

stands would encourage beetle populations to rise and would

contribute to the MPB epidemic growing within the analysis area. The 

MPB population is expected to increase in numbers.

No science is presented to substantiate the circular and empty claims 

made immediately above. We request the Service to explain in detail 

the “potential adverse cumulative effects” to which it eludes in the 

paragraph above. How would these “potential adverse cumulative

effects” differ or be the same as “potential adverse cumulative effects” 

associated with the logging being proposed in both Alternatives to the 

no action alternative. Please explain this in detail.

There would be positive cumulative effects under both of the action 

alternatives. Treatment of ponderosa pine stands intended to lower 

stand density would reduce the susceptibility to MPB infestation. The 

proposed activities would result in MPB caused mortality to decrease 

with the action alternatives.

Again, the above is a mere claim, unsubstantiated by independent 

science. The claim is myopic in that cumulative effects are discussed 

only in terms of beetle impacts which have been proven to continue 

unabated regardless of previous efforts to control the beetles. More 

egregious than its myopic approach in preparing this DEA is that the 

Service has totally ignored, in this section, and skirted, throughout the 

remainder of the document, any meaningful discussion of cumulative

impacts adversely impacting wildlife viability, watershed quality, water 

retention, windfall, wildfire behavior, Threatened and Endangered 

Species, the introduction of invasive non-native plants and animals and 

a host of other important aspects of forest health.

The cumulative effects section has been edited. 

Refer to response to comment 7a on best available science. 

Refer to response to comment 7e on species viability. 

Refer to the “Soils and Waters” section of Chapter 3 of the EA 

for cumulative effects on these resources. 

Refer to the “Fire and Fuels” section of Chapter 3 of the EA for 

cumulative effects to fire hazard. 

Refer to the “Wildlife” section of Chapter 3 of the EA for 

cumulative effects to Threatened, Endangered, and Sensitive 

species. 

Refer to the “Botany, Rangeland, and Noxious Weeds” section 

of Chapter 3 of the EA for cumulative effects. 

7oo Comments on Environmental Consequences Common to All Action 

Alternatives (DEA Common to All Action Alternatives Ch. 3, p. 35)

Comments on Ponderosa Pine

Discussed earlier in our comments.
Briggs Spring Environmental Assessment Appendix H

 H-57

 

Comments on Quaking Aspen

The DEA states:

Many of the aspen stands have been invaded by conifers. Under the no 

action alternative, the aspen stands would not be released from

competition by having conifers removed. This would result in a loss of 

aspen stands throughout the project area. Under the action alternatives 

the aspen stands would be released and not be further invaded by

conifers as conifer seed sources would be removed. Future hardwood 

releases and prescribed burning would maintain and enhance the 

existing aspen stands.

The Service fails to consider the possible reasons for “pine

encroachment” and even refers to conifers as invaders (a highly

subjective and suggestive use of the word). Changing environmental

and climatic conditions are not discussed and presumably not 

considered as a natural cause for so-called conifer encroachment into 

aspen stands. The Service appears alarmed that the forest is rapidly 

changing in structure, composition and spatial configurations but

seemingly indifferent to the root causes of these changes; instead

rather, choosing to freeze the forest profile into some arbitrary and 

capricious point in time, a profile that, interestingly, favors the optimal 

timber harvest cycle rather than the forest’s optimal and natural 

ecological cycle—a cycle that benefits wildlife (i.e., wildlife viability) 

and the sum of all biological and physical processes in the long term.

Ponderosa pine are more shade tolerant than aspen, and 

therefore can grow in places where aspen cannot. 

Aspen is an important component to landscape vegetative 

diversity. Forest Plan Objective 201 says the Forest should 

manage for increased aspen acres. The Briggs Spring action 

alternatives would increase and maintain aspen stands and 

therefore move toward Forest Plan Objective 201.

Refer to response to comment 7e on species viability.

7pp Comments on Understory Vegetation

Past harvest activities have opened the forest canopy and produced 

more understory vegetation in forest stands. In the long term (greater 

than 10 years) trees would reoccupy the understory and future

treatments would be needed to maintain and enhance understory 

vegetation.

Under the no action alternative, canopy closure would continue to 

increase through time and less and less understory vegetation would be 

present under the forest canopy. Currently dense stands would not have 

their canopy opened up. Existing stands with a more open canopy 

would start to close as tree crowns grow together and additional trees

begin to grow from regeneration.
Briggs Spring Environmental Assessment Appendix H

H-58

There would be no adverse cumulative effects to understory vegetation 

as a result of the action alternatives. Both action alternatives would

improve understory vegetation by opening up the forest canopy.

The Service’s discussion immediately above is confusing. On one hand, 

in other sections of this Briggs Spring DEA, the Service speaks to the 

wildfire perils created by the presence of understory growth and above 

speaks to the benefits and desirability of understory. It appears the

Service is attempting to justify canopy removal on one hand and 

understory removal on the other hand. Which is it? Of course, the 

circular reasoning being applied here provides the illusion that one type 

of treatment can be followed by another in an endless cycle of projects. 

Likewise, an endless cycle of disturbance to the forest’s natural 

ecosystem occurs. We reject the circular discussion the Service

provides regarding it treatments of both canopy and understory. 

Certainly the facts presented by the Service are true, in terms of the 

forest’s understory responses to open vs closed canopies but the logic 

applied to the Service’s responses to those facts is deeply flawed in 

terms of any purported Service goal to maintain ecological integrity of 

the impacted area. Sudden, unnatural changes to the canopy and/or the 

understory stress wildlife ranging from, for example, the Northern 

goshawks to the long-eared myotis to the frigid ambersnail. Wildlife

typically adapt to slowly occurring changing environmental conditions 

whether biological, geological, cosmological, or climatic oriented.

Logging projects the size of the proposed Briggs Spring do not mimic 

typically occurring natural disturbances in the project area. If any

natural disturbance is mimicked by sudden canopy removal (thinning), 

it would be akin to a rare ice storm or straight line wind or some other 

natural event the Service would characterize as catastrophic.

The wildfire concerns are with stand density of ponderosa pine. 

Understory, as stated in the EA on page 27, consists of shrubs, 

forbs, and grasses. There are no proposed treatments to 

understory vegetation, other than prescribed burning, which 

would mimic a natural cycle for understory species. 

Refer to the “Wildlife” section of Chapter 3 of the EA for 

impacts to the goshawk (R2 Sensitive Species) and frigid 

ambersnail (Species of Local Concern). 

7qq Comments on Meadows and Grasslands

The historic meadow sites within the project area have been

encroached upon by conifers. Pine encroachment would occur in both 

action alternatives. Removing conifers of all sizes would fully restore 

existing meadows. As a result increased grass and forage production 

would occur. Proposed non-commercial treatments would remove any 

new pine invasion from adjacent forest stands, maintaining the

meadows. There would be no adverse cumulative effects to meadows in 

the project area as a result of either action alternative. The cumulative 

effect under the no action alternative would be that ponderosa pine
Briggs Spring Environmental Assessment Appendix H

 H-59

 

would remain in meadows and continue to seed into more trees,

eventually replacing existing meadow sites. Grass and forage 

production would continue to decrease.

See our previous comments regarding Goal 2, Objective 201 pg. 10 –

11.

Forest Plan Goal 2, Objective 201 refers to aspen and bur oak 

stands, not meadows. It is unclear what the commentor is 

stating. 

7rr Comments on Wildlife (DEA Wildlife Ch. 3, p. 37)

Topography is generally gentle rolling hills that support contiguous

pine stands broken by meadows and/or grasslands with or without 

aspen. The majority of the meadow/grassland acreage is on private 

lands, mostly unoccupied, within the project boundary. This project 

area contains a mixture of tree species such as aspen and ponderosa 

pine. Spruce is very limited within the project area. There are several

intermittent/ephemeral drainages within the project area but no

measurable perennial reaches. Developed and undeveloped springs are 

present on Forest Service lands. The project area has an extensive road 

system. The road density for all roads within the project area is 2.8 

miles/square mile. These roads provide access for various forest

management activities and recreational use, including snowmobile 

routes. In addition there are approximately 13 miles of system OHV 

trails within the project area.

The project is far too heavily roaded and 13 miles of system OHV trails 

in addition to the roads system represents an extremely heavily 

fragmented forest. To illustrate, imagine a one square mile block of 

forest with 2 linear miles of roads that, for example sake, bisect that 

square mile equally north to south and east to west. In that square mile 

the most possible unfragmented space between roads is 1⁄2 linear mile or 

1⁄2 x 1⁄2 = 1⁄4 square mile leaving four (4) 1⁄4 square mile blocks of 

fragmented forest. The same square mile having four equally spaced 

linear miles of road has only twice the length of road but nine (9)

blocks of fragmentation each only slightly over 1/10th mile in length 

and width or about 1/100th of a square mile in size. Now throw in 13 

miles of motorized trails and, hopefully, the depiction of fragmentation 

is clear. This degree of fragmentation is not ecologically sound or 

sustainable. A road density of two point eight (2.8) miles/miles is 

excessive. Thirteen (13) miles of motorized trails, having similar 

impacts to roads, add considerably to the fragmentation of the project 

The Forest recently completed a Travel Management analysis 

and decision which identified open system roads and OHV trails 

throughout the Forest. That decision is outside the scope of this 

project. 

Refer to response to comments 3b and 6n on roads. 
Briggs Spring Environmental Assessment Appendix H

H-60

area. We suggest Service eliminate roads to no more than 1 linear mile 

per square mile and to minimize the motorized trail systems to enhance 

ecological restoration of the project area. What kind of a true forest 

experience can a non-motorized forest visitor expect to have in such a 

fragmented forest? Motorized use is already clearly over-emphasized in 

the Briggs Spring project area. We request that the degree of forest

fragmentation as it is directly associated with linear miles of roads and 

motorized trails be considered and assessed by the Service. Road 

density, expressed as linear miles poorly represents (to the public) the 

forest fragmenting impacts of roads and motorized trails.

Forest fragmentation due to roading has many negative impacts on 

wildlife. One example is the introduction of invasive plants which can 

displace native plant species, produce a monoculture vegetation profile 

and, as a result, eliminate habitat for native plant obligate wildlife. 

Brownheaded cowbirds will parasitize neotropical songbird nests much 

more readily where forests are fragmented. Another example of the

impacts of fragmentation is the fact that elk are stressed by roads as far 

as 0.62 miles away as reported by many scientific investigators and the 

Rocky Mountain Elk Foundation as reported in this DEA10.

10 The Rocky Mountain Elk Foundation (2002) considers the majority 

of the project area as crucial annual range for elk. The southern tip is 

considered crucial annual, summer and winter range. Rumble et al. 

(2005) found that elk generally avoid areas within 1 km of primary and 

secondary roads during this time period. (Briggs Spring DEA Ch.

3. pg. 55).

See the EA, “Wildlife” section, page 75 for effects to Rocky 

Mountain elk, and the “Botany, Rangeland, and Noxious 

Weeds” section, pages 97-98 for effects to Noxious Weeds. 

Brown-headed cowbirds are obligate brood parasites, meaning 

they lay their eggs in other birds’ nests, leaving the 

responsibility of raising their young to other bird species. The 

young cowbird may out-compete the host young for food or 

may even toss the host egg out of the nest. This species prefers 

open to semi-open habitats, including woodland edges, riparian 

areas, farms, and prairies. Brown-headed cowbirds most likely 

are present within the Briggs Spring project area. Due to their 

association with open forest and riparian areas, cowbirds would 

be expected to gain preferred habitat within the project area as 

more open habitat would be created by vegetation treatments 

and/or mountain pine beetle activity. Whether or not vegetation 

treatments occur, mountain pine beetle are expected to change 

habitat, creating open areas that cowbirds prefer. 

No irreparable harm to song sparrow, from cowbird parasitism, 

would occur as a result of this project. 

7ss Comments on Management Indicator Species (MIS) (DEA 

Management Indicator Species (MIS) Ch. 3 pg. 38 - 41)
Briggs Spring Environmental Assessment Appendix H

 H-61

 

White-tailed deer

We question the inclusion of the white-tailed deer, a generalist wildlife 

species, as an MIS. White-tailed deer migration might be an indicator 

of how much snow exists but of all ungulates white-tailed deer are most 

adaptable and least influenced by the screen cover profile of the project 

area.

Whether or not white-tailed deer should be listed as a MIS 

(determined by the Forest Plan) is outside the scope of the 

Briggs Spring EA. 

7tt Black-backed Woodpecker (MIS and R2 Sensitive Species)

The black-backed woodpecker (Picoides arcticus) is distributed in low 

densities throughout most of the Black Hills. In the Black Hills, the 

black-backed woodpecker seems to favor late successional pine forests 

and areas that have been burned over or impacted by insects. Research 

conducted by Mohren (2002) indicated that this species prefers dense 

stands of mature ponderosa pine (SS 4C) and avoids the more open 

nature of SS4A and 4B stands. In 2005-2007, there was almost 2-3 

times as much SS4C available than is desired by the Forest Plan 

objectives (USDA Forest Service, 2006; 2007; 2008). There are 

currently 7,590 acres of SS4B ponderosa pine and no SS4C ponderosa 

pine acres within the project area.

Throughout the Black Hills National Forest, a total of 7,672 acres of 

burned forest habitat was created and largely retained over the last 

five years (USDA Forest Service, 2010). Where wildfires have recently 

occurred, the species has been observed much more frequently and in 

higher densities. The “aging” of large burned areas, such as the

Jasper Fire, into less suitable habitat is likely being offset by the 

increasing acreage of insect-infested timber stands and the stable 

acreage of large diameter, older pine trees. Tree mortality from insects 

from 1996-2007 is estimated at 300,000 acres, and insect-infested

timber stands are increasing. Overall the habitat is relatively abundant 

and Forest Plan Objective 238b is being met on the Forest. This 

species’ Forest-wide population trend is likely to decline in the future 

as vegetation management efforts to reduce the fire-hazard and insectrisk continue (USDA Forest Service, 2010).

Potential suitable habitat is present in the project area. Late succession 

stands containing large diameter dead trees (snags) created by natural 

events (wind, lightening), areas of mountain pine beetle activity, and 

burned acres are present within or adjacent to the Briggs Spring

project area. From 2001-2007 the RMBO has observed black-backed 
Briggs Spring Environmental Assessment Appendix H

H-62

woodpeckers just south of the project boundary (Panjabi, 2001, 2003-

2005; Giroir et al., 2007). In 2005 one was observed within the project 

area (Beason et al., 2006).

The black-backed woodpecker is a case in point for the Service to

manage the project area for more acreage and stands of SS4C and SS5 

(mature) ponderosa pine. The Service acknowledges:

“This species’ Forest-wide population trend is likely to decline in the 

future as vegetation management efforts to reduce the fire-hazard and 

insect-risk continue (USDA Forest Service, 2010).”

How does the Service propose to mitigate the project’s impact as

acknowledged above?

See page 71 of the EA for effects to the black-backed 

woodpecker. The Determination for this species is as follows, 

“Both action alternatives ‘may adversely impact individuals, but 

not likely to result in a loss of viability in the Planning Area, nor 

cause a trend toward federal listing’.” Additional clarification 

has been added: “The Forest is conserving habitat through snag 

management in addition, recent wildfires and MPB infestations 

are contributing towards Objective 221.” 

7uu Brown Creeper (MIS)

Essentially the concerns exist for the brown creeper as for the blackbacked woodpecker. How does the Service propose to mitigate the 

project’s impact as acknowledged above?

See pages 59-60 of the EA for direct, indirect, cumulative 

effects and the species determination for the brown creeper. 

“The proposed action alternatives would meet Forest Plan 

standards and guidelines; therefore this species is likely to 

persist on the Forest.”

7vv Grasshopper sparrow

Why was the grasshopper sparrow chosen as an MIS when the DEA in 

Ch. 3 on pg. 49 indicates this bird is not found in the project area?

The grasshopper sparrow is both a MIS and an R2 Sensitive 

Species. The Forest Plan designates which species are MIS, 

therefore, whether or not the grasshopper sparrow is “chosen” as 

an MIS is outside the scope of this project. Yes, the 

grasshopper sparrow has not been seen within the project area 

during analysis; however adequate habitat for the species exists 

within the project area and therefore it was analyzed as part of 

this project. Page 48 of the EA has been reworded, for more 

clarification, to state, “Of the 26 R2 sensitive species, six 

species have confirmed records of occurrence and eight species 

are expected to be present in the project area.” And further 

clarification on page 49, “Species presence expected and habitat 

present”. 

7ww Ruffed Grouse (MIS)

We appreciate Service efforts to enhance aspen stand health and size

via conifer removal but we wish to remind the service that

environmental conditions are driving the encroachment. We request the 

Service exert more effort to identify the cause of encroachment rather 

than simply to try to force aspen regeneration by unnaturally removing 

competition.

See response to 7oo. 
Briggs Spring Environmental Assessment Appendix H

 H-63

 

7xx Species of Local Concern (SOLC) (DEA Species of Local Concern 

(SOLC) Ch. 3, pg. 41 – 47)

Comments on Species of Local Concern (SOLC)

Invertebrates

The Service fails to discuss or explain how the proposed BS project

will avoid direct or indirect negative impacts to these SOLC. Prescribed 

burns conducted at the wrong time of year can destroy, for example, 

butterfly and fritillary feeding opportunities and can eliminate mating 

and reproductive for an entire generation. This problem is particularly 

pronounced in endemics.

Snails are particularly vulnerable to changes in soil moisture, sunlight 

and changes in chemical composition of soil and detritus. Among 

snails’ chemical sensitivities are those that alter soil pH and salinity.

The EA contains a summary of effects to SOLC species. See 

the EA, pages 60-66. More detailed analysis can be seen within 

the wildlife specialist’s report located in the project record. The 

EA also contains design criteria to lessen the impacts of project 

activities, see Appendix B, page B-10, for design criteria 

specific to snail habitat. 

7yy Birds

The DEA’s discussion of the BS project’s bird SOLC makes clear the 

importance of SS4A, B & C and SS5 stands.

Comment noted.

7zz

Comments on Region 2 (R2) Sensitive Species (DEA Region 2 (R2) 

Sensitive Species Ch. 3, Pg. 48 – 52)

Of this group of species our greatest concerns are for the Northern 

goshawk, Northern leopard frog and Black Hills redbelly snake.

Northern goshawk

Because goshawks hunting habits require rather heavy canopy we 

request the Service consider the impacts canopy removal created on 

this Accipiter.

See pages 68-69 of the EA for effects to the northern goshawk. 

Additional clarification has been added within the 

Determination to state: “Either action alternative would meet 

Objective 221, due to conserving known territories and 

conserving additional habitat. More detailed analysis can be 

found in the wildlife BA/BE found in the project record.

7aaa Northern leopard frog

As commenters we, meaning Biodiversity Conservation Alliance, have 

a particular interest in the conservation of the northern leopard frog. 

We are co-petitioners on the petition to the U.S. Fish & Wildlife

Service to list the species as Threatened or Endangered under the 

Endangered Species Act. The immensity of the BS project area gives 

reason enough to be concerned for the fate of this dwindling

amphibian. Any action that will result in a diminished quality of this 

See pages 71-72 of the EA for effects to the northern leopard 

frog. Additional clarification has been added to the 

Determination, “Riparian habitat would be conserved and/or 

enhanced due to post-sale riparian enhancement projects. 

Therefore the action alternatives would contribute toward 

meeting Objective 221.” Also see Appendix B for design 

criteria to protect riparian areas for amphibians. More detailed 

analysis can be found in the wildlife BA/BE found in the project 
Briggs Spring Environmental Assessment Appendix H

H-64

species habitat is not acceptable and will contribute to the decline of 

this species.

record. 

7bbb Black Hills Redbelly Snake

The Black Hills subspecies (Storeria occipitomaculata) is an isolated 

population; the next nearest population is located in the eastern part of 

South Dakota, some 300 miles away. Suitable habitat may be broadly 

distributed or abundant in the Black Hills. The snake is not rare in 

good habitat and is considered quite common in the Black Hills (USDA 

Forest Service, 2000; SDGFP, 2010c).

Suitable habitat for this species exists in the Briggs Spring project

area. A Black Hills redbelly snake was observed by a district biologist 

at Redbank Spring in July 2003.

We request the Service discuss the impacts of opening the forest 

canopy on this snake.

See page 72 of the EA for effects to the Black Hills redbelly 

snake. Additional clarification has been added to the 

Determination, “Riparian habitat would be conserved and/or 

enhanced due to post-sale riparian enhancement projects. 

Therefore the action alternatives would contribute toward 

meeting Objective 221.” See Appendix B for design criteria to 

protect riparian areas. 

7ccc Comments on Migratory Birds (DEA Migratory Birds Ch. 3, pg. 53

Many species of migratory birds are of international concern due to 

naturally small ranges, loss of habitat, observed population declines 

and other factors. Species of concern applicable to project-level 

conservation are identified by many sources, including the Endangered 

Species Act, the R2 sensitive species list, the Black Hills National 

Forest MIS and Species of Local Concern list, internal and public 

scoping efforts, and the USFWS Birds of Conservation Concern (BCC) 

(USFWS, 2008). BCC 2008 publication partitions North America into 

37 Bird Conservation Regions (USFWS, 2008). The Black Hills is 

included in BCR 17 – Badlands and Prairies. Of the 28 bird species 

found in BCR 17 (USFWS, 2008), fifteen are duplicated on the R2 

sensitive species list, and are evaluated in the BA/BE if they have 

potential to occur in the Black Hills. Six species are not expected to 

occur in the Black Hills due to lack of habitat. There are seven 

remaining species that could potentially occur in the Black Hills: 

golden eagle, prairie falcon, upland sandpiper, black-billed cuckoo, 

red-headed woodpecker, pinyon jay and dickcissel. Of these seven 

species, the golden eagle, prairie falcon, upland sandpiper and redheaded woodpecker have the potential to occur within the project area. 

The black-billed cuckoo, pinyon jay and dickcissel will not be analyzed 

because suitable habitat is not present in the Briggs Spring project 

area.
Briggs Spring Environmental Assessment Appendix H

 H-65

 

We wish to remind the Service that is it obligated to honor the

International Migratory Bird Treaty. We mention this because the

Treaty is not mentioned in the DEA except in Ch. 3 pg. 48 in a 

discussion about consultation with U.S. Fish & Wildlife Service in the 

context of the Bald eagle.

Of the four species believed to inhabit the BS project area we have 

greatest concern about the red-headed woodpecker as declines in its 

populations are being reported throughout the great plains states, 

North-central and North-eastern Canada.

See pages 73-75 of the EA for a summary of effects to 

migratory birds (golden eagle, prairie falcon, upland sandpiper, 

and red-headed woodpecker). More detailed analysis can be 

seen in the wildlife specialist’s report in the project record. This 

project is consistent with the Migratory Bird Treaty Act. 

7ddd Comments on Summaries of Effects on MIS, SOLC,R2 Sensitive 

Species, Migratory Birds, and Demand Species (DEA Summaries of 

Effects Ch. 3 pgs. 57 -76)

After studying the Summaries of Effects on all the categories of

wildlife summarized it is clear that the Service avoid discussing the 

effects of the individual wildlife species listed in the summaries. In 

almost every case, only a brief discussion of the habitat changes each 

alternative would produce is found and essentially no discussion of the 

actual impact or effects on the species itself. Only in the Summary of 

Effects Demand Species are actual impacts to the species itself 

discussed briefly.

The lack of discussion on direct and indirect impacts to wildlife species 

indicates a fixation on the profile of the project area vegetation

character and virtually no focus on the proposed actions’ impacts on 

wildlife and/or wildlife viability.

The EA provides a summary of direct, indirect, cumulative 

effects, and species determination for wildlife species and 

habitat. Detailed analysis can be seen within the wildlife 

specialist report and wildlife BA/BE, both located within the 

project record. 

7eee Impacts are not Fully Analyzed and Critically Assessed in the DEA

We request the FS fully analyze and assess the direct, indirect, and 

cumulative impacts of the BS project to the following:

• Livestock grazing

The FS must fully analyze and assess the cumulative impacts of

livestock grazing to the forests of the BS project area. Livestock

grazing and browsing results in significant negative impacts to forest 

understory and forest floor duff layers are significantly disturbed and 

Livestock grazing was considered as a cumulative action and is 

listed in Appendix F as a past, present, and future action. 

The provided reference was reviewed and it provides no new 

information. 
Briggs Spring Environmental Assessment Appendix H

H-66

surface vegetation trampled under hoof (Belsky, A.J. and D.M. 

Blumenthal. 1997).

7fff • Northern goshawk and its habitat

The DEA does not fully analyze and assess the potentially significant 

effects to the Northern goshawk using quantitative population 

information as a context for the assessment (i.e., how many individuals 

out of the population will be impacted). The DEA fails to fully analyze 

and assess the potentially significant effects to potential goshawk 

nesting habitat (i.e., ponderosa pine vegetation structural stages 5 and 

6) regardless of whether the habitat exists within a known territory, the 

potentially significant effects to goshawk post fledging habitat, and the 

significant effects to goshawk foraging habitat. In light of many 

cumulative adverse effects to the Northern goshawk and its habitat over 

the last few years (e.g., nest vandalism, fires, etc.), we request that all 

late successional habitat and stands of structural stage 4C and 4B be 

deferred from any treatments in order to ensure an adequate amount of 

goshawk nesting habitat is protected.

Habitat is a limiting factor to goshawk population due territorial nesting

behavior (Reynolds and Wight. 1978).

Goshawks hunt a majority of the time in mature stands (Hargis et al, 

1994) with well-closed canopies and they avoid large openings (Smith 

and Mannan. 1994).

Inextricably linked primary factors limiting goshawk populations are 

food supply and habitat (R. T. Reynolds. 1979).

The Forest Service, continuing with its less than 150 year timber cycle 

is continually and cumulatively limiting mature ponderosa stands and, 

by extension, goshawk nesting and foraging habitat.

We submit by reference the content of goshawk research conducted by 

(Susan Patla in 1997).

See response to 7zz. 

Reynolds and Wight, 1978, was reviewed and more recent 

literature authored by Reynolds was used during analysis. 

Hargis et al. 1994 could not be found. 

Smith and Mannan, 1994 was reviewed, red squirrels are not a 

listed species on the Black Hills and are not analyzed in the 

wildlife report. 

RT Reynolds, 1979, was reviewed, more recent literature by 

Reynolds was used for analysis. 

Patla, 1997 was reviewed, the document discusses cover types 

different that those of the Black Hills. 

7ggg Snail species of concern

The DEA fails to fully analyze and assess potentially significant effects 

to all known snail colonies and all potential snail species of concern 

habitat. The DEA fails to fully disclose the general location of all snail 

species of concern colonies within the BS project area to ensure

See response to 7xx concerning snails. 

Whether a species is listed under the Endangered Species Act or 

not is outside the scope of the Briggs Spring project. 
Briggs Spring Environmental Assessment Appendix H

 H-67

 

protection measures adequately protect all known and potential

colonies. We, again, request that the FS implement at least a 1,500 foot 

buffer to adequately protect all known snail colonies. This buffer is to 

ensure that colonies, which are known to shift over time, are fully 

protected and to ensure their habitat is adequately protected. The 

combined effects of beetle kill and the proposed timber extraction and 

fuels treatments will seriously impact watershed moisture retention

capacities. The DEA does not adequately address these impacts. We 

request the FS utilize Biodiversity Conservation Alliance’s petition to 

list the Black Hills mountainsnail under the Endangered Species Act 

for the BS project environmental analysis and to expand its research to

broaden its understanding of these impacts. BCA’s petition can be 

found at

http://www.voiceforthewild.org/bhnf/pubs/final_snail_petition.pdf. We 

hereby incorporate by reference this petition, its cites, and all 

information therein.11

11 Petition for a Rule to list the Black Hills mountainsnail (Oreohelix 

cooperi) THREATENED or ENDANGERED under the Endangered 

Species Act 16 USC 1531 et seq. (1973 as amended) and for the 

designation of Critical Habitat. September 24, 2003

7hhh • Sensitive woodpecker species

We are very concerned over the impacts of the BS project to sensitive 

woodpecker species. Various scientific sources have clearly established 

the relationship between healthy woodpecker populations and woodboring beetles and late successional habitat, which makes it difficult to

believe the BS project will not further jeopardize the viability of 

sensitive woodpecker species and diversity on the BHNF. The DEA 

does not fully analyze and assess the potentially significant effects of 

the BS project to the three-toed woodpecker, black-backed

woodpecker, and Lewis’s woodpecker. The DEA does not fully analyze 

and assess the impacts of reducing, eliminating, or otherwise

attempting to control in any way, any and all mountain pine beetle or

other insect within the project to sensitive woodpecker species

populations in accordance with 36 CFR § 219.19(a)(5). We request the 

FS allow mountain pine beetle outbreaks to occur in a large part the BS 

project area to provide sensitive woodpecker habitat and to function as 

a natural reset of the project area’s (and beyond) ecological balance,

i.e., minimize interference with natural processes that have served to 

The black-backed woodpecker is listed in the Forest Plan as a 

MIS and is also a R2 Sensitive Species. Pages 58-59 of the EA 

discuss the effects of project activities to the black-backed 

woodpecker. Effects to R2 Sensitive Species, black-backed 

woodpecker and Lewis’s woodpecker are discussed on pages 

70-71 of the EA.

The three toed woodpecker has been removed from the R2 

sensitive species list and is therefore no longer analyzed in the 

Briggs Spring project BA/BE. 

More detailed analysis on these species can be seen in the 

wildlife specialists report and the BA/BE located in the project 

record. 
Briggs Spring Environmental Assessment Appendix H

H-68

shape the present day ecology of the Black Hills and in particular the 

BS project area. The FS must utilize the following sources of scientific 

information to gain an adequate understanding of the BS project and 

render an informed and environmentally considerate decision:

Anderson, S.H. and B.J. Crompton. 2002. The effects of shelterwood 

logging on bird community composition in the Black Hills, Wyoming. 

Forest Science 48(2):365-372.

Anderson, T. 2003. Conservation Assessment for the Woodpeckers in 

the Black Hills National Forest South Dakota and Wyoming. Prepared 

for the USDA Forest Service, Black Hills National Forest. April 2003.

Hall, J.S., H.J. Marriott, and J.K. Perot. 2002. Ecoregional 

Conservation in the Black Hills. Minneapolis, MN: The Nature 

Conservancy. 176 p.

Hutto, R.L. 1995. Composition of bird communities following standreplacement fires in Northern Rocky Mountain (U.S.A.) conifer forests. 

Conservation Biology 9(5):1041-1058.

Imbeau, L. and A. Desrochers. 2002. Foraging ecology and use of

drumming trees by three-toed woodpeckers. Journal of Wildlife 

Management 66(1):222-231.

Mohren, S.R. 2002. Habitat Evaluation and Density Estimates for the 

Black-backed Woodpecker (Picoides arcticus) and the Three-toed 

Woodpecker (Picoides tridactylus) in the Black Hills National Forest. 

M.S. Thesis, University of Wyoming, Laramie. 110 pp.

Murphy, E.C. and W.A. Lehnhausen. 1998. Density and foraging 

ecology of woodpeckers following a stand-replacement fire. Journal of 

Wildlife Management 62(4):1359-1372.

Panjabi, A. 2001. Monitoring the birds of the Black Hills: Year 1. Fort 

Collins, CO: Rocky Mountain Bird Observatory. 96 p.

Saab, V.A. and J.G. Dudley. 1998. Response of cavity-nesting birds to 

standreplacement fire and salvage logging in ponderosa pine/Douglas 

This literature was reviewed in analysis.

This assessment was used for analysis, and cited in the wildlife 

specialist report and BA/BE.

This reference has been reviewed during analysis.

This reference has been reviewed during analysis.

The three toed woodpecker has been removed from the R2 

sensitive species list and is therefore no longer analyzed in the 

Briggs Spring project BA/BE. 

This reference was used in the Briggs Spring wildlife specialist 

report. 

This reference was reviewed and does not provide new 

information; other literature was used during analysis for 

woodpeckers. 

This reference was used in analysis and cited in both the Briggs 

Spring wildlife report and wildlife BA/BE. 

This reference was used in analysis and cited in the Briggs 

Spring BA/BE. 
Briggs Spring Environmental Assessment Appendix H

 H-69

 

fir forests of southwestern Idaho. Research Paper RMRS-RP-11. 

Ogden, UT:USDA Forest Service, Rocky Mountain Research Station. 

17 p.

Saab, V.A. and K.T. Vierling. 2002. Reproductive success of Lewis’s 

woodpecker in burned pine and cottonwood riparian forests. The 

Condor 103:491-501.

Spiering, D.J. and R.L. Knight. 2004. Wildlife use of snags in managed 

ponderosa pine stands, Black Hills National Forest.

Vierling, K.T. 1998. Interactions between European starling and 

Lewis’s woodpeckers at nest cavities. Journal of Field Ornithology 

69:376-379.

Vierling, K.T. 1997. Habitat selection of Lewis’s woodpeckers in 

southeastern Colorado. Wilson Bulletin 109:121-130.

We also request the Forest Service utilize these references and any 

other information the agency may have in order to analyze and assess 

the potentially significant effects to red-headed woodpecker, downy 

woodpecker, hairy woodpecker, and red-naped sapsucker.

Although the FS has removed 36 C.F.R. 219.19 from its regulations, 

the mandates of the Multiple-Use Sustained-Yield Act still apply, as 

they always have, to the BHNF. Eliminating a regulation does not 

eliminate a duty. As the former regulation so eloquently stated, “The 

first priority for stewardship of the national forests and grasslands is to 

maintain or restore ecological sustainability to provide a sustainable 

flow of uses, values, products, and services from these lands.” We urge 

the FS to take a hard look at the viability and sustainability of all 

species.

The DEA does not fully analyze and assess potentially significant 

effects to other Region 2 sensitive species, SDGF&P sensitive species, 

T/E species, and all candidate species and their habitat which may exist 

within the project area. The DEA fails to analyze and disclose

quantitative population data in order to accurately analyze and assess 

all potentially significant effects to sensitive, T/E, and candidate

This reference was used in analysis and cited in the Briggs 

Spring BA/BE.

Could not find this reference. 

This reference has been reviewed during analysis. 

This reference has been reviewed during analysis. 

The red-headed woodpecker was analyzed as a Migratory Bird, 

see pages 74-75 of the EA. The downy woodpecker, hairy 

woodpecker and red-naped sapsucker are not listed for analysis 

because it does not occur on any of the required lists of species 

to analyze in environmental analyses on the Black Hills 

National Forest MIS, SOLC, R2 Sensitive Species, nor is it a 

Demand Species.

Refer to comment 7e on species viability. 

See pages 57-78 of the EA for a summary of effects to MIS, 

SOLC species, Threatened & Endangered Species, R2 Sensitive 

Species, Migratory Birds, and Demand Species. More detailed 

analysis can be found in the Wildlife specialist report and the 

Wildlife BA/BE, located in the project record. 
Briggs Spring Environmental Assessment Appendix H

H-70

species of wildlife. We request that all sensitive, T/E, and candidate 

species be fully protected.

7iii • Sharp-shinned hawk, Cooper’s hawk, American kestrel

The DEA fails to fully analyze and assess the potentially significant 

effects to these raptors. Recent monitoring suggests these species have 

declined on the BHNF, an event most likely attributable to extremely 

low snag densities throughout the BHNF and the lack of late

successional forest habitat. The 2006 Monitoring the Birds of the Black 

Hills – Year 6, does not even contain an account for the sharp-shinned 

hawk or the American kestrel, suggesting that their viability and 

sustainability in the Black Hills is being compromised. Given their 

dependence upon snags and large diameter trees, this snag shortage is 

clearly affecting the ability of the FS to ensure viable and welldistributed populations of these species. Unfortunately, the FS has been

unwilling to give any adequate consideration to the needs of these bird 

species in recent timber sale NEPA documents. We hope this will 

change through the DEA for the BS project. We request the FS ensure 

the BS project does not lead to further population declines for these 

species in order to ensure diversity is provided for on the BHNF. The 

FS must utilize the following sources of scientific information to gain 

an adequate understanding of the BS project and render an informed 

and environmentally considerate decision:

Panjabi, A. 2001. Monitoring the birds of the Black Hills: Year 1. Fort 

Collins, CO: Rocky Mountain Bird Observatory.

Panjabi, A. 2003. Monitoring the birds of the Black Hills: Year 2. Fort 

Collins, CO: Rocky Mountain Bird Observatory.

Saab, V.A. and J.G. Dudley. 1998. Response of cavity-nesting birds to 

standreplacement fire and salvage logging in ponderosa pine/Douglas 

fir forests of southwestern Idaho. Research Paper RMRS-RP-11. 

Ogden, UT:USDA Forest Service, Rocky Mountain Research Station. 

17 p.

The summary of effects to the sharp-shinned hawk and 

Cooper’s hawk is on pages 62-63 of the EA. 

The American kestrel is not listed for analysis because it does 

not occur on any of the required lists of species to analyze in 

environmental analyses on the Black Hills National Forest MIS, 

SOLC, R2 Sensitive Species, nor is it a Demand Species.

This reference was used in analysis and cited in the Briggs 

Spring wildlife report and wildlife BA/BE. 

This reference was used in analysis and cited in the Briggs 

Spring wildlife report and wildlife BA/BE.

This reference was used in analysis and cited in the Briggs 

Spring wildlife BA/BE.

7jjj • Black Hills red-backed vole

A DEA fails to analyze and assess the potentially significant effects of 

the BS project to this endemic mammal subspecies. And, while the FS 

claims that this species is widespread and abundant on the BHNF, the 

agency has yet to come forward with any supporting information or

The Black Hills red-backed vole is not listed for analysis 

because it does not occur on any of the required lists of species 

to analyze in environmental analyses on the Black Hills 

National Forest MIS, SOLC, R2 Sensitive Species, nor is it a 

Demand Species. 
Briggs Spring Environmental Assessment Appendix H

 H-71

 

analysis. Therefore, to ensure this species, which is most likely an 

important prey species for many forest predators (e.g., goshawk, 

Cooper’s hawk, marten), is fully protected and to ensure the scientific 

and professional integrity of the FS, the agency must address impacts to 

this mammal and fully protect the species and its habitat. The FS must 

utilize the following sources of scientific information to gain an

adequate understanding of the BS project and render an informed and 

environmentally considerate decision:

Beauvais, G.P. 1997. Mammals in fragmented forests in the Rocky 

Mountains: community structure, habitat selection, and individual 

fitness [Ph.D. dissertation]. Laramie, WY, University of Wyoming

Hall, J.S., H.J. Marriott, and J.K. Perot. 2002. Ecoregional 

Conservation in the Black Hills. Minneapolis, MN: The Nature 

Conservancy. 176 p.

Nordyke, K.A. and S.W. Buskirk. 1991. Southern red-backed vole, 

Clethrionomys gapperi, populations in relation to stand succession and 

old-growth character in the central Rocky Mountains. The Canadian 

Field Naturalist 105:330-334.

Pearson, D.E. 1994. Habitat use by the southern red-backed vole 

(Clethrionomys gapperi): response of an old-growth associated species 

to succession [M.S. Thesis]. Missoula, MT University of Montana.

Could not find this reference. 

This reference was reviewed during analysis. 

Could not find this reference. The southern red-backed vole is 

not a listed species on the Black Hills National Forest and 

therefore is not analyzed. 

Could not find this reference. The southern red-backed vole is 

not a listed species on the Black Hills National Forest and 

therefore is not analyzed.

7kkk • Northern flying squirrel

The DEA must fully analyze and assess the potentially significant 

effects to the Northern flying squirrel. This analysis must fully analyze 

and assess the potentially significant effects to ectomycorrhizal fungi 

that supports Northern flying squirrels in other forests and is 

undoubtedly a part of the flying squirrel’s diet on the BHNF. The FS 

must utilize the following sources of scientific information to gain an 

adequate understanding of the BS project and render an informed and 

environmentally considerate decision:

Bakker, V.J. and K. Hastings. 2002. Den trees used by Northern flying 

squirrels (Glaucomys sabrinus) in southeastern Alaska. Canadian 

Journal of Zoology 80:1623-1631.

Pages 65-66 of the EA discuss the effects to the northern flying 

squirrel. More detailed analysis can be found in the Briggs 

Spring wildlife report, located in the project record.

This reference was reviewed and provides no new information, 

other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring. 
Briggs Spring Environmental Assessment Appendix H

H-72

Carey, A.B. 2002. Response of Northern flying squirrels to

supplementary dens. Wildlife Society Bulletin 30(2):547-556.

Carey, A.B. 2000. Effects of new forest management strategies on 

squirrel populations. Ecological Applications 10(1):248.

Carey, A.B. 1999. Ecology of Northern flying squirrels: implications 

for ecosystem management in the Pacific Northwest, USA. In R. 

Goldingay and J. Scheibe, eds. Gliding mammals. Filander Press, 

Furth, Germany.

Hall, D. 1991. Diet of the Northern flying squirrel at Sagehen Creek, 

California. Journal of Mammalogy 72(3):615-617.

Hall, J.S., H.J. Marriott, and J.K. Perot. 2002. Ecoregional

Conservation in the Black Hills. Minneapolis, MN: The Nature 

Conservancy. 176 p.

Hayward, G.D. and R. Rosentreter. 1994. Lichens as nesting material 

for Northern flying squirrels in the Northernn Rocky Mountains. 

Journal of Mammalogy 75(3):663-673.

Reunanen, P., M. Mönkkönen, and A. Nikula. 2000. Managing boreal 

forest landscapes for flying squirrels. Conservation Biology 14(1):218-

226.

Rosentreter, R., G.D. Hayward, and M. Wicklow-Howard. 1997. 

Northern flying squirrel seasonal food habits in the interior conifer 

forests of Central Idaho, USA. Northwest Science 72(2):97-102.

This reference was reviewed and provides no new information. 

Other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring.

This reference was reviewed and provides no new information. 

Other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring.

This reference was reviewed and provides no new information. 

Other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring.

This reference was reviewed and provides no new information. 

Other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring.

This reference was reviewed during analysis. 

This reference was reviewed and provides no new information. 

Other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring.

This reference was reviewed and provides no new information. 

Other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring.

This reference was reviewed and provides no new information. 

Other literature was used for the northern flying squirrel in the 

analysis for Briggs Spring.

7lll • Flammulated owl

The DEA inadequately analyzes and assesses the potentially significant 

effects to flammulated owl and its habitat. The flammulated owl was 

confirmed to exist during recent monitoring on the Black Hills. See, 

e.g., 2002 Monitoring the Birds of the Black Hills: Year 2. This is the 

last account of the bird in the Black Hills monitoring project. It is 

distressing to note that not a single owl species was observed in the 

2006 Monitoring report. Given the species’ rare status throughout its 

range, its dependence upon old growth ponderosa pine, and the fact that 

this species’ existence has only recently been confirmed on the BHNF, 

Page 70 of the EA discuss the effects to the flammulated owl. 

More detailed analysis can be found in the Briggs Spring 

wildlife BA/BE, located in the project record.
Briggs Spring Environmental Assessment Appendix H

 H-73

 

there is significant concern over the impacts of forest management 

activities to this species and its habitat, which consists of old growth 

ponderosa pine. Special attention must be given to the owl (and all owl 

species in the Black Hills) to ensure its habitat is adequately protected 

and that the owl and its habitat do not suffer adverse impacts as a result 

of the BS project. The FS must utilize the following sources of

scientific information to gain an adequate understanding of the BS 

project and render an informed and environmentally considerate 

decision:

Linkhart, B. D., R. T. Reynolds, R. A. Ryder. 1998. Home range and 

habitat of breeding flammulated owls in Colorado. Wilson Bulletin 

110(3): 342 –351.

Linkhart, B.D. and R.T. Reynolds. 1997. Territories of flammulated 

owls: is occupancy a measure of habitat quality? pp. 226-230 in 

Biology and conservation of owls in the Northern hemisphere (J.R. 

Duncan, D.H. Johnson, and T.H. Nichols, Eds.). USDA Forest Service 

General Technical Report NC-190.

Reynolds, R. T. and B. D. Linkhart. 1992. Flammulated owls in 

ponderosa pine: Evidence of preference for old growth. Old-Growth 

Forests in the Southwest and Rocky Mountain Regions, Proceedings of 

a Workshop. USDA Forest Service General Technical Report RM-213.

Reynolds, R.T. and B.D. Linkhart. 1987. The nesting biology of 

flammulated owls in Colorado. Paper presented at the Symposium on 

the Biology and Conservation of Northern Forest Owls. Winnipeg,

Manitoba, Canada February 3-7, 1987.

Reynolds, R.T. and B. D. Linkhart. 1987. Fidelity to territory and mate 

in flammulated owls. Paper presented at the Symposium on the Biology 

and Conservation of Northern Forest Owls. Winnipeg, Manitoba,

Canada February 3-7, 1987.

Additionally, we request the Forest Service analyze and assess the 

potentially significant effects of the BS project to the Northern sawwhet owl, another old growth and snag obligate that is known to exist 

on the BHNF.

This reference was reviewed and provides no new information. 

Other literature was used for the flammulated owl in the 

analysis for Briggs Spring.

This reference was reviewed and provides no new information. 

Other literature was used for the flammulated owl in the 

analysis for Briggs Spring.

This reference was reviewed and provides no new information. 

Other literature was used for the flammulated owl in the 

analysis for Briggs Spring.

This reference could not be located. 

This reference could not be located. 

Summary of effects to the northern saw-whet owl are on pages 

63-64 of the EA. More detailed analysis can be found in the 

Briggs Spring wildlife report located in the project record.
Briggs Spring Environmental Assessment Appendix H

H-74

7mmm • Black bear

The DEA fails to fully analyze and assess the potentially significant 

effects to the black bear and its habitat. The Forest Service has failed to 

provide any analysis or information supporting their claim that the 

black bear no longer exists on the BHNF. There is a possibility that 

black bear continue to exist on the BHNF as there has been confirmed 

sightings of the bear in the BHNF. We request the Forest Service fully 

consult with the South Dakota Department of Game, Fish, and Parks, 

the South Dakota Natural Heritage Program, the Wyoming Game and 

Fish, and the Wyoming Natural Diversity Database to determine if 

there have been black bear sightings on the BHNF and therefore a 

possibility that this species still exists. Regardless of sightings though, 

the agency must fully consider the possibility that the black bear will 

naturally disperse from other areas to the BHNF and therefore 

reestablish itself. In the meantime, the FS must protect any and all 

existing black bear habitat to ensure this species can restore itself to the 

Forest. The black bear is listed as a threatened species by the South 

Dakota Game, Fish and Parks Department. The FS must utilize the 

following sources of scientific information to gain an adequate

understanding of the BS project and render an informed and 

environmentally considerate decision:

Mollohan, C.M. and A.L. LeCount. 1989. Problems of maintaining a 

viable black bear population in a fragmented forest. Paper presented at 

the Conference on Multiresource Management of Ponderosa Pine 

Forests, Northern Arizona University, November 14-16, 1989.

The black bear is not a MIS, SOLC or Demand Species, nor is it 

a Threatened, Endangered, or Region 2 Sensitive Species. 

Therefore impacts to black bear were not included in this 

analysis. Adding the black bear to any of these lists is outside 

the scope of this project. 

This reference could not be found. 

7nnn • Atlantis fritillary butterfly (Speyeria atlantis pahasapa)

We request the FS fully analyze and assess the impacts of the BS 

project to this endemic butterfly subspecies and fully protect any sites 

where the subspecies exists and fully protect the species’ habitat. While 

the FS has yet to analyze and assess the impacts of a project to this 

species, we hope this will change. We also remind the agency that, 

regardless of whether or not a species is threatened, endangered, 

sensitive, or a management indicator species, the agency

has a duty under NEPA to consider the impacts of its actions to the 

human environment and to address public concerns expressed

during the NEPA comment process. Additionally, the failure to

consider impacts to this subspecies is a sure sign that Endangered 

Species Act protection may be necessary to prevent the extinction of 

Effects to the Atlantis fritillary butterfly are summarized on 

pages 60-61 of the EA. Detailed analysis can be found in the 

Briggs Spring wildlife report located in the project record. 
Briggs Spring Environmental Assessment Appendix H

 H-75

 

this rare butterfly. The following sources of information should be 

referenced to ensure this species and its habitat are not adversely 

impacted:

Hall, J.S., H.J. Marriott, and J.K. Perot. 2002. Ecoregional

Conservation in the Black Hills. Minneapolis, MN: The Nature 

Conservancy. 176 p.

Scott, J. A., N. Kondla, and S. Spomer. 1998. Speyeria Hesperis and 

Speyeria Atlantis are Distinct Species. Papilio No. 8. February 20, 

1998.

This reference was reviewed during analysis. 

This reference could not be found.

7ooo • Fringe-tailed myotis, silver-haired bat, Townsend’s big-eared bat, 

other native bat species

The DEA fails to analyze and assess the potentially significant effects 

to these native bat species and their habitat. The Forest Service must 

also consider the fact that snags, large diameter trees, late successional 

forest, wetlands, streams, ponds, and other open bodies of water also 

provide habitat for native bat species. Recent studies of bat species 

have shown a preference for old growth stands, which typically contain 

abundant snags. The FS must utilize the following sources of scientific 

information to gain an adequate understanding of the BS project and 

render an informed and environmentally considerate decision:

Dowd Stukel, E. 2001. South Dakota’s tree bats. South Dakota

Conservation Digest 68(1):22-23.

Hall, J.S., H.J. Marriott, and J.K. Perot. 2002. Ecoregional

Conservation in the Black Hills. Minneapolis, MN: The Nature 

Conservancy. 176 p.

Mattson, T.A., S.W. Buskirk, and N.L. Stanton. 1996. Roost sites of the 

silver-haired bat (Lasionycteris noctivagans) in the Black Hills, South 

Dakota. Great Basin Naturalist 56(3):247-253.

Schmidt, C.A. 2002. Conservation Assessment for the Fringed Bat. 

Prepared for the USDA Forest Service, Black Hills National Forest, 

Custer, SD.

Effects to northern long-eared myotis, small-footed myotis, 

long-eared myotis and long-legged myotis are discussed on page 

65 of the EA as SOLC species. Effects to the fringed myotis 

and Townsend’s big-eared bat are discussed on pages 67-68 of 

the EA as a R2 Sensitive Species. Clarification was added for 

the fringed myotis and Townsend’s big-eared bat determination 

to include, “The Forest is conserving and enhancing habitat for 

this species through cave, mine, and snag management and is 

therefore meeting Objective 221.” More detailed analysis for all 

these species can be found in the Briggs Spring wildlife report 

and BA/BE located in the project record. 

Could not find this reference. 

This reference was reviewed during analysis.

This reference was reviewed during analysis. The silver-haired 

bat is not a listed species in the Forest Plan and therefore is not 

analyzed for this project. 

This reference was cited in the Briggs Spring wildlife BA/BE. 

7ppp • Native Fish Species

The DEA fails to analyze and assess the potentially significant effects 

There are no known fisheries within the Briggs Spring project 

area. 
Briggs Spring Environmental Assessment Appendix H

H-76

to native fish species. Numerous concerns have been expressed over 

native fish viability on the BHNF (see e.g., Chief’s 1999 Appeal 

Decision for Appeals of the 1997 BHNF Revised Forest Plan) and

therefore, the agency is obligated to ensure the BS project does not 

adversely affect these fish species. Survey data will also enable the FS 

to better analyze and assess the impacts of the BS project to native fish 

species. We request that all native fish species be fully protected. The 

FS must utilize the following sources of scientific information to gain 

an adequate understanding of the BS project and render an informed 

and environmentally considerate decision:

Erickson, J.W. 2002. Current status of the mountain sucker in the Black 

Hills of South Dakota. South Dakota Department of Game, Fish, and 

Parks, Draft Planning Document. 5 p.

Hall, J.S., H.J. Marriott, and J.K. Perot. 2002. Ecoregional

Conservation in the Black Hills. Minneapolis, MN: The Nature 

Conservancy. 176 p.

Isaak, D.J., W.A. Hubert, and C.R. Berry. 2003. Conservation 

assessment of the lake chub (Couesius plumbeus), mountain sucker 

(Catostomus platyrhynchus),and finescale dace (Phoxinus neogaeus) in 

the Black Hills of South Dakota and Wyoming. Report for the Black 

Hills National Forest. 102 p.

This reference was reviewed during analysis.

This reference was reviewed during analysis.

This reference was reviewed during analysis and is cited in the 

Briggs Spring wildlife BA/BE. 

7qqq • Management Indicator Species

The DEA inadequately analyzes and assesses the potentially significant 

effects to all MIS and their habitat that may exist within the BS project 

area. The DEA must include and present quantitative MIS population 

trend data in order to accurately analyze and assess all potentially

significant effects to MIS populations. Special attention must be given 

to the brown creeper as this bird species is an indicator of dense mature 

and late successional forest, a habitat type that has declined

precipitously on the BHNF and now exists in very isolated and sparse 

stands on the forest. The FS must utilize the following sources of 

scientific information to gain an adequate understanding of the BS 

project and render an informed and environmentally considerate

decision:

MIS were analyzed in the Briggs Spring project. A summary of 

effects for MIS can be found on pages 57-60 of the EA. More 

detailed analysis can be found in the Briggs Spring wildlife 

report located in the project record.

Population trend or viability of species is not considered at the 

project level. However, the 2009 Forest monitoring report has 

addressed population and habitat trends for Management

Indicator Species (MIS). 

A viable population is one that has enough individuals that 

produces enough offspring for long-term persistence and 

adaptation of the population in a given place (the ability to 

reproduce, adapt, and sustain itself through time). The 

minimum brown creeper population needed to sustain itself is 

unknown and probably varies through time depending on 
Briggs Spring Environmental Assessment Appendix H

 H-77

 

Anderson, S.H. and B.J. Crompton. 2002. The effects of shelterwood 

logging on bird community composition in the Black Hills, Wyoming. 

Forest Science 48(2):365-372.

Crompton, B.J. 1994. Songbird and small mammal diversity in relation 

to timber management practices in the Northwestern Black Hills [M.S. 

Thesis]. Laramie, WY: University of Wyoming.

Dowd Stukel, E. 1999. Brown Creeper. South Dakota Conservation 

Digest 66(5):26-27.

Panjabi, A. 2001. Monitoring the birds of the Black Hills: Year 1. Fort 

Collins, CO: Rocky Mountain Bird Observatory. 96 p.

Rumble, M.A., B.L. Dykstra, and L.D. Flake. 2000. Species-area 

relations of song birds in the Black Hills, South Dakota. Intermountain 

Journal of Science 6(1):33-48.

climate, weather, disease, predation, and other factors. A 

population viability analysis (PVA) has not been done on brown 

creepers in the Black Hills. A PVA requires detailed data on 

reproductive rates, survival rates, mortality rates, immigration, 

emigration, etc. This detailed information is not currently 

available for brown creepers on the Black Hills. However, an 

analysis was done for the Phase II Forest Plan Amendment to 

determine if enough habitat would be available to sustain brown 

creepers. The Phase II analysis determined that there will be 

sufficient habitat on the Forest to sustain brown creepers if the 

Forest Plan objectives, standards and guidelines are 

implemented. 

This reference was reviewed during analysis.

Could not locate this reference. 

Could not locate this reference.

This reference was cited in the Briggs Spring wildlife report and 

BA/BE. 

This reference was reviewed during analysis.

 

7rrr • Sensitive plant species and plant species of concern

The DEA does not fully analyze and assess the potentially significant 

effects to the following plant species of concern and their habitats:

Autumn coral-root (Corallorrhiza odontorhiza), Autumn willow 

(Salix serissima), Blunt-broom sedge (Carex tribuloides), Dwarf 

scouring rush (Equisetum scirpoides), Foxtail sedge (Carex 

alopecoidea), Giant Helleborine (Epipactis gigantean), Greatspurred violet (Viola selkirkii), Large roundleaf orchid (Platanthera 

The effects analysis in the EA addresses all plants listed as R2 

Sensitive Species or as Species of Local Concern (SOLC). See 

pages 90-91, 93-96 of the EA for analysis of SOLC species and 

R2 Sensitive Species. More detailed analysis can be found in 

the Botany, Rangeland and Noxious Weeds report and the 

Botany BA/BE. 
Briggs Spring Environmental Assessment Appendix H

H-78

orbiculata), Prairie dunewort (Botrychium campestre), Southern 

maidenhair-fern (Adiantum capillus-veneris), Spinulose shield fern 

(Dryopteris carthusiana), Trailing clubmoss (Lycopodium

complanatum), Moschatel (Adoxa moschatellina), Maindenhair 

spleenwort (Asplenium trichomanes), Green spleenwort (Asplenium 

viride), Elegant sedge (Carex bella), Bristly-stalk sedge (Carex 

leptalea), Longstalk sedge (Carex pedunculata), Dog cryptantha 

(Cryptantha cana), American rock-brake (Cryptogramma 

acrostichoides), Large yellow ladies-slipper (Cypripedium calceolus 

var. pubescens), Beaked spikerush (Eleocharis rostellata),

Woodland horsetail (Equisetum sylvaticum), Variegated horsetail 

(Equisetum variegatum), Showy prairie gentian (Eustoma 

russellianum), Secund Bladderpod (Lesquerella arenosa var. 

argillosa), Broad-leaved Twayblade (Listeria convallarioides), Stiff 

clubmoss (Lycopodium annotinum), Treelike clubmoss (Lycopodium 

dendroideum), Marsh muhly (Muhlenbergia glomerata), Gray’s 

lousewort (Pedicularis procera), Arrow-leaved sweet-coltsfoot 

(Petasites sagittatus), Mountain holly-fern (Polystichum lonchitis), 

Hoary willow (Salix candida), Bloodroot (Sanguinaria canadensis),

Woolrush (Scirpus atrocinctus), and Thinleaved blueberry 

(Vacinium membranaceum).

We also are concerned that the DEA fails to present information and 

maps showing the occurrence of high quality and non-high quality

plant habitat, as well as documentation of the results of plant surveys 

conducted in these habitats. We also request the FS fully analyze and

assess the impacts to unique vegetation communities within the BS 

project area. The FS must also fully protect all unique vegetation 

communities and sensitive and/or rare plants in the BS project area. 

The FS must utilize the following sources of scientific information to 

gain an adequate understanding of the BS project and render an 

informed and environmentally considerate decision:

Fertig, W. 1993. Black Hills National Forest Sensitive Plant Field

Guide. Report prepared for the Black Hills National Forest by the 

Wyoming Natural Diversity Database, Laramie, WY.

Hall, J.S., H.J. Marriott, and J.K. Perot. 2002. Ecoregional 

Conservation in the Black Hills. Minneapolis, MN: The Nature 

Refer to response to comment 7a on best available science. 

This reference was reviewed and provides no new information; 

more recent literature was used in the analysis of this project. 

This reference was reviewed and does not provide any new 

information. 
Briggs Spring Environmental Assessment Appendix H

 H-79

 

Conservancy. 176 p.

7sss • Snags, Down-woody debris

Mountain pine beetle infestations, if left alone, lead to the creation of 

snags and consequently the existence of down-woody debris. These 

habitat components are essential to the survival of many native species 

on the BHNF. The DEA fails to fully analyze and assess how the BS 

project will affect snag habitat and down-woody debris habitat, as well 

as snag recruitment and the creation of future down-woody debris. 

Such an analysis and assessment must consider the fact that certain 

native species depend upon large-diameter snags and large diameter 

down-woody debris.

See pages 55-56 of the EA for effects to snags and down woody 

material. More detailed analysis can be found in the Briggs 

Spring wildlife report. 

7ttt • Water quality

The DEA does not fully analyze and assess the potentially significant 

effects to water quality both within the BS project area and downstream 

from the project area to ensure compliance with the Clean Water Act, 

State of South Dakota Quality laws, and Executive Orders 11988 and

11990. The DEA fails to fully analyze the effects of the BS project on 

sedimentation, flow regimes, water temperature alterations, and 

streambeds and banks. When analyzing the effects of the BS project to 

water resources, the FS cannot simply rely on a list of best management

practices (“BMP’s”) in place of analysis, disclosure, and assessment as 

required by the National Environmental Policy Act. For instance, if 

sedimentation will occur as a result of the project, the agency must 

analyze and disclose how much sedimentation will occur in order to 

adequately assess the significance of any and all sedimentation. A mere 

listing of BMP's is a wholly inadequate assessment and does not 

provide the public or the agency with any kind of understanding of the 

potentially significant effects of the BS project to water resources.

Additionally, any analysis and assessment must fully consider the 

cumulative effects of BMP implementation. This is because BMPs do 

not eliminate water quality impacts, but rather “minimize” them. 

Therefore, there are adverse impacts associated with BMP

implementation and the FS must consider the fact that cumulatively, 

BMP implementation has led to potentially significant impacts to water 

quality. Finally, there are indications that BMP implementation does

not adequately protect water quality and aquatic resources. The 

following sources suggest that BMPs are inadequate to protect water 

quality and aquatic resources:

See pages 127-137 of the EA for analysis of water resources. 

More detailed analysis can be found in the soils and water 

specialist report. The specialist report addresses compliance 

with the Clean Water Act, E.O. 11988 and E.O. 11990. 

See the BMP Effectiveness section in Chapter 3 of the EA. 

Refer also to design criteria for soil and water resources in 

Appendix B of the EA. 
Briggs Spring Environmental Assessment Appendix H

H-80

Cederholm, C.J., L.M. Reid, and E.O. Salo. 1981. Cumulative effects 

of logging road sediment on salmonid populations in the Clearwater 

River, Washington: a project summary. Pags 373-398 in Salo and 

Cundy eds. Streamside management: forestry and fishery interactions.

Espinosa, F.A., Rhodes, J.J. and McCullough, D.A. 1997. The failure 

of existing plans to protect salmon habitat on the Clearwater National 

Forest in Idaho. J. Env. Management 49(2):205-230.

Rhodes, J.J., Espinosa, F.A., and Huntington, C., in process. Watershed 

and Aquatic Habitat Response to the 95-96 Storm and Flood in the 

Tucannon Basin, Washington and the Lochsa Basin, Idaho. Final 

Report to Bonneville Power Administration, Portland, Or.

Stanford, J.A., and Ward, J.V., 1992. Management of aquatic resources 

in large catchments: Recognizing interactions between ecosystem 

connectivity and environmental disturbance. Watershed Management: 

Balancing Sustainability and Environmental Change, pp. 91-124, 

Springer Verlag, New York.

Waters, T.F. 1995. Sediment in streams. American Fisheries Society 

Monograph 7. American Fisheries Society, Bethesda, MD.

Ziemer, R.R., and Lisle, T.E., 1993. Evaluating sediment production by 

activities related to forest uses--A Northwest Perspective. Proceedings: 

Technical Workshop on Sediments, Feb., 1992, Corvallis, Oregon. pp. 

71-74.

This reference was reviewed and does not provide any new 

relevant information to the Briggs Spring project. 

This reference does not provide any new relevant information to 

the Briggs Spring project. 

This reference could not be found.

This reference has been reviewed and does not provide any new 

information.

This reference was used in analysis.

This reference does not provide any new relevant information.

7uuu • Riparian areas

The DEA does not fully disclose the existence, extent, and vegetative 

composition of all riparian areas within the BS project and fully 

analyze and assess the potentially significant effects to these riparian 

areas. Please disclose the existence of all riparian areas on maps 

included with the BS project analysis and provide information 

documenting the vegetative composition of riparian areas in the project 

area.

Effects to riparian areas are discussed on pages 132-136 in the 

EA. More detailed analysis can be found in the soils and waters 

specialist report located in the project record. A map of stream 

courses is available in Appendix A of the EA. Locations of 

wetland/riparian areas are in the project record GIS data. 

7vvv • Meadows

The DEA does not fully disclose the location and extent of all historic 

meadows in the BS project area so that reviewers of any environmental 

analysis can fully understand the extent of pine encroachment. 

GIS data that contains cover type information is located in the 

project record. Map 2 and Map 4, with corresponding tiles, of 

the EA show sites proposed for pine encroachment treatments. 

These sites are meadows with encroaching conifers. There is no 
Briggs Spring Environmental Assessment Appendix H

 H-81

 

Furthermore, such a disclosure is necessary to support any assertion 

that pines must be removed from meadows. The DEA fails to disclose 

the acres desired to be meadows in the project area to compare with the 

acreage of meadows that may be created by the BS project. This 

disclosure is necessary so that reviewers of any environmental analysis 

can fully understand the extent of the potentially significant effects of 

the project.

meadow restoration or creation of meadows proposed in the 

Briggs Spring project. 

7www • Late successional habitat

The DEA does not fully analyze and assess the potentially significant 

effects to late successional forest habitat, including the effects upon all 

potential late successional habitat (i.e., the effects of the BS project to 

late successional recruitment). This analysis must also differentiate 

between tree species. To complete this analysis and assessment, the 

Forest Service must first analyze whether or not the amount of late 

successional forest in the project area is sufficient to meet the needs of 

populations of wildlife species dependent on late successional forest. 

The Forest Service must then analyze the effects of the BS project to 

late successional habitat (including future late successional habitat) in 

terms of the needs of those species of wild life dependent on this 

specialized habitat (e.g., Northern goshawk, marten, sensitive

woodpecker species, pygmy nuthatch, Northern flying squirrel, goldencrowned kinglet, and brown creeper). We request that all late 

successional habitat and all potential late successional habitat be 

protected. We request the FS reference the following report to aid in 

its analysis of the effects of the BS project to late successional habitat:

Anderson, S.H. and B.J. Crompton. 2002. The effects of shelterwood 

logging on bird community composition in the Black Hills, Wyoming. 

Forest Science 48(2):365-372.

Baker, W. L., and D. Ehle. 2001. Uncertainty in surface-fire history: 

the case of ponderosa pine forests in the western United States. Can. J. 

For. Res. 31: 1205-1226.

Shinneman, D.J. 1996. An analysis of range of natural variability, 

roads, and timber harvesting in a Black Hills ponderosa pine forest 

landscape. M.A. Thesis, University of Wyoming, Laramie. 99 p.

Shinneman, D.J. and W.L. Baker. 1997. Nonequilibrium dynamics 

Late successional habitat is considered structural stage (SS) 5, 

page 19 of the EA. Table 7, pages 19-20, shows structural 

stages across the project area by cover type. There are no acres 

of SS5. The “Forest Vegetation” section in Chapter 3 of the EA 

discusses late succession; clarification has been added in the 

EA. Late successional habitat is discussed under individual 

wildlife species that require it for habitat. See the “Wildlife” 

section of the EA. 

This reference was reviewed during analysis. 

This reference was reviewed and does not provide any new 

information. 

Could not find this reference. 
Briggs Spring Environmental Assessment Appendix H

H-82

between catastrophic disturbances and old-growth forests in ponderosa 

pine landscapes of the Black Hills. Conservation Biology 11:1276-

1288.

This reference was reviewed and it does not provide any new 

information. 

7xxx • Fragmentation, connectivity

We request the FS fully analyze and assess the direct, indirect, and 

cumulative impacts of the BS project to fragmentation in the project 

area and the BHNF as a whole. We request the FS fully disclose how 

the project will affect connectivity between mature or late successional 

stands and how past timber harvesting has cumulatively affected 

connectivity. Such an analysis and assessment must pay attention to the 

impact of road-related fragmentation, edge effect, and patch size. The 

following sources provide invaluable information that will enable the 

FS to complete an adequate analysis and assessment:

Baker, W.L. and G.K. Dillon. 2000. Plant and Vegetation Responses to 

Edges in the Southern Rocky Mountains. Pages 221-245 in Knight, 

R.L, F.W. Smith, S.W. Buskirk, W.H. Romme, and W.L. Baker, eds., 

Forest Fragmentation in the Southern Rocky Mountains. University 

Press of Colorado, Boulder.

Murcia, C. 1995. Edge effects in fragmented forests: implications for 

conservation. Trends in Ecology and Evolution 10:58-62.

Shinneman, D.J. 1996. An analysis of range of natural variability, 

roads, and timber harvesting in a Black Hills ponderosa pine forest 

landscape. M.A. Thesis, University of Wyoming, Laramie. 99 p.

Shinneman, D.J. and W.L. Baker. 1997. Nonequilibrium dynamics 

between catastrophic disturbances and old-growth forests in ponderosa 

pine landscapes of the Black Hills. Conservation Biology 11:1276-

1288.

Shinneman, D.J. and W.L. Baker. 2000. Impact of Logging and Roads 

on a Black Hills Ponderosa Pine Forest Landscape. Pages 311-335 in 

Knight, R.L, F.W. Smith, S.W. Buskirk, W.H. Romme, and W.L. 

Baker, eds., Forest Fragmentation in the Southern Rocky Mountains. 

University Press of Colorado, Boulder.

The “Wildlife” section of the EA discusses effects, including 

cumulative effects, of project activities to species and habitat. 

See response to 7www in relation to late successional stands. 

The “Forest Vegetation” section of the EA also discusses 

effects, including cumulative effects, of project activities. See 

the wildlife specialist report and the silviculture specialist report 

for more detailed analysis; these are located in the project 

record. There is no late succession habitat in the project area. 

This reference could not be found.

This reference was reviewed and does not provide any new 

information. 

This reference could not be found.

This reference was reviewed and it does not provide any new 

information.

The reference was reviewed and does not provide any new 

information. 

7yyy • Roads, routes, ways, etc.

The BHNF must be aware of the fact that every new road created will 

The Briggs Spring project does not propose any new road 

construction or designate new OHV trails. A Roads Analysis 
Briggs Spring Environmental Assessment Appendix H

 H-83

 

be utilized by off-highway vehicles (OHV), whether or not the BHNF 

formally closes the roads in the future. Thus, new roads will offer that 

many more opportunities for unmonitored recreation and creation of 

new and illegal user routes on the Forest. The DEA does not fully 

analyze and disclose the impacts this project will have on the TMP 

process, as well as all other types of impacts from new and

reconstructed roads.

The DEA does not fully disclose the existence of all roads, ways, twotracks, illegally created routes, off-road vehicle routes, ATV trails, and 

any other pathway that facilitates the transportation and movement of 

motorized vehicles. This is necessary so that the FS can adequately 

analyze and assess the impacts of any and all proposed travel 

management plan to the environment, especially the impacts of road 

construction/reconstruction, road openings, and adoption of usercreated routes as Forest System Roads. The FS must also give attention 

to the cumulative impacts of off-road vehicle use and the illegal 

creation of vehicle routes in the project area. If the FS only analyzes 

classified roads and ignores existing and possibly illegally created offroad vehicle routes or other non-classified routes, ways, etc., then the 

agency cannot possibly assess the effects of travel management. This 

disclosure is also necessary so that the public can fully understand the 

existence of vehicle routes within the BS project area and understand 

the effects of leaving open, closing, decommissioning, constructing, or 

reconstructing routes within the area. We also point out that the FS 

must adhere to the 2001 road rule in determining an appropriate 

transportation system in the BS project area.

Additionally, in analyzing and assessing the impacts of roads, we 

request the agency clearly address the following concerns:

o How will roads be “closed”?

o Will “closed” roads remain open to administrative and periodic

public use?

Process (RAP) was completed for this project. Approximately 

0.8 miles of unauthorized road would be converted to a Forest 

System road in both action alternatives. No closures of forest 

system roads were identified in the RAP or proposed. 

Alternative 2 includes a new campground designed for OHV 

users. See the “Transportation” section of the EA for effects to 

travel. Maps 9-11 of the EA in Appendix A, show existing 

roads and trails, as well as any changes proposed for the action 

alternatives. Any decisions made under the Travel Management 

Plan on the Forest concerning open and closed roads and trails, 

are outside the scope of the Briggs Spring project. GIS data of 

road and trails in the project area are located in the project 

record. 

This project does not propose to close any system roads. 

Temporary roads used for implementation will be closed using 

physical closures, such as rocks, berms, slashing, etc. 

The Forest Travel Management decision did include closure of 

system roads. That decision and its implementation are outside 

the scope of this analysis. 
Briggs Spring Environmental Assessment Appendix H

H-84

o What is the effectiveness of the proposed methods of road closure?

o What is the most effective form of road closure?

o Will the agency have funding and staff to effectively and adequately 

enforce road closures?

o What level of funding and staff are necessary to enforce road 

closures?

o What level of funding and staff does the FS currently have committed 

to enforce road closures?

o If gates are used, what is the effectiveness in using gates to prevent 

use of roads?

o What does “decommissioning” mean?

o Will the FS undertake road obliteration and revegetation?

o If not, why not?

o Will user-created routes continue to be created in the project area?

o What are the impacts associated with user-created routes?

o Is off-road vehicle use a problem in the area?

o What are the impacts associated with off-road vehicle use?

 

All temporary roads used for project activities would be closed 

during post resource management activities.

The Forest Travel Management decision prohibits off-road 

motorized travel. Any existing user-created routes were 

addressed in the Forest Travel Management decision. 

7zzz • Fuels Reduction treatments

We request the FS provide scientific information and analysis 

supporting the effectiveness and the reasonableness of the proposed 

fuels reduction treatments. We also request the FS fully address the fact 

that many of the large fires that have burned on the BHNF in the last 

few years have burned in areas that had been logged and thinned. The 

BS Project Area has recently been logged on at least 19 occasions. 

There does not appear to be any relationship between silviculture 

treatments and potential fire behavior. We therefore request that the 

Supporting scientific literature can be located in the Literature 

Cited section of the Briggs Spring EA, pages144-153. The Fire 

and Fuels specialist report, located in the project record, also 

contains supporting scientific literature used for analysis. 

See page 80 of the EA, Figure 5 shows large fire history in and 

around the project area. Fuels treatments do not eliminate the 

potential for fires to occur. Fuels treatments modify the existing 

fire hazard rating, which alters potential fire behavior and 

severity. 
Briggs Spring Environmental Assessment Appendix H

 H-85

 

proposed vegetation treatments not occur.

The following sources provide invaluable information that will enable 

the FS to complete an adequate analysis and assessment:

Carlson, J. (2008). Potential Risks and Impacts to Soil and Water 

Resources from Mountain Pine Beetle Mortality, Treatments and 

Wildfire in Colorado and Wyoming National Forests. USDA Forest 

Service. Rocky Mountain Regional Office. Mary H. Peterson, Lead 

Forest Supervisor. Bark Beetle Steering Committee. April 11, 2008

Kulakowski, D., T. T. Veblen, P. Bebi (2003) Effects of fire and spruce 

beetle outbreak legacies on the disturbance regime of a subalpine forest 

in Colorado. Journal of Biogeography 30 (9), 1445–1456.

Romme, W.. H., J. Clement, J. Hicke, D. Kulakowski, L. H. 

MacDonald, T. Schoennagel, and T. T. Veblen. 2006. Recent forest 

insect outbreaks and fire risk in Colorado forests: a brief synthesis of 

relevant research. Colorado Forest Restoration Institute, Fort Collins,

CO.

We request the FS fully explain whether or not private landowners in 

the project area have undertaken or are undertaking measures to create 

defensible spaces around their structures. If landowners have not taken 

such measures, then it is likely that the proposed fuels treatments

around these properties will do nothing to protect homes or the land. 

The FS must give serious consideration to the effectiveness of its fuels 

reductions in relation to the protection actually afforded to people 

living within the forest.

This reference was used during analysis.

This reference was reviewed and does not contain any new 

information. Literature specific to the Black Hills was used 

during analysis. 

This reference was reviewed and does not contain any new 

information. Literature specific to the Black Hills was used 

during analysis. 

Whether or not private landowners have taken measures to 

protect their structures is outside the scope of this project. 

7aaaa • Sacred sites

The DEA fails to fully analyze and assess the potentially significant 

effects to American Indian sacred sites in accordance with Executive 

Order 13007. We request that all sacred sites be fully protected.

We also remind the agency that if any alternative is eliminated from 

analysis on the basis that it does not meet the purpose and need to 

“produce timber” or “provide commercial timber”, the agency is 

unreasonably restricting the range of alternatives through an 

unreasonably narrow purpose and need. If the agency proposes a 

See the “Heritage Resources” section of the EA, pages 102-104. 

Also see the Heritage specialist’s report in the project record. 

South Dakota State Historic Preservation Office (SHPO) has 

concurred with the determination of “No Adverse Effect”, dated 

September 6, 2011. 

Refer to response to comment 7a on range of alternatives.
Briggs Spring Environmental Assessment Appendix H

H-86

purpose and need that entails several objectives (e.g., wildlife habitat 

enhancement, improve forest health, etc.), then the agency must

analyze all alternatives that meet at least one of the objectives.

We hope the agency chooses a different path with regards to the 

proposed BS logging project and sets a new and necessary standard of 

ecosystem management on the BHNF. While we do not request the 

agency pursue a No Action Alternative, we do request the agency not 

undertake any logging, thinning, or any other vegetation management. 

We do request the agency undertake Wildland Urban Interface 

treatments where appropriate and where private property owners have

fulfilled their individual responsibilities to protect their own property, 

road decommissioning, and the closing of unauthorized motorized trails 

throughout the BS project area.

Additional References

Belsky, A.J. and D.M. Blumenthal. 1997. Effects of livestock grazing 

on stand dynamics and soils in upland forests of the interior west. 

Conservation Biology 11:315-327.

Hargis, C.D., C. McCarthy, and R.D. Perloff. 1994. Home ranges and 

habitats of northern goshawks in eastern California. Studies in Avian 

Biology. 16:66-74.

Patla, S.M., 1997. Nesting Ecology and Habitat of the Northern 

Goshawk in Undisturbed and Timber Harvest Areas on the Targhee 

National Forest, Greater Yellowstone Ecosystem.

Reynolds, R.T., and H.M. Wight. 1978. Distribution, density and 

productivity of accipiter hawks breeding in Oregon. Wilson bulletin. 

90: 182-196.

Reynolds, R.T. 1979. Food and habitat partitioning in two groups of 

coexisting Accipiter. Corvalis, Oregon: Oregon State university. 116 p. 

Ph.D. dissertation.

Smith A. A., and R. W. Mannan.1994. Distinguishing Characteristics 

of Mount Graham Red Squirrel Midden Sites. The Journal of Wildlife 

Your comments are noted. 

This reference was reviewed and it was found to provide no new 

relevant information. The effects of grazing have been analyzed 

in previous EA’s. 

Could not find this reference.

This reference was reviewed and it does not provide any new 

information.

This reference was reviewed and it does not provide any new 

information. 

Could not find this reference. 

This reference was reviewed and does not provide any new 

relevant information. 
Briggs Spring Environmental Assessment Appendix H

 H-87

 

Management, Vol. 58, No. 3 (Jul., 1994), pp. 437- 445.

Suggested Reading: Bark Beetle and Disease Science

Negron, J.F., K. Allen, B. Cook, and J.R. Withrow Jr. Susceptibility of 

ponderosa pine, Pinus ponderosa (Dougl. Ex Laws.), to mountain pine 

beetle, Dendrotonus ponderosae Hopkins, attack in uneven-aged stands 

in the Black Hills of South Dakota and Wyoming USA.

Worall, J.J., L. Egeland, T. Eager, R.A. Mask, E.W. Johnson, P.A. 

Kemp, and W. Shepperd. Rapid mortality of Populus tremuloides in 

southwestern Colorado, USA. Science Direct. Forest Ecology and 

Management 255 (2008) 686-696. Available online:

www.elsevier.com/locate/foreco or www.sciencedirect.com

This reference has been reviewed during analysis. 

This reference was reviewed and does not provide any new 

information. 

8a Nancy 

Hilding

Briggs Spring EA, comments, letter # 3

Please accept these comments in addition to those we have already 

submitted via BCA and other earlier PHAS letter.

Where does the following objective apply?

Objective 10-01: Manage for 50 to 75 percent moderate-to-low fire 

hazard in the wildland-urban interface and reduce fire hazard within 

proximity of structures to current NFPA standardsŠ

Objective 10-01 applies to the wildland urban interface and AtRisk Communities within and adjacent to the Briggs Spring 

project area. See the EA, page 83, Table 29. Table 29 shows 

Fire Hazard Rating for the project area, with 54% at high to 

very high and 46% at low to moderate. 

8b To our knowledge there is no urban-wildland interface in this area. 

Where is timber being removed due to proximity to structures?

See the EA, “Fire and Fuels” section, pages 81-82. Figure 6 on 

page 81 shows At-Risk Communities adjacent to the project 

area and structures on private property located within the project 

area. Pennington County RapidMap shows approximately 11 

residences contained within the project area and an additional 

15 more within a three mile radius of the project boundary. 

Commercial treatments proposed to improve forest health would 

have a secondary benefit of reducing fire hazard. Mechanical 

fuels treatment would occur only on trees <9” in diameter. See 

Tables 2 and 4 in the EA for the definition. 

8c Table 2 indicates a low level of canopy closure (Structural Stage 4A) 

for the vast majority of the area. What is your reason for harvesting 

such areas?

Table 2 of the EA (page 10-11) is the “Alternative 2 – Proposed 

Action non-commercial treatments” table. There is no 

discussion of “canopy closure” in this table. The table explains 

the proposed non-commercial treatments. Table 7 displays 

existing structural stages in the project area. The purpose and 
Briggs Spring Environmental Assessment Appendix H

H-88

need for action is discussed in Chapter 1 of the EA. 

8d We object to timber harvest along Six Mile Road. This is an important 

elk use area and, as it stands, any treatment would be detrimental to elk.

Your comment is noted. See page 75 of the EA, for effects to 

Rocky Mountain Elk. See Appendix B, pages B-6 –B-7 for 

design criteria to retain screening cover for big game species 

along FSR 301 (Six Mile Road). 

8e We note that in the Rattlesnake decision regarding the inventoried

roadless area along Sand Creek, the Forest Service claimed it could 

effectively manage fire and bark beetles with prescribed fire. We feel 

that this option should be developed for this project.

Using prescribed burning to ‘manage fire and bark beetles’ is an 

alternative not considered in detail. Briggs Spring project does 

not have a roadless area. The Briggs Spring project does 

propose prescribed fire as a management tool for the project 

area. See Chapter 2 of the EA, for prescribed fire for each 

alternative and see the “Fire and Fuels section, pages 77-90.

8f We note that reduction of fire hazard is an objective. We further note 

that where salvage logging has been preformed south of Deerfield 

Lake, red beetle-killed trees are left standing. We find this practice 

belies the stated objective.

Thank you

The Briggs Spring project does not propose any salvage 

logging.