Appendix A Calumet Project Area Public Involvement and Collaboration 

APPENDIX A 

PUBLIC INVOLVEMENT 

AND 

COLLABORATION 
APPENDIX A –PUBLIC INVOLVEMENT and COLLABORATION 

During project development and analysis period, collaborative efforts were made to involve, 

interact, and cooperate with individuals and groups interested in the Calumet Project. Part of this 

effort included public scoping as discussed below. 

Scoping 

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

determine the breadth of issues to be addressed by project actions. The Calumet Project was 

entered into the Schedule of Proposed Actions (SOPA) in September 2011. A scoping letter 

soliciting comments on the proposed action, potential concerns, and opportunities for managing

the Calumet Project Area was mailed to approximately 542 members of the public, American 

Indian Tribes, other public agencies, adjacent property owners, organizations, and Forest Service 

specialists on October 14, 2011. A Notice of Intent (NOI) to prepare an EIS was published in the 

Federal Register on Monday, October 24, 2011. The Notice of Intent and Scoping letter were 

also made available on the Black Hills National Forest website in October 2011. 

A mailing list of property/land owners was generated for the project area by obtaining names and 

addresses from property tax roles held in the Pennington County Department of Equalization. The 

county databases were queried for land/property owners within or near the project area. 

Approximately 509 names were generated. Scoping letters were mailed to these contacts. 

Also, other groups or individuals who are known to have or may have interest in management of 

the National Forest (and specifically this project area) were included on a mailing list and 

contacted with a scoping letter. The mailing list is held in the Calumet Project File. 

A concerted effort was made to engage in consultation regarding the project with Tribal contacts 

known to have interest in management of the National Forest. 

A public meeting was held at the Mystic Ranger District Office in Rapid City, SD on Thursday, 

November 03, 2011. At the meeting, key members of the ID Team presented the project 

proposal to the public, questions were answered, concerns and issues were solicited and 

documented for consideration. Members of the Whispering Pines Volunteer Fire Department 

attended the public meeting and participated in discussion with ID Team members. The public 

scoping period for this project ended on November 23, 2011. Comments were received in 

writing at the public meeting, via regular mail, email, telephone, and personal contact. 

Opportunity to Comment

The public was provided an opportunity to comment on the Calumet Draft Environmental Impact 

Statement (DEIS) during a 45-day comment period. This comment period began when a Notice 

of Availability (NOA) was published in the Federal Register on Friday, June 15, 2012. A Legal 

Notice was published in the Rapid City Journal, newspaper of record, on Saturday, June 16, 2012 

announcing an Opportunity to Comment on the Calumet DEIS. The comment period ended on 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 3 

July 30, 2012. The Mystic Ranger District received 16 responses, including letters, emails, 

facsimiles, phone calls, and meeting with individuals at the Mystic Ranger District Office in 

Rapid City. The responses have been analyzed using a process called content analysis. 

Comment Content Analysis and Agency Response Process 

Content analysis is a method developed by a specialized Forest Service unit, the Content Analysis 

Team (CAT), for analyzing public comment. This method employs both qualitative and quantitative 

approaches. It is a systematic process designed to provide a mailing list of respondents, distinguish 

specific comments in each response, evaluate similar comments from different responses, and from 

those, identify specific concerns. 

The content analysis process strives to identify all relevant issues, not just those represented by the 

majority of respondents. In addition to capturing relevant factual input, the content analysis identifies 

the relative emotion and strength of public sentiment behind particular viewpoints. The intention of 

the content analysis process is to represent the public’s viewpoints and concerns as fairly as possible, 

and to present those concerns in such a way as to assist the ID Team in effectively responding to them. 

The ID Team reviewed the public comment statements and considered the substance of the concerns, 

evaluated whether they triggered a change in the environmental analysis, and drafted responses. For 

some comments, they reviewed the original letter or other input to ascertain the full context for the 

concern statement. 

The ID Team provided any recommendations for adjustments to the DEIS analysis or documentation 

to the Team Leader for review, consideration, and action. The ID Team provided responses to 16 

letters and 45 public comments. No public comment on the DEIS generated the need for reanalysis 

of the alternatives. Additional discussions and/or factual and clarifying information have been 

incorporated in the document. 

In general, the ID Team responded in the following ways to public concerns as prescribed in the 40 

CFR 1503.4. 

• Modify alternatives including the proposed action. 

• Supplement, improve, or modify analysis. 

• Make factual corrections. 

• Explaining why the comments do not need further Forest Service response. 

In response to the comments on the DEIS, the ID Team has made factual and clarifying corrections in 

the document, and/or explained why changes are not warranted. Minimal response (basically 

acknowledgement) has been made to concerns stating a position or an opinion. However, these 

positions and opinions have been compiled by the ID Team for consideration by the Responsible 

Official. Some specific suggestions for management of the project area may be adopted by the 

Responsible Official, other specific concerns are beyond the authority of the Forest Service and 

beyond the scope of the DEIS or determined to be impractical. None of the comments necessitated 

reanalysis of alternatives. 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 4 

The following is a list of individuals and organizations that commented on the Calumet Project 

Area DEIS: 

Name Organization City State 

Mr. and Mrs. Lyle & Wanda Wanda Millard Revocable Trust Appleton Wisconsin 

Van De Hey 

Mr. Gary Kluthe Rapid City South Dakota 

Ms. Suzanne J. Bohan, US Environmental Protection Denver Colorado 

Director Agency, Region 8 

Mr. and Mrs. Roger & Eva Frye Rapid City South Dakota 

Mr. Josh Van Vlack, Forester Neiman Timber Company Hill City South Dakota 

Mr. Dick Artley Grangeville Idaho 

Mr. Carson Engelskirger Black Hills Forest Resource Rapid City South Dakota 

 Association 

Mr. and Mrs. Walt & Cheryll Rapid City South Dakota 

Cannon 

Ms. Sheila Lindquist Albuquerque New Mexico 

Mr. Mervin Guthmiller Rapid City South Dakota 

Mr. Robert F. Stewart US Department of the Interior Denver Colorado 

 Office of Environmental Policy & 

 Compliance 

Ms. Ruth Thatcher Rapid City South Dakota 

Ms. Cynthia A. Bjerrum Oehlerking Holdings Lmtd. Partnership Mitchell South Dakota 

Mr. Bob Black Rapid City South Dakota 

Ms. Jean Public Flemington New Jersey 

Mr. Dennis L. Murphy Unknown 

Public Comment on the Draft EIS 

Public comment on the Draft EIS was rich and varied, and reflects, for the most part, respondents’ 

livelihood, lifestyle, and/or position/opinion on issues or concerns. 

In general, the majority of the respondents living within and adjacent to the project area are very 

supportive of vegetation management to reduce the mountain pine beetle infestation and the risk of 

wildfire under the action alternatives. The following are sample excerpts from original responses: 

“I have read several pages and scanned the remainder of the pages of the draft of the Environmental 

Impact Statement and agree completely with your proposal B. I cannot see any negative impact on 

the environment as a result of moving ahead with proposal B. All the benefits of thinning the 

designated forest make it a project worth moving ahead as quickly as possible.” (Letter 5) 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 5 

“I applaud all efforts to combat the Mountain Pine Beetle epidemic. I also commend the 

thoroughness of the Calumet Project Area Draft Environmental Impact Statement.” (Letter 11) 

“We feel that the timing of this project is very important. We support the use of Healthy Forest 

Authorities and the Action Alternative B. The Calumet Project Purpose and Need is also correct 

in addressing the heightened risk to MPB infestation and fire hazard resulting from the current 

forest conditions.” (Letter 15) 

Agency Response to Public Comments 

In the content analysis process, each response is assigned a unique number (ID) and given a number 

(Letter Number). This ID allows analysts to link specific comments to the original letter. All 

respondents’ names and addresses are entered into a project-specific database, enabling creation of a 

complete list of all respondents. Each comment is given a number (Comment Number) and is coded 

by response. The following report: Calumet DEIS Public Comment and Agency Response Report

contains the complete list of respondents’ comments and the Agency’s response. Original letters are 

held in the Calumet Project File at the Mystic Ranger District Office in Rapid City. 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 6 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

1 1 Plan

Kluthe, Gary

Comment:

Please remove me from your Calumet Project Area mailing list.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

2 1 Fire/Fuels

Artley, Dick

Comment:

The Calumet project clearly deceives the public.

The DEIS at pg. 34 states:

“Most of the Calumet Project Area is outside of its historical range of variability and can be classified as Fire Regime I, Condition 

Class 3 (FRCC). As discussed in other parts of this EIS, FRCC is a classification system for the amount of departure from the 

natural (historical) fire regime of vegetation and fuels conditions in a given area (see Chapter 6 Glossary for full definition of FRCC). 

The Pennington County Community Wildfire Protection Plan designates most of the project area as wildland-urban interface (WUI). 

The project area includes the ‘at-risk’ community of Rockerville, 4,155 acres of private lands, subdivisions, businesses, and a major 

recreational complex.”

Perhaps THE most urgent responsibility of a public land manager is to protect the public living near national forest land should a 

wildfire occur. Fuels reduction timber sales have become a favorite of line-officers. They supply volume and they provide good PR 

with the lay public. Given the fact that hazardous fuels reduction projects are not the most effective way to reduce the risk of fire 

damage to homes in the WUI the USFS does it anyway. Why? It helps to achieve volume expectations given the timber budget. 

Placing personal advancement above the safety of the public is criminal.

Agency Response:

Fuel arrangement, both horizontal and vertical, is a primary factor in fire spread, intensity, and severity. Reducing crown densities 

through vegetative management, (which can include commercial thinning) can have a positive effect of reducing fire hazard (Black 

Hills Phase II Amendment p.III-351). By breaking up fuel continuity, both aerial and surface, rates of spread within a potential wildfire 

could be reduced. A running crown fire threatens forest resources, private property and human life. Commercial and noncommercial thinning and prescribed fire can be effective in breaking up forest fuel continuity. Fuel breaks around private property 

would also be constructed where other treatments are not planned (Calumet DEIS pgs. 139-142).

Letter No: Comment No: Resource:

2 2 Plan

Artley, Dick

Comment:

Bush and Rey did a number on the American public when they sent the HFRA to congress. Every bit of vegetation in the forest will 

burn. The USFS line-officers have learned to exempt timber sales from appeal by declaring it an HFRA sale. The HFRA allows lineofficers to violate the Appeals Reform Act of 1992 with impunity.

Agency Response:

The Healthy Forests Restoration Act (HFRA) of 2003 (H.R. 1904) provides improved statutory processes for hazardous fuel 

(including insect/disease) reduction projects and healthy forest restoration on National Forest System lands. HFRA contains a 

variety of provisions to expedite hazardous fuel reductions on specific types of National Forest land. The Calumet Project is an 

authorized hazardous fuel reduction project under Section 102(a)(4) of the Healthy Forests Restoration Act of 2003. The area 

qualifies under section 102(a)(4) because there is an existing mountain pine beetle epidemic occurring within and adjacent to the 

project area which poses a significant risk to resource values on National Forest and private lands (see Determination of Insect 

Epidemic letter held in the Project File). See Calumet DEIS pg. 20.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 7 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

2 3 Fire/Fuels

Artley, Dick

Comment:

Dr. Jack Cohen is a USFS fire physicist working in Missoula, Montana. He has devoted his entire working career researching 

methods to reduce the risk of fire damage to homes located in the WUI. If you aren’t familiar with Dr. Cohen’s research, please see 

attachment #11.

Dr. Cohen’s fire damage risk reduction methods are the most effective that exist. He does not recommend logging merchantable 

trees miles from the WUI as is being proposed here. This is why he is a black-sheep in the USFS. The USFS does not want the 

public to learn about Dr. Cohen’s research because this would eliminate another excuse to commercially log the national forests.

Dr. Cohen recommends removing fine flash fuels within a few hundred feet of a home at risk. That’s why kindling is used to start a 

fire in the fireplace,

If the new FEIS for the Calumet project does not analyze a Dr. Cohen alternative in detail it will be necessary to inform the public in 

your area about Dr. Cohen’s fire risk reduction methods myself and disclose why Supervisor Bobzien pretends the methods don’t 

exist.

My OpEd or letter to the editor will suggest that the public contact Ranger Thompson and ask him why a Cohen alternative was not 

analyzed in detail and to distribute a package of written material describing how to implement his methods.

The line-officer’s routine response to a request to analyze a Cohen alternative in detail is “the work occurs on private land.” I advise 

you not to try this Ranger Thompson.

You see, logging does not solve everything. Indeed, logging creates reason to spend tax dollars on real restoration projects that do 

not log or build roads.

Agency Response:

Dr. Cohen’s research helped create Firewise, an interagency, cooperative effort to spread solid information that can help a property 

owner positively prepare their home for a wildfire. However, to limit treatments to the immediate area of private property would not 

meet the purpose and need of the Calumet Project (see Calumet DEIS pg. 21). Furthermore, fires in the Black Hills have been 

observed to loft fire brands up to one half mile in front of a fast moving crown fire. Approximately fifty percent of the project area 

receives a high to very high fire hazard rating to limit treatment to the immediate WUI would not adequately protect forest resources, 

private property, or life safety.

Letter No: Comment No: Resource:

3 1 Plan

Black, Bob

Comment:

I'm all for you. Hope you can keep the enviros out of your hair and off your back.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

4 1 Veg

Frye, Roger & Eva

Comment:

I have property on Wrinkle Valley Road on Horse Creek. I have sprayed my trees for the Pine Bark Beetle. My property backs up to 

the Forest Service. I would hope our government would stop sending enormous amounts of money to unfriendly foreign country and 

take care for our own country. Don't let groups like the Sierra Club keep you from taking of this problem. The government should 

spend whatever it takes to spray the entire forest. Thank you for your efforts in saving our forest.

Agency Response:

Comment noted.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 8 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

5 1 Veg

Guthmiller, Mervin

Comment:

I have read several pages and scanned the remainder of the pages of the draft of the Environmental Impact Statement and agree 

completely with your proposal B. I cannot see any negative impact on the environment as a result of moving ahead with proposal B. 

All the benefits of thinning the designated forest make it a project worth moving ahead as quickly as possible. 

Thanks much for thinning the forest north of our development (Stratmeyer Development) and northwest of Baker Timber. The grass 

is already growing in that area. I am sure the deer are enjoying it.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

6 1 Plan

Thatcher, Ruth

Comment:

I have no comments, please keep me informed.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

7 1 Botany

Cannon, Walt & Cheryll

Comment:

Walt and I walk the Forest Service canyon next to our home twice a day. We know it! It has biodiversity already. We have mature 

trees, both evergreen and deciduous, well-spaced. We have a large meadow. We have categorized the flora and fauna for years 

and would be glad to list the things we KNOW live in this canyon, including tanagers, frogs, a turtle, wood lilies, crossbills, and 

hundreds of wildflowers and grasses.

Agency Response:

Comment noted. The Black Hills National Forest Land and Resource Management Plan establishes multiple use goals and 

associated objectives for management of the Forest. Goal number 2 is to “provide for a variety of life through management of 

biologically diverse ecosystems.” The proposed action (Alternative B.) for the Calumet Project strives to achieve vegetation and 

wildlife diversity, while limiting the spread of mountain pine beetle and reducing the risk of wildfire. See Calumet DEIS pgs. 32-33.

Letter No: Comment No: Resource:

7 2 Hydro/Soils

Cannon, Walt & Cheryll

Comment:

The Forest Service area is the watershed for our well, and MANY homes both on Sawmill Rd. and the next road over. We are 

overbuilt and all of us use the water we have wisely. It is not plentiful. There is no aquifer under us. All of our water trickles into a 

huge gravel reservoir underground from precipitation over a huge Forest Service area next to us. Please be careful with that FS 

acreage. It literally "is" our water.

Agency Response:

Design criteria and mitigation measures to protect both surface and ground water resources are listed in the Calumet DEIS, pgs. B-1 

through B-17. These measures apply to proposed management activities aimed at treating and preventing further MPB infestations, 

road work, and prescribed burning. These measures are fully expected to protect water resources within the Calumet Project Area, 

including the contributing watershed area for the water collection gallery described in the comment (Deadman Creek area, located 

at the eastern edge of the Calumet Project Area).

An alternative designed to address water quality in this specific area was considered based on private landowner comments during 

public scoping. As presented in the Calumet DEIS on pgs. 32-33, this alternative was dismissed from further study due to the 

inclusion of these measures that apply to all water bodies across the project area.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 9 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

7 3 Veg

Cannon, Walt & Cheryll

Comment:

Walt got a permit and with the help of a neighbor, fell many trees infested with pine beetle. They are all down. We keep a close eye 

for new infestation and plan to remove trees as necessary, with your permission, of course. We appreciate the effort you are taking 

in the Calumet Project Area. A forest is a renewable resource. I hope the wheel of knowledge circles back to this plain truth.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

8 1 Plan

Public, Jean

Comment:

the us dept of agribusiness should never be in charg eof our national forests, because it is totally exploiting and decimating these 

sites.

we want our kids to have some natural land left, but usda is busily logging, mining, grazing and killing all the animals that need a 

home in these sites. the usda is desttroying the ecology of every site the people of the united states have bought and tried to 

protect. we need to move management of these sites out of the usda, where greed is paramount.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

8 2 Plan

Public, Jean

Comment:

1. i prefer alt. l.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

8 3 Fire/Fuels

Public, Jean

Comment:

pg 33 - prescirbed burning pollutes the air. it releases mercury from burning vegetation. the burning causes lung cancer, heart 

attacks, strokes, allergies, asthma, pneumonia. such burning particularly hurts the young and old people

Agency Response:

The Fire and Fuels section of the Calumet DEIS addresses the effect on air quality by prescribed fire (See Calumet DEIS pgs. 161 

and 163). Also, see Calumet DEIS pg. 156 for air quality effects of the No Action Alternative (Alternative A).

Letter No: Comment No: Resource:

8 4 Fire/Fuels

Public, Jean

Comment:

pg 34 - i believe this agency is prmoting hysteria over potential fire hazard. this hysteria is pushed byt he forest fire emloyees who 

want jobs jpaying big money with lots of overtime. think about it, they dont have a job if there isnt a fire. and they get more money 

when they can burn all of the time. in this economy, such workers wantmoney. all of us need to waatch this....

pg 161 - mercury is released in burning. pollutants do not "DILUTE" QUICKLY.PUBLC HEALTH HAZARDS FROM AIR POLLUTION 

ARE SEVERE NOT NEGLIBLE. I BELIVE THIS AGENCY IS SPIN DOCTORING HYSTERIA OVER FIRE FOR MONEY FROM 

LOGGING. YOU ARE TRYING TO MAKE AMERICANS HYSTERICAL.

Agency Response:

Comment noted. See “An Increasing Hazard” section in the Calumet DEIS on pgs. 153-155. Also see “Fire Hazard” section in the 

DEIS on pgs. 149-150.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 10 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

8 5 Veg

Public, Jean

Comment:

pg 57 - i do not want logging. if the forest is under attack bybeetles, why would this agency further decimate it by logging it too. what 

will be left of this site owned by national taxpayers. national citizens own this land. they have a right to demand and control policy 

that is used on this site.

Agency Response:

Comment noted. See Calumet DEIS pgs. 21-22 for discussion of project purpose and need as well as proposed action. See 

Calumet DEIS pgs. 134-147 for discussion of Environmental Consequences for Alternatives A and B.

Letter No: Comment No: Resource:

8 6 Fire/Fuels

Public, Jean

Comment:

59 no prescribed burning should take place. these prescribe dburns go out of control. you may remember just last year the huge 

new mexico fire that was started by a prescribed fire that went out of control. you also may be aware that a target shooting range 

shot just started a fire in utah - maybe you shoudl make sure no guns ae shot on this site

Agency Response:

Comment noted. The Fire and Fuels section of the Calumet DEIS addresses prescribed fire planning and implementation 

(pgs.160,161). Also see DEIS pgs. B-21 through B-22 for Fire and Fuels Design Criteria, Mitigation, and Monitoring.

Letter No: Comment No: Resource:

8 7 Range

Public, Jean

Comment:

68 grazing is detrimental to soil, trampling and grazing makes an area ripe for uncontrollable firest and brings in invasive species. 

ban grazing....pg 169 water yields for stock ponds. these sites were not established where livestock come before health of the site. i 

oppose continuing grazing....Land does NOT recoverfrom grazing. it stays trampled and devoid of what formerly grew there.

Agency Response:

Decisions pertaining to Range Management are outside the scope of the Calumet Project. See Agency Response to Letter 10, 

Comment 4

Letter No: Comment No: Resource:

8 8 Veg

Public Jean

Comment:

pg 139 i oppose thinning. we need those trees to make osygen we need to breathe. we need them to prevent erosion. we need 

them to use carbon dioxide. we need them to provide homes for birds and wildlife. this agency is killling animals and birds when you 

log and thin trees for no good reson. this overwhelming greed to sell off evbery living thing for money is dangerous, depraved and 

disgusting...214 in view of climate change, all trees and species shuld be left alone and not attacked to kill them as this agency 

proposes. we may end up like easter island the way this agency is plannng.

Agency Response:

Comment noted. See Calumet DEIS pages 175-218 and Appendix D for effects of both Alternatives on wildlife species. See 

Calumet DEIS pages 212-213 for discussion on Climate Change.

Letter No: Comment No: Resource:

8 9 Veg

Public, Jean

Comment:

226 cutting christmas trees shoudl be stopped. they can b sold and the taking will never stop.the opublc which owns this site wants 

this practice stopped. the area can be decimated by this taking practice.

Agency Response:

Comment noted. Christmas tree cutting is outside the scope of the Calumet Project.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 11 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

9 1 Plan

Lindquist, Sheila

Comment:

I have no comments, please keep me informed.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

10 1 Hydro/Soils

US Environmental Protection Agency, Region 8

Comment:

1) Aquatic resources in the project area are of critical importance, requiring evaluation and mitigation of associated impacts...To 

further enhance disclosure and protection of aquatic resources, we offer a few suggestions, as discussed below.

The EPA considers protection of aquatic resources to be among the most important issues to be addressed in any NEPA analysis 

for vegetation management activities. Most treatments contemplated under the proposed action (e.g., thinning, overstory removal, 

sanitation harvest, cable logging, prescribed fire, and road construction) have the potential to adversely impact aquatic resources, 

including surface and ground waters, wetlands, streams, riparian areas, and their supporting hydrology. The Calumet Project DEIS 

provides good disclosure of existing aquatic conditions in the project area and potential project impacts.

Agency Response:

The Black Hills National Forest also concurs that aquatic resources within the Calumet Project Area are of high resource and social 

value. The need to protect these resources from adverse impacts that may be associated with the continued spread of mountain 

pine beetle is presented in Chap. 1 of the DEIS on pg. 24. Design criteria and mitigation measures to protect aquatic resources are 

listed in the DEIS, pgs. B-1 through B-17. These measures apply to proposed management activities under all action alternatives 

aimed at treating and preventing further MPB infestations.

Potential impacts to aquatic resources were analyzed for all alternatives associated with the Calumet Project. A summary of this 

effects analysis is presented in Chap. 3 of the Calumet DEIS, pgs. 40-117. More detailed supporting information is located in the 

project file and is available upon request to all interest parties.

Letter No: Comment No: Resource:

10 2 Hydro/Soils

US Environmental Protection Agency, Region 8

Comment:

1) Aquatic resources in the project area are of critical importance, requiring evaluation and mitigation of associated impacts...To 

further enhance disclosure and protection of aquatic resources, we offer a few suggestions, as discussed below. 

Existing Conditions: The Water Resources section of the DEIS references several important maps that are available in the project 

file, including a map of streams and a map of known wetlands, riparian areas, springs, fens and other ground water-dependent 

ecosystems. In order to better understand existing aquatic resource conditions, particularly for those resources near proposed 

treatment areas, we recommend including these maps in the DEIS Appendix E. Maps. In addition, on p. 100 of the DEIS, the 

Surface Water Quality section notes that recent water quality data for numerous parameters arc available from the USGS monitor 

on Spring Creek, just above the Sheridan Lake inlet. To understand current water quality conditions and inform future monitoring 

following project completion, we recommend that a brief summary of these data be included in the DEIS.

Agency Response:

Supporting data and maps were not included in the Calumet DEIS in the interest of keeping the document as concise as possible 

(per CEQ 1500.3). However this information was used to present the existing resource conditions and effects analysis of watershed 

resources, as summarized in Chap. 3 of the Calumet DEIS on pgs. 40-117. Maps of stream flow regime, water quality, wetlands, 

riparian areas, and ground-water dependent ecosystems are located in the project file and are available upon request to all 

interested parties. Maps and supporting information for current and past water quality are also available from the SD DENR at the 

following web link: http://denr.sd.gov/documents.aspx#Surface

Monitoring conducted at the listed sites in the Calumet DEIS on pg.100 is supplied to the SD DENR and included in the bi-annual 

assessment of water quality across the state. Where appropriate, this monitoring data is summarized in the SD DENR bi-annual 

Integrated Report for Surface Water Quality. The current and past reports are available from the same web link listed above.

A summary of water quality for water bodies currently not meeting all their assigned beneficial uses is presented in the Calumet 

DEIS pgs. 100-102. All other water bodies meet State assigned beneficial uses and the associated water quality criteria.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 12 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

10 3 Hydro/Soils

US Environmental Protection Agency, Region 8

Comment:

1) Aquatic resources in the project area are of critical importance, requiring evaluation and mitigation of associated impacts...To 

further enhance disclosure and protection of aquatic resources, we offer a few suggestions, as discussed below. 

Also, on pp. 95 and 111 of the DEIS, the Stream Channel Stability and Floodplains and the Ground Water-Dependent Ecosystems 

sections each reference additional water quality monitoring and field investigations necessary to quantitatively validate or revise 

several of the general stream health assessments and to confirm several fens identified in initial field investigations. We recommend 

clarifying that USFS is committing to complete these additional investigations and monitoring.

Agency Response:

Monitoring of stream stability is done concurrent with project implementation by the project hydrologist, wildlife/fisheries biologists, 

engineering personnel, and timber sale administrators. Additional field investigations to quantitatively verify stream stability on 

streams identified as having “Diminished” stream health according to USFS Region 2 protocols during qualitative assessments is 

beyond the scope of the Calumet Project, but has been included in the forest inventory of sites needing additional monitoring. 

Wetlands identified as potential fens have been added to the forest inventory for further, more detailed investigation and 

characterization. This ongoing work is being conducted by the project hydrologist as part of her doctoral research on fens in the 

Black Hills Region. All wetlands, including both known and potential fens, are protected by project Design Criteria listed in the 

Calumet DEIS, Appendix B.

Although this additional monitoring and investigation is outside the scope of the Calumet Project, a statement has been added to the 

Calumet FEIS discussions of stream stability and wetlands presented in Chap. 3 in order to clarify that other ongoing monitoring and 

investigations are occurring.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 13 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

10 4 Hydro/Soils

US Environmental Protection Agency, Region 8

Comment:

1) Aquatic resources in the project area are of critical importance, requiring evaluation and mitigation of associated impacts...To 

further enhance disclosure and protection of aquatic resources, we offer a few suggestions, as discussed below. 

Design Criteria, Mitigation Measures and Monitoring Plan: We support the Appendix B list of project design criteria, mitigation 

measures and monitoring requirements to protect aquatic resources, including special requirements for streams, lakes, wetlands, 

riparian areas, and ground water-dependent ecosystems (e.g., fens and springs). To ensure that project activities do not adversely 

impact aquatic resources, we recommend expanding the list as follows:

• Specify steps to protect range improvements (i.e., water developments, spring exclosures, fencing, corrals, etc.) from 

prescribed burning. 

• Specify a 5-year timeframe for monitoring hydrophobic soils following prescribed burns. 

• Monitor effectiveness of temporary and new road closures following treatment and adjust closure methods, if necessary.

• Monitor off-highway vehicle use in treatment areas following completion of project activities to ensure that removal of trees 

has not created access to non-designated areas.

• Clarify that the Appendix B project design criteria identified for wetlands apply to all wetlands, regardless of whether each 

wetland meets the regulatory definition of “jurisdictional," as noted on p. 109 of the DEIS.

• Monitor revegetation efforts for 5 years to ensure success.

• Specify steps to protect the Sheridan Lake North Marina Public Water Supply from project impacts.

• Monitor Sheridan Lake and its major inlet stream, Spring Creek, to ensure effectiveness of project design criteria in 

meeting the Total Maximum Daily Load requirements for management activities to reduce phosphorus loading.

Agency Response:

Monitoring items related to soil and water resources were inadvertently missing from the monitoring list in the Calumet DEIS. These 

monitoring items have been included in the Calumet FEIS and address many of the suggested monitoring items provided. 

The following Design Criteria were added to the Calumet FEIS (Appendix B) to ensure protection of range improvements during 

vegetation and prescribed burning operations:

• Fence lines, water developments, and other range improvements will be shown on Timber Sale Area Maps and 

designated as sites to protect.

• Cattleguards located on roads used during timber sales will be included in the road package as part of Timber Sale contract 

documents. Requirements for maintenance and/or repair of cattle guards damaged during timber sale operations will be 

included in this package.

• During prescribed fire operations, take measures to protect fences, water developments, and other range improvements 

from damage by fire or related equipment.

Monitoring of soil disturbance, including severely burned soils, was one of the monitoring items that was inadvertently missing from the 

monitoring list for watershed resources. This has been corrected in the FEIS. Post-burn monitoring of soils was included in design 

criteria listed in the Calumet DEIS (pg. B-11) to evaluate the presence and/or breakdown of hydrophobic soils following the application of 

fire. A timeframe was not specifically identified because hydrophobic conditions on the Black Hills have not been found to persist beyond 

a couple of years due to freeze-thaw cycling and vegetative recovery. In addition, prescribed burn operations generally do not result in 

hydrophobic soil conditions due to the low to moderate fire intensities used. Please refer to the discussion of prescribed fire effects on 

soils in the Calumet DEIS pgs. 71-74 and 78-79. 

Road closure design criteria is listed in the Calumet DEIS, pg. B-19. Roads used for logging operations will be closed as part of the 

post-use maintenance activities by the Timber Purchaser. Timber contractors are legally bound by the timber sale contract to perform 

specified road closure work. Timber Sale Administrators must inspect completed road work and accept it as effective prior to each 

individual timber sale unit and the overall sale to be considered completed. Road closure effectiveness is also monitored by district 

personnel as part of post-sale funded activities, depending on availability of funding. Some unauthorized roads may be closed as part 

of post-sale area improvement activities, and road closure effectiveness is also monitored by district personnel as part of post-sale 

activities, depending upon availability of funding.

EPA’s suggestion to clarify the wetland Design Criteria listed in Calumet DEIS pg. B-2 has been incorporated into the Calumet FEIS 

Appendix B.

Monitoring of soil disturbance, including vegetative recovery and effective ground cover, was one of the monitoring items that was 

inadvertently missing from the monitoring list in the DEIS. This has been corrected in the FEIS.

Protective measures for the Sheridan Lake North Marina public water supply are included in Design Criteria listed in Calumet DEIS 

Appendix B for protecting water resources and specifically addressed as part of measures related to activities near Sheridan Lake 

(Calumet DEIS, pgs. B-3 and B-4). The marina’s public water supply is a well located within the campground and is therefore 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 14 

protected by the listed Design Criteria. 

Water quality in Spring Creek and Sheridan Lake is monitored by the South Dakota Department of the Environment and Natural 

Resources (SD DENR). A memorandum of understanding (MOU) exists between the Forest Service and SD DENR, which states that 

implementation of Watershed Conservation Practices (WCPs), above and beyond the SD Forestry Best Management Practices (BMPs), 

would maintain or improve water quality. The Calumet Project incorporates both WCPs and BMPs to protect soil and water resources 

(Calumet DEIS pgs. B-1 through B-17). The Sheridan Lake TMDL is related to reducing phosphorus loading by controlling management 

activities on large impervious areas (i.e., urban areas), streamside grazing, streamside residences, and unstable stream banks. With the 

exception of unstable stream banks, the remaining activities are beyond the scope of the Calumet Project. Any unstable stream banks 

present in the Calumet Project will be protected or avoided as part of required Design Criteria and BMPs listed in the Calumet DEIS on 

pgs. B-1 through B-17. 

Timber Sale Administrators will closely monitor contractor operations and compliance with contract requirements, which incorporate 

design criteria developed from WCPs and BMPs. Sale administrators routinely consult with the hydrologist and other resource 

specialists as appropriate to ensure that measures specified in the planning document are implemented on the ground.

Letter No: Comment No: Resource:

10 5 Fire/Fuels

US Environmental Protection Agency, Region 8

Comment:

2) Air quality impacts associated with the project are a critical concern that must be fully evaluated.

It is particularly important to assess and mitigate air quality impacts associated with the Calumet Project given the project area is 

near the population center of Rapid City and two mandatory Class I Federal areas (Wind Cave National Park and Badlands National 

Park). We appreciate that the DEIS includes an Air Quality section that addresses many of our scoping recommendations related to 

air quality, including a summary of available data for existing conditions, a qualitative discussion of potential project emissions from 

prescribed fire and pile bums and a description of mitigation measures to address related prescribed fire emissions.

Existing Conditions: Information regarding current conditions will be an important tool for monitoring the impacts of project activities. 

Decision-makers will need to understand baseline conditions in an effort to ensure that Calumet Project activities, when combined 

with air quality impacts from external sources, do not adversely impact the National Ambient Air Quality Standards (NAAQS) or air 

quality related values (AQRVs). While the DEIS docs provide some baseline data related to the NAAQS, no baseline data are 

presented for Class I Federal areas near the project area. Therefore, we recommend broadening the existing conditions discussion 

to include the trending of air quality at the nearby Class I Federal areas over the past several years. (See the VIEWS site for AQRVs 

at http://views.cira.colostate.edu.web/.)

Agency Response:

The FEIS for the 1997 Revised LRMP (USDA Forest Service 1996) presented information on the affected environment of air quality 

in the Black Hills region on pages III-15 to III-18 which generally presented information on the National Air Quality Standards 

(NAAQS). The FEIS stated that air quality within the Black Hills National Forest is generally very good. Air quality is better than 

national ambient air quality standards (NAAQS) for all pollutants. The Forest Plan Phase II FEIS (pgs. III-442-447) identified some 

activities that could potentially affect air quality on the forest.

A solid working relationship exists between the Black Hills NF and the South Dakota Department of Natural Resources. There have 

been few, if any, problems identified and communicated to the Black Hills NF regarding negative impacts to air quality relating to 

prescribed fire activity in the last 10 years. The only case of known impacts was a short term event that lasted less than two hours. 

The USFS believes that the design criteria listed in the Calumet DEIS on pgs. B-21 through B-22 for Fire and Fuels have shown to 

be effective in past prescribed fires. The same design criteria will be utilized under the selected alternative for this project.

See Calumet DEIS, Chap. 3 pgs. 152-153 for Existing Condition discussion for Air Quality. Also see Calumet DEIS, Chap. 3, pg. 156 for 

Direct/Indirect Effects of the No Action Alternative (Alternative A) as it relates to Air Quality. See Calumet DEIS, Chap. 3, pgs. 161-162 

for Direct/Indirect Effects of the Proposed Action (Alternative B) as it relates to Air Quality. The Calumet DEIS on pgs. 163-164 discusses 

Cumulative Effects of Prescribed Fire as it relates to Air Quality.

See Agency Response to Letter 10, Comment 6.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 15 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

10 6 Fire/Fuels

US Environmental Protection Agency, Region 8

Comment:

2) Air quality impacts associated with the project are a critical concern that must be fully evaluated. Prescribed Fire: The proposed 

action includes the application of prescribed burning over multiple years to a total of 15,990 acres. This significant prescribed fire 

activity may cause degradation of air quality in the region. We appreciate the clear explanation of potential prescribed fire impacts 

and the detailed steps to minimize such impacts. We fully support the prescribed fire design criteria and monitoring 

recommendations as outlined in the Fire and Fuels section of the DEIS and as detailed in Appendix B. Since the proposed action 

also includes the use of pile burning, please clarify whether pile burns are included in the Burn Plans prepared for prescribed fire 

applications and/or are subject to the same process described in the Interagency Prescribed Fire Planning and Implementation 

Procedures Guide (July 2008).

Agency Response:

Historically, pile burning was covered by a forest wide programmatic pile burning Burn Plan. Forest leadership has directed the 

Districts to prepare their own individual pile burning Burn Plans. The Interagency Prescribed Fire Planning and Implementation 

Procedures Guide will be used in the writing of the new programmatic District plan. All critical elements will be addressed.

Letter No: Comment No: Resource:

10 7 Trans

US Environmental Protection Agency, Region 8

Comment:

2) Air quality impacts associated with the project are a critical concern that must be fully evaluated. Dust Control: Air quality and 

AQRVs are negatively impacted by dust. Under the proposed action, 15 miles of temporary roads are proposed. We recommend 

that detailed dust control plans be developed to include mitigation measures such as dust abatement, speed limits on unpaved 

roads, prompt revegetation and monitoring. Since dust can also severely impact vegetation along roadways, as well as contribute to 

water quality concerns associated with runoff of salts and sediments, we recommend that the monitoring plan include a schedule for 

5 years post revegetation to ensure success. Given the challenges associated with reclamation, the EPA believes that reduction of 

surface disturbance will be the most effective means of reducing dust in the Calumet Project Area.

Agency Response:

Temporary road miles shown in the Calumet Project Area are listed because they have the potential to be used for proposed 

treatment activities. The use of these roads, when requested and approved by the FS, will be of short time duration for proposed 

treatment activities only. The 15 miles of temporary roads identified are existing routes on the ground. These roads would be utilized 

to remove timber, however stand conditions may change and these temporary roads would not be utilized. Where roads have 

adequate width, vegetation may not require removal, thus reducing surface disturbance. Period of use when roads are snow 

covered will be another factor in minimizing dust from hauling. Restoration including seeding, closing, and in some cases 

recontouring will occur following treatment activities.

During treatment activities, the area is inspected and monitored frequently by Sale Administrators. Speed limits are not posted on 

National Forest System Roads. Traffic during treatment activities will also be monitored through contract inspections and if speeds 

are excessive, corrective action will be taken. Signs are also posted warning of truck hauling.

See Agency Response to Letter 10, Comment 5.

Letter No: Comment No: Resource:

10 8 Plan

US Environmental Protection Agency, Region 8

Comment:

EPA's Rating and Recommendation

Consistent with Section 309 of the CAA, it is EPA's responsibility to provide an independent review and evaluation of the potential 

environmental impacts of this project. Based on the procedures EPA uses to evaluate the adequacy of the information and the 

potential environmental impacts of the proposed action, The EPA is rating this DEIS as Environmental Concerns - Insufficient 

Information (EC-2). The "EC" rating indicates that EPA review has identified environmental impacts that need to be avoided in order 

to fully protect the environment. The "2" rating indicates that the EPA has identified additional information, data, analyses or 

discussion that should be included in the Final EIS to disclose and fully assess project impacts. A full description of EPA's rating 

system is enclosed.

Agency Response:

Comments and EPA's rating ("EC-2") are acknowledged.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 16 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

11 1 Plan

Van De Hey,Lyle & Wanda

Comment:

I applaud all efforts to combat the Mountain Pine Beetle epidemic. I also commend the thoroughness of the Calumet Project Area 

Draft Environmental Impact Statement.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

11 2 Lands/Minerals

Van De Hey, Lyle & Wanda

Comment:

In Appendix D-Summary of Biological Evaluations for Wildlife, Fisheries, and Botanical Resources in the Pactola Project Area of the 

Calumet Project Area Draft Environmental Impact Statement there are numerous statements indicating, “May adversely impact 

individuals, but not likely to result in the loss of viability in the Planning Area.” While those statements are referring to the various 

animals in the area I just want to say that I feel the portion of the plan that involves trading land “may adversely impact me” as an 

individual who will no longer own land next to the Black Hills National Forest but instead will own land next to another private 

landowner who may or may not have plans for the land that will impact me. So in other words, while I understand the Forest Service 

is doing what is best for the public in general I am worried about who my neighbor will be and what plans he/she have for the land 

bordering our property.

Agency Response:

This comment is outside the scope of the Calumet Project DEIS. The Calumet Project Proposed Action (Alternative B) does not 

propose any “trading land” (land exchange).

The land exchange that you are referring to was a part of the “Grey Hound Land Exchange with Capstone Properties, LLC” Decision 

Notice (DN) and Finding of No Significant Impact (FONSI) that was signed by Deputy Forest Supervisor Dennis Jaeger for Forest 

Supervisor Craig Bobzien on May 11, 2012. The DN and FONSI were subject to a 45-day appeal period (36 CFR 215). No appeals 

were filed.

Letter No: Comment No: Resource:

12 1 Plan

US Department of the Interior

Comment:

The U.S. Department of the Interior (Interior) has reviewed the Draft Environmental Impact Statement, Calumet Project Area, 

Multiple Resource Management Actions, Implementation, Pennington County, SD and has no comments.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

13 1 Plan

Oehlerking Holdings Lmtd. Partnership

Comment:

I have no comments, please keep me informed.

Agency Response:

Comment noted.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 17 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

14 1 Plan

Neiman Timber Company

Comment:

First, Neiman Timber Company would like to express its' support of Alternative B, the proposed alternative. We feel that the 

appropriate actions are being proposed to address the mountain pine beetle epidemic and resulting hazardous fuels within the 

project area. We also support the use of HFRA on this project. 

Alternative B 

Overall, we feel that this is a well prepared and timely project considering the rapid MPB expansion and heavy fuel loading within 

the project area. We agree that Alternative B meets the purpose and need of the project, however we have the following concerns.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

14 2 Veg

Neiman Timber Company

Comment:

Our primary concern is the number of acres being retreated in the former Bitter and Hollow timber sales. Nearly 20% of the 

proposed commercial/non-commercial treatments fall within the 2,718 acres of Bitter and Hollow. These sales were sold in 

2002/2003, and some Bitter units were completed as recently as 2008. The proposed silvicultural treatments are similar to those 

previously implemented. We would like the re-entry of these units explicitly justified within the FEIS. Given the amount of area 

requiring treatment across the forest, we have serious reservations about re-entering stands treated only four years ago.

Agency Response:

The Bitter Timber Sale was part of the Lakes EA which was signed in 2002, and the Hollow Timber Sale was covered by the Hollow 

EA which was signed in 1995. Both were prior to enactment of the Healthy Forest Restoration Act of 2003 (HFRA). At that time 

mountain pine beetle populations were at endemic levels in this area. We are currently dealing with epidemic conditions within the 

Calumet Project Area (USDA Forest Service 2012a). The Calumet EIS is being conducted under HFRA.

The recreation complex around Sheridan Lake is a high use and high value area. We want to keep the unique aesthetic values of 

the area by making the residual stands less susceptible to MPB infestations, which requires more open stand conditions.

Letter No: Comment No: Resource:

14 3 Veg

Neiman Timber Company

Comment:

Additionally, we encountered several issues in certain Bitter units that would need to be addressed on re-entry. First, while operating 

in the Beretta Road area, our equipment was subject to frequent vandalism and theft. The sheer quantity and type of traffic in the 

area lends itself to future conflicts. The bigger issue in the Beretta road area was the hidden damage and debris within the logs, 

making them unusable. A boundary change was made during logging, removing a large majority of the units adjacent to the 

shooting areas due to metal in the logs. For these reasons, NTC would not be interested in timber adjacent to the shooting areas 

within the project. The second issue that arose while logging Bitter involved the units in and around the Sheridan Lake 

campgrounds. The low volume and extremely technical tree removal around improvements make these areas more suitable for tree 

service type operations than commercial logging operations.

Agency Response:

Comment noted. Comparing shooting areas with treatment areas, most treatment units around Beretta Road are more than a quarter 

mile away from popular shooting locations. They also tend to be on the back side of the ridge away from the shooting areas. This 

should limit the amount of shooting fragments within the trees designated for harvest. The area would be evaluated for bullets in the 

trees during the layout process and we would exclude these areas. Areas that were dropped during the Bitter Timber Sale would not 

be laid out in Calumet. Also, the Beretta Road area could be temporarily closed to the public during harvest activities for the safety of 

personnel and equipment.

We are not planning to have a timber sale within the camp sites around Sheridan Lake. We will leave a buffer around sites and 

these areas will be treated with a sanitation removal to remove MPB infested trees as necessary.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 18 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

14 4 Veg

Neiman Timber Company

Comment:

Management Direction 

The project summary on page iii states that; "Ultimately, the intent [of the Calumet Project] is to limit effects to the environment from 

MPB and reduce the potential for loss of property or life die to large-scale wildfire." However, nowhere in the DEIS is any reference 

made to the national, regional, or local Mountain pine beetle management strategies. NTC feels that, at minimum, the Management 

Direction section of the FEIS should outline how the project meets the goals, objectives and actions outlined in the USFS Western 

Bark Beetle Strategy (WBBS), as well as the Black Hills National Forest Mountain Pine Beetle Strategy (BHNF-MPBS). These 

documents were developed for the purpose of guiding, directing, and prioritizing management activities, yet they are continually 

ignored. NTC strongly suggests that the FEIS outline in detail how, and to what extent, the action alternative will comply with the 

WBBS and the BHNF-MPB strategy.

Agency Response:

The WBBS and the Black Hills National Forest MPB Strategy are guidance documents for addressing NFS lands affected by MPB. 

These strategies, to varying degrees, are addressed by the Calumet Project Area. Actual treatments will follow Forest Plan Standard 

and Guidelines. Language has been added to the FEIS Chapter 1, “Other Direction” about the WBBS.

Letter No: Comment No: Resource:

14 5 Travel

Neiman Timber Company

Comment:

Travel Management 

We also have concerns relating to Travel Management that arose in our recent Joker Timber Sale ( Pactola Project). The Pactola 

DEIS and FEIS both state that the trail systems within the sale will be closed to facilitate logging operations, yet the Timber Sale 

contract places operation restrictions on logging activities due to the trail system. We do not wish to see this repeated in the Calumet 

Project area. the Travel Management section of the Calumet DEIS states: Some motorized trails and roads open to all that were 

system roads prior to designation as trails would be converted back to system roads to accommodate project activities and thus would 

not be available for non-highway legal motorized use, either seasonally or yearlong. Trails needed for project activities that were 

unauthorized routes or citizen submitted routes prior to designation would be closed to all motorized use during project activities. The 

Travel Management FEIS also states that Travel Management will have no impact on logging activities. We would like to see 

vegetation treatments given the highest priority within the project area, and no operation restrictions based on motorized recreation.

Agency Response:

Off-Highway-Vehicle (OHV) miles within the Calumet Project Area are significantly less than within the Pactola Project Area. The 

Calumet OHV miles are dispersed along the northeastern boundary, in the vicinity of Victoria Lake, and adjacent to and west of 

Highway 385 in the Horse Creek Area. 

Conversely, OHV miles in the Pactola Project Area are greater and concentrated in the northern portion.

The Black Hills National Forest Travel Management Plan Record Of Decision (ROD) “acknowledges that certain designated routes 

may not be available in any particular season or year because of contractor or timber purchaser operations, public safety, or 

resource concerns, leading to reduced miles available for OHV use” (See Calumet DEIS pg. 228).

The Calumet DEIS also includes design criteria requiring “timber sale prep and layout personnel to coordinate with the District 

Travel Management Coordinator during layout and prior to sale package preparation” (See Calumet DEIS pg. B-32).
Appendix A Calumet Project Area Public Involvement and Collaboration A - 19 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

14 6 Veg

Neiman Timber Company

Comment:

Best Available Science: 

In the winter of 2011 and 2012, Neiman Timber Company engaged in an exercise to map all new MPB activity within the BHNF. 

Utilizing the Forest Service 1M Digital Aerial Photography taken in the fall of 2011, NTC technicians identified and hand-delineated 

all new red top trees within the photo coverage. Every effort was made to exclude green patches within beetle killed areas, as well 

as other patches of timber mortality due to fire or other insects. This process was repeated for the 2010 Forest Service 1M Digital 

Aerial Photography. The resulting GIS data clearly shows the MPB caused mortality from the 2009 and 2010 MPB flights. We feel 

that this data is superior to the aerial sketchmapping data referenced in the DEIS, an opinion supported by the USFS document A 

Comparison of Aerial Sketchmapping and Aerial photo Interpretation Techniques for Conducting Forest Health Surveys in the Black 

Hills National Forest, Backsen and Howell, 2012. This data has been previously provided to GIS and resource staff at the 

Supervisors Office and is attached to these comments.

Agency Response:

To capture recent collaborative efforts for the Black Hills NF the following is summarized: Neiman Timber Company and the State of 

South Dakota hand-delineated red top trees from recent aerial photographs. For fiscal year 2012, there is a cooperative effort lead 

by State of South Dakota for late summer 2012 aerial photographs to repeat the digitizing to capture the mountain pine beetle 

attacks. The Forest Health flights do not have this degree of accuracy. The Forest Health aerial reconnaissance flight is not 

scheduled due to the improved accuracy of the digitizing of the aerial photo flight. The Forest Health program has elected to utilize 

the digitizing work to replace the annual Forest Health flight.

Letter No: Comment No: Resource:

15 1 Plan

Black Hills Forest Resource Association

Comment:

We feel that the timing of this project is very important. We support the use of Healthy Forest Authorities and the Action Alternative 

B. The Calumet Project Purpose and Need is also correct in addressing the heightened risk to MPB infestation and fire hazard 

resulting from the current forest conditions.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

15 2 Plan

Black Hills Forest Resource Association

Comment:

Overall, we would offer some general comments regarding the Calumet project. 

• We support the significant reduction in high risk acres to fires and bugs across the project area.

• We urge the use of landscape treatments, focusing on 80% and greater treatment of areas.

• With significant amounts of MPB caused mortality, the Calumet Project has the potential to reduce the level and extent of 

spread towards Rapid City.

Agency Response:

Comment noted. The pine stands that would be treated under Alternative B of the Calumet DEIS are typically those identified as 

having high hazard for MPB infestation. Some sites will not be treated due to access or operability issues and have been identified 

in the DEIS. After implementation of treatments it is estimated that 91% of the Calumet Project Area would have a MPB hazard 

rating of low. These treatments will also facilitate reduction of the high/very high fire hazard from 50% to 14%.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 20 

Calumet DEIS Public Comment and Agency Response Report

Letter No: Comment No: Resource:

15 3 Veg

Black Hills Forest Resource Association

Comment:

The following comments focus on implementation of the project: 

• We support and urge the use of a sanitation clause to allow for flexibility in responding to MPB within the Calumet Project 

Boundary.

• During the planning and layout of timber sales, we recommend extending the timber sale area boundaries far beyond the 

unit boundaries, allowing for effective response to new pockets of MPB.

• We generally support commercial thinning resulting in residual basal areas around 60. 

• We would recommend accounting for current MPB mortality in marking activities to ensure that stands are left with the 

desired residual basal area.

Agency Response:

Comment noted. Sanitation language is included in the DEIS. On the ground conditions and MPB activity are taken into account 

when laying out units, as are treatments for adjacent stands. While marking, MPB infested trees are not designated as leave trees. If 

MPB activity impacts a unit after it is marked and prior to harvest, the unit will be evaluated and may need to be remarked.

Letter No: Comment No: Resource:

15 4 Plan

Black Hills Forest Resource Association

Comment:

• We also recommend elevating the priorities of on the ground treatments over secondary uses such as OHV, scenic, 

recreation trails, etc. This will help reduce timing restrictions and allow greater flexibility during project implementation.

• Overall, we support Design Criteria similar to what was proposed in the Mountain Pine Beetle Response Project. These 

DC allowed for flexibility in MPB response while still protecting sensitive resources such as botanical, water, and wildlife.

Agency Response:

The Calumet DEIS utilizes design criteria that are based on Forest Plan direction and “Best Management Practices” (BMP). Some 

design criteria include clarification of the types of activities that would be consistent with Forest Plan standards and guidelines. The 

intent is to consider the different treatment methods, along with the purpose for the protective measures, and any potential risks to 

those protected resources, i.e., botanical, water, wildlife, heritage, and/or recreational use.

The Calumet DEIS design criteria does provide for flexibility. This is done in order to provide protection of resources across the 

project area, and on a site specific basis, minimizing the impacts resulting from implementation of the action alternative. In an effort 

to effectively manage the MPB outbreak, while remaining consistent with Forest Plan direction.

Letter No: Comment No: Resource:

15 5 Plan

Black Hills Forest Resource Association

Comment:

We would like to thank the Mystic Ranger District for allowing us to comment on the Calumet Project. We feel there is adequate 

analysis of proposed activities that meet the Purpose and Need. Again, we voice our support for Action Alternative B and urge 

implementation of a signed ROD as soon as possible.

Agency Response:

Comment noted.

Letter No: Comment No: Resource:

16 1 Plan

Murphry, Dennis

Comment:

Please add my email address to the distribution list for updates on the Calumet project.

Agency Response:

Comment noted.
Appendix A Calumet Project Area Public Involvement and Collaboration A - 21 

Calumet Project Area Draft Environmental Impact Statement Distribution List 

Name Organization City State 

V.R. Wood c/o Sherry Eckholm Hill City South Dakota 

Mr. Mark Krenn Real Estate & Construction, AT&T Rapid City South Dakota 

Mr. and Mrs. Gregory & Harrisburg South Dakota 

Jocelyn Myers 

Mr. and Mrs. Gene & Joan Rapid City South Dakota 

Bushnell 

Mr. Chris Cutler Rapid City South Dakota 

Mr. Reed Wilson Rapid City South Dakota 

Mr. Steve Hatlestad Garretson South Dakota 

Mr. Robin Berg USDA Forest Service Fort Collins Colorado 

 FHP/FHTET 

Mr. and Mrs. Brendan & Rapid City South Dakota 

Jonette Murphy 

Mr. Russell Payton Rapid City South Dakota 

Mr. and Lyle & Wanda Wanda Millard Revocable Trust Appleton Wisconsin 

Van De Hey 

Mr. Troy Du Bois, Storm Mtn Center Rapid City South Dakota 

Facility Manager 

Mr. Mike Skaare Rapid City South Dakota 

Mr. Chris Matkins Fort Collins Colorado 

Mr. John Bandel Hill City South Dakota 

Ms. Helen Maureen Hightower Placitas New Mexico 

Mr. Gary Kluthe Rapid City South Dakota 

Mr. Don Platnoe Rapid City South Dakota 

Mr. Breck Woodard Alexandria Virginia 

Mr. and Tom & Karen Murphy Rapid City South Dakota 

Mr. Daniel Paschke Rapid City South Dakota 

Mr. Gene Quinn Rapid City South Dakota 

Mr. Mark Balding Spearfish South Dakota 

Mr. John Jones Rapid City South Dakota 

Blue Wing Recreation Corp Rapid City South Dakota 

Mr. Steve Burling Rapid City South Dakota 

Mr. and Patrick & Sarah Brondos Hill City South Dakota 

Mr. Reg Pitts Rapid City South Dakota 

Mr. and Mrs. Roger & Eva Frye Rapid City South Dakota 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 22 

Mr. Josh Van Vlack, Neiman Timber Company Hill City South Dakota 

Forester 

Mr. and Mrs. John & Mary Rapid City South Dakota 

Groethe 

Mr. Dick Artley Grangeville Idaho 

Mr. Dean Fuelling Rapid City South Dakota 

Mr. Carson Engelskirger Black Hills Forest Resource Assoc. Rapid City South Dakota 

Ms. Kay Taylor Colorado State University Fort Collins Colorado

 Libraries - Documents Processor 

Ms. Nancy Hilding Prairie Hills Audubon Society Black Hawk South Dakota 

Mr. Colin Paterson, Norbeck Society Rapid City South Dakota 

President 

Ms. Lorraine McMahan Rapid City South Dakota 

Ms. Regina LeFort Arvada Colorado 

Mr. Elbert Johnson Rapid City South Dakota 

Mr. Dan Coon Rapid City South Dakota 

Mr. and Mrs. Walt & Cheryll Rapid City South Dakota 

Cannon 

Mr. and Mrs. Rolland & Hill City South Dakota 

Dawnette Owens 

Ms. Dawn Rice Rapid City South Dakota 

Ms. Sheila Lindquist Albuquerque New Mexico 

Mr. Mervin Guthmiller Rapid City South Dakota

Dr. Arden Christen Indianapolis Indiana 

Dr. Friesema Northwestern University Evanston Illinios

 Environmental Policy and Cultural 

 Program 

Mr. Dan Buehler Hill City South Dakota 

Mr. Vince Jones Hartford South Dakota 

Mr. and Dick & Carol Sethney Rapid City South Dakota 

Mr. Rich Jensen Rapid City South Dakota 

Mr. Daniel Comer Rapid City South Dakota 

Ms. Ruth Thatcher Rapid City South Dakota 

Mr. Dennis Nagel Rapid City South Dakota

Mr. Bill Cissell &Ms. Alicia Sturgis South Dakota 

Spencer 

Mr. A. Dean Oehlerking Oehlerking Holdings Lmtd. Mitchell South Dakota 

 Partnership 

Mr. and Mrs. Thomas & Crofton Nebraska 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 23 

Tara Pavlik 

Mr. and Mrs. Guy & Fargo North Dakota 

Beva Paulson 

Ms. Marilyn Schatz Gilbert Arizona 

Mr. John Halter Chandler Arizona 

Ms. Barbara Landguth Rapid City South Dakota 

Mr. Bob Black Rapid City South Dakota

Mr. Mark Pieloch Melbourne Florida 

Ms. Jean Public Flemington New Jersey 

Ms. Gayle Ostermann Menomomie Wisconsin 

Mr. and Mrs. LC Mike & Rapid City South Dakota 

Terri Vidal 

Mr. Brent Thurness Rapid City South Dakota 

Mr. and Mrs. Edwin & Rapid City South Dakota 

Evelyn Johnson 

Mr. Wayne King Rapid City South Dakota 

Mr. Norbert Sebade Rapid City South Dakota 

Mr. and Mrs. Randy & Rapid City South Dakota 

Mary Daughenbaugh 

Mr. and Mrs. Dwight & Iowa City Iowa 

Nancy Rossley-Barnes 

Mr. and Mrs. John & Rapid City South Dakota 

Denice Murphy 

Congressional: 

Senator Tim Johnson 

Senator John Thune 

Congresswoman Kristi Noem 

Native American Tribes: 

Cheyenne River Sioux Tribe Tribal Chairman 

Cheyenne River Sioux Tribe Tribal Historic Preservation Officer 

Cheyenne River Sioux Tribe Cultural Program Administrator 

Cheyenne/Arapaho Tribes Of Oklahoma Cultural and Heritage Program 

Cheyenne/Arapaho Tribes Of Oklahoma Governor 

Crow Creek Sioux Tribe Tribal Chairman 

Eastern Shoshone Tribe Tribal Chairman 

Eastern Shoshone Tribe Historical Preservation Officer 

Flandreau Santee Sioux Tribe Tribal Chairman 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 24 

Kiowa Ethnographic Endeavor For Preservation 

Lower Brule Sioux Tribe Tribal Chairman 

Lower Brule Sioux Tribe Director of Cultural Resource 

Mandan, Hidatsa & Arikara Nation Tribal Chairman 

Mandan, Hidatsa & Arikara Nation Cultural Preservation Office 

Northern Arapaho Tribe Tribal Chairman 

Northern Arapaho Tribe Tribal Historic Preservation Officer 

Northern Cheyenne Tribe President 

Northern Cheyenne Tribe Tribal Historic Preservation Officer 

Northern Cheyenne Tribe EPA Director 

Oglala Sioux Tribe President 

Oglala Sioux Tribe Tribal Historic Preservation Officer 

Rosebud Sioux Tribe President 

Rosebud Sioux Tribe Tribal Historic Preservation Officer 

Rosebud Sioux Tribe Sicangu Lakota Treaty Council Office 

Santee Sioux Nation Tribal Chairman 

Sisseton-Wahpeton Sioux Tribe Tribal Chairman 

Sisseton-Wahpeton Sioux Tribe Tribal Historic Preservation Officer

Spirit Lake Sioux Tribe Tribal Chairperson 

Standing Rock Sioux Tribe Tribal Chairman 

Standing Rock Sioux Tribe Tribal Historic Preservation Officer 

Standing Rock Sioux Tribe Environmental Protection Specialist 

Yankton Sioux Tribe Tribal Chairman 

Yankton Sioux Tribe Tribal Historic Preservation Officer 

Federal, State, County, and Local Agencies: 

Environmental Protection Agency, Region VIII EIS Review Coordinator 

USDA National Agricultural Library Head, Acquisitions and Serials Branch 

USDI Office of Environmental Policy and Compliance 

US Environmental Protection Agency, Office of Federal Activities, EIS Filing Section 

Advisory Council on Historic Preservation, Planning and Review 

USDA APHIS PPD/EAD 

USDA Natural Resources Conservation Service 

US Army Engr. Northwestern Division 

US Coast Guard, Environmental Management CG-443 

FAA Great Lakes Region 

Federal Highway Administration 

US Dept. of Energy, Office of NEPA Policy and Compliance 

US Bureau of Reclamation – Rapid City Office 

South Dakota Governor’s Office – Governor Dennis Duagaard 

South Dakota Department of Game, Fish, and Parks 

South Dakota State Historic Preservation Center 

South Dakota Department of Water and Environmental Resources 

South Dakota Department of Transportation 

South Dakota Division of Forestry 

Pennington County Commissioners 
Appendix A Calumet Project Area Public Involvement and Collaboration A - 25 

Pennington County Highway Department 

Rapid City Mayor’s Office – Mayor Sam Kooiker 

Rapid City Chamber of Commerce 

Rapid City City Council 

Rapid City Public Library