County calls for rethink of Black Hills National Forest Plan assessments

Crook County has joined the call for the U.S. Forest Service to rethink its draft assessments for the revised Black Hills National Forest Plan. A comment letter submitted by the county commissioners touts "significant concerns" with the science used to create the drafts, and with the level of public input solicited so far.

"I think we probably have some of the most comprehensive comments that will be submitted," commented Dru Palmer of Dru Consulting, who prepared the 21-page letter on behalf of the county.

The letter expresses concern that the draft assessments fall short of meeting the 2012 Planning Rule objective, which requires "the use of best available scientific information to inform planning and plan decisions" and emphasizes the need for meaningful opportunities for public participation.

"While the Forest Service did involve the counties early and worked with the counties to have additional time to review and provide comments on the assessments, the federal agency should have attempted to reach out more thoroughly to the public and interest groups or stakeholders for data to inform the assessments," states the letter.

"The counties did work to play a role in reaching out to private stakeholders but the overall process seemed to miss its intended goal."

The letter also lists several pages of specific issues within the draft assessments, ranging from a "a lack of consistent and thorough monitoring" in assessing aquatic, riparian and groundwater dependent ecosystems to the black-footed ferret being listed as present in the Bearlodge Ranger District with no supporting documentation.

Included in the letter are concerns about the assessment of timber within the Black Hills National Forest, a topic that has gathered significant interest following the announcement from Neiman Enterprises that it would be cutting hours at the Hulett sawmill. According to the letter, several statements made within the timber assessment suggest that the Forest Service had "already determined their preferred alternative for the revision process".

Said Palmer, the county is prepared to delay the process of preparing the new forest plan now in order to get a better product in the future.

County Involvement

The Forest Service holds 9% of the land within Crook County at 168,978 acres. According to the letter, the county has "a vested interest in proactive management of the Black Hills" and knows that any management decisions made now will impact the local economy now and into the future.

"It is imperative that this planning revision process reflect a balanced approach to multiple use management, while providing economic opportunities for our industries and communities to thrive," states the letter.

Commissioner Jeanne Whalen expressed the importance of the county's involvement in the planning process, sharing her concern that it could provide reasons to shut down access. For example, she said, the assessments only concentrate on endangered animals and don't include common, larger animals such as deer and elk.

Once things get shut down, Whalen said, it's hard to open them back up again.

Senator Ogden Driskill, present at the meeting, complimented Palmer on the comprehensive nature of the comments included in the letter.

"Your work is above and beyond, especially in such a short period," he said.

Driskill made note of his own concerns about the assessments, such as that there doesn't appear to be much mention of topics including snowmobiling and mining. He also spoke to the need to work hand-in-hand with the other counties, stating that he feels the outcome of the assessments was predetermined before they were written.

"We've got to be joined at the hip or we're going to lose," he said, later adding that this is about "whether we have access to our own forests."

On that note, Crook County is not the first to object to the draft assessments. The Black Hills Pioneer reported last week that Lawrence County had also asked for a second draft after passing a resolution stating that all seven counties within the Black Hills feel there are deficiencies that need to be addressed.

The resolution reportedly called for the second draft to address data gaps, utilize the best available scientific information, refrain from including obsolete data, refrain from bias and omit or acknowledge conflicting statements between the individual assessments. It also called for the Forest Service to properly engage all stakeholders and local governments.

However, Palmer told the commissioners last week that she felt the Lawrence County Commissioners acted too soon to pass the resolution, as it was "premature in the process" and Crook County's commission had not yet had an opportunity to have that discussion.

The commissioners decided to work on a resolution for Crook County alone, following a similar vein but not referring to the other involved counties. Whalen and Palmer agreed to work on the wording in time for the commission to consider it at the next regular meeting.

Cooperating Agency

In the meantime, the forest plan appeared on the commission's agenda a second time for discussion of the memorandum of understanding that would designate the county as a cooperating agency. Whalen expressed concern that the Forest Service wants a single point of contact, but the county would prefer to have three.

Specifically, the commissioners agreed that Palmer would be well-placed to act as the county's representative thanks to her extensive knowledge and experience. However, Whalen should be the alternate in case Palmer is unable to make one of the meetings – a possibility because Palmer is a consultant and therefore has more than one client's needs to meet.

Crook County Natural Resource District (CCNRD) is also eager to participate, preferably under its own umbrella.

"Our request is a seat at the table and the ability to write our own comments that re natural resource-based, rather than socioeconomic," explained Sarah Anderson, CCNRD.

County Attorney Joe Baron noted that the county's goal is "to get our person – Dru – on the committee that writes the plan" and CCNRD's involvement only increases the county's potential input. He advised the commissioners that he thinks it would be better for CCNRD to be a separate cooperating agent and sees no reason why the county should restrict them from doing so.

The commission decided to keep the two entities separate. However, no action was taken as the county is waiting on the Forest Service to proceed.