Letter to Hon. Tom Vilsack, Secretary of the Department of Agriculture - South Dakota, Wyoming Delegations Continue to Urge USDA to Prioritize the Health of the Black Hills National Forest and Its Timber Sale Program

Letter

Dear Secretary Vilsack:

We write to express our deep concerns with the recently announced drastic reductions to the
Black Hills National Forest (BHNF) timber sale program over the next three years. Unless the
Forest Service swiftly reverses course, its ability to care for the forest will be severely
compromised, and the economically-vital forest products industry that supports families in small
communities throughout the Black Hills will be decimated. Last year, a mill in Hill City, South
Dakota, closed due to log shortages, even in the midst of a robust lumber market, and we are
concerned that additional mill closures are imminent. Even if some smaller companies survive,
the Forest Service's capacity to manage the BHNF will be greatly diminished. If the remaining
mills are lost, the BHNF will ultimately turn into yet another overly dense national forest at risk
of expansive insect mortality and wildfires.

For more than 100 years, the timber sale program on the BHNF has been the primary tool for
successfully managing the forest and minimizing insect epidemics and catastrophic wildfires that
continue to plague other western national forests. In recent years, the BHNF successfully
defeated the mountain pine beetle epidemic because of its collaborative work with partners to
target and coordinate forest treatments, thereby increasing the overall amount of management.
While the forest products companies' limited annual capacity to treat acres was a primary
bottleneck in those efforts, retaining and utilizing the forest products companies' sawmill
infrastructure was central in the strategy to eradicate the pine beetle and protect the BHNF. This
was further confirmed in lessons learned documents prepared by the BHNF and others through
the collaborative process.

The recent Forest Service 10-year strategy to combat wildfires clearly states the need to
drastically increase the number of acres treated on our national forests, and the corresponding
need to build and retain an industry-driven infrastructure to complete the work. The 10-year
strategy includes the BHNF, which, for now, does not yet need to undertake the long (and often
unsuccessful) process of attempting to attract companies into an area to help manage the forest.
In the Black Hills, timber sales have historically been the primary means to treat hazardous fuels,
and the local forest products infrastructure has completed this important work. If the Forest
Service moves forward with significant reductions in the timber sale program, the infrastructure
that plays a critical role in implementing the strategy to confront the wildfire crisis will
disappear, crippling the agency's ability to manage and protect the forest in perpetuity.

In recent correspondence, Forest Service Chief Moore stated that the vast majority of the BHNF
suitable base for timber production has been analyzed under the National Environmental Policy
Act (NEPA) at least once. Yet, as described by the state foresters of Wyoming and South
Dakota and confirmed by the Forest Service's 10-year strategy, BHNF data shows areas
currently at risk of high severity wildfires. We believe the amount of previous analysis, acres
designated as insect and disease treatment areas, and the immediate need for management in
ponderosa pine systems optimally positions the BHNF to use many NEPA authorities to reduce
wildfire hazards.

We urge the Forest Service to immediately use all NEPA authorities available -- including the
fuel and fire break categorical exclusion and emergency actions authority recently passed by
Congress -- to expedite treatment on the BHNF in fiscal years 2022 through 2024, while planning
additional work in subsequent years. Also, in light of additional funding recently provided by
Congress to the Forest Service for wildfire reduction efforts, we urge the Forest Service to
provide funding and staffing resources necessary to be successful in this task. Thank you for
your prompt consideration of this request.

Sincerely,[...]