66 



In the Buffalo Gap National Grasslands, another 74,100 acres are proposed for 

 wilderness, including small portions of Badlands National Park. These areas are: 

 Indian Creek Badlands, 37,900 acres; Rake Creek Badlands, 16,700 acres; Red Shirt, 

 9,900 acres; and Cheyenne River, 9,600 acres. The proposed Act also requests that a 

 5,760 acre area around Crow Peak in the northern Black Hills be designated is a 

 Wilderness Study Area. 



I. BLACK HILLS FOREST PLAN REVISION 



The Black Hills Group has been active in forest issues in the Black Hills since its 

 inception in the early 1970's. The group was instrumental in the establishment of 

 the Black Elk Wilderness Area surrounding Harney Peak, which is the only wilder- 

 ness area in the Black Hills. The group sponsors monthly backcountry hiking and/ 

 or cross country skiing outings in the Black Hills, and publishes the definitive map 

 of the hiking trail system in the Black Elk Wilderness and the surrounding Norbeck 

 Wildlife Preserve. 



The 1983 Forest Plan for the Black Hills was one of the first forest plans formu- 

 lated under the National Forest Management Act. As such, it had no "models" to 

 emulate, and little guidance in comprehensive multiple-use planning was then avail- 

 able. As a result, many public lands issues, such as wildlife, water quality, and 

 recreation (and particularly non-motorized recreation) have received little manage- 

 ment emphasis, and totally inadequate levels of funding, since 1983. 



The Black Hills Group has extensive concerns regarding Forest Service manage- 

 ment policies on the Black Hills, and is particularly concerned with the limited 

 range of alternatives being offered to the public; the major issues not being ad- 

 dressed at all; and the failure of the Forest Service to adequately review viable wild- 

 life population issues, wilderness designations, and recreational needs on the Black 

 Hills National Forest. 



A. Forest Plan Alternatives 



The Black Hills Group is extremely disturbed at the choice of "alternatives" being 

 offered for public comment. As the Forest Service is well aware, most of the public 

 will assume that the ultimate decision is limited to the scope presented in these al- 

 ternatives. We strongly disagree, since there is nothing remotely resembling our 

 vision of future forest management presented in any of the alternatives. 



The major deficiency of all of the offered alternatives is that they do not meet, or 

 even describe, the minimum habitat conditions needed for viable wildlife popula- 

 tions. This has been the major issue in our appeals of the past 18 months, and to 

 date the Forest has declined to answer our concerns. Without establishing minimum 

 constraints on the set of all alternatives, development of alternatives such as those 

 presented to the public is little more than drawing lines on a map. 



We contend that none of the offered alternatives is even legal, since viable popu- 

 lation requirements have not been addressed. The Forest seems to be under the im- 

 pression that the regional office has upheld their actions over the past 18 months; 

 again, we strongly disagree. The regional office has upheld that "... these are not 

 project-level decisions, but are much more appropriately topics for Forest Plan Revi- 

 sion." We estimate that our recent appeals contain 150-200 such implicit remands 

 on just the viable populations issue. 



We have requested that the Forest review our concerns over wildlife raised in the 

 Kirk/Runkle, Limestone, Graveyard, Benchmark, Minnesota/ Moonshine, Victoria, 

 Mallo, Walker, and Wabash/ Buckhorn Appeals. These concerns were directly relat- 

 ed to Forest Plan management practices and prescriptions, and should be considered 

 as comments on the Forest Plan Revision. For comments on standards and guide- 

 lines, we also request that the Forest review our appeal of the Rocky Mountain Re- 

 gional Guide. 



It is becoming increasingly apparent that the Forest is unwilling or unable to 

 produce management alternatives that provide for balanced multiple use on the 

 Black Hills Forest. If the Forest cannot produce acceptable NEPA documentation on 

 viable populations, we suggest that, as a minimum, you designate 50 percent of the 

 suitable timber base as "non-scheduled" for the time period covered by the new 

 Forest Plan. 



A well established principle of NEPA is that the Forest Service must analyze al- 

 ternatives to any proposed action. 42 USC 4332(2)(c)(iii). The standard by which the 

 adequacy of alternatives is judged is one of reasonableness; an EIS must consider all 

 reasonable alternatives before arriving at a preferred course of action. Robertson v. 

 Knebel, 550 F.2d 422, 425 (8th Cir. 1977). While remote or speculative alternatives 

 need not be addressed, the range of alternatives must be adequate in order to pro- 

 mote a "reasoned choice". Id. An EIS is rendered inadequate by the existence of a 



