67 



viable, but unexamined alternative. Cities for a Better Henderson v. Hodel, 768 F.2d 

 1051, 1057 (9th Cir. 1985); see also 40 CFR 1502.14(a) (Agency must rigorously and 

 objectively evaluate all reasonable alternatives). 



The importance of evaluating a sufficient range of alternatives to a reasoned 

 choice was explained by the District Court for Montana: 



This court recognizes the broad scope of an agency's duty to study all reasona- 

 ble alternatives. Appearing twice in the text of NEPA, the duty is more perva- 

 sive than the duty to prepare an EIS. 



Bob Marshall Alliance v. Watt, 685 F.Supp. 1514, 1521 (D. Mont. 1986) (emphasis 

 added). 



The ultimate decision as to the development of alternatives remains with the 

 agency. However, NEPA requires that alternatives benefiting all of the resources 

 that the Forest is required to manage be at least considered during the development 

 of the EIS. This is especially true here, where we have been requesting an analysis 

 of additional wilderness for nearly 2 years now. 



Our repeated request for an analysis of 25 percent old grovrth plus an additional 

 25 percent mature, closed-canopy forest is also a reasonable and viable alternative. 

 We request that such an analysis also be included among the alternatives presented 

 in the Draft EIS. Such an alternative would clearly include the proposed wilderness 

 additions within these less intensively managed areas; however, we ask that the 

 analysis be sufficiently disaggregate and detailed to allow assessment of the wilder- 

 ness areas on their own merits. 



Below, we summarize some of our main concerns and suggestions from our past 

 revision comments and appeals. 



1. Riparian Areas and Wetlands 



Riparian habitat is critical to many species, and given the land ownership pattern 

 in the Black Hills, these areas on the Forest are of critical concern. These areas are 

 not only highly productive in themselves, but they "boost" the overall productivity 

 of the adjacent landscape up to a point where species can maintain healthy popula- 

 tions. 



We believe that a major revision in management direction is needed to address 

 the retention of riparian-upland ecosystems as one landscape unit, instead of the 

 typical pattern of leaving riparian buffer strips and taking everything else. Riparian 

 standards should establish a minimum percentage of the linear distance along 

 streams that must retain large tracts of upland forest; an absolute minimum should 

 be at least 50 percent. Within the riparian area itself, 70 percent of the forest 

 should be old growth. 



Riparian habitats need to be blended in with old growth and forest interior habi- 

 tat standards to provide contiguous habitat units. At least 50 percent of riparian 

 forests should be contiguous with old growth and forest interior habitat. 



2. Deer and Elk Cover 



The standards for maintaining cover along roads and openings for deer and elk 

 are completely inadequate to provide quality big game habitat, and must be radical- 

 ly altered in the new Forest Plan. The security area concept recently developed ap- 

 pears to provide a better means of measuring big game security. At present, the 

 minimum threshold level of this security habitat has been suggested as 30 percent 

 of the landscape. 



We believe it is critical that a forest-wide standard establish the minimum level of 

 30 percent security habitat that has recently been recommended by Montana Forest 

 Service and Montana Department of Fish, Wildlife and Parks biologists. This re- 

 quires that 30 percent of the landscape exist as at least 250 acre blocks of generally 

 contiguous forest habitat that is at least V2 mile from open roads. This measure pro- 

 vides a much more meaningful criteria for big game security than does Habitat Ef- 

 fectiveness or cover levels. This standard would fit in nicely with the retention of 

 forest interior and old growth habitat, and limitation of total road densities to one 

 mile per section. 



3. Forest Interior Habitat 



The Forest needs to implement a conservation strategy to maintain forest interior 

 habitat; this will be structural stage 4C and 5 stands. It is becoming increasingly 

 evident that large tracts of forest interior habitat, which are threatened on public 

 lands, are not only needed to maintain forest interior wildlife, but to prevent exces- 

 sive predation and brood parasitism on species that can tolerate more open forest 

 habitats. We suggest that a forest-wide standard should be the retention of a mini- 



