69 



9. Recreation 



Although the Forest Plan is currently being revised, the Forest Service has re- 

 fused to consider recreation as a revision topic; instead, the management practices 

 from the 1983 plan are to be retained for the next 10-15 years. The Black Hills 

 Group has repeatedly requested that recreation in general, and trail use in particu- 

 lar, be thoroughly addressed through a comprehensive recreation plan. 



Among the topics the Black Hills Group would like to see addressed are: increases 

 in primitive and semi-primitive non-motorized recreation; increased protection and 

 enforcement of the Centennial Trail and other trails from mechanized use; expand- 

 ed maintenance budgets and establishment of recreation staff positions within the 

 Black Hills Forest Service; and a forest-wide inventory of existing and potential 

 trails. 



No Forest Service planning document contains an inventory of hiking or cross 

 country skiing trails for the Black Hills; no published analysis of forest-wide trail 

 use currently exists. Yet the Black Hills are receiving increasing recreation pres- 

 sure as the area is promoted as a regional tourist destination. This conjunction has 

 produced a critical "window" for comprehensive recreation planning in the Black 

 Hills. Left unmanaged, these increasing pressures will soon degrade the quality of 

 the recreation experiences available throughout the Hills. 



The Forest Service must incorporate substantive recreation and trail systems 

 planning in the ongoing Revision of the Black Hills Forest Plan. We again ask the 

 Forest Service to consider the requirements of the Multiple Use — Sustained Yield 

 Act regarding recreation in the Black Hills National Forest. We feel that, given the 

 dominant timber usage on this Forest, that recreation, and the impacts of timbering 

 and grazing on recreation, must be included as a Forest Plan Revision Topic. 



B. Roadless Area Review 



The Black Hills Group of the Sierra Club is extremely concerned with the cava- 

 lier and pro forma "review" of roadless areas presented in the Analysis of the Man- 

 agement Situation, Ch. VIII, and as summarized in Alternative C of the Forest Plan 

 Revision. We find this review cursory, inadequate, and indefensible. This modest re- 

 quest for an additional 4 to 5 percent wilderness in the Black Hills is both reasona- 

 ble and viable; under scientifically defensible analyses, it may also be essential for 

 maintenance of biological diversity in the Black Hills. 



As was pointed out to you in a November 15, 1991, letter from our Northern 

 Plains Office, limiting your review to only previous RARE II identified roadless 

 areas was found to violate NEPA in California v. Block. Adding areas suggested by 

 the public does not remove from the Forest its obligation to review all areas for pos- 

 sible wilderness designation. 



By basing your review primarily on the flawed RARE II process which was pre- 

 pared 16 years ago, you will present interested individuals and groups with the op- 

 portunity to challenge the revised Plan not only on its merits, but also on the defi- 

 ciencies of the 1977 RARE II study. Given the dearth of wilderness on the Black 

 Hills Forest compared to the average of all Forest System lands, cursory review of 

 new wilderness designations will also allow the plan to be challenged on wilderness, 

 recreation, wildlife and watershed grounds. 



A number of potential roadless areas were presented to you by the Sierra Club, 

 including Pilger Mountain, Black Fox, Warren Peak, Hell Canyon, and Elk Moun- 

 tain. The recently completed Homestake land exchange also presents opportunities 

 in Stagebarn Canyon and Crow Peak. If a comprehensive inventory is conducted, we 

 believe that the Forest Service would recognize these areas as well as others suita- 

 ble for wilderness designation. 



We are dismayed by the shoddy logic and cursory review used to "disqualify" 

 Black Fox, Pilger Mountain, and Norbeck from more thorough review. No field re- 

 connaissance trips were conducted by the ID team in reaching their recommenda- 

 tions on these areas. We find this totally unacceptable, and ask that these areas be 

 given proper and thorough consideration in the Forest Plan revision. 



Black Fox was "disqualified" due to supposed heavy roading and planned timber 

 sales (AMS, p. VIII-5). These roads were never identified or documented as to their 

 technical standards; so far as we are aware, there are no engineered roads in Black 

 Fox. The other "reason" given for disqualification was four planned timber sales. 

 We have recognized the 1990 sale on the western limestone plateau, and have ad- 

 justed our proposal accordingly. Future sales planned for 1993 and 1997 have no 

 bearing whatsoever on the technical review required under NFMA. Compatibility 

 with future timber-program goals is not a consideration in the roadless review envi- 



