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1. The Black Hills National Forest is being harvested at levels that are not biologi- 

 cally sustainable, and has been for some years. This has attracted large corporate 

 timber operators, who have pressed for retaining these excessive harvesting levels to 

 pay off their investments rapidly. This has led to an expansion of local employment 

 sufficient to mask the overall downward employment trend within the national 

 timber industry. As harvesting returns to sustainable levels, the impact on the local 

 timber workers will be accentuated, since they will feel the full brunt of both indus- 

 try mechanization and lower overall harvest levels. 



2. There is too much milling capacity in the Black Hills for local forest resources 

 to support. The large, corporate mills moved into the Black Hills in 1982-83, when 

 the timber harvest level was raised in the 1983 Forest Plan. Currently, there is mill 

 capacity for 300 million board feet per year, more than triple the amount biological- 

 ly producible from National Forest lands, and more than double the amount produc- 

 ible from all local sources. Of course, a shakeout within the industry is the inevita- 

 ble result, and this is now reaching to the levels of the smaller corporate mills. 



3. Mechanization of logging and milling operations is reducing the need for labor. 

 This is an industry-wide phenomenon, and is eliminating jobs within the timber in- 

 dustry at the rate of 50 percent per decade (based on the labor required per million 

 board feet). Since the harvests from the forest cannot be doubled each decade indefi- 

 nitely, long term loss of jobs within the timber industry is also inevitable. 



4. The tendency within the industry is toward bigness. This involves more than 

 mechanization of the logging and milling operation. It also involves the scale of 

 timber sales most efficient for such logging methods. These are in the 5-10 million 

 board foot range, sales on which small operators and local mills cannot possibly bid. 

 The local mills have virtually dropped out of the timber bidding process over the 

 past year. 



Increased public involvement may play a dovetailing role in this increase in the 

 size of the timber sales being offered, since the Forest Service can reduce its paper- 

 work burden through larger sales. However, this is a minor effect compared to tech- 

 nological and organizational changes within the industry itself. 



Local jobs can be retained in the short term only by limiting or prohibiting 

 mechanized logging and upgrading of milling technology. These jobs would be saved 

 at the expense of overall industry efficiency, so that such short term gains might 

 merely offset longterm losses. Since much of the local timber comes from public 

 lands, however, this tradeoff (jobs vs. industry efficiency) should be given serious 

 public debate. 



The current layoffs at Continental are not due to any shortage of timber coming 

 off of Forest Service lands. Fiscal 1992 saw 119 million board feet offered for sale, or 

 about the level projected in the 1983 Forest Plan. Continental's problems arise frorn 

 its inability to present winning bids for these offerings. This is due to the determi- 

 nation of Pope & Talbot and Crook & Co. to survive the current shakeout, and to 

 their greater success at submitting winning bids. 



Continental may be at a competitive disadvantage due to its more labor-intensive 

 operations. Again, on public lands forestry, the question arises as to whether all- 

 mechanical logging is in the best interests of the local timber industry. 



Of course the local loggers and small towns are not responsible for the current 

 State of affairs, any more than environmentalists are. These workers and communi- 

 ties may have been deceived by industry promises, they may have been unwilling to 

 see the handwriting on the wall (e.g., the inevitable job losses due to machine har- 

 vesting), they may have simply hoped against hope that the jobs would last. They 

 deserve our sympathy and support, but that doesn't change the fact that major re- 

 adjustments are inevitable. 



They may not find it very palatable to admit, but the changes that environmen- 

 talists have been requesting on the Black Hills would have produced a longer 

 stream of timber industry jobs, since forest practices would have been more labor- 

 intensive and at sustainable levels. 



D. Improper Use of Even-Age Management 



NFMA clearly requires even-aged management to be used only in exceptional 

 cases, rather than as the norm. On the Black Hills National Forest, even-aged man- 

 agement is being routinely applied in situations and under conditions for which is it 

 clearly not the optimal, or even a desirable, alternative. 



On May 12, 1993, Judge Robert Parker ordered a halt to continued even-aged log- 

 ging in the national forests of east Texas. Judge Parker relied on the express re- 

 quirement in the NFMA that the Forest Service must insure that even-aged cutting 

 be "carried out in a manner consistent with the protection of soil, watershed, fish. 



