72 



wildlife, recreation, and aesthetic resources, and the regeneration of the timber re- 

 source." 16 use 1604(gK3)(F)(v). Judge Parker concluded that: 



The NFMA states that the Service can use even-aged logging practices only in 

 the exceptional circumstances — i.e., only when such is insured to be consistent 

 with the protection of the forest's natural resources. And this statutory duty 

 clearly requires protection of the entire biological community — not of one spe- 

 cies (e.g., the Red-Cockaded Woodpecker) alone. Indeed, the imposition by this 

 provision of such a broad and stringent duty to protect reflects the truism that 

 the monoculture created by clear-cutting and resultant even-aged management 

 techniques is contrary to NFMA-mandated biodiversity. See 16 USC 

 1604(g)(3)(B). 



The Black Hills Forest continues to implement even-aged management as the 

 rule, rather than the exception. Indeed, these practices are mandated by the silvi- 

 cultural prescriptions in the Forest Plan. Given the increasingly obvious connection 

 between excessive even-aged logging and degradation of biodiversity, the public can 

 reasonably conclude that the 1983 Forest Plan is in violation of the National Forest 

 Management Act. 



II. SOUTH DAKOTA WILDERNESS ACT 



In the Wilderness Act of 1964, Congress declared its commitment "to secure for 

 the American people of present and future generations the benefits of an enduring 

 resource of Wilderness." Since then, only one wilderness area, the 10,700 acre Black 

 Elk Wilderness surrounding Harney Peak, has been created in the 1,235,000 acre 

 Black Hills National Forest. The Sierra Club believes that the expressed will of the 

 Congress can only be effected in the Black Hills National Forest by expanding the 

 wilderness system, and that only in this way can the diverse benefits of these glori- 

 ous public lands be preserved for generations to come. 



An expansion of the wilderness system in the Black Hills National Forest is 

 sorely needed. The Black Hills was the first National Forest established in the 

 United States. The Forest Service's first timber sale occurred here, providing tim- 

 bers to the Homestake Mining Company. Mining, grazing, and logging have been 

 practiced for more than a century. Historical preclusion of homesteading on forested 

 lands led to the extensive privitization of mountain meadows and open areas, espe- 

 cially riparian areas. Decades of vigorous fire suppression and extensive logging 

 have led to denser stands of smaller trees over most of the forest. More recently, 

 pressures from suburbanization and recreational uses have increased. 



The Black Hills National Forest is far and away the most developed, suburban- 

 ized, and intensively managed forest in the Forest Service's Region II, which in- 

 cludes Colorado, Wyoming, South Dakota, Nebraska and Kansas. Its extensive pri- 

 vate inholdings and high accessibility to logging have produced the highest road 

 density in the region. Combined with a near-ideal climate for Ponderosa Pine, an 

 intensive logging program produces 42 percent of the region's annual timber produc- 

 tion. Eighty four percent of its total acreage has been declared suitable for logging, 

 with a current annual harvest of nearly 150 million board feet. This is three times 

 the volume of the region's second-ranking timber producer, Colorado's San Juan Na- 

 tional Forest, and twelve times the average timber production of the other 16 forests 

 in the region. 



In short, the Black Hills National Forest is much more developed and intensively 

 managed than other western National Forests. In 1989, only one National Forest in 

 the entire country — Oregon's Winema — surpassed the Black Hills in number of 

 acres logged. Nearly 300,000 acres within the forest boundary are not under Forest 

 Service control, and are experiencing increasing pressure from ranchers and private 

 developers. The Black Hills' only existing wilderness area, the Black Elk Wilderness 

 near Mt. Rushmore, is among the most popular in Region II, yet it comprises less 

 than 1 percent of Forest lands. Demand for a wilderness experience on the Black 

 Hills National Forest is fast approaching the maximum physical and social carrying 

 capacity of the Black Elk Wilderness. 



While comparison across forests is made difficult by variations in topography, 

 soils, climate, and dominant usage, the accompanying table nevertheless gives a 

 clear indication of the extensive multiple-use pressures on the Black Hills National 

 Forest (the Bighorn National Forest, which is more typical of Forests in Region II, is 

 located 200 miles to the west in Wyoming). 



