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driven more mills away from Forest Service timber sales. Price are driven up, contractual 

 requirements become more onerous, and the small business mills are either driven out of business 

 or they give up purchasing federal timber. 



All along the Forest Service has displayed an almost paranoid fixation related to fair and open 

 competition. In the late 1980's, after the liquidation by Pope & Talbot of the Garhart & Poole 

 mill in Spearfish, the Forest Service initiated an anti-trust investigation against many of the small 

 mills in the Black Hills. Policy was changed to require sealed bid only timber sales and 

 company records of all Black Hills mills were requested as part of a Justice Department anti-trust 

 investigation. After two years, the Justice Department dropped the investigation without bringing 

 any charges of wrong-doing. 



During this same time period, three mills were purchased and auctioned off by Pope & Talbot, 

 and one other was purchased that remains a Pope & Talbot operation today. 



It is important to remember that all this happened during a period of raising lumber markets. 

 None of these closures can be blamed on widespread adverse market conditions. The lumber 

 market during this period has continued to improve. Although some of these companies may had 

 been weakened by the timber market crash of the late 1970's, most had recovered and were 

 extremely competitive in the mid-eighties before the Forest Service either knowingly decided to 

 exterminate the small business mills in the Black Hills, or unknowingly bungled their 

 responsibility to maintain community stability while encouraging fair and open competition for 

 products sold off the National Forest. 



ADDITIONAL WILDERNESS IS NOT NEEDED AND WOULD ADVERSELY AFFECT 



FOREST HEALTH 



To understand the Black Hills National Forest, one must understand the pre-settlement conditions 

 which existed on the Black Hills, the cyclical nature of catastrophic fire and insect epidemic, and 

 review public use of the existing wilderness areas, including the Norbeck Wildlife area. 



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