Sunday, February 22, 2015

Item # 2, Events/Deadlines

We may shelter e-mail addresses by replacing @ with (at) 



New Section ON ISSUES
scroll down for various issues that are old files....some are out-of-date

1) SD river otters
2) Nest Predator Bounty Program
3) Mining
4) Protecting greater sage grouse 
A) SD  Mountain Lion Plan Revision & NE's hunting season's alert 
B) Mineral Mountain Resources Exploration project
C) Croell Sand/Gravel Mine Issue
D) Non-meandered waters Alert
E) Alert on Resilient Landscape DEIS (Forest Service)
F) announcement of Petitions to list or de-list under ESA and 
G)  S3254/SB 114 (Land Trade Little Spearfish Canyon & Bismark Lake) & 
H).  SD Important Bird Areas
I)  Missouri River Recovery
J) to Sage Grouse Litigation filed by PHAS and others in February  2016
K) then goes to - suspended campaigns discussions, 
for which comment deadlines have past, but related issues persist



NORTHERN RIVER OTTERS - 3 historic alerts combined
Alert #1 - Trapping Season
Alert # 2 - Otter Management Plan Revision
Alert # 3 - Otter Delisting

The issues in the otter section are now relevant to the September 2nd-3rd meetingwhen the Commission plans to approve a River Otter Management Plan - with no plans for West River reintroduction & only aspirational plans for monitoring.  


July 12, & July 16th-17th & IRRC meeting, August 18th)
SDGFP Commission meeting (historic)
Hunting season for river otters was considered.
Commission vote was on 7/17.
The 15 otter trapping season was approved by the Commission. The trapping area was reduced to be just the counties that overlapped the map of otter recovery area.  On 7/17 both the amendment to reduce area and motion to pass the season as amended, passed unanimously by the Commission. 
It was approved at the Interim Rules Review Committee meeting on 8/18.
To see data on historic Commission meetings

On PHAS web page (home page scroll down to August 18th)  are very long alerts on otters in which
 you can find reference material, more background and talking points in opposition to the trapping season. However some highlights might be:

1. You object to the otter delisting, done in May. GFP removed its' "threatened” status.
2. The otter delisting was done illegally, as GFP did not provide the required 30 days public notice. They only gave 23 day's public notice. Thus the trapping season is tiered to an illegal rule making action (the delisting of the river otter was done illegally).
3. It is suspected that the 15 otters might be taken in the first week. Every year about 15-16 otters are killed incidentally as non-target takes in other traps, but the otter season could be 2 months (or less) and other trapping seasons last 6 month (such as beaver) or are year long (such as raccoon), so the state might see 15 otters taken intentionally in November & 15 (or more otters) taken accidentally during the rest of the year. The average number of verified otters sightings each year was 35 otters.
4. SDGFP does not yet have a population monitoring plan, just the intention to work on developing one. A trapping season should not move forward,
 till a peer reviewed population monitoring plan is active.

 Recommended changes from last year: To establish a conservative river otter trapping season.
These were modified to make the season only in the far eastern side of the state.

1. Establish a trapping season that is open from sunrise on November 1 to sunset on
December 31 in all counties of the state.
2. Limit of one river otter per trapper per season.
3. Statewide harvest limit of 15 river otters. Season will end prior to December 31 if the harvest
limit is reached.
4. Trapping season open to residents only with a furbearer license.
5. A river otter shall be reported to the Department within 24 hours of harvest. At time of reporting, arrangements will be made to check-in carcass and detached pelt at a GFP office or designated location for registration and tagging of the pelt within 5 days of harvest. Additionally, once the season has closed (last day of season or harvest limit reached), a person has 24 hours to notify the Department of a harvested river.
6. The pelt shall be removed from the carcass and the carcass shall be surrendered to the Department. After the pelt has been tagged, it shall be returned to the trapper. Upon request, the carcass may be returned to the trapper after the carcass has been inspected and biological data collected.
7. Any river otter harvested after the 24-hour period following the close of the season, will be considered incidental take and shall be surrendered to the Department.
8. A person may only possess, purchase or sell raw river otter pelts that are tagged through the eyeholes with the tag provided by the Department or if the river otter was harvested on tribal or trust land of an Indian reservation or another state and is properly and securely tagged with a tag supplied by the governmental entity issuing the license.

Help protect SD River Otters from Trapping
We objected to the otters removal from SD's threatened species list  but we lost, although the SDGFP staff failed to provide 30 days public notice that was required by SD's Endangered Species Act's law (SDCL 34A-8-5.) . They provided only 23 day's notice. This is a legal argument against the delisting, that  needs to go to Court.

Post-delisting we will request their reintroduction west river, at least to La Creek National Wildlife Refuge
and/or the Little White River. We will request no season west river and either no trapping in 2020, or reductions and limitations to the trapping season to the far east side of SD.

An immediate issue/problem is proposed otter trapping season (finalization on July 16th) ....You can testify on behalf of otters:
1. Testify against otter delisting (although they already decided to do that), explain the delisting was done with illegal
             procedure and thus creates a shaky foundation for this trapping season..
2. Testify against the proposed otter season  - ask them to postpone doing it, till we have more numbers of otters in SD, & otters are recovered in both east & west river      
 3.  Ask for season to be applied to a smaller area  (Ask for the season not apply to west river and not apply along the Missouri River)            
        4..  Ask for west river otter reintroduction project(s), especially to La Creek NWR before any West River trapping.
5.  Otters are killed accidentally in beaver, raccoon and mink traps. Ask them to shorten the beaver trapping season West River. The current West River season - except Black Hills -  is 365 days,  East River season is 6 months. The Black Hills Season is 3 months. The reason for this longer west river  season is  alleged that West River ranchers complain more about "conflict" beavers.   Why not require them to apply for permit to take  a "conflict" beaver, as provided in SDCL 41-8-23,  rather than have year long trapping? You can also ask that all beaver traps, that are not set during an otter season to have the trip wire off to the side, as  thus beaver trappers will be less likely to incidentally take otter.
6. Ask that any otter taken by humans..incidental trapping, vehicle kills, be counted against the next seasons "harvest limit"
      7. Object to the insufficiency of the 2020 SD Otter Management Plan...complain about inadequate information in it.  (It is 12 pages long before the appendix and 44 pages with appendix and bibliographies). Will it's final version be ready for review by public and Commission before July 16th, 2020?   Link to draft revision of the SD River Otter Management Plan -
  8. Ask that needs of wildlife watchers, photographers & hikers, are given adequate respect by SD GFP and that enough   otters be kept to expand to west river and offer otters for not-otter-trappers to watch & enjoy all across SD. Recognize that viewing otters provides the benefits to quality of life for residents and reasons to visit for tourists.
9. Ask for a better monitoring plan.         
 10 Ask for consultation with SD Tribes.
         11. If they insist on a season, ask for modifications to the otter can ask for a smaller "harvest" cap. 
             A commissioner said trappers told him the 15 otter "harvest cap" would be trapped out in the 1st week of the season.  Staff said about 15 otter per year were incidentally/accidentally trapped in recent years.  Most were taken in beaver traps.  We could see 15 otters taken in the first week of season and then another 15  otters incidentally during the rest of the year - thus giving a total otter trapping kill in  2020-2021 of 30 otter. 
              Remember we just have 42 verified sightings of otter (2016) as highest level verified in any year and a 35 verified otter sighting as the average over last 5 years. Flandreau Santee Sioux Tribe reintroduced 35 to start recovery.  Quote from draft 2020-2029 River Otter Management Plan  page 3:        
    " incidental  trap reports (n = 216) over the last 41 years (Figure 4).....Incidentally  caught river otter were  reported in all months of the year but were most frequent in March (n = 27), April  (n = 43), and November (n =  86)".  If we assume 15 otters incidentally trapped per year, this would mean that 6 otter are normally taken in the  entire month of November and 9 in other months.  The GFP could be permitting a not sustainable take from the existing population. "       

# 2 Alert on 

Northern River Otter 
Photo by Tom Koerner/USFWS

June 19, 2020 First Deadline (see September 3rd now)
- SD River Otter,  

SDGFP has released and had made it available for public comment 
the draft Otter Management Plan 

(May 2020 version).

(July 2020 version 
with response to comments in Appendix)

SDGFP's  existing management plans can be found online at  

Results - Item continued the Plan approval to the Commission's to Sept.meeting.
GFP Commission will be adopting the final version at the Sept 2nd-3rd Commission meeting.

There is a final Jully 2020 version (see links to both version's above). The changes were mostly word-smithing type editing and not substantive and did not address our concerns. If nothing else, they made the commitment to developing a monitoring plan more vague.


Originally written comments on the plan would have been sent to 523 E. Capitol Ave., Pierre, S.D. 57501, or emailed to 
Comments must have been received by June 19, 2020 

Native Sun News Article on Commenting on Otter Management Plan

However now you write to the Commission, who must adopt it, and complain about the otter management plan, as they made no substantive changes to it between the May to July draft revision.

We suggest these comments:

1. Object to the 2020 removal of the river otter from SD's threatened species list 
as a premature action, not supported with sufficient data.
2. Insist on more up-to-date and verified material about what is happening with otters in drainages not in the recovery area  (far eastern SD) - namely data for the main stem of the Missouri River and all of West River. They give us charts and graphs showing a mix of verified, unverified otter sightings for 40 years and proof of breeding for 40 years. We need to know what otter sightings have been verified in West River and on main stem of Missouri in the last 5 years, so we know about current status.
3. Insist on a plan to reintroduce river otters to the main stem of the Missouri and to West River be included in the Plan. Insist on a discussion of exactly where they can be reintroduced West River, including a review of tribal lands/waters. Insist on a discussion of reintroduction cost and why West River reintroduction has not happened, except for 2 otters to La Creek NWR in 2013.
4. Insist either that a.) no trapping of otters be allowed or (b.) (History - We got this change) >>> that it only be allowed within GFP's  identified otter recovery area 
(where they have provide data on verified sightings for last 5 years). 
5. GFP admits monitoring otters is difficult.   GFP plans to-  identify needs and guiding principles -  for monitoring  program, which they will eventually develop.  We want an actual otter monitoring plan in place before they start otter trapping. Ask them to discuss the cost of monitoring efforts and whether monitoring is considered difficult, because GFP is unwilling to spend enough money to do it well.
6. Insist on objectives to reduce incidental take of otters during beaver trapping and ask for objectives to
 increase beavers in western SD and reduce beaver trapping. These objectives should be mandatory, not just education of trappers, with voluntary compliance.
7. Insist on a study of fisheries in the Black Hills to see if any Black Hills waters have Black Hills fish population necessary for otters. Identify which if any Black Hills fisheries could be stocked differently, to better support otters. (The Black Hills native fish are too small for fishing and Black Hills streams are stocked with exotics. Otters are not good at catching trout.)
8. Insist on documented consultation with all Tribes in SD over otters and ask GFP to provide a discussion of cultural significance of otters to tribes and whether any tribes want  GFP to protect them, trap them and/or reintroduce them to their reservations (if sufficient habitat exists on and/or near the reservations.)
9. Insist that the Plan considers the value of otter watching to SD residents and visitors and considers the impact of trapping on the distribution and number of otters available for watchers to view. Discuss economic value of wildlife watching of otters vs economic value of trapping of 15 otters.
10 . The Plan shows insufficient consideration of the status of the threats to the river otter and their habitat, especially with respect to agricultural pollution and climate change issues. Threats are actually discussed in the appendix "Status Review" document. Insist on threats being discussed in the main text and include a discussion of agricultural derived pollution and climate change threats.

GFP chart of verified otter sighting by year.

GFP's map of Recovery Area is below with verified sightings for last 5 years.

MAY & JUNE deadness
Discussion of Issues.
SD river otters had been listed as threatened under the SD Endangered Species Act since 1977.   They may have once been extirpated from the state and 35 otter were reintroduced by Flandreau Sioux Tribe to the Big Sioux River in 1998 & 1999. SD Game, Fish and Parks staff proposed to de-list the species, believing it's population distribution east river, indicates recovery. The delisting was proposed at the March Commission meeting.  The SD GFP Commission approved the  de-listing of otters  at a virtual meeting May 7th-8th conducted by teleconference. The IRRC concurred in early June. They will be officially delisted about June 24th, 2020.
To listen to  & learn about the May 7th-8th or other Commission meeting - 

We objected to the delisting on the following major points

1. GFP needs to base delisting criteria on estimates of population numbers & also on population structure, not just on population distribution. GFP is basing the delisting on the population distribution and population structure in drainages in the far eastern side of the state. It does not claim to have an estimate of population numbers..
2. Verified population numbers of otters are still too low   
3. GFP should insure the river otter is successfully reintroduced to river(s) in western SD before it is delisted: at least restarting the reintroduction effort at La Creek National Wildlife Refuge
4. Delisting review shows insufficient consideration of the status of the threats to the river otter and their habitat
5. Otters are fun to watch and the wildlife watchers are not less important than trappers.  SDGFP should insure that otters are spread around  SD in greater numbers & to west river before delisting.


   Otter will be trapped as fur bearers once they are delisted (this was proposed for rule finalization on July 16th, 2020  & approve by Commission on July 17th with IRRC approval on August 18th. It was modified to only apply in east river drainages & some of Missouri River.) and wildlife watchers should have otters better distributed across SD, in higher numbers for watchers to enjoy, before more population reduction from trapping starts. Otters are fun to watch. 

GFP acknowledges they are now found in the Big Sioux, Vermillion, James, Jorgenson, Little Minnesota, Whetstone, Yellow Bank, Kim Cree/Big Slough river  drainages and the Missouri River downstream from Pierre.   SD GFP identified a recovery area in far eastern SD. Otters have been found existing in 40% of the sub-basins in the recovery area & breeding in basins that make up 60% of recovery area.  Both criteria were met for 2 of 5 years prior to delisting proposal. The highest number of verified otters sightings in SD in any recent year was 42 otters in 2016.  Verified sightings for the last 6 years are: 2014 - 33 otters, 2015 - 23 otters, 2016 - 42 otters, 2017- 33 otters, 2018 - 38 otters,  2019 - 40 otters.  That is a 5 year average of 35.2 otters. However more otters will exist than folks are seeing/finding, reporting and that GFP can verify.  Half the reports are from Grant, Moody and Roberts Counties. Study of dead otters found, shows they substantially died at 2 years or younger.
Possible west river reintroduction sites are identified as the Little White River, the Cheyenne and Belle Fourche Rivers. La Creek National Wildlife Refuge and the Little White River have suitable habitat and have had a very small but sort of successful reintroduction.Two otter were reintroduced to La Creek National Wildlife Refuge in 2013. The female died of heart problems but had given birth to a pup before hand. Fate of the male and pup is uncertain, but there were verified sightings (including photos) of single otters up to 2018 and also a not verified otter sighting in 2019. If there is just one otter or two of the same sex, they can't breed.

 Otters are associated with beaver, who help create suitable habitat for them in a drainage system. Most otter are currently killed in SD, as incidental take during beaver trapping. The second leading cause of death is being run over by vehicles. Of 117 reported river otters killed in South Dakota from 1979 through 2016, 73% were killed incidental to legal trapping activities; 15% of the 117 reported river otter mortalities resulted from being struck by vehicles.  SD otters eat fish, frogs and crayfish and live in aquatic systems: streams, ponds, marshes but they travel cross country from one surface water to the other. They need vegetation along the banks for habitat. They don't build dens, but use dens created by other wildlife or nature.  Surface water systems located east river can see change to their edges & size as water levels rise and fall due to variance in rain fall or due to drainage tiling. We face era of climate change & uncertain weather.  We question if they should disclose more info on status of the threats to otter, especially from climate change, water pollution (especially from agriculture and specifically drainage tiling) and wetlands drainage. 

  In the west river prairie of SD beavers are hunted 365 days. The Black Hills beaver season is 3 months and east river is 6 months. The long west River season is alleged to be at the request of land owners who don't want to apply for special permits, if beaver dams/digging are damaging roads or stock dams. We need to insist on a reduction in the level of beaver trapping west river, to reduce the human predation on any otters reintroduced.

Trout  are a non-native introduced species, the Black Hills native fishes were too small for fishing and our Black Hills streams are stocked full of exotics. Trout are difficult for otters to catch (trout swim too fast). We should request that GFP explore managing some stream(s) in Black Hills  for fish species  that otters can catch, so we can re-establish them in at least one drainage in the Hills. 

We failed to prevent the delisting of the otter, we can work to delay the immediate approval of an otter furbearer season and/or once one is approved make sure it is very small and limited to East River. 

Please note most otters are killed currently are killed via incidental takes during trapping. Such death can involve drowning under water while restrained. We can also work to protect beavers. Percentages of otter death by type of trapping are: 53.7 % for beaver trapping, 32.4 % for unknown trapping, 8.8 % for raccoon trapping, 2.3 % for fish trapping , 1.4% for mink trapping  and other 1.4%

We need to insist on reintroduction to La Creek National Wildlife Refuge or to the Little White River, working with either GFP, USFWS and/or Rosebud Sioux Tribe.  We can work for introductions on Cheyenne & Belle Fourche Rivers, working with GFP and/or tribes  The work to protect the otter will not be over on May 7th, no matter what happens - so write in support of otter recovery and west river reintroduction, even if you miss the May 3rd or May 7th deadlines.



We had a Zoom meeting Wednesday, 4/29/20)by Zoom, 
Topic: South Dakota's River Otters
Time: Apr 29, 2020, 6:30 PM Mountain Time 
Speaker: Silka Kempema of SD Game, Fish and Parks (GFP) Wildlife Diversity Program 

Here is the link to recording of the meeting (already happened). This will be deleted just before August 27th next meeting. 
Nancy was a little late starting the recording and missed the first three slides, which included the title slide, a slide titled Mustelid - which had 4 characteristics listed (carnivore, long body, short legs, scent glands) and a slide titled Biology, which had 3 points.- (adapted to life in water, indicator of water quality, associated with beaver.)

A draft of the revised river otter management plan can be found online at under “Plans Up for Revision.” 

To read de-listing proposal

 Link to SD GFP's status review for endangered and threatened Species. -  
See page 122 for the North American river otter section, page 127 for recovery criteria/goals:

"Determination of river otter (Lontra canadensis) distribution and evaluation of potential sites for population expansion in South Dakota", 2011- 2015,
See page 69 for Melquist's recommended parameters to be met before de-listing and also reintroduction recommendations

Link to GFP's 2012 SD Otter Management Plan
SD GFP Commissions March 5th meeting had a discussion of the proposed delisting..if you go to the meeting archives you can scroll through page till you find "Proposal River Otter Delisting" with small image of an audio horn to the right. To view any past Commission meeting archives, which includes audio of meetings:

SD Endangered Species laws

SD Endangered Species Rules

2020 SD House concurrent resolution to de-list otter and manage as a harvested furbearer (resolutions are not law, just legislative suggestions)

Best Management Practices for Trapping River Otter, Association of Fish and Wildlife Agencies

Native Sun News articles on river otter

The Black Hills Pioneer had an article on the proposed delisting, February 29th, 2020.

Here are some links to videos on otters, but I have not watched much of them yet.

River otters on the rise - Keloland in SD , Feb 5th, 2020, short - just a few minutes long

Nest Predator Bounty Program
Nest Predator Bounty Program
Will SDGFP and Kristi Noem propose another NPBP for 2021?

1. History of 2019 past Nest Predator Bounty Program and beginning of the 2020 proposed Nest Predator Bounty Program 
2. Links to other's alerts & references
3. Reasons to oppose the nest predator bounty program.
1. History of 2019 past program and 2020 proposed program

Last year (2019), SD Game, Fish and Parks (GFP) approved a bounty program that started on April 1st and ended on August 12, 2019 when they ran out of money. It was supposed to provide $500,000 for bounties. This program paid ten dollars each for 54,470 tails and killed: 43,779 raccoons, 6,001 striped skunk, 3,706 opossum, 494 red fox & 490 badgers. 

 The bounty program had 3,151 participants of which 90% were from East River and 12% were under 17 years old. SDGFP also gave away live traps. They taught a trapping course to 603 participants of which 387 were youth & taught an ethics course to 50 youth. License sales increased by 6.7%.  

The live trap give-away program cost $958,171, the payment for tails cost $547,400, salaries/benefits cost $190,915 & miscellaneous expenses cost $35,778 - This has a total cost of $1,732,264.  The alleged purpose was to increase success of pheasant and duck nests and thus increase their populations and increase number of trappers, especially children and introduce children to outdoor recreation and conservation/wildlife management (via trapping).
  The staff approved the expenditures and the program before taking public comment on the program. The commission also passed a rule to extend the deadline to remove live traps from public land and public right-of-ways from May 1st to September 1st.

Despite the 2019 expenditure of 1.7 million on the NPBP,  "South Dakota  Pheasant Brood Survey 2019 Report" showed that the statewide Pheasants Per Mile (PPM) index for the 2019 pheasant brood survey decreased 17% (2.47 to 2.04, 90% confidence interval = -32 to 0%) compared to 2018. Link to SD GFP’s 2019 Report: 

On 1/16/2020, the SD GFP Commission & staff created a draft resolution for support of the 2020 Bounty program.
It includes:  1) A $250,000 expenditure on a nest predator bounty, targeting the same species as last year. 2) This year the bounties will be $5 each (not $10). 3) Applicants for bounty must possess a hunting, fishing or trapping license  (unless youth or landowner hunting on their own land).  & 4) The time period will be shorter --from April 1st to July 1st (last year it was permitted till the end of August but ran out of funds & thus ended in mid August) & method of take can include shooting.  There is no provision for giving away free traps this year.

Return of tails is slower in 2020, -- Bounty is $5 per tail, not $10 per tail and they are  spending about an eighth of the money on this program than they did in 2019 and due to virus , they are requiring people to wait in cars while submitting tails.. Only about half the tails were submitted and half the money appropriated was spent.
 Link to tails report

To see the 2020 Nest Predator Bounty Program Approval Resolution - that GFP Commission voted to approve  at a meeting on March 5th - visit this link:

2. Links to other's alerts /references

Links to SD HSUS & SD FACT’s Facebook Pages. Both have alerts on this issue, you need to scroll down their pages

The Humane Society of U.S. (HSUS) funded a public opinion survey on the NPBP of 1,000 random people that got much different responses, than SD GFP funded public opinion survey.  HSUS asked some of the same questions and some different questions than SDGFP. After a series of questions 26% approved of NPBP and 53% disapproved. Link to HSUS report:
Link to the SDGFP’s public opinion survey of 400 random people  - GFP funded both a NPBP participants and a public opinion survey (found in the second half of report).  Link to survey:

GFP references this study in the resolution about 2020 NPBP and on their current web page about the bounty program.   SD GFP’s hired survey (of random people) found that 62% South Dakotans had no clue about the Nest Predator Bounty program and only 38% knew about it, of which 43% were mostly positive about it (which would be 16% of the population supported it, before being read GFP's description of program). (Page 44 of report)

Survey staff then read the respondents a short 3 sentence description of the program, which description convinced them to support it and then survey then claimed 83% of SD folks support the program. (Page 45). This is what GFP and Governor seem to brag about. HSUS found different results…Please compare GFP survey with HSUS’s larger survey (scroll up), some questions are the same cold asks but then they have different prompted questions — with different paragraphs read into the prompted/shepherded questions, surveys get different answers.

For statements that predator control won't work well in large area
visit these links on predator control and pheasants/ducks:

We refer you to Pheasants Forever's web page on "Effects of Predators",

& Ducks Unlimited's web page on "Ducks, Habitat Conservation & Predators": 

Also see page 11 of SD GFP's Pheasant Management Plan, in the section on predators:
"Where predator control may be considered as a management option, managers should be aware that cost, logistics, and lack of effectiveness often limit success when compared to habitat management."

SD's 2019 Pheasant Brood report

Greater prairie chicken's IUCN Red List web page.
 Please remember the exotic male pheasant fight over territory with and drive off the male chickens and female pheasants lay eggs in the chicken's nest, which hatch before the chickens, causing moms to abandon their own eggs:
4. Reasons to oppose the nest predator bounty program.
This killing of predators is not scientifically justified.   ----
- Wildlife biologists agree that nest predator control is ineffective unless it is extremely intense and carried out annually.
- Effective nest predator control may require hundreds of dollars & man-hours per year & per section of land. The Governor’s budget might be enough to cover one township, or possibly even a county, but certainly not the state.
- Even intense predator control has limitations. Those animals that escape capture or death often reproduce at a higher rate. This means more effort must be expended and more money must be appropriated each year.
- Nature does not exist in a vacuum. When one animal is removed, others move in, including other species that may be more effective predators.
- Nest predators also feed on rodents. Opossums also eat ticks.  If these nest predators are successfully controlled, an explosion in rodents can be expected, with a huge and potentially devastating impact on farmers and ranchers. Rodents eat grain in the field, & infest grain bins, outbuildings and farmhouses. In SD rodents carry Hantavirus or  fleas/ticks that can have bubonic plague, or Lyme disease. These costs must also be considered.
- Some nest predators are protected by state and federal laws. This would include ALL raptors. (Hawks, owls and eagles are examples.)
- The nest predator bounty may encourage illegal activity, from trespassing and unlawful night hunting to submitting tails collected out-of-state. NO funds have been allocated for the extra law enforcement.  
-The nest predator program is fiscally irresponsible. The money is desperately needed on habitat programs that actually do provide a return on the investment.
- Habitat improvements can be cost shared at a rate of 50% to over 75% through a variety of programs. GF&P receives 75% cost share on habitat purchases and improvements through Pittman Robertson funds.
- Predation is much lower when sufficient habitat for nesting birds is provided.
- Successful nesting will not occur where there is not sufficient habitat, regardless if most predators are removed or not.
 -  Good habitat also provides high-protein food sources, clean water and protection from the elements, all in a suitable arrangement. Habitat for pheasants/ducks also benefits various other wildlife & bird species.
- This is a statewide program, but areas with pheasant and duck populations are much more limited West River.  Why pay bounties for West River predator tails?
- Much of SDGFP budget derives from sale of licenses and most hunters do not want GFP’s limited budget spent on this program.
- Pheasants are an exotic species that competes with a native species - the greater prairie chicken, whose range and population are declining -- losing half its' population every decade.
- Accidental take of threatened and endangered species may occur. The swift fox is state listed. The black-footed ferret is listed federally. There is a petition before the USFWS to list the plains spotted skunk and the prairie grey fox under the Endangered Species Act. The American Martin is a “sensitive species” for the Black Hills National Forest.
- This program will result in animal cruelty. Some trappers will be trapping with leg-hold traps or snares, or body crushing traps. Some will use live traps.  People should realize that in SD the law allows for animals to be left in traps West River for three and a partial day and East River for two and a partial day. Trapping can be cruel.  In high heat or bitter cold, an animal in a box can die in half a day. Animals in boxes or leg-hold traps can freak out and damage their bodies and/or teeth & thus not survive even if released. Dead animals or animals in boxes or traps can't feed their dependent young. Even via a "live trap" non-target species adults and their dependent young will die, in addition to target species.
- Part of the rational/spin for the program is to introduce children to nature & trapping. Why not introduce children to nature via non-lethal interactions with wildlife such as wildlife watching and spend money on nature guidebooks, binoculars, cameras & not via bounties & traps?
- Empathetic children may encounter moral dilemmas such as how to kill the 12 or 13 babies in an opossums pouch, and later learn that they did this killing of babies, based on lies told them by SD GFP about effects of a bounty program on nesting success. How does this engage children with nature or give them trust in government?


Projects/process on federal land that might move forward in 2020/2021


It is possible that Rare Element Resources will restart, at any time, the moving forward of it's application process for the proposed rare earth mine north of Warren Peak, in the Bearlodge and associated mill at Upton, Wyoming. The Forest Service, the Nuclear Regulatory Commission and the Wyoming Department of Environment Quality, put the Companies applications and approval process on hold in early 2016, at the request of the Company. The Company stopped work on a DEIS on a proposed mine due to short fall of revenue, at a time when the market conditions on rare earth minerals changed. (Scroll down towards bottom of home page for more info.) Formal notice on restart has not been given yet. Where in the  approval process it will be restarted is not known yet. China is the major source of rare earth minerals and Trump and China conflict, may change the market. Contact Karl Emanuel  at the Northern Ranger District for more information or to be added to notice mailing list -

It is possible that the mineral exploration will restart at Mineral Hill, in Wyoming. This exploration would be very near the Sand Creek Roadless area and a FS Botanical Area. Area is north of Cement Ridge and west of Tinton ghost town. In previous exploration efforts in the area, the target minerals were gold, silver and copper.  Scoping has not yet started on this, nor has exploration re-started and this may be on hold.  Contact Karl Emanuel  at the Northern Ranger District for more information or to be added to mailing list -, 605- 443-3072

Mineral exploration has started near Rochford, SD for Mineral Mountain Resources, scroll down for our alert on that topic. Scoping has past and this project is active.. Contact DENR at Roberta.Hudson (at)

Another project in the Central Hills  near inlet to west of  Pactola Res. is also being considered. The company involved in the gold exploration project near the inlet to Pactola is F3 Gold of Minneapolis.

There are two companies that have applied for gold exploration permits on Forest Service land that are currently secret.  The Forest Service will not say who or where specifically they are, but has said they are also in the central Black Hills. 

Azarga Uranium, locally known as Powertech, has proposed an in situ uranium mine on over 10,000 acres in western Custer and Fall River Counties.  The company is in the permitting process and has received one of the ten permits it would need to start mining.  The permit they have received is under litigation.  For more information:

F3 is proposing the Jenny Gulch Exploration Drilling project. 
The project involves exploratory drilling in up to 42 locations north of Silver City, Pennington County, South Dakota in Sections 19, 30, 31, T2N R5E and Sections 13, 14, 24, 25, T2N R4E.
F3 has submitted a Plan of Operations to conduct exploration on their claims located on National Forest System (NFS) lands. A short presentation will be provided at 6:00pm to discuss details of the plan. The Plan of Operation is tentative and may be subject to change based on the forthcoming environmental analysis.
Here is a link to the Forest Service Web page on the Jenny Gulch F3 project
link to map on this page

Below is a link to Instructions on how to comment (comments due to the Forest Service - Feb 5th -  It is best to meet any scoping deadline, however if you miss the deadline, we always suggest you still send in comments ASAP, as this is scoping (the beginning of planning).
Scoping is about identifying the issues and concerns that the Forest Service should address in a future impacts study that will be completed prior to approving the project. (NEPA review- Environmental Assessment or Environmental Impact Statement).

Why you should be concerned about gold mining near Rapid City’s water supply (Pactola Reservior)?


PHAS also provides you with this  link to 2006 Kuipers report on their study of the history of mines in US on meeting water quality goals/predictions.
“The overall purpose of this study is to examine the reliability of pre-mining water quality predictions at hard rock mining operations in the United States.”

Here are much shorter summary versions (2007 & 2005)

Comments canbe submitted via mail to 8221 S. Mt. Rushmore Rd., Rapid City, SD 57702; via email ( with “F3 Jenny Gulch Exploration Project” as the subject; or by fax (605-343-7134). Comments are requested by February 5, 2020. Comments submitted, including names and addresses of commenters, are public information. 

Protecting Greater Sage Grouse:
Oct 16th, 2019 
Judge Winmill grants a preliminary injunction against Trump's BLM  (History)
in lawsuit brought by Prairie Hills Audubon Society, Western Watersheds Project, 
Center for Biological Diversity & WildEarth Guardians.
Our Attorneys: Advocates for the West

Link to the injunction is below:

New York Times Article on

Dec 18th, 2019 (History)

 Interior Department, states appeal Judge Winmill'sage grouse ruling

Link to article about"

    We are suing to protect Sage Grouse
    NEWS - PHAS Press Releases - 

    Excerpt from Press Release
    Former Oil Industry Lobbyist Violated Federal Law, Groups Say
    BOISE, Ida. ― Four conservation groups sued Acting Interior Secretary David Bernhardt and the Bureau of Land Management (BLM) in Idaho federal court today over their recent decisions to gut protections for greater sage grouse across millions of acres of public land in the West.  A copy of the lawsuit is available here. The groups are Western Watersheds Project, Center for Biological Diversity, WildEarth Guardians and Prairie Hills Audubon Society. 
    “The Trump Administration is gutting sage-grouse protections on at least 50 million acres of public lands without admitting what they are doing,” said Laird J. Lucas, lead attorney for the Plaintiff groups with Advocates for the West. “The lawsuit today exposes these actions as violating bedrock federal laws and flouting the extensive body of science on what sage-grouse need to survive.”

    Photo of Sage Grouse, copyright Dan Licht

    April 22th Update - Preliminary Injunction Requested
    Court Order Sought to Stop Destruction of Sage-grouse Habitat in Seven States 

    BOISE, Idaho― Four conservation groups have asked a federal judge to block new plans that allow drilling, mining and other destructive activities across 51 million acres of greater sage-grouse habitat in seven western states: Idaho, Wyoming, Utah, Colorado, Nevada, California and Oregon.

    The motion for a preliminary injunction, filed Friday in U.S. District Court in Boise, says the land-management plans approved by Interior Secretary David Bernhardt last month would gut protections for the birds’ dwindling populations and destroy their habitat.


    Recent News article on this injunction request.

    Here are links about PHAS's 2016 original litigation 
    that these recent 2019 filings supplement.


     BLM's Supplemental EISs on the management of greater sage grouse on their lands in 6 western states (DEADLINE  to comment past). They did these SEISs as a response to the litigation's complaints about their NEPA processes.


    ZOOM MEETING recorded (History - link will be deleted Sept 29th)
    PHAS monthly meeting - Greater Sage Grouse
    Prairie Hills Audubon Society March Meeting, Tuesday March 31st
    Topic: “The Fight to Save the Greater Sage Grouse”
     Speaker: Erik Molvar, Executive Director Western Watersheds



     In March 2019, Prairie Hills Audubon Society and 3 other conservation groups sued acting Interior Secretary David Bernhardt and the Bureau of Land Management in federal court  over their recent decisions to gut protections for greater sage grouse across millions of acres of public land in the West. Western Watersheds Project, WildEarth Guardians, the Center for Biological Diversity and Prairie Hills Audubon Society are represented in the case by attorneys from Advocates for the West.

    February 2016 Original Litigation
    March 2019 Litigation supplement
    April 2019 Injunction request


    Mt. LIONS

    The revised 2019 mountain lion management plan can also be found online at  

      A biennial report on SD mountain lions can be found at  The 2010-2015 report can be found at the bottom of the mountain lion webpage at

    Oct 2018 Commission meeting.
    SDGFP staff presented an update on lion management. It will eventually be available on the web site, however Audio of meeting is here

    June 17th and June 19th,
    Nebraska Mountain Lion Hunting Season Comment deadlines

    NE proposes to shrink the harvest limit from 8 to 4, as the population numbers have been reduced by the over hunting of early 2020 in the Pine Ridge of NE.
    RESULTS - Season passed

    The link to the agenda for 6/19/20 Commission meeting in Lincoln, NE

    June 17th, 2020 - Comment Deadline on Nebraska 2021 Mountain Lion Hunt
    June 19th, Nebraska Game and Parks (NGP) Commission meeting in Lincoln, NE

     Sam Wilson with NGP recently gave a 10 minute presentation to the commission (see here for the presentation) which included a new population estimate of 34 total mountain lions (about 22 adults and subadults) for the Pine Ridge of Nebraska, which was conducted prior to this year’s hunting season when seven mountain lions were killed by hunters.
    This is nearly half of NGP’s previous estimate of 59 mountain lions.

    In 2010-2015 Pine Ridge population numbers were estimated to be stable at 22-33 total animals. Nebraska presents a new population estimate of 34 total mountain lions (about 22 adults and subadults) for the Pine Ridge of Nebraska, which survey was conducted prior to this year’s hunting season when seven mountain lions were killed by hunters. This is nearly half of NGP’s previous year’s estimate of 59 mountain lions.

    Pursuant to research, Washington State had adopted a harvest rate of 12 to 16% of adults and sub-adults as the harvest levels that result in a sustainable population. Kittens should not be included in the population estimate because juveniles of all species have high mortality rates.

    A hunt of 16% of 22 adults/sub adults would be 3.52 lions and 12% would be 2.64. Subtracting 7 more animals from 22 adults/sub adults, gives us 15 adults/sub adults and 12% take is 1.8 lions, 14% is 2.1 and 16% is 2.4 lions. 

    The Nebraska Pine Ridge cougar habitat is more isolated than Washington State's and these percent may need to be lower in Nebraska due to Pine Ridge population's relative isolation.  

    Maintaining connectivity between Nebraska’s three small lion populations  (Scottsbluff, Niobrara Valley and Pine Ridge) is important.  Sub-adults are needed to disperse between these populations, to maintain genetic diversity. The Pine Ridge Ecosystem extends into South Dakota and Wyoming.  South Dakota now has a cougar breeding population and has had a hunting season on the Oglala Sioux Tribe lands (Pine Ridge Reservation)

    NGP is proposing a 2021 hunt with a quota of four total lions and a sub-limit of two females, which is half of this year’s (2020) quota of 8 total lions and four females. They are combining the two Pine Ridge hunting areas into one large area, and they will offer 320 permits for up to $4,800 in revenue. There will be no recreational hunting in the rest of the state.

     The Pine Ridge ecosystem exists in three states - Wyoming, Nebraska and SD, but Nebraska has the best and largest habitat.  Wyoming breaks it's state up into 32 lion hunting areas with different seasons and goals per each. I think that Wyoming Pine Ridge sits in Wyoming's Area 24 in which there are no season limits, hound hunting is allowed, people can get 2 licenses per person and the season lasts 9 months long. Oglala Sioux Tribe (OST) has had proof of breeding lions.  Last year's (2019) harvest limit was 20 lion of any sex and 10 females and we think that repeats again this year (need to verify). It is questionable if that number of lions exist on OST and/or that such levels of hunting are sustainable. If lions wander off OST lands to nearby lands in SD's jurisdiction, in our Prairie Unit we have lion hunting 365 days a year, with no harvest limit & hound hunting allowed.

    See here for the proposal and link to submit comments:
    Send comments to
    The comment deadline was June 17th  (1 pm CT) and the commission reviewed and voted on the proposal on June 19th in Lincoln.

    PHAS wrote in support of a season  with an acceptable range of zero lions to 2 lions. We believe HSUS, Mountain Lion Foundation and Cougar Fund were opposing any season this year.
    MLF Alert
    Nebraska HSUS Alert

    Link to a newspaper article about this

    Link to Article about this in a blog

    Nebraska Mountain Lion Plan

    Projects/process on federal land that might move forward in 2018/2019


    It is possible that Rare Element Resources will restart, at any time, the moving forward of it's application process for the proposed rare earth mine north of Warren Peak, in the Bearlodge and associated mill at Upton, Wyoming.
    The Forest Service, the Nuclear Regulatory Commission and the Wyoming Department of Environment Quality, put the  Companies applications and approval process on hold in early 2016, at the request of the Company. The Company stopped work on a DEIS on a proposed mine due to short fall of revenue, at a time when the market conditions on rare earth minerals changed. (Scroll down towards bottom of home page for more info.) Formal notice on restart has not been given yet. Where in the  approval process it will be restarted is not known yet. China is the major source of rare earth minerals and Trump and China conflict, may change the market. Contact Karl Emanuel  at the Northern Ranger District for more information or to be added to notice mailing list -
    It is possible  that mineral exploration will re-start at Mineral Hill, in Wyoming. This exploration would be very near the Sand Creek Roadless area and a FS Botanical Area. Area is north of Cement Ridge and west of Tinton ghost town. In previous exploration efforts in the area, the target minerals were gold, silver and copper.  Scoping has not yet started on this, nor has exploration re-started and this may be on hold.  Contact Karl Emanuel  at the Northern Ranger District for more information or to be added to mailing list -, 605- 443-3072

    Mineral exploration has started near Rochford, SD for Mineral Mountain Resources, scroll down for our alert on that topic. Scoping has past and this project may be on hold. Contact DENR at Roberta.Hudson (at)
    Another project in the Central Hills  near inlet to west of  Pactola Res. is also being considered.

    Mineral Mt Resources Rochford Exploration Project
    Exploration was approved and is ongoing. They are trucking in water.
    UPDATE - Scroll up to Jenny Gulch project, another mining project in the area.

    SCOPING DEADLINE was - Oct 27th, 2017
    After the deadline - we suggest folks send in short letters expressing basic concern and asking to be on the  mailing list for the project. 

    Mineral Mt Resources Rochford Exploration Project 
    on the Mystic Ranger District.  
    A scoping period was underway - Forest Service (FS) sought public input on proposed project.  Link to FS info:

    The Forest Service was considering whether to approve exploratory drilling for gold by the Canadian company, Mineral Mountain Resources, Ltd . 
    The drilling would occur on public national forest land south of Rochford, South Dakota.
     This proposed project on public land is in addition to a similar project planned by the same company on private land next to Rapid Creek, less than a mile SE of Rochford near the old Standby Mill site. The Standby Project's site is handled by DENR not the FS. 

     The Stanby exploration project will consist of drilling up to 120 drill holes from 12 different drill sites. No drill holes will exceed 4,000 feet in depth. Approximately 3,000 feet of additional overland trails may be needed to access all planned drill site locations.  
    The company already has a mine exploration permit from DENR on the private land 
    (Standby Project) site, but may not have started work yet, but it does not yet have permit for exploration on Forest Service lands.

    Standby Project Map of private land -- 
    on which exploration has already been permitted by DENR
    is below

    Mineral Mountain EXNI  for the Rochford/Standby Area - DENR's records.
    Map of Proposed exploration sites on Forest Service Land near
    Meyersville and Castle Peak is below

    Mining Claims on federal land in the Area, as mapped by Clean Water Alliance
    is below
    This map is not guaranteed to be accurate 
    The above map is not guaranteed to be accurate. It was done circa 2016 and claims may have been added or deleted since then

    Aerial Map of the region provided by Bing maps
    to zoom in and out at various resolutions

    You may click HERE for a version of local opponent's  presentation that discusses the issues.       Concerned local folks are organizing and sponsored a recent meeting about the project -  for questions to locals contact - rees.doug (at) 
    Comments were due on the proposed exploration drilling on Forest Service lands near Rochford on October 13 (original deadline was extended and folks  got another extension - new deadline was Oct 27th).   
    This would be partly in the Rapid Creek watershed.  The upper edge of the  Forest Service site is about 2 miles south of Rochford and Rapid Creek. The sites continues past Castle Peak  to north of North Fork of Castle Creek and are also near Meyersville (historic town). There is a historic mine site (Alta Lodi) at Meyersville/Meyers City.,_South_Dakota   Here is a view of Castle Peak Campground, which is within a mile south of  site on the Forest Service land. -  
      This project on FS lands involves constructing 21 drill sites for the purpose of collecting core samples with a track or rubber tired mounted drill rig. Maximum water to be used for exploration on FS land is 1.8 million gallons of water (5.52 acre feet) at a maximum rate of 200 gallons per minute from Rapid Creek. This may convert to .45 cubic feet/second...The limits may translate to - withdrawing less than 5% of the flow of the lowest recorded level at a downstream Rapid Creek gauge location, for about an hour a day, for about three months duration.   Water is to be trucked to the site. The Company has received a Temporary State Water Right Permit to withdraw the water, which expires on December 31st, 2017.  Both sites may rely on the same temporary permit's 1.8 million gallons. Water Rights Program Chief Engineer approves temporary water withdrawals, but has the discretion to refer such to the Water Management Board.  Some closed roads will be opened and use of un-named trails and 3400 LF of over-land routes is planned. 
     The Forest Service at this point is planning to use  a "categorical exclusion" (CE) on the exploration. This designation (CE) means a less thorough environmental review happens for the exploration phase and Decision Memos are not subject to FS Objection process .  Folks should object to the "categorical exclusion" and ask for higher grade of NEPA, one that at least releases the environmental study on the exploration phase to the public for comments, before the Forest Service's decision is made & allows for objections to be filed. This exploration may lead to a large mine in the area.  Folks could express concern about water withdrawal from both projects and cumulative impacts to Rapid Creek's in-stream flows, water quality and Rapid City water supply - - the exploration impacts now may be much less significant than if a large mine ever results.  Also express concern for Castle Creek's water as some drill sites are near the North Fork of that Creek and Castle Peak Campground.  Canyon City Research Natural Area (RNA) is down stream of both Castle Peak and Rochford areas and is upstream of Silver City.  Pe Sla (Reynolds Prairie)  is to the south. Mickelson Trail runs along Rapid Creek through Standby site.  One can ask if there are any potential impacts to these special resources - some are next to the activities and some in the region.  One can express concern for bonds and liability assurances.
    If they find minerals this could morph into a large mine. We suggest concerned people keep in contact with the F.S. & DENR with your concerns even after deadlines and ask to be added to the mailing list.
    For questions to the Forest Service:
    District Ranger
    Mystic Ranger District Office
    8221 South Highway 16
    Rapid City, SD 57702
    (605) 343-1567,
    Also Gary Hauge at Mystic (605) 343-1567 and Ralph Adams at Supervisor's office (605-673-9200).
    Roberta Hudson at Minerals and Mining Program, DENR, Pierre - Roberta.Hudson (at), (605) 773-4201

    Eric Gronlund, Water Rights Program, DENR, 605 773-3352, eric.gronlund (at)


    MAY 8th & 10th Hearings
    Croell Sand Gravel Mine Application (new application)
    Also called "PERLI PIT ROCK QUARRY "

    MAY 8th  & May 10th were Hearing on
    Croell Sand Gravel Mine Application (new application)
    (This is a proposed mine off of Highway 16, SW of Rapid City)
    before the 
    Pennington County Planning Commission & Full Board of Commissioners,
    The Planning Commission recommended approval and it went to the full commission
    Full Commission recommended approval also
    RCJ article about such:

    This application was  considered under the old Ordinance 507A and 507B existing before March 2018 as well as the current Ordinance 320 passed on or about March 28, 2018. 
    Subsequently the SD Supreme Court upheld a challenge to the public notice for the new Ordinance 320, so the new Ordinance is dead, and the mine is thus permitted under the old ordinance.
     Then at the end of the year (2019) Pennington Cty started process to re-adopt Ordinance 320 and correctly public notice it.
    Notes on Croell Sand Gravel Mine Application (new application)
    Also called "PERLI PIT ROCK QUARRY "

    This is a controversial Project that has been subject to past litigation and a citizen's group was formed to oppose it. For information Black Hills Concerned Citizens - duane.abata (at)
    We had copied the Black Hills Concerned Citizens  6 page Alert on the issue, but deleted it due to lack of space on the Blog.

    SD law and the County's ordinance are inadequate to protect locals and the environment from adverse impacts from sand/gravel mining. Scroll down on PHAS web page for more info on the battle over Pennington County mining ordinance rewrite.

    Croell Mining Case (Old history but relevant history)
    Link to SD Supreme Court Decision that upholds Pennington County's decision to reject Croell Redi-Mix's mining application. This is about a historic lawsuit filed by miners over Pennington County rejecting Croell's mine application ( a sand/gravel/aggregate mine). The County won in the Supreme Court. It explains at least partly why Pennington worked to rewrite it's Sand/Gravel/Rock ordinance in 2017-2018. Some Commissioners  have changed since this past vote.

    Alert on Croell Mining from
    Black Hills Concerned Citizens
    Deleted to save space
    Contact Duane Abata for more information




    Marsh Wren. - painting by JJ Audubon

    PAST EVENTS - for current events, scroll up.

    Update January 2020

    We have deleted a lot of the non-meandered water section text and attached sheets, to create space on the blog.

    Link to map showing closed lakes or sections of lakes  (about 17 closures)

    Link to GFP Discussion of "Progress Update"

    This section has been modified to remove most of the text to create space on the blog.
    We have deleted more non-meandered waters text to create space on the blog.


    Bear Butte Lake (east side)  Original Survey map - to find lake look on west edge of map.

    The origin of meandered & non-meandered juxtaposition for lakes: the 1868 federal instructions to surveyors were to not draw meander lines around a body of water that was, (a) less than 40 acres;  or (b) shallow or likely in time to dry up or be greatly reduced by evaporation, drainage, or other causes. In these cases the surveyors included the water body and its bed in their survey as part of the lands available for settlement. 
     Water like this are called non-meandered waters & the person with title to the land(s) owns the ground underneath the lake (the lake bed) but the public owns the water (& living animal creatures in the water itself) - above the lake bottom 
    The waters & ground beneath "meandered waters" were given to the public & the ground beneath meandered waters were never open for settlement. 

    Link to the 1868 Surveyor's instruction manual

    These land surveys in SD did not necessarily happen right away after 1868 -- in 1868 western SD was part of the recently designated "The Great Sioux Reservation" by the 1868 Fort Laramie Treaty.

    This link leads to what we suspect is the original first USA surveys (BLM General Land Office Records) - you can look up the "original survey" map for your area. Inputing your area's township and range allows you to find your square of land surveyed and then look for "plat image" in the various drop down menus and choices.

    We have deleted more non-meandered waters text to create space on the blog.


    Temporarily deleted Native American section of non-meandered waters to create space on Blog


    October 30th Comment Deadline

    March 30th-April 29th, 2018 Objection Period
    Black Hills Resilient Landscape Project
    Notice of the FEIS was released on Friday March 30th. The objection period for Forest Plan Amendment shall end 60 days after March 30th and 30 days after March 30th for  objections to the Project.

    A large project which will determine actions on the Forest for  perhaps the next decade is available online/

    Further information on the project is also available at:
    It is on this webpage that you can also go to the “Reading Room” (in the right hand column of the page under “Get Connected”) to read comments (including those of the Norbeck Society) that were given about a year ago when the Forest Service conducted Scoping on the Project and recent comments.
    Paper copies of the DEIS available on request and at all Black Hills National Forest offices. 605-673-9200

    We recommend reading Norbeck Society, & Sierra Club comments
    If you have time to read and then if you agree with the content of one or more - you could write to the FS  and tell them that you agree with any of these writer(s)

    Norbeck Society's
    Black Hills Group Sierra Club

    The purpose of the proposed project is to move landscape-level vegetation conditions in the project area toward objectives set by the Black Hills National Forest Land and Resource Management Plan, as amended, in order to increase ecosystem resilience to insect infestation and other natural disturbances, contribute to public safety and the local economy, and reduce risk of wildfire to landscapes and communities.

    Proposed activities include reduction of hazardous fuels, prescribed burning, enhancement of hardwoods and grasslands, timber harvest, non-commercial thinning, and associated actions. The project area, which includes most of the Black Hills National Forest, consists of the areas designated under Healthy Forests Restoration Act authority at the request of the Governors of South Dakota and Wyoming.

    This is the beginning of a PHAS alert on this Project

    Please oppose any reduction in mature dense pine stands. These have been reduced by logging for timber, logging to protect trees from mountain pine beetle or fire and also by the beetle and fire themselves. These are Structural Stage (SS)  3B and 3C, 4 B and 4C and 5 .  Have the Forest Service leave anything with a 35% canopy cover alone.  This lack of dense stands risks the viability of goshawk, brown creeper, martin and also indirectly black-backed woodpecker.  The woodpecker needs dense stands that have been killed by fire or beetles, but the stands have to first exist in order to be killed.

    The mountain pine beetle epidemic is over and the beetles are at slightly below endemic levels and decreasing.  The MPBR Project is still logging mature dense stands, of which we don't have enough, in order to protect us from
    a threat that is over.

    The project will impact about 4/5ths of the forest... the project will occur in the major management areas to which most of the forest is assigned.  In these management areas only 1% or less of structural stage 5 (old growth) remains, except for MA 5.6, which is  2.2% of the forest & is found up in the NW corner of the forest. It has 2% old growth (SS 5)  left.  This means that the past management policy and structural stage goals for most of the forest (which goal was to have 5% old growth)  have not adequately protected the old growth from 1)  logging to produce timber output, 2)  logging with hope to reduce the beetle & fire risk,  3) beetle kill, and 4) fire kill.     Goshawks need old growth and the Forest Plan requires 180 acres of such near nests and also meeting the Plan's structural stage objectives generically, which protection has been inadequate as too few dense stands are left near nests. The current objectives of the existing Plan don't work for old growth.  A Forest Plan amendment is needed to address how to create and secure adequate replacement old growth -- before more logging is approved via this project.  What the Forest has been doing since 1996 obviously does not work.

    There is not enough protection of the forest from the spread of weeds. Too much surface disturbance has happened in past and will happen in the future to promote pine regeneration and allow for logging and roads. The Forest Service  likely does not have the budget to treat all  the weeds - that  will grow after the planned disturbances. Funding for treating noxious weeds should be a limiting factor to actions that create them.

    One of the side effects of beetles, fires and logging to prevent beetles and fire is to open the canopy which
    results in the Black Hills in little pines sprouting like weeds.  These will grow and create a lower canopy fire risk and ladder fuels.  The real fire risk from beetles is not the standing dead pine trees. The needles fall off the dead trees. Needles on a live pine tree during drought can be just as flammable as dead pine tree needles.  A risk comes after 10 or 20 or so years later when the small pines start growing in mass next to the ground and producing ladder fuels.  The Forest Service pays for small pine thinning by cutting down big trees... but the Forest Service has a limited supply of those left.  The Forest Service does not need to be planting more small needs a plan to reduce the supply we have. The FS should not disk, rake & scarify sod to plant little pines.

    The Forest is cutting timber at a rate that the forest can't sustain and the timber industry is heading off a cliff. The Forest is going to run out of timber. It needs to slow down the rate of the cut.

    The Forest needs to protect birch stands from adverse impacts of logging pine from birch. Also small stands of lodgepole, doug fir and limber pine need to be protected and expanded. At one time there were blue grouse in the Black Hills, which are extirpated they need old ponderosa pines  or the above conifer species.  Aspen needs to be protected and expanded. Mixed aspen/pine stands are useful for species richness and visuals, and the Forest should save some of those, not just eradicate them.

    The Healthy Forests Restoration Act (HFRA) seeks to “reduce the risk or extent of, or increase the resilience to, insect or disease infestation” in areas experiencing declining forest health (defined in the Act as “a forest that is experiencing substantially increased tree mortality due to insect or disease infestation…”).  A large portion of the remedies presented in the proposed project, namely the harvest of 185,000 acres of Structural Stage 4A stands and the associated road- building, will do very little-to-nothing in the way of reducing the risk and extent of, and increase resilience to mountain pine beetle infestation and the incidence of catastrophic wildfire.

     . Send written comments to: BHRL Project, Black Hills National Forest, 1019 North 5th Street, Custer, SD 57730, or via facsimile to 605-673-9350, c/o BHRL Project. Written comments also may be hand-delivered to the above address between 8:00 a.m. and 4:30 p.m. Mountain time, Monday through Friday except federal holidays.



    temporary deleted to make space on the Blog. 
    Oct 24th, 2019
     USFWS announces intent to delist the interior least tern.
    Dec 23rd, 2019 was the deadline to Comment on this. Link to Federal register:

    May 16th
    American Burying Beetle Status Review, 90 Day Finding, comment deadline

    American Burying Beetle Photo - Lindsay Vivian,

    Parts  of American burying beetle section are deleted for space 

                                       We have the northern long eared bat listed as federally threatened in SD.

    Researchers “Translate” Bat Talk. 

    Turns Out, They Argue—A Lot

    A machine learning algorithm helped decode the squeaks Egyptian fruit bats make in their roost, revealing that they “speak” to one another as individuals.


    Spearfish Canyon and Bismark Lake 
    Land Exchange Act
    This SD State Park Enlargement Effort Is Likely Dead For Now
    Prairie Hills Audubon Board voted to oppose this proposed 
    land trade ("land grab") on Oct 18th, 2016. 

    PHAS [and the Forest Service, the Norbeck Society, Black Hills Chapter of the Izaak Walton League of America , BHG of Sierra Club and Black Hills Group of Dakota Rural Action] opposed the proposed land trade from Forest Service to SD GFP for Spearfish and Little Spearfish Canyon and Bismark Lake.
    Also opposing was an ad hoc group. Below is link to their page: 


    a subset of a National Audubon Society Nationwideprogram

    More details on PHAS web page




    Announce litigation


    Thursday February 25th, 2016
    Complaint filed about greater sage grouse
    PHAS major campaign announcement

    On 2/25/16 Prairie Hills Audubon Society joined 3 other environmental groups (WildEarth Guardians, Western Watershed Projects, Center for Biological Diversity) in filing litigation to protect greater sage grouse. 

    More details on the issue and litigation can be found on another PHAS web page or scroll up.


    Delayed/suspended Campaigns

    (OUT-OF-DATE alert) 

    We have deleted  text  on mining threats relative to rare earth mining, proposed in Hills to create space on the blog.



    OLDER POSTS INDEX - see below
    2. 2015 items - Deadlines & Events old , this has events, that recycle each year (will occur again next year)
    3. 2014 & 2015  items - Recently expired comment periods with link to public documents

    Even Older - Below items are from the 2014 SD legislative session 
    #2. - #4 various out of date & obsolete legislative 2014 alerts
    (in Feb Blog Archives )
    5. Links to Environmental Bill Tracking Services on the Internet (SD 2014 Legislature)
    (In January  Blog Archives)
    6. How to Contact SD Legislature 2014
    (In January Blog Archives)
    7. SD Legislative Cracker Barrels and Legislative Coffees 2014,

     (In January  Blog Archives )
    8. Grey Wolf Delisting Comment Opportunity 
    9. Christmas Bird Count List 2013-14
    10 Mt Lion, SDGFP Commission meet
    11 BlackBacked Wood Pecker Meeting
    12, Missouri River Ponca Bluffs  Meeting
    13. BLM Management Plan Revision