Stop the emergency Roby logging and burning plan on 49,431 Black Hills acres
Roby Forest Management Project
U.S. Forest Service· Hell Canyon Ranger District, Black Hills National ForestU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
4 groups predicted likely to care in South Dakota and Wyoming
Predicted likely to care is a guess from footprint in South Dakota and Wyoming, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Badlands Natural History Association
Predicted likely to care · a guess
Works South Dakota: they work only in South Dakota.
- Wind Cave National Park Friends Group
Predicted likely to care · a guess
Works South Dakota: they work only in South Dakota.
- Wyoming Outdoor Council
Predicted likely to care · a guess
Works Wyoming: leading opposition to BLM's 2025 reopening of the just-finalized Rock Springs RMP, with program director Alec Underwood arguing the Golden Triangle and Big Sandy Foothills are too special to lease and develop.
- Wyoming Wilderness Association
Predicted likely to care · a guess
Works Wyoming: organized citizen outings at Skull Rim to build opposition to BLM lease parcels around Adobe Town Rim and has pressed the agency to shrink lease sales touching the WSA and surrounding lands with wilderness characteristics.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
Using emergency wildfire authority, the Forest Service proposes commercial logging on 9,677 acres and burning up to 46,073 acres of the 49,431-acre Roby project area without analyzing a full range of alternatives.
What’s at risk
The agency's own tables show mature pine structural stages 4A and 4B moving further from Forest Plan objectives, not closer, and a threatened bat species already has a 'likely to adversely affect' determination. Goshawk nesting habitat would further decrease outside known territories, weed infestation could reach 4,400 non-priority acres, and cultural resource surveys remain incomplete for part of the project area.
If this goes through
Implementation is anticipated to begin in late 2026 and activities are expected to continue for an estimated 15 years, ending around 2042, with fire hazard effects on the ground persisting 10 to 20 years after treatment. The emergency designation also means no formal objection process applies and the public comment period has no set duration or format.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Total project area vs. National Forest System land
- 49,431 acres total, 46,844 acres NFS
- Commercial timber harvest proposed
- up to 9,677 acres
- Prescribed broadcast burning proposed
- up to 46,073 acres
- New and reconstructed roads for timber access
- 0.5 mile new, 20 miles reconstructed
- Public motorized-use road miles, before vs. after
- 118 miles reduced to 102 to 108 miles
- Priority weed acreage projected after 5 years
- 29 acres could grow to 56 acres
General Location of Proposal
Open the document ↗“It includes 49,431 acres of land on the Hell Canyon Ranger District, including 46,844 acres of National Forest System (NFS) land”
Summary of Proposed Action
Open the document ↗“Commercial timber harvest is proposed on up to 9,677 acres.”
Fuel Reduction
Open the document ↗“Prescribed broadcast burning is proposed on up to 46,073 acres throughout the project area”
Summary of Proposed Action
Open the document ↗“approximately one-half mile of new permanent road would be constructed. Reconstruction of 20 miles of roads would also occur”
Transportation System
Open the document ↗“reduce the total mileage of roads in the project area open to public motorized use from approximately 118 miles to 102 to 108 miles”
Non-native Invasive Plants
Open the document ↗“after five years the total could be as high as 56 acres”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 3
- Hold up
- 3
- No support given
- 2
- Never analyzed
The Forest Service proposes commercial timber harvest on up to 9,677 acres, thinning and conifer removal on tens of thousands more, prescribed burning on up to 46,073 acres, and road building, repair and closures west of Custer, South Dakota. It says this will cut fire hazard, boost timber production as federal direction requires, and restore riparian areas, meadows, a research natural area and roads.
“The proposed action would result in beneficial effects by proactively managing the landscape to increase resilience and safety.”
Discussion
Effects
No support given
Soil disturbance won't exceed the Forest Plan's 15 percent limit or cause long-term loss of soil productivity.
The agency says almost all soils rate high for restoration potential, there are no known areas of concern, and operations would occur on dry or frozen soils with slash mats on steep slopes. It also cites Black Hills monitoring finding detrimental levels uncommon and a study showing zero to 12 percent disturbance with steep-slope methods. But it names soil disturbance in combination with other activities as a substantive issue, admits monitoring hasn't occurred recently in the area, and gives no existing or projected disturbance figures after 16,052 acres of harvest since 2006 in Table 7. So closeness to the 15 percent limit can't be checked.
The agency’s words, the record and the law +Hide the words
The agency says
“Because the proposed action includes design criteria protecting soil health and would be implemented consistent with Forest Plan standards and best management practices, it would not result in loss of long-term soil productivity or exceed regulatory thresholds.”
Soil Productivity
Elsewhere in the same document
“Soil disturbance monitoring has not occurred recently in the project area.”
Soil Productivity
“Concern was raised that the proposed action, in conjunction with past activities in the project area, could cause detrimental soil disturbance levels to approach this threshold in some areas.”
Soil Productivity
The law
“Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗
Effects
No support given
Lower wildfire risk will prevent enough future weed spread to outweigh the weed increase the project causes.
The agency cites a study that severely burned forests are prone to invasion. It quantifies the project's side: priority weeds from 29 to as high as 56 acres in five years, and non-priority weeds from about 2,300 to as many as 4,400 acres. It never estimates how many weed acres lower fire risk would avoid, so the weighing has nothing on the other side.
The agency’s words, the record +Hide the words
The agency says
“With implementation of proposed weed control measures, this positive effect of fire hazard reduction would be expected to outweigh the potential harm.”
Non-native Invasive Plants
Elsewhere in the same document
“Non-priority species could increase to as many as 4,400 acres.”
Non-native Invasive Plants
“Design criteria described starting on p. 16, including avoidance of areas infested with priority weed species, cleaning of equipment, prompt reporting of new infestations, and control actions, are expected to reduce but not eliminate the potential for additional infestation.”
Non-native Invasive Plants
Effects
No support given
Cultural resources, including tribal sacred sites, will be protected by avoidance.
The agency has finished inventory and consultation on 18,219 acres in the north, with 16 areas to protect by avoidance and a finding of no adverse effect. It commits that implementation won't occur until inventory and Section 106 consultation are complete, under a phased approach allowed by a 2019 programmatic agreement. Still, inventory in the southern part, which makes up most of the National Forest acres, is in progress, its protection measures aren't written yet, and tribal consultation on sacred sites is ongoing, so protection there can't be confirmed from this text.
The agency’s words, the record and the law +Hide the words
The agency says
“Identified cultural resources would be protected from adverse impacts by avoidance during project implementation.”
Relevant Executive Orders
Elsewhere in the same document
“Inventory of historic properties and Section 106 consultation have been completed on 18,219 acres in the northern part of the project area, resulting in 16 areas to protect (see p. 17).”
Heritage and Cultural Resources
“Similar measures will be developed for the southern part of the project area before project implementation (see p. 27).”
Heritage Resources Protection
The law
“shall take into account the effect of the undertaking on any historic property.” National Historic Preservation Act, 54 U.S.C. 306108 ↗
What the document never analyzes
Not analyzed
Climate and carbon effects
The project would burn up to 46,073 acres and harvest thousands of acres of mostly mature pine, yet emissions are discussed only for Clean Air Act smoke compliance.
Searched all 45 pages for ‘climate’, ‘carbon’, ‘greenhouse’. None appear.
Not analyzed
Groundwater and spring flows
The area has 185 springs, 195 wetlands and a limestone plateau, yet the water analysis covers only surface streams and sediment.
Searched all 45 pages for ‘groundwater’, ‘aquifer’, ‘recharge’. None appear.
Where its own record backs the agency
AuthorityThe National Forest Management Act and Forest Plan allow commercial harvest on lands unsuitable for timber production to meet non-timber goals.Why it holds +
The document cites 36 CFR 219.14 and the Forest Plan for allowing unscheduled harvest on unsuitable lands to meet multiple-use goals. Table 20 ties 1,188 of the 1,649 acres to fire hazard, old growth and aspen goals. For the 461 acres of restrictive topography, the table points back to the purpose and need, which includes fire hazard reduction, meadow restoration and other non-timber goals. It also says advanced logging would make harvest feasible there. A reader may want a clearer tie for those 461 acres, but the legal point the claim makes is supported.
The agency says
“While the Forest Plan identifies certain lands as “unsuitable,” NFMA and the Forest Plan allow unscheduled commercial harvests on such sites, including low-productivity areas and old-growth landscapes, to achieve multiple-use objectives like hazardous fuels reduction.”
National Forest Management Act
Its own record backs it
“Eleven percent of the project area consists of forest considered to be unsuitable for timber production (Forest Plan Appendix G-1).”
Timber Production
EffectsThe project would lower fire hazard compared with doing nothing.Why it holds +
Table 19 shows very high hazard falling from 4 to 3 percent of pine acreage and high hazard from 27 to 15 percent, with medium rising from 66 to 82 percent. The existing ratings leave out recent wind-damage fuels, so the baseline may understate hazard, but the document's own figures back the direction of the claim.
The agency says
“The proposed action would decrease fire hazard as compared to the effects of taking no action (Table 19).”
Fire Hazard
Its own record backs it
“Approximately four percent of pine acres in the project area are currently rated as having very high fire hazard.”
Fire Hazard
“These figures are based on verified stand structural stage and size class but do not account for scattered areas of hazardous fuels created by recent wind damage, especially in the southern part of the project area.”
Fire Hazard
EffectsWater quality will see no more than minimal changes in temperature and sediment.Why it holds +
The agency cites monitoring reports showing best management practices generally prevent or minimize road sediment, notes aquatic management zone buffers, and plans 16 miles of road closures. The baseline supports low risk: three main watersheds are functioning properly, no streams are listed as impaired, and 97 percent of stream miles are ephemeral or intermittent.
The agency says
“With full implementation of project-specific design features, Forest Plan standards and guidelines, watershed conservation practices, and best management practices, the proposed action would be expected to cause no more than minimal changes to water temperature, sedimentation, and sediment yields.”
Water Quality
Its own record backs it
“Proposed road construction, improvement, and maintenance would be conducted in accordance with best management practices, which have been shown to generally prevent sedimentation or reduce it to negligible levels (USDA Forest Service 2020, 2026b).”
Water Quality
“No streams in the project area are listed as impaired by the State of South Dakota.”
Water Quality
Read from the agency’s own decision document ↗, all 45 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The agency used emergency authority under the 2022 Infrastructure Investment and Jobs Act to limit this EA to only a proposed action and a no-action baseline, so no full range of action alternatives that might reduce logging, road building, or burning intensity was ever developed or compared. The document itself admits this was a choice made possible by the emergency designation, not a finding that no reasonable alternatives existed. The agency should prepare or analyze a genuine range of action alternatives, or explain in detail why no alternative between full build-out and no action was feasible for a 46,844-acre National Forest project.
- The agency's own Table 22 shows that habitat structural stages 4A and 4B, which together make up the majority of pine acreage in both Management Areas 5.1 and 5.4, would move further away from Forest Plan objectives under the proposed action, not closer, directly undercutting the EA's narrative that the project produces broadly beneficial structural outcomes. The agency should directly reconcile this admitted divergence from Forest Plan objectives with its overall beneficial-effects conclusion and disclose whether the project is consistent with the Forest Plan's structural stage direction.
- The biological assessment reaches a 'may affect, likely to adversely affect' determination for the northern long-eared bat, a federally threatened species, citing potential loss of roost trees, alteration of roost areas, and disruption of hibernation, yet the EA proceeds toward a finding of no significant impact without a detailed public discussion of how this adverse determination squares with that conclusion. The agency should disclose the full biological opinion analysis and explain how a likely-adverse-effect finding for a threatened species is consistent with a finding of no significant impact.
- The agency's own weed analysis projects that under the proposed action, priority weed infestation could expand at up to 14 percent per year compared with 8 percent under no action, and non-priority weed species could reach as many as 4,400 acres, yet the EA concludes this is outweighed by fire-hazard benefits without quantifying the ecological cost of a potential 4,400-acre weed footprint. The agency should analyze the 4,400-acre non-priority weed projection in the same detail given to fire hazard and disclose monitoring commitments to verify it does not occur.
Show every point from the document
- The agency admits that soil disturbance monitoring has not occurred recently in the project area, meaning there is no current baseline data on existing detrimental soil disturbance, yet the EA still concludes that combined past and proposed activities will not approach the Forest Plan's 15 percent detrimental disturbance threshold. The agency should conduct current soil disturbance monitoring before finalizing this determination or explain what data actually supports the no-threshold-exceedance conclusion in the absence of recent monitoring.
- Outside the four known active goshawk nest area stands, which receive no commercial harvest, the agency's own wildlife analysis states that the proposed action would further decrease potential nesting habitat and retain few stands that could provide near-future habitat if existing habitat is lost, and that this could result in displacement of goshawks or reduced breeding success. The agency should analyze the cumulative effect of this habitat reduction on goshawk population viability across the project area rather than limiting mitigation to currently known, already-active territories.
- The agency's Culmination of Mean Annual Increment determination, which is used to justify which stands are mature enough for final removal harvest under 16 USC 1604(m), relies on stand age as a proxy specifically because the agency lacks limited recent stand inventory data, rather than on current growth measurements. The agency should collect and disclose current stand inventory data supporting the CMAI determination rather than relying on an age-based proxy for a legally mandated growth calculation.
- Because this project was authorized as an emergency action, it is exempt from the standard pre-decisional objection process under 36 CFR 218, and the EA itself states that the duration and format of the public comment period is not prescribed, leaving the public without a defined window or a formal objection mechanism to challenge the decision before it is finalized. The agency should voluntarily commit to a defined, adequate comment period and a mechanism for the public to formally challenge findings before signature.
- Section 106 inventory and consultation with the State Historic Preservation Office have been completed only for the northern part of the project area; the agency states that inventory and consultation for the remainder of the project area are still ongoing at the time this EA was released. The agency should complete cultural resource inventory and tribal consultation for the full project area, including the southern portion, and disclose findings publicly before finalizing this decision, rather than deferring completion to the implementation phase.
- For Executive Order 13186 on migratory birds, the EA states in a single sentence that the analysis determined no measurable negative effect on migratory bird populations, without presenting the supporting analysis, despite the project proposing broadcast burning on up to 46,073 acres and commercial harvest on up to 9,677 acres across pine, meadow, riparian, and shrubland habitats used by many bird species. The agency should disclose the underlying migratory bird analysis and species-specific effects rather than stating a bare conclusion.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
The Roby Forest Management Project proposes timber harvest, fuel reduction, prescribed fire, road improvements, meadow restoration, and riparian restoration activities.
On the record for this fight
1 person has filed on this fight through PLAN. The official record is still catching up.
- Karen W.49 seals
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards
Did the agency answer?
10 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe agency admits that soil disturbance monitoring has not occurred recently in the project area, meaning there is no current baseline data on existing detrimental soil disturbance, yet the EA still c
The agency admits that soil disturbance monitoring has not occurred recently in the project area, meaning there is no current baseline data on existing detrimental soil disturbance, yet the EA still concludes that combined past and proposed activities will not approach the Forest Plan's 15 percent detrimental disturbance threshold. The agency should conduct current soil disturbance monitoring before finalizing this determination or explain what data actually supports the no-threshold-exceedance conclusion in the absence of recent monitoring.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's own Table 22 shows that habitat structural stages 4A and 4B, which together make up the majority of pine acreage in both Management Areas 5.1 and 5.4, would move further away from Forest
The agency's own Table 22 shows that habitat structural stages 4A and 4B, which together make up the majority of pine acreage in both Management Areas 5.1 and 5.4, would move further away from Forest Plan objectives under the proposed action, not closer, directly undercutting the EA's narrative that the project produces broadly beneficial structural outcomes. The agency should directly reconcile this admitted divergence from Forest Plan objectives with its overall beneficial-effects conclusion and disclose whether the project is consistent with the Forest Plan's structural stage direction.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe biological assessment reaches a 'may affect, likely to adversely affect' determination for the northern long-eared bat, a federally threatened species, citing potential loss of roost trees, altera
The biological assessment reaches a 'may affect, likely to adversely affect' determination for the northern long-eared bat, a federally threatened species, citing potential loss of roost trees, alteration of roost areas, and disruption of hibernation, yet the EA proceeds toward a finding of no significant impact without a detailed public discussion of how this adverse determination squares with that conclusion. The agency should disclose the full biological opinion analysis and explain how a likely-adverse-effect finding for a threatened species is consistent with a finding of no significant impact.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's own weed analysis projects that under the proposed action, priority weed infestation could expand at up to 14 percent per year compared with 8 percent under no action, and non-priority we
The agency's own weed analysis projects that under the proposed action, priority weed infestation could expand at up to 14 percent per year compared with 8 percent under no action, and non-priority weed species could reach as many as 4,400 acres, yet the EA concludes this is outweighed by fire-hazard benefits without quantifying the ecological cost of a potential 4,400-acre weed footprint. The agency should analyze the 4,400-acre non-priority weed projection in the same detail given to fire hazard and disclose monitoring commitments to verify it does not occur.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingOutside the four known active goshawk nest area stands, which receive no commercial harvest, the agency's own wildlife analysis states that the proposed action would further decrease potential nesting
Outside the four known active goshawk nest area stands, which receive no commercial harvest, the agency's own wildlife analysis states that the proposed action would further decrease potential nesting habitat and retain few stands that could provide near-future habitat if existing habitat is lost, and that this could result in displacement of goshawks or reduced breeding success. The agency should analyze the cumulative effect of this habitat reduction on goshawk population viability across the project area rather than limiting mitigation to currently known, already-active territories.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency's Culmination of Mean Annual Increment determination, which is used to justify which stands are mature enough for final removal harvest under 16 USC 1604(m), relies on stand age as a proxy
The agency's Culmination of Mean Annual Increment determination, which is used to justify which stands are mature enough for final removal harvest under 16 USC 1604(m), relies on stand age as a proxy specifically because the agency lacks limited recent stand inventory data, rather than on current growth measurements. The agency should collect and disclose current stand inventory data supporting the CMAI determination rather than relying on an age-based proxy for a legally mandated growth calculation.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingBecause this project was authorized as an emergency action, it is exempt from the standard pre-decisional objection process under 36 CFR 218, and the EA itself states that the duration and format of t
Because this project was authorized as an emergency action, it is exempt from the standard pre-decisional objection process under 36 CFR 218, and the EA itself states that the duration and format of the public comment period is not prescribed, leaving the public without a defined window or a formal objection mechanism to challenge the decision before it is finalized. The agency should voluntarily commit to a defined, adequate comment period and a mechanism for the public to formally challenge findings before signature.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingSection 106 inventory and consultation with the State Historic Preservation Office have been completed only for the northern part of the project area; the agency states that inventory and consultation
Section 106 inventory and consultation with the State Historic Preservation Office have been completed only for the northern part of the project area; the agency states that inventory and consultation for the remainder of the project area are still ongoing at the time this EA was released. The agency should complete cultural resource inventory and tribal consultation for the full project area, including the southern portion, and disclose findings publicly before finalizing this decision, rather than deferring completion to the implementation phase.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency used emergency authority under the 2022 Infrastructure Investment and Jobs Act to limit this EA to only a proposed action and a no-action baseline, so no full range of action alternatives t
The agency used emergency authority under the 2022 Infrastructure Investment and Jobs Act to limit this EA to only a proposed action and a no-action baseline, so no full range of action alternatives that might reduce logging, road building, or burning intensity was ever developed or compared. The document itself admits this was a choice made possible by the emergency designation, not a finding that no reasonable alternatives existed. The agency should prepare or analyze a genuine range of action alternatives, or explain in detail why no alternative between full build-out and no action was feasible for a 46,844-acre National Forest project.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingFor Executive Order 13186 on migratory birds, the EA states in a single sentence that the analysis determined no measurable negative effect on migratory bird populations, without presenting the suppor
For Executive Order 13186 on migratory birds, the EA states in a single sentence that the analysis determined no measurable negative effect on migratory bird populations, without presenting the supporting analysis, despite the project proposing broadcast burning on up to 46,073 acres and commercial harvest on up to 9,677 acres across pine, meadow, riparian, and shrubland habitats used by many bird species. The agency should disclose the underlying migratory bird analysis and species-specific effects rather than stating a bare conclusion.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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