Click on points below to learn about important issues in the Travel Plan and the Pryors Coalition’s response. Stop before you get overloaded with details. Send a note to Custer National Forest (with a copy to us) based on what you have learned and issues most important to you. If later you find other issues important to you, there is no reason you can’t send additional comments to the Forest.

Notations such as (DEIS page 3-134) in the comments below mean that the quotation is from Chapter 3, page 134 of the DEIS.

What is all this jargon about DEIS, Alternatives A, B, C, Comment Period, etc....?

Does the Forest Planning process have a sufficiently long range view?

“For temporal scope, a ten year timeframe for project implementation is used.” (DEIS page 3-1) “…ten year planning horizon of the travel management decision….” (DEIS page 3-134)

Planning only ten years ahead is short sighted. The last travel plan prepared has lasted (poorly) for twenty years and counting. The first assumption should be that the new travel plan will be in effect for just as long. In any case impacts on ecosystems and landscapes last for far longer than ten years. Land management planning should have a much longer vision. What we do now will strongly affect the Pryors and the people who love them for many decades.

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Does the Forest recognize the long term importance of its Travel Planning decisions?

“Travel Management direction would not be an irreversible or irretrievable commitment because human travel is not a consumptive use and the direction itself could be changed at any time.” (DEIS page 3-4)

This is only a little bit true. The impacts of human travel are not as irreversible as open pit mining. But many impacts can be effectively irreversible, and bad decisions may be effectively irretrievable. Many road impacts can only be restored with great time and/or money. Some impacts, such as the introduction of noxious weeds and the resulting landscape changes, are clearly irreversible. The original ecosystem can never be restored. Loss of soil, especially in arid landscapes, is also irreversible on a human time scale. The decision to allow a particular road is also very difficult to reverse politically. The belief that Travel Management decisions are reversible and retrievable makes it too easy to avoid recognizing that the decisions made in this Travel Plan will determine the character of the Pryors for many decades and beyond.

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Does the Forest Service begin with a vision for the future of the Pryors?

“Zoning areas by type of use or similar management prescription is more appropriate for land management planning. This analysis is largely focused on the designation and use of routes (roads and trails), rather than prescriptive land use direction that would require amending current Forest Plan land use direction which is beyond the scope of this analysis.” (DEIS page 2-10)

This is a rationalization for not having a vision and a plan for the Travel Plan. Travel Planning IS management planning. Very few management decisions have more impact on land use direction than travel planning. This designation of roads preempts future management planning. The Travel Plan is doing management planning by default. It seems obvious that to protect ecosystems and individual species the first thing to do would be to define zones for the purpose. Then similar zones would be defined for conflicting human uses. Then the travel routes would be planned around this outline. It appears that no thinking of this sort was done in this travel planning process. This is unfortunate given the irreversibility of the decisions being made. These decisions will affect many generations of people. The Forest’s proposal is a Plan without Vision.

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The Pryors Coalition has a Vision.

Several years ago a small, ad hoc group of volunteers began working on a Travel Plan proposal for the Pryors. This group slowly developed into the current Pryors Coalition. We quickly understood that the best, and easiest, way to create a road proposal was to start with a Vision of what we thought the Pryors should look like several decades into the future. Why are the Pryors important? How can that be preserved? What will be the value of the Pryors to people in the region in the future?

We understood that a broad range of resources needed to be protected, and a broad range of recreational interests needed to be accommodated while minimizing conflict among them. People needed motorized access, and people needed to be able to get away from roads. We developed an overview with non-motorized enclaves surrounded by motorized corridors. This web of road corridors provides abundant access to, around, and between the quiet areas. Great motorized tours of the Pryors are available. Great escapes from motorized commotion are possible. Wildlife have secure habitat.

With this outline it was relatively easy to decide which of the many user created tracks should remain motorized and which should not.

If the small, ad hoc group of volunteers could approach the problem this way, why didn’t the full time, professional staff in the Custer National Forest?

Although the Forest’s planning procedure did not base the range of alternatives on a vision (or visions) for the future, Alternative C is based largely on the Pryors Coalition Vision. The Travel Plan DEIS does not mention this vision, and Custer National Forest does not endorse it, but the pattern of roads is (with one exception) consistent with the Vision. Choosing this option would allow the Coalition’s vision to be developed in the future. The exception is route #2088 which should be non-motorized to the west of Crater Ice Cave. Please support Alternative C with this important modification.

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Does the Forest’s analysis of the alternatives support its choice of Alternative B as the Preferred Alternative?

Most of Custer National Forest’s own lengthy (202 page) and detailed analysis of the eleven significant issues identified by the Forest indicate that Alternative C is much better than Alternative B. We found none of the identified significant issues which on analysis supported the choice of Alternative B.

We believe Forest officials should be held to a high standard. They should pick the Alternative which is shown by their analysis to be best for all resources. It is not good enough to choose an alternative providing a lower level of resource protection without compelling and clearly stated reasons.

When explaining why Alternative B was chosen despite their own analysis of a particular issue strongly supporting Alternative C, Custer National Forest officials talk of “trade-offs” and “competing needs”. We can not find these “competing needs” or “trade-offs” in the DEIS since the Forest’s own analysis does not show ANY of the significant Issues supporting Alternative B over Alternative C.

Overall the Forest’s own analysis powerfully supports Alternative C as the Preferred Alternative. See the issue by issue analysis that follows.

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Significant Issues identified by the Forest:

• Economics

  This issue concerns the potential economic effects on surrounding communities. The Forest’s economic study shows that non-motorized use (especially hiking and walking) account for far more positive economic impact than motorized use (especially more than Off-Highway Vehicle -- “OHV” use). Non-motorized use has about 3.5 times the effect of motorized use. Hiking and Walking has about 10 times the effect of OHV use.

  Clearly this study suggests that Alternative C should be preferred over Alternative B. Alternative C includes more opportunities for non-motorized use, but includes abundant opportunity for Driving for Pleasure. It also allows considerable OHV opportunities.

  The table below shows results of the Forest’s study of economic effects. From this data the Forest concludes,

  “The Table indicates that approximately 72 total jobs … and $1.463 million in total labor income was attributable to non-motorized activities on the Forest... The vast majority (76%) of these jobs and income were associated with hiking/walking.

  “Motorized activities were responsible for approximately 22 total jobs … and $447,773 in total labor income…. Driving for pleasure on the Forest accounted for approximately 15 total jobs (69% of the motorized total) and $302,302 in total labor income (67% of the motorized total). OHV use on the Forest accounted for approximately 5 total jobs (23% of the motorized total) and $110,110 in total labor income (25% of the motorized total).” (DEIS page 3-11)

  Economic Effect: Data from Table 3-6. Employment and Labor Income Effects by Activity Type (DEIS page 3-11)

  Activity	Employment Effects (full & part-time jobs)	Labor Income Effects ($)
  Non-motorized use
  Backpacking	7.1	$145,315
  Hiking/Walking	54.6	$1,113,300
  Bicycling	7.8	$157,616
  Motorized use
  OHV	5.1	$110,110
  Driving for Pleasure	15.0	$302,302

  This table includes the activities most relevant to the Travel Plan decision. It combines the Direct and Indirect Effects, and the Local and Non-local categories. (The way the study was done Billings people were considered “Non-local”.)

  This analysis can be criticized for lumping the Pryors in with the rest of Custer National Forest. The results show, however, that the economic effect of non-motorized use is many times that of motorized use. Correcting this deficiency could not erase that overwhelming difference. Furthermore, it should be noted that this is the data the Forest used to make its decision.

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• Human Environment

  The Economic data show a significantly higher potential economic effect of changes in non-motorized than in motorized opportunities. The Recreation data show that significantly more forest users recreate by walking than by OHV. Given these facts, one would expect that the Forest would choose an alternative which does not significantly decrease non-motorized opportunities in favor of motorized opportunities. Yet the Forest’s Preferred Alternative B decreases non-motorized recreation opportunity by nearly 15% , and increases motorized recreation opportunity by over 11%,. This is especially surprising since Alternative C still provides more than half (53%) of the USFS Pryors for motorized recreation. (See table 3-16, page 3-30)

  As long as both motorized and non-motorized recreation are allowed in the Pryors there will be conflicts among users. These conflicts could be reduced, however, by basing the Travel Plan on a zoning plan. Unfortunately, the Forest rejected this approach. (See “Does the Forest Service begin with a vision for the future of the Pryors?”)

  Important Note: The percentages in Table 3-8 are calculated incorrectly from the data in Table 3-16. The incorrect values greatly underestimate the impact of Alternative B on non-motorized recreation. (See the excerpt from Table 3-16 at the end of the Recreation section below.)Both the incorrect and corrected data are included in the two tables below.

  For example: Non-motorized Recreation Opportunity decreases from 33,913 acres in the No Action Alternative to 28,849 acres in Alternative B. This is a decrease of 5,064 acres, which is 14.9% of 33,913 acres. Decreasing from 43% to 37% of total (motorized and non-motorized acreage) is much more than a 6% decrease in the acres available for non-motorized users. A loss of 5,064 acres, and 14.9% decrease accurately reflect the impact on non-motorized users.

  Incorrect Table 3-8. Percent Change in Acreage Available for Motorized and Non-motorized Recreation Opportunities Compared Against No Action (DEIS page 3-17)

  	Alternative A	Alternative B	Alternative C
  Pryor Unit
  % Change in Motorized Recreation Opportunity	15% increase	10% increase	3% decrease
  % Change in Non-motorized Recreation Opportunity	14% decrease	6% decrease	4% increase

  
  
  

  Corrected Table 3-8. Percent Change in Acreage Available for Motorized and Non-motorized Recreation Opportunities Compared Against No Action

  	Alternative A	Alternative B	Alternative C
  Pryor Unit
  % Change in Motorized Recreation Opportunity	25.7% increase	11.5% increase	5.5% decrease
  % Change in Non-motorized Recreation Opportunity	33.4% decrease	14.9% decrease	7.2% increase

  
  
  

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• Recreation

  The Forest’s data shows that non-motorized use (especially hiking/walking) is significantly greater than motorized use (especially OHV). See Tables below. Table 3-15 also projects use trends into the future showing an increase in all uses, but no significant change in the relative proportion of motorized and non-motorized uses.

  This data clearly supports the choice of Alternative C as the Preferred Alternative. Alternative B makes a nearly 15% reduction in non-motorized opportunities. Alternative C decreases motorized opportunity a small amount but still allows 53% of the land in the Pryors for motorized use. (See Table 3-16 below and discussion of Issue 2. Human Environment.)

  The projection shows visits for wildlife viewing increasing at more than twice the rate of increase of all other activities. This again supports Alternative C which provides more secure wildlife habitat.

  “The survey data shows that OHV use is a specialized use of the forest and not a major recreational use for most forests”. (DEIS page 3-24)

  Excerpt from Table 3-3. Custer NF Activity Participation and Primary Activity
  (DEIS page 3-7)

  Activity	% Participation	% as Primary Activity	Estimated Number of Primary Visits
  Relaxing	26.8	6.6	50,051
  Hunting	19.6	11.1	84,176
  OHV use	2.9	1.6	12,134
  Driving for Pleasure	26.7	5.0	37,917
  Hiking/Walking	40.2	14.5	109,960
  Bicycling	3.9	2.1	15,925
  Viewing Wildlife	42.9	1.0	7,582

  
  
  

  Excerpt from Table 3-15. Beartooth District Recreation Use by Activity Projections (DEIS page 3-29)

  Activity Type	Use %	2002 Visits	2008 Visits	1 year %	2018 Visits
  Hiking or Walking	47.8	271,866	284,916	8.0	307,709
  Wildlife Viewing	52.2	296,892	328,956	18.0	388,168
  Biking	4.3	24,547	25,633	8.0	27,684
  OHV use	2.9	16,494	17,244	7.6	18,555

  The tables include the activities most relevant to the Travel Plan decision in the Pryors. This analysis can be criticized for lumping the Pryors in with the Beartooths. The results show, however, that non-motorized use is many times that of motorized use. Correcting this deficiency could not erase that overwhelming difference. Furthermore, as before, it should be noted that this is the data the Forest used to make its decision.

  Excerpt from Table 3-16. ROS* setting acreage by alternative (acres) (DEIS page 3-30)

  ROS Setting	Alternative B	Alternative C	No Action
  Pryors Unit
  Motorized	63% (49,119)	53% (41,621)	56% (44,055)
  Non-motorized	37% (28,849)	47% (36,347)	43% (33,913)

  *ROS means "Recreation Opportunity Spectrum"

  
  

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• Cultural Resources

  “This issue concerns the potential effects that travel management … may have on the scientific, traditional, cultural, and intrinsic values of archeological, cultural, and historic sites …. In addition, motorized use in the Pryor Unit could have an adverse effect to certain areas of traditional importance to the Crow Tribe.” (DEIS page 2-4)

  The following paragraph from the Forest’s DEIS is a very strong statement in support of choosing Alternative C as the Preferred Alternative instead of Alternative B with its 11.5% increase in motorized area in the Pryors.

  “Expanded access to remote areas has increased vandalism of the cultural resource and general degradation of the historic and natural landscape. Crow Cultural Commission Chairman George Reed states that motorized vehicles are threatening the sacredness, solitude and pollution free atmosphere of the Pryor, Arrow Shot Into Rock, Mountain, the last sacred place where individuals go for guidance and prayer without disturbance and interference. He calls for restriction of motorized vehicle travel in the Pryor Unit.” (DEIS page 3-61)

  The same concern is expressed again below:

  “Adverse effects to setting have especially serious consequences for traditional cultural properties, since these sites were chosen for their pristine qualities and remoteness, among other things. Introduction of noise, smells, dust along with increased visitation and accessibility may adversely affect the traditional cultural properties and their continued use.” (DEIS page 3-59)

  A specific example of this concern with regard to the Preferred Alternative B is discussed in the next quotation from the DEIS.

  “Shriver Peak Road accesses the Big Pryor overlook which is now a relatively remote location but still can be visited by motorized traffic. Any increase in access to this area threatens to expose these fasting areas to the same circumstances as the Dryhead Overlook has experienced. The seasonal use restriction may alleviate some of the access damage, but the primary season of use is when most of the motorized use activity occurs that can damage the TCPs and affect the site setting. Increased traffic can be expected with the use of the seasonal “high country loop” provided by a portion of this route and routes 2091 and 2095A which could further affect the overlook setting with the introduction of noise, dust and fumes. Dispersed vehicle camping at the end of the route may begin to affect cairn locations much the same as is occurring in the areas of the Beartooth unit.” (DEIS page 3-64,5)

  Note that the Pryors Coalition does not support this particular motorized “high country loop” although we do support others, including all of route #2091. In our plan the “Shriver Peak Road” (#2088) ends at Crater Ice Cave, and road #2095A is not open for motorized use. The Forest’s analysis of the Cultural Issues in this area suggests that maybe Route #2088 should be closed in its entirety to motorized traffic. (For further analysis see the section about route #2088.)

  The Forest’s analysis of the Cultural Issue ends with the following strong statement about Cumulative Effects.

  “As our national population grows and the west becomes increasingly developed for minerals, residences, and recreational sites, it is becoming increasingly difficult for practitioners of Native religions (or other practitioners) to find places for ceremonial purposes and traditional cultural practices. Fasting overlooks and plant gathering areas that were once isolated locations have become more rare, or harder to utilize, for religious purposes as development and increased access continues. This loss, along with the loss of other TCPs and ethnographic landscapes are irreplaceable and very difficult, if not impossible to mitigate.” (DEIS page 3-66)

  How can choosing Alternative B as the Preferred Alternative be justified?

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• Soils

  “Motorized and non-motorized recreation activities can affect soil and vegetation productivity, cause soil compaction, and soil erosion. (DEIS page 2-4)

  “The magnitude and extent of soil impacts are generally the least on trails designed for non-motorized uses compared to roads and motorized use trails.” (DEIS page 3-73)

  According to Table 3-28 on page 3-74, Alternative B will have 140 miles of motorized roads and trails on areas with a Land Type Assessment (LTA) Erosion Hazard Rating of High. Alternative C will have 94 miles of roads with the High Hazard Rating. We suspect that the difference of 46 miles is mostly in the Pryors although the DEIS mixes both the Pryors and Beartooths in the same table so it is impossible to be sure.

  On page 3-75 the Forest indicates that motorized travel is prohibited on 32 more miles of high erosion hazard routes in Alternative C than in Alternative B.

  We saw no mention of cryptobiotic soils in the Forest’s analysis. Does the Forest have an inventory of such soils in the Pryors and the potential of Travel Plan alternatives to impact them?

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• Vegetation

  The spread of noxious weeds is probably the biggest concern here. Noxious weeds such as leafy spurge, spotted knapweed, Canada thistle, and houndstongue are in and around the Pryors. They have a high potential to radically and irreversibly change Pryor mountain ecosystems.

  “Motorized vehicles and equipment contribute the most to introduction and spread of noxious weeds because of vehicle mobility and size, and/or distance of travel within a given time.” (DEIS page 3-127)

  Different habitats vary significantly in their susceptibility to weed invasions. Table 3-52 on page 3-133 indicates the number of acres which are highly susceptible to infestation by noxious weeds, and which are within the motorized road corridors in each of the various alternatives. In Alternative B 11,000 acres are highly susceptible. While only 2200 are identified as highly susceptible in Alternative C. This factor of five improvement is a strong reason for choosing Alternative C.

  Unfortunately the Forest does not indicate how much of the 9,000 acre difference in susceptible acreage is in the Pryors. We suspect that much, if not most, of it is.

  The table also reports the percentage of total weed susceptible acres within the motorized route corridors. (12% for Alt. B, and 2% for Alt C). Since total includes both the Pryors and the Beartooths it is highly likely that these percentages greatly underestimate the risk in the Pryors where the total acreage is much smaller. In any case this “small” percentage is no great comfort since, as the Forest says: “ Once the weeds are introduced into an area they generally continue to spread into adjacent areas.” (DEIS 3-36) Thus it can be assumed that any noxious weeds which become established will eventually spread far beyond the 400 foot road “buffers” considered. This is a situation where the ten year planning horizon is extremely inappropriate.

  Given the seriousness of the threat of noxious weeds, and the fact that five times as many acres are highly susceptible within the motorized road corridors in Alternative B than in Alternative A, we simply can see no basis for the following sentence which appears, without justification, in the middle of the analysis.

  “Based on these observations, there is insufficient data to draw a definite conclusion that any alternative would have a significant difference on the spread of noxious weeds based only on the type of use allowed under that alternative.” (DEIS page 3-135)

  Note: there is apparently a typographical error in table 3-54. The number 7,808 acres susceptible to weed infestation in Alternative C in that table contradicts the number 2,211 which appears in tables 3-52 and 3-55 and elsewhere in the text.

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• Wildlife

  The results of the Forest’s analysis for General Wildlife, and for individual species, strongly support the choice of Alternative C . The Forest’s Preferred Alternative B is not the best for wildlife.

  General Wildlife:

  “To analyze the general effects of motorized and non-motorized routes on wildlife, a one km buffer on each side of a route was used as suggested by Ruediger (1996). This is considered the “virtual footprint” (Forman et al. 2003) of the route on the land. …. The percent of the Beartooth Unit and the Pryor Unit untouched by the two km footprint of these routes is referred to as “core” The percent of the District outside the two km footprint is the area where wildlife generally is undisturbed by travel routes and the activities that accompany them.” (DEIS page 3-179)

  In Alternative C the wildlife core is 35% of the Pryors. It is only 25% in Alternative B. (DEIS page 3-180)

  “Alternative C. Mortality: This alternative has the lowest potential for leading to wildlife mortality. Habitat Modification /Changes to Behavior: For the Pryors Unit, “core” is the highest under this alternative.” (DEIS page 3-181)

  Clearly Alternative C should be “Preferred”. The following comment under Cumulative Effects – General Wildlife strengthens the argument.

  “Hiking, biking, fishing, ATV use, horseback riding, dispersed camping, and other recreational activities are projected to increase sizably over the next ten to twenty years. This will gradually add to cumulative impacts over time.” (DEIS page 3-182)

  Deer and Elk:

  In the DEIS white-tailed deer and mule deer are identified as “habitat indicator species”, and “key species”. However they are not analyzed because the Forest says the “analysis for elk serves as a surrogate for white-tailed deer”, and “impacts are expected to be similar for” elk and mule deer. (DEIS pages 3-151, 153)

  There are currently no elk in the Pryors but there used to be and could be again with suitable land management. Further, as just noted, the Forest is using the elk analysis as surrogate for a deer analysis. The following conclusion is therefore important, and also applies to deer:

  “Alternative C. Open motorized route density would be lowest in both Units under this alternative and, as expected, elk security cover would be highest. For the Pryors Unit, this is the only alternative that would meet Canfield et al’s (1999) less than 1.0 mi/sq mi road density recommendations.” (DEIS page 3-170)

  This is a strong argument in favor of Alternative C instead of Alternative B which has 1.7 times the road density.

  The Forest also says (page 3-169) that “motorized access is one of the major factors influencing elk vulnerability” and “defined secure areas as >250 acres in size and >0.5 miles from an open road”. By implication this also applies to deer. Alternative C has more area over 0.5 miles from a road – and would be even better without route #2088.

  Bighorn Sheep:

  Escape terrain is critical for bighorn sheep. Alternative C has 1,200 acres more escape terrain in the Pryors than Alternative B. That is 7.3% more than Alternative B. (See Table 3-168, page 3-172.)

  “Alternative C. The availability of escape terrain would be the highest under this alternative in both the Beartooth and Pryors Units. The greatest difference would be in the Pryors, where Alternative C would provide 9.9% more escape terrain than under the No Action Alternative.” (DEIS page 3-173)

  Canada Lynx:

  In their analysis of Canada Lynx the Forest lumps the Pryors in an average with the Beartooths and draws the following conclusion:

  “Alternatives B and C. The availability of lynx habitat would be effectively the same under Alternatives B and C and slightly higher than in Alternatives A and the No Action alternative. Again, the 0.1 mi/sq mi decrease in road density compared to Alternatives A and No Action would be very small, as would the decreased lynx vulnerability and potential for mortality.” (DEIS page 3-156)

  Since the Pryors are very different from, and much smaller, than the Beartooths this approach of combining the Pryors and Beartooths (used several times in the DEIS) can produce invalid results. Fortunately in this case the Forest also provides the independent Pryors data in Table 3-63 on page 3-155. The above conclusion is based on the final “totals” line which shows the same road density (0.2 mi/sq mi) for Alternatives B and C, and 0.3 mi/sq mi for Alternatives A and No Action.

  But the Pryor Mountain Lynx Analysis Unit (LAU) is only one eighth of the area of the total which includes three larger LAUs in the Beartooths. This average road density data is not valid for the Pryors where the road density is much larger (0.6 mi/sq mi in No Action), and there is a big difference between the alternatives. The road density is 0.5 mi/sq mi in Alternative B, and 0.3 mi/sq mi in alternative C which is a 40% decrease. If route #2088 was closed the road density in Alternative C might be even less.

  Migratory Birds:

  The following conclusion suggests that Alternative C is better than Alternative B, but since it is based on averaging the Pryors and the Beartooths it obscures the difference between the alternatives in the Pryors. We suspect that in the Pryors the difference would be significantly greater.

  “Alternative C. The total motorized route miles and average motorized route density (0.27 mi/sq mi) for the District would be lowest under Alternative C. Thus, adverse effects to susceptible bird species would be lowest under this alternative.” (DEIS page 3-188)

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• Maintenance and Administration of Roads and Trails

  Unfortunately none of the data in this section of the DEIS separates the Pryors Unit from the Beartooth Unit. However we expect that much (if not most) of the difference is in the Pryors.

  According to Table 3-79 on page 3-200, the estimated yearly maintenance cost for Alternative B is $96,000 greater than for Alternative C. On the same page the Forest says: “Costs are for comparison only. Actual costs and funding levels vary by year, location and current situation.” This seems to be a tactful way to say that funds for the needed maintenance may or may not be available. It doesn’t seem wise to create more motorized routes than funding is available to maintain. So Alternative C seems both less expensive and wiser.

  But the estimated maintenance cost is only part of the cost difference between Alternatives A and B. For example: Five times as many acres in Alternative B are highly susceptible to noxious weed infestation than in Alternative C. (See Vegetation section.) This will require more funding and staff time for weed monitoring and treatment. If the needed weed control staff and funding are not available then it is probably that noxious weeds will infest significant areas of the Pryors.

  Another example: The more complex road system and greater number of motorized routes in Alternative B will require more funding and staff time for enforcement. If the enforcement level is the same in Alternatives A and B (as claimed in Table 3-76, page 3-197) then enforcement in Alternative B will be spread thinner and be less affective. Ineffective enforcement will lead to more resource damage which will require even more funding and staff time to correct.

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