CGNF 2022 Land Management Plan
Reverse Chronological Order
Most recent actions at the top. For chronological sequence read from bottom up.
One of the most important parts of a Land Management Plan is the designation, or not, of Recommended Wilderness Areas (RWAs) - especially in areas, like the Pryors, which currently have no formally designated Wilderness Areas. Therefore we paid particular attention to this issue throughout the planning process. A helpful place to begin reading about this topic might be our April 13, 2017 letter to CGNF proposing RWAs in the Pryors (linked at the very bottom of this page).
N. January 28, 2022: CGNF released the Land Management Plan, Final Environmental Impact Statement and Final Record of Decision. These final documents have been modified, in mostly minor ways, to address the Regional Forester’s April 15, 2021 Response to public Objections to the July 9, 2020 versions. The Plan covers the entire three million acres of the Custer Gallatin National Forest, but here we only address the Pryor Mountain part.
We are pleased that the final Plan, like the previous version, designates the 10,662 acre Bear Canyon Recommended Wilderness Area (RWA) which the Pryors Coalition proposed more than a decade ago. This would not have happened without considerable effort by the Pryors Coalition (and allies) to persuade CGNF. See the many letters linked below.
We remain deeply disappointed that CGNF failed to provide the same protection to other at least equally deserving areas we proposed as RWAs: the Punch Bowl and Dryhead Creek area, the Big Pryor Plateau area, and a considerable expansion of the Lost Water Canyon area. The “Backcountry Area” designations for Punch Bowl and Big Pryor are simply inadequate substitutes for Wilderness designation. And CGNF greatly reduced the size of our proposed Punch Bowl area.
As a result of our formal September 6, 2020, Objection, and the Regional Forester’s April 15, 2021 Response, the final Plan states that no new motorized or mountain bike routes will be constructed or designated in the Big Pryor Backcountry Area. (It would be much better if there were no such routes.) The final Plan also states that motorized and mountain bike use will not be permitted in the Punch Bowl Backcountry Area. (It is good to make this explicit, but such uses were already illegal and violations have been very infrequent - if ever.
M. April 15, 2021: Regional Forester, Leanne M. Marten, released her responses to eligible objections to the July 2020 draft record of decision for the CGNF Land Management Plan. Usually appeals and objections to higher levels within the USFS (or BLM) bureaucracy result in a conclusion that “We think our decisions were good.” This time there was a possibly favorable response to one of our objections requesting addition of a management standard stating that no new mountain bike routes would be constructed within Pryor Mountain Backcountry Areas.
“…it’s not fully clear how plan components for the Big Pryor and Punch Bowl Backcountry Areas will limit expansion of mountain bike trails as indicted in the draft record of decision. Therefore, I am instructing [Forest Supervisor Erickson] to clarify how the plan direction will achieve the described management intent for this area in the final record of decision.” Leanne Marten, Regional Forester
We will see whether an appropriate change is made in the final Land Management Plan.
L. September 6, 2020: The Pryors Coalition and allied organizations filed objections to CGNF’s July 2020 Land Management Plan Revision and EIS. Most importantly we requested that the decision to designate the Punch Bowl and Big Pryor areas as “Backcountry Areas” rather than Recommended Wilderness Areas be reconsidered. We also asked that an additional management standard be added to the Plan for management of the Punch Bowl and Big Pryor Areas: “New mechanized trails shall not be constructed or designated.” to enforce the intent, stated by Forest Supervisor Mary Erickson in the Plan, that “existing ... mechanized transport [i.e. mountain bikes] can continue but not expand.” See the Pryors Coalition et al. September 6, 2020 Objections.
K. July 9, 2020: CGNF released the 2020 Land Management Plan, Final Environmental Impact Statement (FEIS), and draft Record of Decision. We were very pleasantly surprised that CGNF was designating a 10,366 acre Bear Canyon Recommended Wilderness Area (RWA). From the beginning CGNF had been resistant to our proposal for this RWA (and others). The Pryors Coalition, its supporters, and partner organizations had kept the pressure on CGNF for this designation for three years. (See below.) We were not surprised, but very disappointed, that CGNF did not designate RWAs in the Big Pryor Plateau, and Punch Bowl areas. Instead they designated the areas as “Backcountry Areas” - a rather toothless “Wilderness Lite.”
J. June 1, 2019: The Pryors Coalition and partner organizations sent a comment letter to CGNF regarding the March 2019 draft LMP and DEIS. In this letter we again strongly argued for designation of Bear Canyon, Big Pryor, and Punch Bowl RWAs, and for expansion of the minimalist Lost Water Canyon RWA. The draft March 2019 EIS included CGNF’s Recommended Wilderness Analysis for the four RWAs proposed in Alternative D. It appears that much of this analysis was designed to justify not designating the areas as RWAs. We explicitly and in detail, pointed out numerous fatal flaws in CGNF’s “analysis” of the wilderness value of these areas. The letter also explains how “Backcountry Area” designation is an utterly inadequate alternative for areas worthy of Wilderness designation. See the Pryors Coalition et al. June 1, 2019 Comment Letter.
I. March 1, 2019: CGNF released a Draft Land Management Plan and Draft EIS. The structure of this Draft LMP was five different alternatives (A, B, C, D, and E). Alt. A was the standard “existing condition” or “no-action alternative.” It is there for comparison and is rarely selected in the final decision. Generally there is an alternative that seems to be the direction the Forest planners are leaning. (Sometimes, but not this time, they call this the “preferred" alternative.”) Alts. B and C appeared to play this role. They mimic CGNF’s January 3, 2018 “Proposed Action.” Finally the planners generally draft “extreme” alternatives on either side of the “preferred” alternative. Alternatives D and E played that role. This allows the decision makers to pick the “preferred alternative” and claim it is a “moderate” compromise.
One of our biggest interests in the new Land Management Plan is the designation, or not, of Recommended Wilderness Areas (RWAs). In this draft LMP alternatives A, B, and C all included a single minimalist (6,804 acre) RWA that already existed having been designated in 1968 - 54 years ago! Alternative E proposed eliminating that RWA. That is extreme! Alternative D proposed four RWAs totaling 43,861 acres. That was essentially the Pryors Coalition Proposal. We don’t consider that proposal extreme. (See our April 13 2017 letter at the bottom of the page.) The draft EIS associated with this 2019 LMP includes CGNF’s analysis of the wilderness value of these RWAs.
H. February 28, 2018: The Pryors Coalition and allied organizations submitted a comment letter to CGNF regarding the 2018 Proposed Action for Forest Plan Revision. We objected to the “Backcountry Area” designations as poorly defined, variably interpretable, and easily modifiable. They are not a valid substitute for the well understood gold standard of “Wilderness.” Backcountry Areas seem human centered and recreation focused, while Wilderness is ecosystem centered and landscape focused. And there are well established legal standards for Wilderness. We again argued for RWA designation.
We also objected to CGNF’s also proposal for a ¼ mile boundary setback of special designated areas from all 4WD routes. In a small landscape like the Pryors this would significantly reduce protection for any wilderness designations (and for Backcountry Areas to whatever extent they are protective). We pointed out that these setbacks actually violated USFS policy, and were inconsistent with BLM practice in the Pryors. (These setbacks were removed from CGNF’s 2019 draft plan.)
Some excerpts from the Summary of Main Points in the Pryors Coalition et al. February 2018 comment letter:
“Develop a Management Plan with policies consistent with BLM and BCNRA based on a unified and holistic vision of and for the Pryor Mountain landscape. Seriously imagine what the Pryors might be in 2050 and beyond – and how this Plan will affect that future.”
“Develop a robust set of Pryors-specific plan components, including desired conditions, standards and guidelines, to maintain or restore the ecological integrity and diversity of ecosystems and habitat types.”
“Designate as Recommended Wilderness Areas those areas proposed as “Backcountry Areas” in the Proposed Action. Landscapes east of the Beartooths merit and need protection equal to that of western Montana landscapes. The fact that they are very different is a reason to designate them – not a reason to overlook them. They will enrich the National Wilderness Preservation System.”
“Expand the Lost Water Canyon RWA east to Burnt Timber Rd to include all the Inventoried Roadless area. This will also make management consistent across the southern CGNF border with BLM.”
“Include desired conditions and plan components to provide balanced opportunities for quiet recreation and motorized access in the Pryors. All recreation opportunities must be secondary to preservation of ecological values of the landscape.”
See the Pryors Coalition et al. February 28, 2018 Comment Letter. (Appendices V, VI, & VII of this letter are reproductions of our previous letters submitted to CGNF on April 13, August 25, and September 25, 2017. See below.)
G. January 3, 2018: CGNF released a Proposed Action for the Revised Forest Plan for public comment. CGNF did not accept our previous proposal for Recommended Wilderness Areas in the Pryors. Instead they proposed a new, ad hoc, and much weaker designation they named “Backcountry Areas.” However CGNF did include 41,976 acres of Big Pryor Mountain in the Wilderness Inventory of areas that qualified for evaluation to consider for wilderness recommendation. This included the Bear Canyon and Big Pryor areas we had proposed for designation as RWAs. This inclusion in the Wilderness Inventory was a small step forward because previously CGNF had claimed these areas did not even qualify for consideration as Wilderness Areas. But CGNF’s evaluation of these areas was seriously inadequate. One big flaw was their evaluation was of the entire 42,000 acres, rather than focusing on the characteristics of the two specific areas that might be RWAs.
F. Note: After we sent the three letters below, CGNF revised the Wilderness Inventory to include 42,000 acres of Big Pryor Mountain including the areas we propose for RWAs. However we wonder whether a bias against designating more Pryors Wilderness that allowed CGNF staff to accept the obviously absurd results of their GIS Model may have influenced the later tepid evaluation and analysis of our proposed new Pryor Mountain RWAs. Presumably due to three years of pressure from the Pryors Coalition, many partner organizations, and individuals, CGNF did eventually designate the Bear Canyon RWA.
E. September 25, 2017: Pryors Coalition Field Study: Noticeability of Range Improvements on Big Pryor Mountain. The August 9 & 25 letters (below) respectively identify fatal flaws in CGNF’s standard for noticeability, and in their GIS model. This September 25 letter addresses a third fatal flaw in CGNF’s Wilderness Inventory: CGNF clearly did not field check their GIS model. We did. This letter reports the results of our Field Study, which shows that the Big Pryor and Bear Canyon areas do not have substantially noticeable range infrastructure. In fact the few water developments and fences are rarely even visible. The area “generally appear[s] to have been affected primarily by the forces of nature, with the imprint of man’s work substantially unnoticeable.” These areas, which we have proposed for designation as RWAs, overwhelmingly satisfy all the criteria in the FS Planning Handbook for Wilderness designation. Read the Pryors Coalition’s Field Study: Noticeability of Range Improvements.
D. August 25, 2017: Pryors Coalition – Supplementary Wilderness Inventory Comments.
In this letter the Pryors Coalition identified the serious methodological flaws in CGNF’s GIS Model for Range Improvements. CGNF’s GIS model used all water developments and miles of fence within 3.5 miles of any point to supposedly determine the local density, and therefore “substantial noticeability” of range infrastructure. (Did the CGNG GIS modelers realize they were using a 3.5 mile radius circle?) Using a 3.5 mile radius circle has two major problems: 1. Most of the area of this 7 mile diameter (25,000 acre) circle is far outside the ~10,000 acre Bear Canyon and/or Big Pryor areas being considered for Wilderness recommendation. According to FS Planning Handbook, developments (including range infrastructure) outside the proposed wilderness must not be considered. 2. According to the FS Planning Handbook the question is not what the density of range infrastructure is, but whether it is “substantially noticeable.” If it can’t be seen, it is not noticeable. Read the Pryors Coalition’s August 25, 2017 Letter.C. August 9, 2017: The Pryors Coalition’s first response letter to the CGNF Wilderness Inventory. This letter challenges CGNF’s range infrastructure density standard for inclusion in the Wilderness Inventory. CGNF provides absolutely no rationale for their arbitrarily invented standard of less than one water development or mile of fence per square mile. A little consideration of this standard shows that it is absurd as a measure of “substantially noticeable” infrastructure. In fact CGNF’s standard is about “density” only and does not address noticeability or even visibility. Read the Pryors Coalition’s August 9, 2017 Letter. The most pertinent section of the letter from the middle of page 2 at the heading “5. Big Pryor Mountain” to the middle of page 4.
B. July 10, 2017: CGNF Wilderness Inventory. According to the FS Planning Handbook the first step toward possible designation of Recommended Wilderness is to make a Wilderness Inventory of all areas that might qualify. Only areas in the Wilderness Inventory continue through the process of evaluation, analysis, and finally recommendation as wilderness - or not. The first version of CGNF’s Wilderness Inventory excluded most of the wildest parts of Big Pryor Mountain from further consideration - including our proposed Bear Canyon and Big Pryor RWAs. We asked CGNF, “Why?”
CGNF said it was based on a GIS model that showed too high a density of human developments of cattle range infrastructure. A July 18 email from Pam Novitzky, CGNF Wilderness and Recreation lead on Forest Plan Revision, cited their July 10, 2017 Wilderness Inventory Protocol under Range Improvements:
“Concentrations of infrastructure where the density is greater than one mile of fence or one water development (wells, tanks, spring developments, stock ponds / reservoirs, etc.) per square mile are considered substantially noticeable and were removed from the inventory.”
Our next three letters to CGNF, August 9, August 25, and September 25 (above) each address a different fundamental flaw in CGNF’s Wilderness Inventory.
A. April 13, 2017: Recommended Wilderness Areas in the Pryors. In this letter to CGNF the Pryors Coalition and partner organizations described and provide extensive and we think compelling, rationale for the four Recommended Wildernesses we propose for the Pryors: Bear Canyon, Big Pryor, Punch Bowl and a greatly expanded Lost Water Canyon Wilderness Areas. CGNF has resisted these proposals every step of the way - apparently considering our ideas to be extreme. We think this was, and still is, a moderate proposal. In our letter we wrote:
“Analysis of the CGNF landscape shows that more RWAs can appropriately be designated with lands that clearly qualify for Wilderness designation - and without serious disruption of existing uses of the land. The Pryors Coalition has identified 40,000 additional acres within CGNF that qualify for designation as RWAs.
“In our selection process we worked within the framework of the 2008 Travel Management Plan. We identified four “wild” areas, each well over the 5,000 acre minimum and suitable to be managed to preserve their wilderness character. These areas have either no designated public motorized roads, or only a few miles of dead end routes.
“Thus almost the entire extensive network of motorized routes in the Pryors is preserved. In particular this includes all the most popular and heavily used routes to the best views and through all the many landscape types. Our proposal also preserves all existing motorized loop routes.”
Read the Pryors Coalition’s April 13, 2017 Letter and form your own opinion.