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November 16, 2007
Steve E.
Williams, Forest Supervisor comments-northern-custer-beartooth@fs.fed.us RE: Beartooth Travel Management DEIS Dear Mr. Williams and Mr Epperly; The Wyoming Wilderness Association is concerned about the Pryor and Beartooth Mountains and Custer National Forest as an adjacent ecosystem which shares resources cross state boundaries. Our organization is based in Sheridan, Wyoming with a membership of over 500 citizens. It is our mission to work to protect our wild public lands for future generations and wildlife. We urge the Forest agency to protect all roadless lands and do not allow any user created routes to be legitimized, or any motorized trials in roadless areas to be managed for upgrades or maintenance should be allowed. Keeping roadless areas primitive will best secure the natural and wild resources for generations to come. We urge the FS to adopt Alternative D for wildlife and wilderness potential of roadless lands, but Alternative C is acceptable as the more balanced alternative, but will suggest improvements. It allows abundant motorized access, which we do not support, especially if there is off-road degradation. We realize that it may be important to allow existing roads for access to spectacular landscapes and viewpoints, but it is important that half of the area allow for quiet recreation opportunities in the natural landscape. No new roads should be built without equal or more being put to bed and restored. We urge that if adopting Alternative C do not allow the two track route #2088 to extend miles into the heart of the Big Pryor North Hiking, Riding and Resource Protection Area. We urge the FS to preserve this area for quiet recreation and wildlife. Route #2088 should not be open to motorized use west of Crater Ice Cave. ATVs have a place in the Pryors, but they shouldn’t be the dominant feature of landscape they’re fast becoming. With a balanced plan for ever-increasing levels of motorized use, we’ll all be able to enjoy the landscape in years to come. We would like to see a balanced management plan that keeps more areas open for hiking, riding, hunting, and enjoying the Pryors’ wildlife. The Custer NF must care for the land and protect the natural resources first -- then manage both motorized and non-motorized recreation within limits the land can tolerate. With increasing motorized abuse on all public lands, the FS must be proactive in protecting the resource and providing good stewardship measures. This means setting reasonable and balanced limits to motorized use. 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. Multiple use does not mean all uses on all acres, thus we urge the FS to consider the adoption of a plan that sets aside quiet non-motorized areas from motorized areas, even mountain bike areas from horse areas should be considered. Some identified areas should be off-limits for deer parturition and critical winter habitat. 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. 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. The Forest’s data shows that non-motorized use (especially hiking/walking) is significantly greater than motorized use (especially OHV). 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. 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). But there are no elk in the Pryors, although there were historically and should reintroduction occur habitat should be set aside and managed for elk. The FS conclusing that Alt c would provide the lowest road density in both Units thus elk security would be highest is further evidence for adopting Alt. C. For Bighorn Sheep, it is noted that Escape terrain is critical. Alternative C has 1,200 acres more escape terrain in the Pryors than Alternative B. That is 7.3% more than Alternative B. Lynx also require low density for roads that Alt C provides. Alt C suggested upgrades: 1. Route #2088 on Big Pryor Mountain should be converted to a non-motorized trail to the west of Crater Ice Cave. Perhaps it could remain open for administrative use. Inclusion of this route in Alternative C is the most serious deviation from The Pryors Coalition’s Vision. 2. The seasonal closures as proposed in alternative B are well selected. These would be a good addition to Alternative C on those routes that are open to motorized use. The resource protection value of these restrictions is high. The short two month closure (April 15 to June 15) is, however, insufficient to protect the resource. The seasonal closures should be from December 1 to July 1 as in the Forest's 2004 proposal. 3. We urge the Forest’s closure of the Dryhead Loop route (#2308B) in Alternative B, and would like that same closure in Alternative C. The cultural reasons are compelling. The Forest Service needs to subscribe to a long range vision, adopt measures to secure cultural resources, vegetation, water, air, noise, wildlife, and non-motorized recreation opportunities. Thanks for this opportunity to comment. Please keep us comprised of any further activities in this area. Sincerely,
Liz Howell,
Director
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