Comment Analysis and a Route Forward for the Shoshone Travel Management Plan

Wyoming Wilderness Association releases analysis of public comment for the Shoshone National Forest's latest Travel Management Plan

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The Wyoming Wilderness Association has produced a report analyzing over 1600 public comments submitted in response to the Shoshone Travel Management Plan 2021 Environmental Assessment (EA). The analysis found overwhelming public support for a conservative travel plan that protects the unique backcountry character of the Forest with better enforcement and maintenance of the Shoshone’s existing motorized travel system.

Read the Full Comment Analysis Report Here

The Shoshone River leading into Shoshone National Forest outside Cody, WY

Key findings include:

• The majority of all comments opposed new motorized roads and trails on the Shoshone. Eighty-four percent of all comments expressly opposed expanding or adding additional wheeled motorized routes to the existing system.

• Eighty-four percent of comments favored limiting or restricting over-snow vehicle (OSV) use to some degree on the Shoshone, like conservative seasonal restrictions. Of the comments specific to the High Lakes Wilderness Study Area (WSA), 93% favored limiting or restricting OSV use to protect wilderness character.

• Enforcement concerns and process concerns were substantial and pervasive across all user groups.

• Many commenters expressed difficulty in interpreting the location or impacts of routes or changes proposed in the short virtual comment period for the 2021 EA. A lack of comments specific to several new proposed changes and new OHV routes in the revised draft appeared to confirm this difficulty.

• Less than 4% of public comments expressed support for any of the alternatives considered in the 2021 EA.

While quantitative analysis showed the majority of public comments were classified as conservation-oriented, the reviewers found more commonality than divergence in public opinion. The majority of motorized users expressed a desire not to lose existing motorized access, while many conservation-oriented users asked the Shoshone National Forest to maintain and enforce the existing system, not add new roads and trails. Every alternative presented in the 2021 EA proposed significant new roads and trails without addressing enforcement concerns and significant on-the-ground access changes, resulting in a startling lack of support for any of the alternatives presented by the SNF. By providing at least one alternative that prioritizes enforcement and maintenance of the existing system instead of adding to it, the Shoshone likely could have found common ground and broad public support for that proposed alternative.

Latest Travel Plan fails to respond to public input

The recent report examined comments submitted on the 2021 EA, just one of six public comment periods during a lengthy, disjointed, and ongoing travel management process first initiated in 2015. As part of this planning process, the SNF is required to examine and consider all comments submitted since 2015. The recent report authored by the Wyoming Wilderness Association attempted to quantify the most recent submitted comments in a manner that was helpful to decision-makers. Regarding the thousands of comments submitted during multiple earlier comment periods, a Freedom of Information Act (FOIA) request recently produced a helpful summary document from Shoshone National Forest staff titled “Top Issues Identified in Public Comments” from those earlier, more robust public comment periods (2015-2017). (View the USFS internal comment summary document here). While only an unofficial, internal document, The Forest Service’s own review accurately describes consistent public opinion and priority themes pervasive throughout the travel planning process - yet none of the issues identified by Forest Service staff are addressed, acknowledged, or reflected in the 2021 EA. For example, the Forest Service lists the first three Top Issues identified by the public as:

• “New routes should not be located in any critical wildlife habitat (MA 5.4, WGFD crucial winter range, parturition areas, migration routes, etc.”

• “User created routes proposed for conversion to the system should not be considered as it rewards bad behavior.”

• “New additions should not be added until the current system is maintained and enforced adequately.”

In almost mirror contrast to the top comments summarized by Forest Service staff prior to developing the 2021 EA, every alternative in the 2021 EA:

• Proposes three to four new OHV routes, all concentrated on the district with the greatest enforcement and maintenance concerns

• Adds new OHV routes through crucial winter range, an Inventoried Roadless Area, and secure elk habitat

• Establishes several new OHV trails described by the Shoshone as user-created routes, rewarding illegal use

• Fails to address enforcement or maintenance concerns and protect the unique backcountry character of the Shoshone National Forest in winter or summer.

Less than 4% of the public supported any of the alternatives presented in the 2021 EA because the Shoshone has yet to provide one alternative that recognizes and responds to the public comments the Forest Service has received and identified.

New Year, New Leadership, and A Route Forward

New leadership on the Shoshone provides a new opportunity to work towards an informed and supported sustainable travel plan reflective of public comments. Shortly after the close of the November 2021 comment period, the Supervisor and Project Coordinator that launched a new fast-tracked Environmental Analysis in 2020 both vacated their positions with the Shoshone National Forest. In June of 2022 the Shoshone welcomed a new Forest Supervisor, Diane Taliaferro, who brings a wealth of positive travel planning experience and deep connections to the Greater Yellowstone Area. The new year brings a new opportunity for new leadership to correct course. The Forest Service characterizes travel planning as notoriously contentious, but the commonality in public comments highlights an easy path forward. Long-invested conservation partners are asking for the following:

• The Forest Service must analyze travel planning through an Environmental Impact Statement (EIS), as was intended and expected from the beginning of the travel planning process. Much of this work has already been completed in the Environmental Analysis, and could easily be carried forward with the required site-specific analysis for new routes.

• New leadership and planners should review the extensive project record and thousands of meaningful, site-specific comments already submitted to inform decision-making and next steps. Any next draft of the travel plan should include a response to comments and issues raised by the public, and articulate how public comment is reflected in the range of alternatives and final plan.

• The EIS should then include at least one “common sense” alternative reflective of overwhelming public comment. Our review of public comments suggests a more broadly supported alternative would:

  • Enforce and maintain the existing system without adding multiple new motorized routes on the Wind River District.

  • Preserve the wilderness character of the High Lakes WSA with common-sense restrictions like a conservative season end date and enforceable over-snow boundaries

  • Exclude contentious proposals converting popular access roads to 65” OHV-only-access

• Site-specific analysis and public field visits must be conducted for any proposed new motorized routes so that the public can understand and meaningfully comment on potential impacts.

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Travel planning is a once in a generation opportunity to protect the natural and cultural resources of our

oldest, wildest national forest. This travel plan process is the result of a decade-long Forest Planning process confirming the Shoshone’s unique backcountry niche. The Shoshone can still create a sustainable, broadly-supported travel plan by providing an EIS with one common sense alternative that honors public input and protects that unique backcountry character.