Forest and BLM Planning [updated April 2, 2008]
Beaverhead-Deerlodge National Forest
The Beaverhead-Deerlodge is developing a revised Forest Plan that will set out guidelines for management of the Forest over the next 15 years or more. The recently distributed proposed plan fails to address important issues regarding motorized use on the Continental Divide National Scenic Trail. There is no problem with regard to the substantial portions of the Forest that are within wilderness or other defined nonroaded areas. The issue arises because some other portions of the CDT would be situated in "management areas" that allow ATVs and other vehicles. Under the proposed plan, "new segments" of the CDT would be nonmotorized. But the term "new segments" is undefined, so portions of the Trail constructed in those areas after Congressional designation (in 1978) but before adoption of this plan, and hence not "new," could remain open to motorized use -- contrary to provisions of the National Trails System Act and Forest Service stated policy. We were disappointed that our earlier comments on this topic, submitted in 2005, appeared to receive no consideration. We have indicated our continuing concerns to the Forest staff and have submitted written comments calling for clear and correct policy guidance to be included in the revised plan. Information about the Forest Plan is available at http://www.fs.fed.us/r1/b-d/forest-plan/index.shtml .
Other topics related to the Beaverhead-Deerlodge National Forest (including the pending Miner-Berry-Goldstone environmental assessment) are discussed below.
Proposed Policy Directive
The Forest Service has circulated "Proposed Directives" (www.gpoaccess.gov/fr/index.html retrieve page 32276) that would supersede portions of the 1985 Comprehensive Management Plan. The proposal has many good features, but its treatment of mountain bike use on the Trail is highly controversial. The Society has always sought to have the CDT managed as a "quiet" trail -- free from motorized and mechanized (i.e., bicycle) vehicles in the same way as the Appalachian and Pacific Crest Trails. We have expressed these views in our comments to the Forest Service, though we suggest that there might be exceptions for bikes taking into account such factors as levels of use and proximity to highways or other populated locations. Click here to read our July 13, 2007 comment letter.
As a result of the September 28 denial of our appeal regarding the selection of a route near Mount Taylor (see below), we have also proposed additional language to clarify Forest Service policy with respect to the availability of water along the CDT. Our suggested language is to include another provision as follows:
In general, water sources will be limited to surface water naturally occurring along the trail. Additional water sources should be constructed/developed, or temporary caches provided, if the interval between usable sources (excluding dirt stock tanks) exceeds a full day's travel by an average experienced backpacker.
Lewis and Clark National Forest
The Lewis and Clark National Forest has published a draft environmental impact statement that includes several travel management alternatives. We are concerned about the document's treatment of the Badger-Two Medicine area (between Glacier National Park and the Bob Marshall Wilderness).
The DEIS considers impacts upon the CDNST -- but only upon a so-called "interim" route that includes the unattractive Elkcalf and Kip Creek trails. The valleys of the South Fork of the Two Medicine River and North Badger Creek -- our recommended guidebook route (that nearly all hikers follow) -- are not recognized as a CDT location for purposes of the DEIS. We have filed comments that call for an examination of CDNST alternatives, including the Two Medicine-North Badger route and locations along the Divide, before and not after the travel management decisions are made. Unless this is done, we anticipate that the interim route will become the permanent official route. The Forest Service can then pretend that they have done a good job (because their chosen location will be nonmotorized), while in fact they are likely to allow and encourage ATV and other motorized use on the logical and desirable valley routes for the Trail. The background of this issue is discussed, along with our views, in our comment letter of July 19, 2005. The DEIS can be downloaded at http://www.fs.fed.us/r1/lewisclark .
Beaverhead-Deerlodge National Forest
We are reviewing an environmental assessment for the Miner-Berry-Goldstone segment of the CDNST in the Wisdom Ranger District. The Forest Service's preferred alternative is very disappointing, as it would permit the use of motorized vehicles on several miles of the route (north of Berry Creek, and along the Jahnke drainage). To request a copy of the EA, phone the Supervisor's Office at 406/683-3900 or send an email to cmartin@fs.fed.us . The comment period extends to the end of June. Written comments should be sent to Noelle Meier, BDNF, 420 Barrett, Dillon MT 59725, Subject: CDNST Miner-Berry-Goldstone. Comments may also be sent to Noelle by phone at 406/683-3932 or by fax at 406/683-3855. We expect to support selection of Alternative #6, which offers a nonmotorized route up the Pioneer drainage and then remains close to the Divide southbound to Goldstone Pass. We will post a link to our comments here.
On April 18, 2007, the Beaverhead-Deerlodge National Forest issued a decision on relocations between I-15 (south of Anaconda) and the Anaconda-Pintler Wilderness. We are pleased that the Forest has agreed to take a second look at the portion west of Mule Ranch, and that it has selected the existing American Creek alignment instead of the up-and-down circuitous location it had originally proposed. ( Click here to read excerpts from our comments on the proposal that had been issued by the Forest Service.) We nevertheless appealed the decision because the continued use of motorized vehicles on certain portions had not been justified. After discussions with the Forest Service, we agreed to withhold our challenge (and withdraw our appeal) until the planned travel management review is undertaken, probably in 2008. We are particularly concerned about a section of new trail constructed in 1994-95, where motorized use runs counter to the National Trails System Act and Forest Service policy. Where the trail is routed on historic motorized travelways, this motorized use will be continued for the time being as the Forest Service will include in the record an affirmative finding that such use will not substantially interfere with the nature and purposes of the Trail -- and the Forest Service will maintain a log of user observations and conflicts, to monitor continued conformity with the nature and purposes of the trail.
Our concerns about the Nez Perce Trail (north of Butte, east of I-15) appear to have been resolved. The issue involved the use of motorized vehicles on a segment of trail that was constructed as part of the CDT, which would violate provisions of the National Trails System Act. The Forest Service has now decided to eliminate the problem by constructing an entirely new nonmotorized travelway for the CDT. (This will tie in with the planned relocation along the Continental Divide from the Lady of the Rockies to Homestake Pass.)
BLM Rawlins Field Office
We reviewed a draft Environmental Impact Statement for the proposed revision of the Rawlins Resource Management Plan (RMP). Under the Plan, thousands of oil and gas wells might be drilled in the area over the next 20 years, with undefined impacts on the CDNST.
Our comments conclude that the DEIS "completely misses the mark... The DEIS pays no attention to the recreational and environmental values implicit in Congressional designation of a national scenic trail and fails to evaluate or consider how these values would be affected if any of the proposed alternatives were to be adopted."
[Click here to read our comments, dated March 9, 2005.]
Update: BLM's final environmental impact statement fails to make any significant changes with respect to the CDNST. On January 31, 2008, the Society submitted a formal protest raising the same issues as in 2005.
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We welcome any comments that you may have concerning these (or other) projects.