Wildlands CPR Files Forest Plan Appeal - A Wonky Perspective

Wildlands CPR filed an appeal this week on the Beaverhead-Deerlodge Revised Forest Plan, citing several flaws in the final decision and supporting analysis. Joining us in our appeal was the Winter Wildlands Alliance, Friends of the Bitterroot and Montanans for Quiet Recreation.  

One of the main problems we found in the Revised Plan was its handling of winter motorized recreation. Forest Plans are strategic or programmatic documents that provide a variety of general directions over the whole landscape. In other words they provide guidance for future on-the-ground actions. Towards this end, the new Revised Plan allocates large areas for snowmobile use, just as it does for summer motorized recreation. The big difference is that the Record of Decision explains Travel Management planning must occur in order to actually designate roads and trails for summer motorized recreational use; unfortunately it does not require the same for winter motorized use. What this means is that the Revised Plan essentially turns general allocations into site-specific actions without the supporting environmental analysis. The result is that snowmobile use will occur in crucial wolverine habitat such as in the West Big Hole and Mt. Jefferson Roadless Areas; for the latter a backcountry ski outfitter will most certainly lose business. Only through winter Travel Management Planning can the Forest Service officially designate these places for over-snow vehicles, but the Beaverhead-Deerlodge has not committed to that process.

Since the Revised Plan sets direction for future management activities it must provide accurate instructions, but it did not do so in regards to the Interim Roads and Trails Map. When creating this map, forest planners included approximately 2,100 miles of user-created routes and other non-system roads, and then explain that the map is a starting point for Travel Management planning. One can imagine how this will skew the process. If planners start with the inflated road miles instead of the forest’s official system, any subsequent analysis will be based on 2,100 miles that has never undergone appropriate environmental review. In our appeal, we ask that summer planning starts with the currently designated road system instead of the inflated numbers on the Interim Road and Trail Map.

Our appeal also challenged direction that states, “[e]stablished routes to dispersed campsites are recognized as part of the Forest transportation system.” (Revised Forest Plan, p. 31). This directly violates existing regulations. Only through Travel Management Planning can these routes be added to the transportation system and designated for motor vehicle use. But the Revised Plan circumvents this requirement and we called for the removal of this provision.