Final Environmental Impact Statement

Appendix D: Content Analysis for Travel 

Management Planning

Introduction

On November 9, 2005, the USDA Forest Service published in the Federal Register, Volume 70, 

No.216, the final rules and regulations for designating routes and areas for motor vehicle use for 

travel management activities (hereafter referred to as final rule) on National Forest System lands 

to become effective December 9, 2005.

Forest Service regulations at 36 CFR part 212 governing administration of the forest 

transportation system, and regulations at 36 CFR part 295 governing use of motor vehicles off 

National Forest System (NFS) roads are combined and clarified in this final rule as part 212, 

Travel Management, covering the use of motor vehicles on National Forest System lands. These 

regulations implement Executive Order (EO) 11644 (February 8, 1972), “Use of Off-Road 

Vehicles on the Public Lands,” as amended by EO 11989 (May 24, 1977). These Executive 

orders direct Federal agencies to ensure that the use of off-road vehicles on public lands will be 

controlled and directed so as to protect the resources of those lands, to promote the safety of all 

users of those lands, and to minimize conflicts among the various uses of those lands.

Black Hills Travel Management Planning

As a result of the publishing of the final rule, the Black Hills National Forest initiated the process 

to plan and designate routes, trails, and areas available for motor vehicle use. The Forest 

published a notice of intent (NOI) to prepare an environmental impact statement (EIS) in the 

Federal Register, Volume 72, No. 175, on September 11, 2007. The NOI initiated the scoping 

process for the environmental analysis (EA) for the Black Hills National Forest Travel 

Management Plan (referred to as Travel Management Plan) by identifying the purpose and need 

and a proposed action for the project. The notice also identified the responsible official, public 

involvement, schedule for public meetings, preliminary issues, and expected timeline for the 

analysis.

In addition to the Federal Register publication and news releases to local papers, the Black Hills 

sent to individuals, agencies, special interest groups, and other interested parties a letter 

describing the proposed action for designating motor vehicle use on the Black Hills National 

Forest, including a map of the proposal identifying specific routes, trails, and areas available for 

motor vehicle use. Larger scale maps were made available to the public through the district 

office and supervisor’s office of the Black Hills National Forest. Four public meetings were held 

to discuss the proposal and answer specific questions from the public. A comment form 

developed by the Black Hills National Forest was available to the public to encourage 

participation in the scoping process.

Summary Comments

During the scoping period, 738 responses were received from the public. The letters were 

received in three forms: Audubon Society form letter, some with individual comments; 

individual letters or e-mails; and the Black Hills National Forest OHV form, some with 

individual comments. Of the 738 letters sent; 60 were the Audubon form, including 14 letters 

containing no original comments or presented in duplicate from the sender; 217 individual 
Black Hills National Forest Travel Management Plan

letters, including 23 duplicates from sender; and 460 Black Hills OHV form, including 7 

duplicates.

After reviewing the 738 letters, some 1,991 specific comments were identified and grouped. The 

comments were defined into 16 categories with sub-categories to improve the analysis of the 

comments and define clear issue statements. A public concern statement was identified to 

describe each main category. These public concerns were then used to define issue statements.

Issues represent conflicts posed by the proposed action, and are important because they can serve 

as the basis for alternatives.

The comment categories are summarized below, along with the disposition showing how they 

were incorporated into the EIS analysis.

Category 1: Add Motorized Routes (404 Comments)

Public Concern: The Forest Service should add trails, roads, and trailheads to the Travel 

Management Plan as presented by the public for motorized opportunities.

Subcategories:

Comments wanting ATV routes (25): These comments focus on the need to have more 

trail opportunities for less than 50-inch vehicles. Two comments focus on Hell Canyon, 

including the Pleasant Valley area. There are two comments that believe the 50-inch 

tread width should be increase to 54-inch or 60-inch.

Comments wanting destinations or ties to communities or businesses (10): These 

comments ask for connections to services such as gas, food, or other places of business.

They request that the road/trail system be developed to connect communities and 

provide opportunities for points of interest. One commenter requested these 

communities, business, or points of interest be placed on the map.

Comments making general statements about wanting more of everything (60):

General statements include leaving the travel system as it is currently (3), keeping all 

roads open to motorized travel (9), including plans for future expansion (4), ensuring use 

of user submitted routes (2), the proposed plan is way too restrictive (concerned with 

lost motorized opportunities) from the current system (22), the motorized travel system 

needs to be dispersed throughout and not concentrated in any individual area (3), desired 

for winter time access (1), and encouragement to use paved, county, or gravel roads for 

connectors (4).

Comments wanting more loops (46): The desire for these comments is to connect 

dead-end roads with loops (5) or just to create more looping opportunities in general 

(35), with specific mention of Hell Canyon needs for looping trails (2), Lead/Deadwood

connectors (3) and utilizing county roads for connectors (4). Primary focus was for 

“trails” and not roads. One comment specifically mentioned less than 50-inch loop trails.

Comments wanting more single-track trails (64): Of these comments, four included 

increasing the single-track miles to 300 or 500 or 1000, and nine comments desire single 

track in specific locations (i.e., Hell Canyon, Rochford, Camp 5, Piedmont, Nemo, 

Victoria Lake, Sugar Shack, Spearfish, Custer, and Newcastle). Several comments (10) 

disappointed in the 79 miles proposed, stating that “it would not provide enough 

enjoyable riding for a week’s stay in the Hills”.

Comments requesting specific routes by description or route numbers (122):

○ All District—usually submitted by spreadsheet from user groups (9)
Final Environmental Impact Statement

○ BL (18); 1 comment shared with HC

○ NH (38); with 2 comments shared with BL; 5 with MY; 2 with HC

○ MY (39); with 4 comments shared with NH

○ HC (18); with 3 comments shared with MY; 1 with NH

Comments requesting trailheads (8): Two general comments about trailhead locations, 

one to place in strategic locations and another to ensure looping opportunities for trails 

return to a common parking area. Other comments were for specific locations for 

trailheads; i.e. Peaceful Pines, Spearfish, Dumont, Pilot knob, Rochford, junction of 

Custer Crossing and Minnesota Ridge Road, Mad Mountain Adventures and 

Experimental Forest area.

Comments requesting trails for both ATV and motorcycles (48): There were 48 

comments requesting more trails for a variety of motorized uses, including rock crawlers 

(5), ATV use (2), comments for both motorcycles and ATV (19), and desire for trails in 

general rather than roads (21). Trails in general also include specific locations Hell 

Canyon (2), Bearlodge (1) and Northern Hills (1).

Comments wanting consideration for UTV (6): Six comments received to include 

utility terrain vehicles in with all-terrain vehicles for trail designation. Their desire is for 

the less than 50-inch designation to increase to either 54-inch or 60-inch.

Comments requesting year-round access (16): Sixteen comments were received for 

year-round use of the proposed motorized travel system. Of these, five were specific for 

winter access; one because of a business.

Disposition: The comments in this category reflect the purpose and need for this project, which 

calls for the development and designation of a motorized travel system. Many comments also 

request the Forest to provide a variety of motorized recreation opportunities. These comments 

were generally incorporated into Issue 2, Effects on Recreation Opportunities.

Category 2: Remove Motorized Routes (292 Comments)

Public Concern: The Forest Service should remove specific motorized trails, roads, and 

trailheads from the Travel Management Plan as presented by the public.

Subcategories:

Comments wanting removal of dead end spurs (22): Comments request elimination, 

obliteration, or decommissioning of dead-end spurs to prevent user-created loops (8).

These dead-end routes are seen as “go nowhere” and encourage users to “break the 

rules”. To facilitate enforcement, comments recommend removing dead-end spurs from 

the map unless they lead to a destination.

Disposition: Comments in this category call for the development of a motorized travel system 

that could reasonably be maintained and enforced. These comments were incorporated into Issue 

3, Effects on Management Capabilities.

Comments making general statements about wanting less of everything (98):

Comments focused on a need to reduce the overall miles available for roads and trails to 

the motorized vehicles. Comments included 54 statements to reduce the road miles; 17 

to reduce the trail opportunities for ATVs and 4 to reduce motorcycles; and 18 that 

specifically mention 3,988 miles or 4,000 miles is “way too much”. Reasons for the 

reduction include 10 concerns for environmental resources; 6 to management concerns 

to maintain; and 7 for reduction in road density.
Black Hills National Forest Travel Management Plan

Comments wanting less loops (4): These comments request not increasing the 

opportunities for loops to prevent abuse of the land and conflicts with the general public.

Comments requesting specific routes removed by description or route numbers 

(158):

○ All District—usually submitted by spreadsheet from user groups (6)

○ BL (8); 3 comments shared with HC

○ NH (76); with 2 comments shared with BL; 2 with MY; 1 with HC

○ MY (51); with 1 comment shared with NH; 2 with HC

○ HC (13)

Comments requesting removal of trailheads (5 specific to Peaceful Pines) (11): 

These comments recommend removing specific proposed trailhead locations.

Disposition: These comments reflect concerns for effects of motorized travel use on natural 

resources. They were incorporated into Issue 1, Effects on Natural and Cultural Resources.

Category 3: Off-Road Opportunities (327 Comments)

Public Concern: The Forest Service should add motorized off-road opportunities for dispersed 

camping, game retrieval, cross-country travel, teaching beginners to ride and mud bogging to the 

Travel Management Plan.

Subcategories:

Comments wanting areas for off-road use (95): These comments request areas be 

identified to allow off-road opportunities anywhere the rider desires to go. Of the 

comments; 2 had suggested specific areas (Piedmont and Sheridan Lake); 5 

recommended a specific size to consider (1 square mile [2], 15 square miles [1], and 100 

acres [2]); 9 wanted areas for motorcycles with 1 specifically requesting small jumps; 

and 2 requested access to designated system from private property. One comment 

wanted to ensure the Prairie Creek decision was incorporated into the new Plan. Another 

comment suggested areas be set up for winter cross-country opportunities.

Comments wanting areas set up to teach beginners (“tot lots”) (12): These 

comments request areas, sometimes refer to as a “play area”, to provide beginners a 

place to learn to ride and develop skills. Two comments recommended gravel pits as a 

suitable place.

Comments specifically supporting dispersed camping (103):

○ 60 comments specifically requesting 300 feet

○ other comments ranged between 150 to 1,000 feet

○ 2 comments for less than 100 feet

Comments specific for wanting game retrieval (93):

○ Request for increasing the distance; distances were from 500 feet to unlimited

Comments wanting mud-bogging (24): These comments believe that mud bogging 

areas should be identified to reduce enforcement concerns or user-created ones from 

occurring (3). Two comments specifically state that “man-made mud bogs” could be 

built and one recommended the Farmingdale area.

Disposition: These comments express desires for various forms of motorized recreation. They 

were incorporated into Issue 2, Effects on Recreational Opportunities.
Final Environmental Impact Statement

Category 4: Accessibility (23 Comments)

Public Concern: The Forest Service should consider the needs of the elderly and person with 

disabilities while designing a motorized travel management plan for the Black Hills National 

Forest.

Subcategories:

Comments specific to disability travel (categorized as recreation oriented) (7): 

These comments focus on the recreational opportunities of motorized travel for persons 

with disabilities. Two comments suggest that the proposed designated motorized system 

would eliminate a large area of the Forest from their access due to inability to hike.

Comments related to hunting needs for disability or elderly (16): These comments 

also include increasing the distance for game retrieval (5) and designating deer for 

retrieval (3).

Disposition: These comments express concerns for various forms of motorized recreation. They 

were incorporated into Issue 2, Effects on Recreational Opportunities.

Category 5: Environmental Concerns (93 Comments)

Public Concern: The Forest Service should evaluate impacts from motorized opportunities on 

environmental resources such as water, soil, wildlife, plants and other resources on the Black 

Hills National Forest.

Many of the comments received identified more than one resource area of concern for the 

proposed action for Black Hills motorized travel opportunities. The main resource areas of 

concern were for soil (7); water (21); wildlife and fish (36); plants (8); and archeological 

resources (5). Additional comments mentioned air, global warming, monitoring, mining access, 

private property, research natural areas, wilderness, and sensitive vegetation.

Disposition: These comments were incorporated into Issue 1, Effects on Natural and Cultural 

Resources.

Category 6: Enforcement Concerns (83 Comments)

Public Concern: The Forest Service should evaluate the law enforcement personnel available on 

the Black Hills to ensure compliance with the travel management plan.

Subcategories:

Comments concerning enforcement capabilities and wanting stronger enforcement 

(64): General concern statements focus on the enforcement of the proposed designated 

system. Some comments (28) suggest that 4,000 miles of motorized routes will not be 

enforceable and a strategy or enforcement plan (4) should be developed before 

implementing the new plan. Some comments (5) recommend that the enforcement 

capabilities of the Forest should dictate the designation of the motorized system.

Comments wanting heavier fines (5): Comments specifically recommend heavier fines 

to deter misuse of the system.

Comments wanting signs or gates to improve enforcement (14): Comments 

recommend signing (10) the designated system of routes and trails and gating closure 

areas (1) to alleviate problems with lack of enforcement personnel.
Black Hills National Forest Travel Management Plan

Disposition: Comments in this category call for the development of a motorized travel system 

that could reasonably be maintained and enforced. These comments were incorporated into Issue 

3, Effects on Management Capabilities.

Category 7: No Off-Road Opportunities (111 Comments)

Public Concern: The Travel Management Plan should limit the motorized opportunities to only 

trails and roads.

Subcategories:

Comments against dispersed camping activities (32): These comments recommend 

not allowing dispersed camping on the Forest anywhere. Of the 25 comments made, 18 

recommend that camping be allowed only in designated campgrounds and 7 comments 

specifically identify fires as a reason to prevent it.

Disposition: These comments reflect concerns for effects on natural resources. They were 

incorporated into Issue 1, Effects to Natural and Cultural Resources.

Comments against any off-road game retrieval (30): Comments believe hunters 

should find other means of retrieving their harvested animal rather than relying on 

motorized opportunities. Suggestions were quartering the animal, using hand carts, sleds, 

horses, or dragging. One comment suggested that hunting should “be an effort”.

Disposition: These comments were incorporated into Issue 2, Effects to Recreational 

Opportunities.

Comments supporting no mud-bogging activities (22): These comments generally 

support the Plan to not designate any mud-bogging areas on the Forest.

Comments generally okay with no off-road opportunities (27): Comments are 

supportive of not providing any off-road opportunities in the travel plan for the Black 

Hills National Forest. Comments support restricting the motorized opportunities to 

designated routes and trails.

Disposition: Comments in these two sub-categories reflect concerns about impacts to natural 

resources. They were incorporated into Issue 1, Effects to Natural and Cultural Resources.

Category 8: Special Permits (39 Comments)

Public Concern: The Travel Management Plan should designate motorized off-road 

opportunities for Forest Service permitted activities such as grazing and firewood gathering.

Subcategories:

Comments for firewood collection (31): Comments concerned about the new 

designated motorized system would not allow for firewood gathering. Six comments 

recommend designating a distance, 300 feet, for this activity.

Comments about grazing activities (7): Comments are concerned that the new 

designated system of motorized travel will affect their ability to administer their grazing 

permits. One comment was concerned about allotment gates being left open on 

designated motorized system.

Comment about special privilege for trapping activities (1): One comment requested 

special consideration for trapping activities.
Final Environmental Impact Statement

Disposition: These comments indicate concerns over possible effects of motorized travel to other 

Forest programs and multiple-uses on the Forest. Firewood gathering on the Forest would be 

regulated under other authorities and would not be subject to this decision. Similarly, access by 

permittees to administer their grazing permits would be governed by the terms of their permit 

and not this decision. Effects of the alternatives on access for other recreational purposes will be 

disclosed in the EIS.

Category 9: Big Game Retrieval (39 Comments)

Public Concern: The Forest Service should incorporate all big game species, including deer, 

turkey, mountain lion, and mountain goat in the Travel Management Plan for off-road motorized 

big game retrieval opportunities.

Subcategories:

Comments wanting to include game retrieval for all species (16): These comments 

believe game retrieval should be included for all big game species, with 1 comment 

specifically requesting turkey; 2 for mountain lions; and 1 for mountain goats.

Comments wanting deer to be included with elk retrieval (20): These comments were 

specific to including deer within the big game retrieval distance.

Special Consideration—Game retrieval based on weight (1); game retrieval for all 

vehicle types (2); increasing the distance (7); consideration for elderly (2): One 

comment suggested that big game retrieval should be based on the weight of the animal.

Two comments requested consideration for all types of vehicles to retrieve big game and 

not restrict to ATV retrieval. The other comments were also included in the above counts 

because they also identified interested in particular species for retrieval.

Recommendations for increasing the distance for game retrieval ranged from 600 feet to 

1,000 feet.

Disposition: Access for retrieval of harvested game was considered, and the Forest Service 

decided to address this issue in various ways in different alternatives. These concerns were 

incorporated as part of Issue 2, Recreational Opportunities.

Category 10: Roads versus Trails (29 Comments)

Public Concern: The Travel Management Plan should consider more motorized trails rather 

than roads.

Subcategories:

Comments wanting to use existing roads (9): These comments object to the building 

or construction of new trails due to the extensive amounts of roads on the Black Hills 

National Forest. Recommendations are to utilize only existing roads for the travel 

management plan.

Comments wanting more trails rather than “gravel” roads (20): These comments 

prefer the experience of trail riding to road riding. Seven of the comments specifically 

mention “no gravel roads”, while three mention that riding on roads is not much of an 

experience. One commenter specifically requested that the ORV trail system should not 

include roads passable to automobiles, while another recommend consideration of 

logging roads in the travel management plan. Two comments also mentioned the desire 

for a challenging system and that roads were not capable of providing a “challenged 

ride”.
Black Hills National Forest Travel Management Plan

Disposition: These comments reflect different preferences for recreational motorized use. They 

were incorporated into Issue 2, Recreational Opportunities.

Category 11: General Support (23 Comments)

Public Concern: Some commenters generally supported the Travel Management Plan as 

proposed.

Subcategories:

Comments generally support various portions of the proposal from working with 

partnerships, “closing unless open” philosophy, or plans for future expansion. Some 

comments state “OK” or “generally support”.

Disposition: These comments showed support for different aspects of the proposal, but did not 

identify reasons. The Forest Service appreciates the comments.

Category 12: General Disagreement (19 Comments)

Public Concern: Commenters prefer not to be restricted to designated routes.

Subcategories:

Comments fully disagree with proposal (3): These comments disagree with all 

proposed points of the proposed travel management plan.

Comments general statements (5): These comments offer general statements such as 

“losing freedom of enjoying the Forest”, “objection to off-road travel is a problem 

throughout the Hills”, and “eliminate all user supplied input from the proposal”.

Comments requesting the Forest Service to utilize the “current system” of 

roads/trails (11): These comments specifically request to leave the current management 

strategy “open unless designated closed” for the motorized travel opportunities.

Disposition: These comments reflect a variety of preferences for recreational motorized use.

They were incorporated into Issue 2, Recreational Opportunities.

Category 13: Multi-Use Conflicts (186 Comments)

Public Concern: The Black Hills National Forest should evaluate conflicts to other users such 

as noise, impacts to nonmotorized activities, ranchers, residential property, etc., when developing 

the motorized travel management plan.

These comments respond to conflicts with other uses of the Forest such as nonmotorized 

opportunities, solitude, safety, private property, communities, economics, and motorized 

impacts with other motorized users. The majority of these comments focused on noise 

(82), private property concerns (27), and impacts with nonmotorized users (43).

Disposition: Concerns reflected in these comments were incorporated into Issue 3, which 

includes user safety; and Issue 4, Social and Economic Concerns.

Category 14: Partnerships/Cooperations (117 Comments)

Public Concern: The Forest Service should consider all opportunities for funding, including 

developing a user fee system to help support the maintenance of the proposed travel management 

plan.

Subcategories:
Final Environmental Impact Statement

Comments not broken out (usually comments against Governor’s Task Force) (28):

Comments generally support working with local, state, and other government offices to 

develop a motorized travel system. Eleven of the comments object to the formation of 

the Governor’s Task Force with two stating that there was no representative supporting 

nonmotorized interests.

Comments related to funding sources (33): These comments are split between 

supporting (13) various means of providing funding to support the motorized system and 

disagreeing (14) with any outside organization providing funding for a specific interest.

Those not supporting a variety of funding sources state that external funding sources 

could influence the management direction and achieve objections of outside 

organizations. Two comments recommend utilizing existing funds to provide a balance 

between all the needs of the Forest. Four comments recommend that users pay for the 

opportunities.

Comments requesting no additional fees added for the system (3): These comments 

believe enough taxes are paid for this purpose or not enough of a trail system is offered 

to make a payment viable.

Comments supporting user fees (53): These comments support user fees or a sticker 

system for motorized use. Three comments would like to see nonmotorized users with a 

user fee as well. Thirteen comments request the funds to support the motorized trail 

system.

Disposition: These comments generally focus on how any motorized travel system might be 

implemented. Questions regarding fees, funding sources, and partnerships are outside the scope 

of the decision to be made on this project, and will be decided after a decision is issued.

Category 15: Duplicate Records (51 Comments)

Disposition: This is a records management concern. Disposition does not relate to the issues.

Category 16: Forms with No Specific Comments (155 Comments)

Subcategories:

Audubon form letter with no additional comments (16)

OHV form letter with no additional comments (139)

Disposition: This is a records management concern. Disposition does not relate to the issues.

How Public Concern Statements Relate to Issues

From the comments and concerns summarized above, the Forest Service identified the following 

key issues.

Issue 1: Effects on natural and cultural resources

The alternatives considered in the EIS may have effects on natural and cultural resources. Effects 

to these resources will vary between alternatives and are mostly dependent on the miles of roads 

and trails open to motorized use. Restricting motorized use to a managed system of designated 

roads and trails, identifying specific seasons of use, and identifying authorized types of vehicle 

use, would improve protection for these natural and cultural resources. Effects to natural and 

cultural resources between alternatives are identified in detail in the effects analysis in Chapter 3.
Black Hills National Forest Travel Management Plan

Issue 2: Effects on recreational opportunities

The alternatives considered in the EIS may have effects on the amount of available recreational 

opportunities provided on the Forest, including motorized use on roads and trails, mixed 

motorized use roads, dispersed camping, big game retrieval, motorized trailheads, and 

nonmotorized opportunities. Effects to the recreational opportunities by alternative are identified 

in detail in the effects analysis in Chapter 3.

Issue 3: Effects of transportation system design on management capabilities

The alternatives considered in the EIS may have effects on the Forest’s ability to proactively 

designate and manage system roads and trails, while also optimizing recreation experiences. The 

alternatives considered will have different effects on how the transportation system is able to 

address management concerns (such as law enforcement, user education, signing, and 

maintenance) while reducing management costs and focusing limited resources. Addressing 

many of the management concerns will be dependent on available funding sources, which will 

most likely be limited. The transportation system design can also affect public safety depending 

on the miles of mixed-use roads. Any roads identified for mixed use will be reviewed in a mixeduse roads analysis that includes mitigation to make reasonable accommodations for the public’s 

safety.

Issue 4: Social and Economic Concerns

The alternatives considered in the EIS may affect the economic sustainability of local businesses 

and communities. Effects may be related to dust, noise, traffic level, trespass on private property, 

distance from motorized routes to private land, and miles of routes open to motorized use.