United States Department of Agriculture 

Forest Service

Shoshone Land Management Plan 

Revision

Final Environmental Impact Statement

Volume II

Appendix A. Content Analysis Report

Shoshone National Forest, Park, Fremont, Sublette, Teton, and Hot Springs Counties, Wyoming

January 2014
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provider and employer.
Shoshone National Forest Land Management Plan Revision

Final Environmental Impact Statement

Park, Fremont, Sublette, Teton, and Hot Springs Counties, Wyoming

Lead Agency: USDA Forest Service

Cooperating Agencies: State of Wyoming

Fremont County Commission

Hot Springs County Commission

Park County Commission

Big Horn County Commission

Cody Conservation District

Dubois-Crowheart Conservation District

Hot Springs Conservation District

Lower Wind River Natural Resource District

Meeteetse Conservation District

Popo Agie Conservation District

Teton Conservation District

Responsible Official: DANIEL JIRÓN, REGIONAL FORESTER 

Rocky Mountain Region

740 Simms Street

Lakewood, Colorado 80401

For Information Contact: JOESEPH G. ALEXANDER, FOREST 

SUPERVISOR

Shoshone National Forest

808 Meadow Lane Avenue

Cody, Wyoming 82414

CARRIE CHRISTMAN, FOREST PLANNING 

STAFF

Shoshone National Forest

808 Meadow Lane Avenue

Cody, Wyoming 82414

(307) 578-5118

JOHN RUPE, REGIONAL PLANNER

Rocky Mountain Region

740 Simms Street

Lakewood, Colorado 80401

(303) 275-5148

Abstract: This final environmental impact statement (FEIS) documents analysis of seven alternatives 

developed for programmatic management of the 2.4 million acres administered by the Shoshone National 

Forest. The Forest Service has identified alternative G as the preferred alternative.

The announcement of the release of the final plan and this final environmental impact statement will be 

published in the Federal Register. This will be followed by a 60-day objection period. To qualify for 
Shoshone National Forest Land Management Plan Revision

“standing,” objections must be linked to a prior substantive comment submitted during opportunities for 

comment on the proposed decision. Objections will be resolved and/or responded to within 90 days 

following the 60-day objection period. The Record of Decision for the revised Forest Plan will not be 

issued until the reviewing officer has responded to the objections.
Final Environmental Impact Statement – Appendix A

687

Appendix A. Content Analysis Report

Final Environmental Impact Statement – Appendix A

689

Introduction

The notice of availability of the Shoshone Land Management Plan Revision DEIS was published in the 

Federal Register on August 3, 2012 (77 FR 46433). The notice of availability began the official 90-day 

comment period, which ended on November 1, 2012. We received approximately 23,480 responses from 

individuals, organizations, agencies, and businesses by email or U.S. Post Office. The responses included 

approximately 22,400 form letter submissions and 1,080 unique extensive and detailed comment letters.

We prepared responses to the public comments, which in some cases resulted in changes to the EIS. 

Concerns were not determined by majority opinion but rather by the substance of the comments. The 

content analysis process ensured that every comment was read, analyzed, and considered.

Comment letters that contained references to specific literature citations were reviewed, analyzed, 

addressed, and the responses to each literature citation are included in the project record.

The lists below include the Table 1 lists the Federal, State and local agencies, elected officials, Tribes, 

organizations, groups, businesses and individuals that submitted unique comment letters. Some 

individuals or groups submitted more than one unique letter. Originators of form letter submissions are 

noted and the content of form letters was considered. Comment letters from individuals that were not 

signed, or where the commenter’s last name was not provided, were considered; however, those 

incomplete names are not included in this listing.

The following Federal, State and local agencies, elected officials, Tribes, organizations, groups and 

businesses submitted unique comments: 

Abcycles, Bryce Carroll

American Council of Snowmobile Associations, Christine Jourdain

American Rivers, Michael Fiebig

American Whitewater, Kevin Colburn

Backcountry Hunters and Anglers, Holly Endersby

Big Wild Adventures, Marilyn Olsen

Biodiversity Conservation Alliance, Erik Molvar

Californians for Western Wilderness, Michael Painter

Cody Country Chamber of Commerce, Darby Michael

Continental Divide Trail Society, James Wolf

Defenders Of Wildlife, Mike Leahy

Department Of Environmental Quality, John Wagner

Dowco Valve Company, Rob Copenhaver

Elk Creek Ranch, Tina Moore

Fitzgerald's Bicycles, Scott Fitzgerald

Forest Service Employees for Environmental Ethics, Jennifer Fairbrother

Fremont County ATV Association, John Johnson

Greater Yellowstone Coalition, Charles Drimal

Greater Yellowstone Coalition, Thomas Rogers

Guardians of the Range, Kathleen Jachowski

Hot Springs County Planner, Bruce Bowman

Intermountain Forest Association, Tom Troxel

International Mountain Bicycling Association, Jeremy Fancher

Lander Llama Company, Scott Woodruff

Meeteetse Conservation District, Clara Yetter

Meeteetse Museums, Jim Allen
Shoshone National Forest Land Management Plan Revision

690

Meeteetse Recreation District, John Fernandez

National Outdoor Leadership School, Aaron Bannon

National Resources Defense Council, Christine Wilcox

North America Pack goat Association, Andrew Irvine

North American Pack goat Association, Charles Jennings

Northwest Wyoming Off Highway Vehicle Alliance, Dana Sander

Northwest Wyoming OHV Alliance, Dennis Nagy

Office of the Governor, Matthew Mead

Outdoor Alliance, Adam Cramer

Park County Historic Preservation Commission, Matt Hall

Powder River Basin-Resource Council, John Fenton

Public Lands Advocacy, Claire Moseley

Roger Sport Center, Dustin and Jenni Rosencranse

Ry Timber, Inc, Edward Regan

Shoshone and Arapaho Tribes Joint Business Council, Earlene Three Irons

Shoshone Back Country Horsemen, 

Shoshone Cooperating Agency Coalition, 

Sierra Club, WY Chapter, Connie Wilbert

Sierra Club/Shasta Group, Bruce Waggoner

South Dakota Snowmobile Association, Mary Anne Grabow

State Historic Preservation Office, Mary Hopkins

Sunlight Landowner's Association, Marshall Dominick

Teton Mountain Bike Alliance, Mike Lien

The Nature Conservancy, Holly Copeland And Paul Hunker

The Teacher Store 

The Wilderness Society, Dan Mccurdy

The Wilderness Society, Vera Smith

The Wilderness Society 

Theodore Roosevelt Conservation Partnership, 

Trout Unlimited, Cathy Purves

United States Dept of Interior, Robert Stewart

United States Environmental Protection Agency Region 8, Amy Platt

Utah Snowmobile Association, Curtis Kennedy

Western Watersheds Project, Jonathan Ratner

Wild Sheep Foundation, Kevin Hurley

Wind River Front, Tim Hudson

Winter Wildlands Alliance, Forrest Mccarthy

Wyoming Department of Agriculture, Jessica Crowder

Wyoming Department of State Parks and Cultural Resources-State Trails Program, Ron McKinney

Wyoming Game and Fish Department, John Emmerich

Wyoming Legislative Service Office, Matt Obrecht

Wyoming Native Plant Society, Amy Taylor

Wyoming Outdoor Council, Lisa Mcgee

Wyoming Pathways, Tim Young

Wyoming State Forestry Division, Jay Hein

Wyoming State Snowmobile Association, Jeff Moberg

Wyoming Wild Sheep Foundation, Kevin Hurley

Wyoming Wilderness Association, Sara Domek

Wyoming Wildlife Federation, Joy Bannon
Final Environmental Impact Statement – Appendix A

691

The following individuals submitted unique comments on the DEIS:

Les and Sharon Aasheim

Lenice Abbott

Kenneth Able

Dave Abrams

Rick Ackerman

Rick and Sherry Adair

Clay Adams

Frankie Adams

David Agnello

Bonita Albrecht

Matt Alford

Bret and Deanna Allard

Katie Allen

Larry Amundson

Marta Amundson

Jennifer Anders

Richard Anderson

Tom Anderson

Jorge Andromidas

Bill and Joan Arndt

Cindy Arnette

Linda Arnold

Joy Aso

Joe Austin

Anne Austin

Henry Austin

David Bacon

J Bailey

D Baily

Gene Ball

G Barnard

J. Adrian Barnes

Karla Barrell

Jennifer Barrett

Brian Barrett

Laurel Barrett

Ray Barry

Wendy Barteaux

David and Cindy Bartle

Lin Bashford

Diane Bastian

Chris Bates

Harold Bauer

Shanny and Thommy 

Baughman

Richard Bearzotti

Jessica Beaucin

Terry Beaver

Nick Bedel

Sandy Bell

Mike Bellah

Cam Belter

Wade Bemmels

Kaci Benefield

Susan Benepe

Elaine Bengston

Karen Bennett

Linda Benson

Linda Benson

Ted Beringer

Mark Bertels

Tony Bibeau

Greg Bigler

Paul Bindert

Alexander Bing

Jason Binner

Frank and Karla Bird

Oscar Bird

Donna Bishop

John Bjorkman

Robert Black

Richard Blain

G.D. Blaine

Andrew Blair

Marvin Blakesley

Marvin Blakesley

L Bland

Eric Blankemeier

Elizabeth Blassingham

Auzie Blevins

Mike Blymer

Judi Blymyer

Perry Bongiani

Philip Bongiorno

Lorraine Bonney

Bryce Born

Joni Bosh

Michael Bostick

Tammy Bowers

Joe Boydston

Cynthia Boyhan

Korby Bracken

Joseph Brady

Connie Brakebill

Erin Brandmier

Robert Branscomb

Misti Braun

Kalman Brauner

Jeanne Brenneman

John Brink

Steven Brock

Dave Bromley

T.A. Brooks

Porter Broughton

Barbara Brown

Janet Brown

Kristen Brown

Mary Brutger

James Bryant

Saidi Buher

Brooke Bullinger

Paul and Ann Bumsted

Dave Burke

Perry Burkhart

Matt and Family Burkhart

Virginia Burris

Mary Burton

Joann Butkis

William Butler

Cenie Cafarelli

Lorie Cahn

Deborah Cain

Cheryl Caldwell

Mark Calhoun

Daniel Calhoun

Jackie Canterbury

Pat and Byron Carnahan

Bryce Carroll

Donald Casavant

Steve Caughey

William Champion

Christina Chapman

Diane Chapman

Kathleen Cheatham

Alice Chesly

Saul Chessin

Frances Chilcohe

Martha Christensen

Dee Christensen

Sharon Christensen

Matt Chuch

Jackson Clarendon

Fritz and Jan Clark

Virginia and Darrell Clark
Shoshone National Forest Land Management Plan Revision

692

Ryane Clark

Margo Clark

Nancy Clark

Jack Clinton

Mike Close

Michael Cluff

Mary Lou Cohen

Dave Colavito

Nick Colgn

Carl Colonna

Gina Colovich

Susan Colvin

Jennifer Connell

Frank Connelly

Dennis Conniff

Sue Consolo-Murphy

James Cook

Perry Cook

Carlyn Cook

Brian Cook

Holly Copeland

Scott Copeland

Karly Copeland

Rob Copenhaver

Eugenie Copp

Dale Corkill

Stephen Cornell

Donald Cornish

R.H. Corrothers

Jeffrey Counts

David Courtis

Kewdahl Cox

Keith Cozzens

Ryan Crabb

Eva and Peter Crane

Adam Crenshaw

Joe Crutcher

Elaine Dacken

Pam and Eric Dahl

Nate Dahlin

William Daily

Matt Daly

Christopher Daly

Carl Dammann

Richard Dandurand

Kent Daniels

Alan Daniels

Kent Daniels

Anita Daquila

Hannah Darcy-Weisser

Huella Darling

Dale and Teresa David

Robert Davis

Kristen and Tad Davis

Brenda Davis

Alice Deangelis

Zane Debuse

Roger Dehaan

Jane Demayo

Lou Anna Denison

Carol Deno

Mark Deorsay

Helen and Paul Desmarais

Irene Devin

Marybeth Devlin

Johanna Devries

Lewis Diehl

Dennis Dietl

Christopher Dingman

Katrina Dingman

Corey Dinsdale

Wendy Dixon

Nick Dobric

Thomas Dolese

Mark Domek

Callie Domek

John and Lynn Dominick

Jane Dominick

David Dominick

Marshal Dominick

Joyce Donahoe

Gerald Donahue

Steven Donham

Robert Donner

Bradley Douglass

Virginia Dubeis

Ken Dunn

Carol Edwards

Allen Edwards

Amity Eisele

Hilary Eisen

Richard Elkins

H Jo Ellis

Judith Embry

Lamar Empey

Fran Essex

Jody Evans

Russell Ewoldt

Dirk Faegre

Kim Fander

Jay Farfalla

Margie Farias

Bill Farley

Bruce Fauskee

Bruce Fauskee

Barbara Felton

Jon Ferrian

Maybi Filpourih

Vicki Finley

Joanne Fisher

Katrina Fisher

Ric Fisher

John Flannigan

Bob Fleming

Herbert Flower

Bonnie Foley

Keysha Fontaine

Melodie Foos

Gregg Foote

Julie Ford

Russ Foren

David Forssaint

Robert Forster

Genette Foster

Ryan Fourlen

Bayard Fox

Alan Frank

Gretchen Freda

Beau Fredlund

Jason Freeze

Catherine Frischmann

Laurence Fritz

Clay Fulcher

Matt Funk

Vince Furst

Sherrill Futrell

Mary Gadski 

John Gallagher

Jackson Gallegos

Barry Gammell

Jessica Garcia-Torres

Martin Garhart

Lydia Garvey

Joann Gaynor

Dorothy Geisler

Monse Geller

Rich Gerow
Final Environmental Impact Statement – Appendix A

693

Marla Gerstue-Wooll

Jonel Geske

Pat Ghidden

Lori Gibson

Ed Giguere

Carolyn Gillette

Rick and Josephine 

Gilpatrick

Rick and Josephine 

Gilpatrick

Nicholas Gistaro

Steve Glenn

Jennifer Goe

J. Taylor Goforth

Marcus Goodbody

Serena Gordon

Shelby Gores

Sarah Gorin

Lisa Gosnell

Bud Grace

James Graeter

James Graeter

Fay Graning

Connie Grant-Howell

Dorothy Green

Diana Green

Mark Griffin

Gregory Griffith

Shirley Grimes

Nick Gruneich

Judd Grunzke

Joe Gutkoski

Philip Gyr

Nick H

Dolores Hakes

Tacy Halen

Maurice Hall

Robert Hamborg

Shad Hamilton

Janet Hannel

Erin Hannelly

Deborah Hans

Robert Hanselman

Dennis Hardin

Merlin Hare

Matt Harmon

Brian Harrington

Ronald Harris

Nathan Harris

Shaleas Harrison

Ruthanne Harstad

Donald Hartley

Sydney Hartsuch

Ann Harvey

Ann Harvey

Scotthaskamp

Nick Haskin

Nan Hassey

Karen Hayes

Mary Hays

Bruce Hayse

Pat Headley

Linda Healow

Virginia Hedbrand

Steve and Tina Hefel

Bonnie Heidel

Mitch Helling

Phil Helman

Melissa Helman

Hilary Heminway

Jaclyn Henry

Bernadette Henzi

Thrall Hershberger

Donald Heyneman

Mark and Ardie Hickerson

Laney Hicks

Edwim Higbie

Dan Hilger

Marion Hillard

Edward Hiller

Lois Hiller

Don Hillman

Bern Hinckley

Cory Hinsz

Robert Hitchcock

Robert Hitchcock

Philip Hocker

Carlyle Hodges

Mark Hogan

Elaine and G.W. Hogan

Katie Hogarty

Jay Hojer

Brad Holland

Scott Holloman

Aaron Holton

Sidney Hoopes

Lowell Horan

Jack Houliston

Liz Howell

Clayton Howes

Barbara Hudson

Tim Hudson

Martin Huebner

Don Hundley

Gail Hunt

Sete Hunt

Phil Hutchison

Mollie Iler

Dick Inberg

Judy Inberg

K Inman

Joan Intrator

James Jackson

Sego Jackson

Jeanne Jacobs

Eric Jacobs

Jerry Jayne

Ralph Jenkins

Lisa Jenkins

Judith and Michael Jenkins

Charlie Jennings

Charlie Jennings

Jim

Cindie Jobe

Marcia Johns

Deborah Johnson

John Johnson

Thomas Johnson

Alex Johnson

Thomas Johnston

Robert Johnston

Jim Johnston

Pamela Johnston

Jim Jones

George Jones

Beth Jones

Don Jones

Tj Jones

Lorin Jones

Logan Jones

Valente Jordan

Tommy Jorgensen

George Judson

Rob and Cathy Juno

Peggy Kaestle

Denise Kalakay

Dennis Kaleta
Shoshone National Forest Land Management Plan Revision

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Bruce Kamminga

Randy Kane

David, Elizibeth, Sarah, 

Rachel, Joshua, Jacob 

Kauffman

Randall Kaufmann

Bonnie Kautz

Tom Keating

Bill Kehler

Bart Kehler

Robert Keiser

Mary Keller

Pamela Kelley

Mike Kelly

Richard Kenyon

Joy Keown

Edward Kershner

Thomas Kiefer

Nancy King

Clifford Kirk

Robert Kizik

Luther and Shirley Kleckner

Charles Klingsporn

Dennis Knight

Bill Knutson

Bart Koehler

Bart Koehler

Patricia and Kenneth Kolm

Betty Kooner

Robert Koppe

Thomas Korytowski

Dorothy Koster

Ira Kowall

Ronald Krafjack

Lisi Krall

Sarah Krall

William Kranse

Joseph Krawiec

William Krogman

Curtis Kruer

Katrina Krupicka Dingman

Elizabeth Krusko

Michael Kulakofsky

Karen Kunz

Juan Laden

Randy Laird

Sussan Lamb

Paul and Carol Lamberger

Donna Lanciotti

Bill and Jill Lander

Mike Langhenry

Josh Larsen

Tony Larson

Jerome Lascola

Grant Law

Jim Laybourn

Sean Leach

Linda Leblang

Mary Ellen Lee

John and Janet Lee

Bryon Lee

Thomas Lee

Jack Lee

Randy Lehman

Jeff Leininger

Patrick Leonard

Richard Leonard

Catherine Leonardi

Jeanne Leske

Arthur Levit

Barry Lewis

Thomas Lewis

Larry Lewis

Larry L'heureux

Ken Lichtendahl

Jason Lillegraven

Karen Linarez

David and Pam Lindahl

Vicki Lindner

Ed Livingston

Matthew Llyod

R Locker

Andy Lockhart

Elizabeth Lockwood

Robert Loftfield

Marilyn Logan

Carolyn Lopez

Doug Lowham

Justin Loyka

Larry Luckinbill

James Luebbers

Tim Lund

Ann Lund

Tyler Lund

Mary Jane Luther

Dorcas Macclintock

Don Macfarlane

Jon and Ginnie Madsen

Fred Maguire

David Maness

Bill Manke

Jon and Marcia Maroon

Jordan Marrou

Rob Marshall

Arnold Martelli

Amy Martens

David Martin

Steve and Jen Martin

Roy Martin

John Martin

Alan Martin

S Martin

Linden Martineau

Carlos Martinez Del Rio

Martha Martinez Del Rio

Mike Maurer

Jim Maves

John Maxwell

Elaine Mcandrews

Karen Mcbee

Carla Mccall

Jacqueline Mccauley

George Mcclelland

Traci Mcclintic

J G Mccue

Nancy Mcdonald

Jazmyn Mcdonald

John Mcdonald

Charles Mcdowell

Sherry Mcfall

John Mcgee

Thomas Mcguire

Colin Mcleod

Lilian Mcmath

Mimi Mcmillen

Sally Mechels

Diane Mehling

Joellen Meier

Craig Meiter

Edwin Mellander

Kathryn Mellander

Char-Lena Meloney

Hugo Melvoin

Armando Menocal

Jessie Crow Merme

J Merrick

Laura Merrill
Final Environmental Impact Statement – Appendix A

695

Gregg Messel

Andy Metzler

Brad Metzler

Patrick Mezzuno

Smith Michele

Wynn Miller

Bert Miller

Jeremy Miller

Tabitha Miller

Neil and Jennifer Miller

Cate Miller

John Millhone

Leigh Mintz

Dee Mirich

Jess and Lisa Mitchell

Vanne Mocilac

Joan Montagne

Robert Moon

Carol Moore

Dave Moore

Chris Moran

Steve Mordt

Robert More

George Mores

Mike Mores

Vic Mosbrucker

Gary Moss

S. David Moss

Michael Mougel

Craig Muderlak

Peter Muldon

Wayne Muller

Zak Munro

Zak Munro

Donna Murphy

Warren Murphy

Ester Murray

Ester Murray

Martha Muth

Randal Mutter

Julia Nania

Anthony Natale

Chuck Neal

Dan and Mary Neher

Lee Nellis

Michael Nerby

Craig Nerone

Randall Neumann

Tom Neumayr

Dot Newton

Dale and Margaret Nichols

Fred Nicol

Glenn Nielson

Leslie Nistico

Itrey Nolarned

Noname

Noname

Keith Norleen

Laura Norman

Florence Norstrom

David Novak

Jeremy Obrien

John and Christine Obyrne

Micaela Occonnor

Bob Ohler

Danny Ohler

Paul Onken

M. E. Oppenheim

Steve Oppermann

Andrea Orabona

Diane Orme

David and Sharon Orphey

John Osgood

Tracy Oullette

Kim Overfield

Barbara Owens

Scott Pace

Spencer Paddock

Ryan Palmer

John Pansewicz

Garth Parish

Sherrie and Daryl Parker

Carol Parkor

Daniel Parshall

Matthew Parsons

R.D. Pascoe

Debra Patla

Susan Patla

J. Nichols Patrick

Joyce Patrick

Wade Patrick

Leslie Pattern

Chister Pauls

Jim Paulsen

Michael Pearlman

Ali Pearson

Dorothy Pearson

Mark Pearson

Katherine Pellow

Karl Pernich

Toddy Perryman

Wayne Person

Leslie Petersen

Nikki Peterson

Chris Peterson

Elaine Phelps

Jeff and Jill Phillips

Julien Phillips

Roger Phillips

Orion Pipersky

Nancy Pitblado

Scott Ploger

Patricia Poletti

Elizabeth Poletti

Doug Pollema

Christina Powers

Kevin Pownell

Don Pownell

Jim Pratt

Penny Preston

James Proctor

Alison Prost

George and Angelina Pryich

Jean Public

Ed Pyle

Justin Quandt

John Raby

Dana Ramos

Julie Rapp

Dallas Rasmussen

Richard Raushenbush

Garth Reber

Family Redford

David Reeves

Dorothy Reichardt

Joseph Reichert

Barry Reiswig

Bill Resor

Linda Reynolds

Gail and John Richardson

Joanne Richter

Catherine Rideler

Hap Ridgway

E. Chester Ridgway

Hap Ridgway

J.R. Riggins

Christian Rinker
Shoshone National Forest Land Management Plan Revision

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Nate Robbins

Shauna Roberts

Shauna Roberts

Robert Robinson

Jeanne Robinson

Shannon Rochelle

Katie Rodgers

Reenie Roe

Evan Roman

Mark Romer

Robin Roscher

Stephen Rose

Robert Rosenberg

Dustin Rosencranse

Jacquelene and Steven Rouff

Mary Rovell

Charles Rowe

Bob Rowen

Victor Rowen

Casie Rowland

Derick Ruchti

Barbara Rugtzke

Charles Rumsey

Mary Rumsey

Charles Rumsey

Charles Rumsey

Richard Rusnak

Richard Rusnak

Tyler Rybicki

Ben Salisbury

Phil Salonek

Al Sammons

Arne Sandberg

Dana Sander

Pam Sanders

Irine Saphra

Greg Sauer

David Saurman

George Sauter

Anne and Jim Schifferle

Kathy and Willie Schilling

Erich Schimps

Michael Schirmer

Kuni Schmerzear

Ryan Schmidt

Lee Schmidt

Rudy Schmiedt

Laura Schneider

Betty Schraer

Dave Schreiber

Andrew Schrum

Kathryn Schultz

Daniel Schurg

Paul Schutt

Duane Schweigert

Zachary Scott

Roger Sebesta

Les Seely

Victoria Seever

Charlene Sehorn

Aaron Seifert

Family Severns

Jason Severns

Sean Sheehan

Sherry Shelley

Matthey Shelley

Judy Shepard

Tom Shephard

Donna Sherwood

Vance Sherwood

Daniel Shively

Fred Shoemaker

Karen Shoemaker

Heather Shop

Sandy Shuptrine

Micah Shuster

Natalie Shuttleworth

David and Uly Silkey

Tony Simek

Terry Simpson

Alan Simpson

Holly Sinclair

Benjamin Sinclair

Katherine Sinclaire

Chad Siroky

Linda Sisco

Lenore Sivuuch

Jerry Skelton

Geoff Skews

Andrew Sleeper

Barb Slovisky

Jerry Smith

Carol and Dave Smith

Patricia Smith

Bryce Smith

Cj Smith

Keith Smith

Jack Smith

Tom Solin

John Spahr

Steven Spencer

Douglas Sphar

Richard Spotts

Carolyn St. James

Patricia Stahler

Jeff Stangler

Duane Stanley

Melissa Stanley

Peter Steele

Larry Steffensmeir

Mark Steinmueller

V. A. Stimac

Louis Stoddard

Jean-Pierre Stoermer

John Stoltenberg

Kristi Stouffer

Jesse Stover

Kathleen Stover

Jason Stowe

Mark Strobel

Sarah Sturges

Arlene Sturm

Rene Suda

Karen Suisse

David Suisse

Roberta Sullivan

Madeline Sutherland-Meier

Dan Swift

Frank Symington

Les and Pat Szewzk

Martha Tate

Jim Taylor

Barbara Taylor

Erica Tenbroek

Neil Thagard

Sydney Thielke

Rebecca Thomas

Darren Thomas

Rebecca Thomas

Renate Thomee

Todd Thompsen

Barbara Thompson

Derek Thompson

Bruce Thompson

Rock and Donna Thums

Nanette Till

Buck Tilton
Final Environmental Impact Statement – Appendix A

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Joan Timchak

Ellen Tiygstad

Lawrence Todd

Lee Tofelmeyer

Lane Tomme

Kathy Topkins

Leslie Towle

Nancy Traer

Joseph Treanor

Kathleen Treanor

Laurence Treanor

Michael Trewartha

Elizabeth Tronstein

Martha Tunjunit

Thomas Turek

Thomas Turnino

Keith Twombly

Juliet Unfried

James Unger

Ethan Valenstein

Benjamin and Jennifer 

Valentine

Bob and Sandy Van Deest

Clinton Van Siclen

Michael Van Stone

Dewey Vanderhoff

Marjorie Vanochten

Jeff Vanuga

Joseph Veghts

Robert Vermillion

Barbara Vietti

Sally Vogel

John Vogel

Kathy Vukasovich

Paul Vukmanc

Richard Vullogpio

John Wadsworth

Hygi Waetermans

Mary J Wagner

Kip Wagner

Rebecca Walchli

Jj Walden

Ted Waldron

Noah Waldron

Rebecca Wall

Frank Ward

Jacob Ward

G.A. Warren

Lynne Warts

Warren Watkins

Margaret Webster

Richard Wecker

Richard Wecker

Todd Weeks

Andy Weenig

Thomas Weil

Virginia Weiler

Rc Weimann

Joyce Welbon

Jennifer Wellman

Darren Wells

O. Alan Weltyien

James Wenninger

Terri Wentworth-Davis

Jennifer and Kent Werlin

Sallie Wesaw

Katherine West

Walter Wethenell

Jeff Wethod

Ali Wheeler

Hal Wheeler

Bill Whetstone

Lornie White

Donna Whitham

Brian Whitlock

Kevin Whitmore

Stifler Wiezbenslie

Kim Wilbert

Jost Wilhide

Gail Wilke

Patricia Wilkens

Patricia Wilkens

Bill Willers

Fred Williams

Sharelynn Williams

Tom Williams

Allison Willoughby

Richard Wilson

David Wilson

Sundre Winslow

Elizabeth Winston

Thomas Wise

Debra Wolf

Chad Wolf

Lillian Wolter

Hunter Wood

Jeff Woodard

Kari Wouk

George Wuertherner

B Wyberg

John and Lavinia Ycas

Steve Yenko

Frank Young

Ken Younger

Linda Yow

Zare

James Zeasley

Tina Zenzola

Thomas Zieber

Tom Zimmer

Cristin Zimmer

Thomas Zimmer

James Zubik

L Zwick
Final Environmental Impact Statement -- Appendix A

699

Content Analysis Process

All of the comment letters were analyzed using a process called content analysis. The Forest Service 

followed a systematic process of carefully reading, coding and summarizing all viewpoints and concerns 

that were submitted. The interdisciplinary team members read the comment letters. Of the approximately

1,080 comment letters that contained unique and substantially different comments, over 6,300 comments 

were coded, analyzed, and grouped by subject or topic. The most helpful comments were those that were 

unique, substantially different, and specifically related to the analysis disclosed in the DEIS. When an 

individual raised multiple concerns within the same letter, each unique comment was coded separately by 

subject or topic. Table 1 displays the coding structure breakdown of the subject or topic applicable for the 

comments received on the DEIS. 

Table 1: Coding structure used for comments on the DEIS 

Category 

Code Category Description

100 Proposed Action General

101 Forest-wide Goals and objectives – general

102 Forest-wide Standards and guidelines –

general

103 Insufficient Science

104 Beyond the Scope

105 Best Science

150 Management Area 1.1 Wilderness - General

151 Management Area 1.1 Wilderness - Desired 

Condition

155 Management Area 1.1 Wilderness -

Guidelines

156 Management Area 1.1 Wilderness -

Standards for the Pristine Wilderness Setting

157 Management Area 1.1 Wilderness - Plan 

Management Approach

158 Management Area 1.1 Wilderness - More of 

this Management Area

159 Management Area 1.1 Wilderness - Less of 

this Management Area

190 Management Area 1.3 – Back country 

recreation year-round non-motorized -

General

191 Management Area 1.3 – Back country 

recreation year-round non-motorized -

Desired Condition

194 Management Area 1.3 – Back country 

recreation year-round non-motorized -

Standards

197 Management Area 1.3 – Back country 

recreation year-round non-motorized -

Management Approach

Category 

Code Category Description

198 Management Area 1.3 Back country 

recreation year-round non-motorized- More 

of this Management area

199 Management Area 1.3 Back country 

recreation year-round non-motorized - Less 

of this Management area

210 Management Area 1.5A – Clarks Fork of the 

Yellowstone Wild River - General

218 Management Area 1.5A – Clarks Fork of the 

Yellowstone Wild River- More of this area

230 Management Area 1.6A – High Lakes 

Wilderness Study Area - General

232 Management Area 1.6A – High Lakes 

Wilderness Study Area - Goals

250 Management Area 1.6B - Dunoir Special 

Management Unit - General

270 Management Area 2.2A – Line Creek Plateau 

Research Natural Area- General

275 Management Area 2.2A – Line Creek Plateau 

Research Natural Area - Guidelines

290 Management Area 2.3 – Proposed Research 

Natural Areas - General

294 Management Area 2.3 – Proposed Research 

Natural Areas - Plan - Standards

310 Management Area 3.1A – Swamp Lake 

Botanical Area - General

330 Management Area 3.1B – Proposed Little 

Popo Agie Geological Area - General

335 Management Area 3.1B – Proposed Little 

Popo Agie Geological Area - Guidelines

350 Management Area 3.1C – Proposed Sawtooth 

Peatbed Geological Area - General
Shoshone National Forest Land Management Plan Revision

700

Category 

Code Category Description

370 Management Area 3.3A– Back Country 

Recreation Year-Round Motorized - General

371 Management Area 3.3A– Back Country 

Recreation Year-Round Motorized - Desired 

condition

372 Management Area 3.3A– Back Country 

Recreation Year-Round Motorized - Goals

377 Management Area 3.3A– Back Country 

Recreation Year-Round Motorized -

Management Approach

378 Management Area 3.3A– Back Country 

Recreation Year-Round Motorized - More of 

this area

379 Management Area 3.3A– Back Country 

Recreation Year-Round Motorized - Less of 

this area

390 Management Area 3.3B– Back Country 

Recreation Summer Non-Motorized With 

Winter Motorized -General

392 Management Area 3.3B– Back Country 

Recreation Summer Non-Motorized With 

Winter Motorized - Goals

394 Management Area 3.3B– Back Country 

Recreation Summer Non-Motorized With 

Winter Motorized -Standards

397 Management Area 3.3B– Back Country 

Recreation Summer Non-Motorized With 

Winter Motorized - Management

398 Management Area 3.3B– Back Country 

Recreation Summer Non-Motorized With 

Winter Motorized - More

399 Management Area 3.3B– Back Country 

Recreation Summer Non-Motorized With 

Winter Motorized - Less

410 Management Area 3.3C-Back Country 

Recreation Summer Motorized with Winter 

Non-Motorized -General

417 Mgt Area 3.3C– Back Country Recreation 

Summer Motorized with Winter NonMotorized -Mgt Approach

418 Mgt Area 3.3C– Back Country Recreation 

Summer Motorized with Winter NonMotorized -More of area

419 Mgt Area 3.3C– Back Country Recreation 

Summer Motorized with Winter NonMotorized -Less of area

Category 

Code Category Description

430 Management Area 3.5– Back Country 

Recreation and Forest Restoration - General

431 Management Area 3.5– Back Country 

Recreation and Forest Restoration - Desired 

Conditions

434 Management Area 3.5– Back Country 

Recreation and Forest Restoration -

Standards

437 Management Area 3.5– Back Country 

Recreation and Forest Restoration - Mgt 

Approach

438 Management Area 3.5– Back Country 

Recreation and Forest Restoration - More of 

this area

439 Management Area 3.5– Back Country 

Recreation and Forest Restoration - Less of 

this area

450 Management Area 3.6A – Continental Divide 

National Scenic Trail - General

451 Management Area 3.6A – Continental Divide 

National Scenic Trail - Desired Condition

452 Management Area 3.6A – Continental Divide 

National Scenic Trail - Goals

453 Management Area 3.6A – Continental Divide 

National Scenic Trail - Objectives

454 Management Area 3.6A – Continental Divide 

National Scenic Trail - Standards

455 Management Area 3.6A – Continental Divide 

National Scenic Trail- Guidelines

457 Management Area 3.6A – Continental Divide 

National Scenic Trail - Mgt Approach

460 Management Area 3.6A – Continental Divide 

National Scenic Trail - Monitoring

470 Management Area 3.6B – Nez Perce (NeeMe-Poo) National Historic Trail - General

490 Management Area 4.2 – Scenic Byways, 

Scenic Areas, Vistas, and Travel Corridors 

General

510 Management Area 4.3 – Back Country Access 

Corridor - General

517 Management Area 4.3 – Back Country Access 

Corridor - Mgt approach

530 Management Area 4.5A – Proposed Kirwin 

Historical Area - General
Final Environmental Impact Statement -- Appendix A

701

Category 

Code Category Description

538 Management Area 4.5A – Proposed Kirwin 

Historical Area More of area

550 Management Area 5.1 – Managed Forests 

and Rangelands - General

551 Management Area 5.1 – Managed Forests 

and Rangelands - Desired condition

558 Management Area 5.1 – Managed Forests 

and Rangelands - more of this mgt. area

559 Management Area 5.1 – Managed Forests 

and Rangelands - more of this mgt. area

570 Management Area 5.2 – Public Water Supply 

– Water Quality Emphasis - General

590 Management Area 5.4 – Managed Big Game 

Crucial Winter Range - General

591 Management Area 5.4 – Managed Big Game 

Crucial Winter Range- desired condition

592 Management Area 5.4 – Managed Big Game 

Crucial Winter Range- Goals

594 Management Area 5.4 – Managed Big Game 

Crucial Winter Range - Standards

595 Management Area 5.4 – Managed Big Game 

Crucial Winter Range - Guidelines

597 Management Area 5.4 – Managed Big Game 

Crucial Winter Range - management 

approach

598 Management Area 5.4 – Managed Big Game 

Crucial Winter Range- more of this mgt. area

599 Management Area 5.4 – Managed Big Game 

Crucial Winter Range- less of this mgt. area

610 Management Area 8.1 – Developed 

Recreation Areas - General

611 Management Area 8.1 – Developed 

Recreation Areas - Desired Condition

630 Management Area 8.2 – Ski-Based Resorts -

General

650 Management Area 8.6 – Administrative Sites 

- General

670 Misc. - Attachments

671 Misc. - Incorporate by reference other 

comments

672 Misc. - Information Requests

673 Misc. - Miscellaneous Comments

674 Misc. - Non-substantive Comments

675 Monitoring - General

Category 

Code Category Description

676 Monitoring - Annual monitoring and 

evaluation report

677 Monitoring - Components of the monitoring 

strategy

680 Monitoring and Evaluation

700 DEIS Chap 1 - Purpose and need

701 DEIS Chap 1 - Proposed action - general

702 DEIS Chap 1 - Decision Framework - 1982 

Planning rule

704 DEIS Chap 1 - Public involvement – general

710 DEIS Chap 1 - Revision Topics – general

711 DEIS Chap 1 - Recreation uses and 

opportunities

713 DEIS Chap 1 - Vegetation management

716 DEIS Chap 1 - Commercial livestock grazing

730 Other - general

732 Other - Climate change scorecard - general

733 Other - Multiple Use

750 DEIS Chap 2 - Alternatives Considered -

General

751 DEIS Chap 2 - Alternative A

752 DEIS Chap 2 - Alternative B

753 DEIS Chap 2 - Alternative C

754 DEIS Chap 2 - Alternative D

755 DEIS Chap 2 - Alternative E

763 DEIS Chap 2 - Exclude human presence in 

crucial big game winter range

764 DEIS Chap 2 - Add additional special interest 

areas

765 DEIS Chap 2 - Undesignated Wilderness 

areas, RNA, SIA

767 DEIS Chap 2 - Pro-recreation

768 DEIS Chap 2 - Changes to travel management

770 DEIS Chap 2 - No oil and gas surface 

occupancy forest-wide

780 DEIS Chap 2 - New Alternatives

800 DEIS Chapter 3 - affected environment and 

environmental effects – general

801 DEIS Chapter 3 - Resource protection 

measures

802 DEIS Chapter 3 Environmental consequences

803 DEIS Chapter 3 Cumulative effects summary 

table - general
Shoshone National Forest Land Management Plan Revision

702

Category 

Code Category Description

804 DEIS Chapter 3 Climate change – general

810 Water and Soil - Resource – general

812 Water and Soil - Methodology

813 Water and Soil - Affected environment

814 Water and Soil - Desired condition

815 Water and Soil Direct and indirect effects 

include general effects

817 Water and Soil Climate change

818 Water and Soil Incomplete and unavailable 

information

819 Water and Soil Monitoring

831 Water and Soil Desired Condition

832 Water and Soil Goals

833 Water and Soil Objectives

835 Water and Soil Guidelines

836 Water and Soil Management Approach

850 Riparian/Wetlands Resource general

852 Riparian/Wetlands Methodology

853 Riparian/Wetlands Affected Environment

876 Riparian/Wetlands Management Approach

900 Air Quality Resource – general

901 Air Quality Legal and administrative 

framework

907 Air Quality - Climate change

923 Air Quality - Objectives

950 Vegetation - Resource – general

953 Vegetation - Affected environment (AE)

954 Vegetation - AE -Rangeland

955 Vegetation - AE –Cover types

957 Vegetation - AE - Unique habitats

958 Vegetation -Desired condition

959 Vegetation - Direct and indirect effects

962 Vegetation - DE - Vegetation Structure 

Components

965 Vegetation - Climate change

966 Vegetation - Incomplete and unavailable 

information

967 Vegetation - Monitoring

981 Vegetation - Desired Condition

982 Vegetation - Goals

983 Vegetation - Objectives

Category 

Code Category Description

984 Vegetation - Standards

985 Vegetation - Guidelines

986 Vegetation - Management Approach

1000 Species Diversity - General

1001 Species Diversity - Terrestrial wildlife

1002 Species Diversity - Legal and administrative 

framework

1003 Species Diversity - Methodology

1004 Species Diversity - Wildlife Corridors

1010 Threatened endangered proposed candidate 

species - TES - General

1020 Threatened endangered proposed candidate 

species - Gray wolf

1030 Threatened endangered proposed candidate 

species - Canada Lynx

1040 Threatened endangered proposed candidate 

species - Grizzly bear

1050 Forest Mammals - American marten

1070 Forest Mammals - Northern American 

Wolverine

1090 Forest Birds - Boreal Owl

1100 Forest Birds - Northern Goshawk

1120 Grassland/Sage Mammals - Rocky Mountain 

bighorn sheep

1125 Grassland/Sage Mammals Disease

1130 Grassland/Sagebrush Birds - Brewer’s 

sparrow and Sage sparrow

1160 Grassland/Sagebrush Birds - Greater sagegrouse affected

1190 Grassland/Sagebrush Birds - Short-eared owl

1270 Riparian Amphibians - Boreal western toad

1290 Riparian Amphibians - Northern leopard frog

1300 Caves and mines mammals - Fringed myotis

1340 Management Indicator Species (MIS) - Ruffed 

Grouse

1360 Management Indicator Species (MIS) - Redbreasted nuthatch

1390 Species of local concern - Rocky Mountain elk

1400 Species of local concern - Mule deer

1410 Species of local concern - Moose

1450 Aquatic, Riparian and Fisheries Resources -

General
Final Environmental Impact Statement -- Appendix A

703

Category 

Code Category Description

1452 Aquatic, Riparian and Fisheries Resources -

Methodology

1453 Aquatic, Riparian and Fisheries Resources -

Affected environment

1454 Aquatic, Riparian and Fisheries Resources -

Desired condition

1455 Aquatic, Riparian and Fisheries Resources -

Direct and indirect effects

1459 Aquatic, Riparian and Fisheries ResourcesMonitoring

1476 Aquatic, Riparian and Fisheries Resources -

Management Approach

1500 Rare Plants - Resource – general

1600 Fire and Fuels Management - Resource 

general

1602 Fire and Fuels Management - Methodology

1604 Fire and Fuels Management - Desired 

condition

1605 Fire and Fuels Management - Direct and 

indirect effects

1606 Fire and Fuels Management - Cumulative 

effects

1607 Fire and Fuels Management - Climate change

1608 Fire and Fuels Management - Incomplete and 

unavailable information

1626 Fire and Fuels Management - Management 

Approach

1650 Insects and Disease - Resource General

1652 Insects and Disease - Methodology

1654 Insects and Disease - Desired condition

1656 Insects and Disease - Cumulative effects

1670 Insects and Disease - Background

1677 Insects and Disease - Management Approach

1700 Invasive Species - Resource general

1701 Invasive Species - Legal and administrative 

framework

1706 Invasive Species - Cumulative effects

1709 Invasive Species - Monitoring

1750 Commercial Livestock Grazing - Resource –

general

1751 Commercial Livestock Grazing - Legal and 

administrative framework

1752 Commercial Livestock Grazing - Methodology

Category 

Code Category Description

1753 Commercial Livestock Grazing - Affected 

environment

1754 Commercial Livestock Grazing - Desired 

condition

1755 Commercial Livestock Grazing - Direct and 

indirect effects

1756 Commercial Livestock Grazing - Cumulative 

effects

1757 Commercial Livestock Grazing - Climate 

Change

1758 Commercial Livestock Grazing - Incomplete 

and unavailable information

1759 Commercial Livestock Grazing - Monitoring

1770 Commercial Livestock Grazing - Background

1771 Commercial Livestock Grazing – Desired 

Condition

1774 Commercial Livestock Grazing - Standards

1776 Commercial Livestock Grazing - Management 

Approach

1800 Forest Products - Resource General

1802 Forest Products - Methodology

1804 Forest Products - Desired Condition

1820 Forest Products - Background

1821 Forest Products - Desired Condition

1822 Forest Products - Goals

1824 Forest Products

1825 Forest Products - Guidelines

1826 Forest Products - Management Approach

1850 Special Forest Products - Resource General

1872 Special Forest Products - Management 

Approach

1900 Land (Special Uses) - Resource General

1924 Land (Special Uses) - Standards

1950 Minerals - Resource – general

1951 Minerals - Legal and administrative 

framework

1952 Minerals - Desired condition

1954 Minerals -

1955 Minerals - Direct and indirect effects

1958 Minerals - Incomplete and unavailable 

information

1960 Minerals - Monitoring
Shoshone National Forest Land Management Plan Revision

704

Category 

Code Category Description

1961 Minerals - Oil and Gas Leasing

1982 Minerals - Goals

1983 Minerals - Objectives

1986 Minerals - Management Approach

2000 Roads and Trails - Resource – general

2001 Roads and Trails - Legal and administrative 

framework

2004 Roads and Trails - Desired condition

2005 Roads and Trails - Direct and indirect effects 

include general effects

2006 Roads and Trails - Cumulative effects

2021 Roads and Trails - Desired Condition

2022 Roads and Trails - Goals

2023 Roads and Trails - Objectives

2024 Roads and Trails - Standards

2025 Roads and Trails - Guidelines

2050 Recreation - Resource – general

2051 Recreation - Legal and administrative 

framework

2052 Recreation - Methodology

2053 Recreation - Affected environment

2054 Recreation - Desired condition

2055 Recreation - Direct and indirect effects

2058 Recreation - Incomplete and unavailable 

information

2059 Recreation - Monitoring

2060 Recreation - OHV

2061 Recreation - Snowmobile

2062 Recreation - Bicycle

2063 Recreation - Noise Pollution

2064 Recreation - Trails

2081 Recreation - Desired Condition

2082 Recreation - Goals

2083 Recreation - Objectives

2084 Recreation - Standards

2085 Recreation - Guidelines

2086 Recreation - Management Approach

2100 Designated Wilderness and Recommended 

Wilderness - Resource – general

2105 Designated Wilderness and Recommended 

Wilderness - Direct and indirect effects

Category 

Code Category Description

2107 Designated Wilderness and Recommended 

Wilderness - Climate Change

2125 Designated Wilderness and Recommended 

Wilderness - Guidelines

2126 Designated Wilderness and Recommended 

Wilderness - Management Approach

2150 Designated and Eligible Wild and Scenic 

Rivers - Resource – general

2152 Designated and Eligible Wild and Scenic 

Rivers - Methodology

2175 Designated and Eligible Wild and Scenic 

Rivers - Guidelines

2200 Inventoried roadless areas - Resource –

general

2202 Inventoried roadless areas - Resource –

Methodology

2204 Inventoried roadless areas - Desired 

condition

2209 Inventoried roadless areas - Monitoring

2250 Research Natural Areas – general

2255 Research Natural Areas – Direct and indirect 

effects include general effects

2271 Research Natural Areas – Desired Condition

2277 Research Natural Areas - Management 

Approach

2300 Special Interest Areas

2350 Scenery Resources – general

2373 Scenery Resources - Objectives

2374 Scenery Resources - Standards

2375 Scenery Resources- Guidelines

2400 Heritage Resources – general

2421 Heritage Resources - Desired Condition

2423 Heritage Resources - Objectives

2424 Heritage Resources - Standards

2425 Heritage Resources - Guidelines

2427 Heritage Resources - Public Involvement -

general

2450 Social and Economic - Resource – general

2452 Social and Economic - Methodology

2453 Social and Economic - Affected environment

2454 Social and Economic - Desired condition

2455 Social and Economic - Direct and indirect 

effects include general effects
Final Environmental Impact Statement -- Appendix A

705

Category 

Code Category Description

2456 Social and Economic - Cumulative effects

2458 Social and Economic - Incomplete and 

unavailable information

2459 Social and Economic - Monitoring

2477 Social and Economic - Public Involvement -

general

2501 Other Required Disclosures - Environmental 

Justice

2503 Other Required Disclosures -Potential 

Conflicts with Goals and Objectives of Other 

Agencies

2600 Appendix A – Public Involvement

2800 Appendix C Evaluated Areas for Potential 

Wilderness

2806 Appendix C Evaluated Areas for Potential 

Wilderness Trout Creek 02044

Category 

Code Category Description

2813 Appendix C Evaluated Areas for Potential 

Wilderness Franc’s Peak 02051

2814 Appendix C Evaluated Areas for Potential 

Wilderness Wood River 02052

2819 Appendix C Evaluated Areas for Potential 

Wilderness Dunoir 02058

2829 Appendix C Evaluated Areas for Potential 

Wilderness Togwotee Pass 02903

2833 Appendix C Evaluated Areas for Potential 

Wilderness High Lakes 02915

2900 Appendix D Wild and Scenic River Eligibility 

Evaluation – general

3000 Appendix E - Maps General

3100 Commercial Livestock Allotment Capable and

Suitable Acres and AUMS - general

Once the unique and substantially different comments were coded, concerns raised by different 

commenters on the same subject and with the same intent and issue were grouped and summarized into 

public concern statements that capture the essence of those like concerns. We developed over 900 public 

concern statements from the comments received.

In this way, multiple comments may be addressed by one response. In some cases, more nuanced or 

complex concerns may be answered through multiple responses to multiple concern statements, or they 

may have a single response dedicated to just that specific comment. It is important to keep in mind that 

even though the public concern statements attempt to capture the full range of public issues and concerns, 

they should be reviewed with the understanding that there is no limitation on who submits comments. 

Therefore, the comments received do not necessarily represent the sentiments of the public as a whole. 

Every comment has the same value, whether expressed by many, or by one respondent. Analyzing 

comments is not a vote-counting process. The Forest Service response to the public comments, which in 

some cases resulted in changes to the DEIS, was not determined by majority opinion but rather by the 

substance of the comments. The content analysis process ensured that every comment was read, analyzed, 

and considered.

Following are the public concern statements pertaining to the Draft Environmental Impact Statement 

prepared for the Shoshone Land Management Plan Revision. The statements are a summary of similar 

grouped submitted comments. The full letters are available in the project file at the Shoshone National 

Forest Office in Cody, Wyoming.

Shoshone National Forest Land Management Plan Revision

706

The public concern statements are organized by subject (table 1). If you look for the subject that most 

closely aligns with your comments, it might be easier for you to find the public concern statement that 

captures your comment. In some cases, your concerns may be addressed as part of several different, but 

related public concern statements. The public concern statements and the Forest Service response follow.

Public Concern Statements and Forest Service Response

Subject: 100 - Proposed Action General

Public Concern #1

The Forest Service should keep management approaches for fish and wildlife, recreation, habitat 

preservation, and energy development consistent with neighboring public lands and agencies using strict 

conservation measures to preserve the forest’s pristine environment for future generations by limiting new 

road construction and not allowing surface occupancy for gas and oil development.

Response

The revised Forest Plan identifies the need and desire to cooperate with agencies and adjacent 

landowners. Many comments identified issues with the preferred alternative not matching management on 

adjoining BLM and State lands, particularly for oil and gas management. Those comments are being 

addressed between draft and final. The modified preferred alternative will include changes to make 

management more consistent as appropriate.

Public Concern #2

The Forest Service should address Endangered Species Act Issues through the Section 7 consultation 

process. The following should be addressed in the final Plan: (1) The Forest should create additional 

wilderness areas. (2) Protection of lower elevation zones. (3) Better measures to protect wildlife and 

natural resources. (4) Better back-country management. (5) Recognize management needs for future 

generations. (6) On page 12, Vision, paragraph 5, modify sentence one as follows: “Forested ecosystems 

... while providing habitat for viable populations ... species.” Sentence two should be modified as follows: 

“Sensitive species are stable ... toward recovery. " (6) Define management actions and management 

activities. (7) Should other state and federal planning and management efforts cumulatively affecting the 

region including the BLM’s Big Horn Basin Resource Management Plan. (7) On page 230, change the 

citation for conservation agreement to Montana Fish Wildlife and Parks 2010.

Response

We will consult with Fish and Wildlife Service on the final decision.

Alternatives C and D provide more wilderness and less development in back country areas. The decision 

maker will consider the public comments requesting less management in these areas in addition to other 

public comments in making the final decision.

The vision statement provides the overarching picture of the plan. Its current wording provides that 

picture. The language about increasing sensitive species is a key concept. Where possible, we want 

sensitive species to reach to a point where they are no longer sensitive.

We will add definitions for management actions and management activities in the glossary. Other State 

and Federal agency plans are considered in the EIS analysis. That analysis is not directly addressed in the 

revised Forest Plan, because the plan addresses management for National Forest System lands. The plan 

does discuss other plans in the Preface.
Final Environmental Impact Statement -- Appendix A

707

We will verify the citation for the Yellowstone cutthroat trout conservation agreement.

Public Concern #14

The Forest Service should consider consistent management across the ecosystem and work with 

Yellowstone National Park, BLM, State Lands to manage the area the same especially along the 

Absaroka-Beartooth Front with BLM and Wyoming Game and Fish Dept.

Response

See Public Concern (PC) #1

Public Concern #22

The Forest Service should consider focusing on multiple use and not wilderness which will allow for more 

options for forest management.

Response

Multiple use is part of the mission of the Forest Service. The alternatives analyzed have a wide range of 

both recommended wilderness allocation and allocation to other multiple uses. The deciding officer will 

consider the various options along with other comments during the decision process.

Subject: 101 - Forest-wide Goals and Objectives – General

Public Concern #3

The Forest Service should make the best efforts to maintain the wild legacy and heritage of the Shoshone, 

preserving the wild and scenic environment and rich and diverse wildlife for future generations through 

conservation of resources and research protection programs. The Forest should make conservation and 

wildness a focus with a reduction in motorized use areas, which will help preserve the quite solitude of the 

back-country experience.

Response

The recreation opportunity spectrum setting is an indicator of the development level and character of a 

landscape. Back country landscapes are predominately in the primitive and semi-primitive end of the 

spectrum. We analyzed differences in the percentages of acres in these two settings. These ranged from a 

low of 66 percent in alternative F to a high of 87 percent in alternative C. The deciding officer will 

consider the various options along with other comments during the decision process.

Public Concern #4

The Forest Service should ensure the forest follows the direction of the National Forest Management Act 

and Multiple-Use Sustained-Yield Act to provide and plan for multiple-use of the forest which include a 

level of commerce including timber harvesting and management of outdoor recreation and range 

resources, in addition to the management of wildlife and resource conservation.

Response

We prepared the forest plan under the guidance of the National Forest Management Act and Multiple-Use 

Sustained-Yield Act. The plan provides guidance for a range of uses including timber products, 

recreation, and livestock grazing among others. The plan also contains direction to protect soil and water, 

in addition to wildlife and other resources.
Shoshone National Forest Land Management Plan Revision

708

Public Concern #5

The Forest Service should consider the following in the Draft Land Management Plan (DLMP): 

(1) Public water supply and big game crucial range are currently not placed in a Management Area that 

does not protect these resources as discussed in the Management Area direction and should be protected. 

(2) The plan should recognize the importance of not allowing fires to burn natural resources. (3) A more 

appropriately balanced desired condition should state: “Front country areas provide a wide range of 

recreation opportunities for motorized and non- motorized recreation in a natural setting.” (4) Forest 

planers should prioritize an emphasis on recreation planning and management that protects economic 

interests of the community. (5)The Plan should increase some of its Forest-wide direction language as it is 

currently lacking in specifics in the discussions of how activities will be conducted and monitored, 

sensitive species and management indicator species, water and soil, minerals, roads and trails, and the 

ensuing potential impacts these activities have on fish and wildlife, air quality, and water quality. (6) The 

Plan should ensure that adequate Objectives and Standards are consistent throughout the Land 

Management Plan. (7) On page 53 of the DLMP the guideline recommendations to oil and gas and wind 

energy development should be referenced in other sections of the document addressing wildlife and 

energy development, not just sensitive species. (8) On page 93 of the DLMP, Scenery, guidelines the final 

LMP needs to describe whether wind energy of winder turbines were considered within the scenery 

section. (9) On pages 40-42, Chapter 1, Forest-wide direction, additional quantifiable Objectives tied to 

other species should be included and Standards should be more species specific and quantifiable. (10) On 

pages 48-49, Chapter 1, Forest-wide direction, the plan should ensure that all Standards have 

quantifiable language and Standard 6 should provide an example or definition of “authorized use” as 

stated in “Do not allow recreational pack goat use in core native bighorn sheep ranges, except for 

authorized use.” (11) Under Goals, page 90: Goal 1 add “.....while not compromising the integrity of 

important wildlife habitats” to the end of the sentence. (12) Under Standards, page 90, add a second 

quantifiable Standard addressing the maintenance of habitat integrity through the use of HE/HS analyses 

and thresholds. Under Management Approach, page 91 add, “...... which do not compromise the integrity 

of wildlife habitat” to the end of the following sentence, “Forest recreation management focuses on 

community and visitor interests, new as well as traditional recreational activities, and year round 

enjoyment of outdoor recreation on the Shoshone.” (13) Page 191, the Goal is stated as a statement of 

fact, not a goal with any accompanying Objectives and should be corrected. (14) An updated Forest 

Inventory and Analysis should be completed since the last one completed was in 1999. (15) On page 13, 

Need for Change, the Forest should address the impacts of “changes” to wildlife and wildlife habitat. 

(16) The final LMP should be more specific in nature and provide a more comprehensive and consistent 

use of Standards and Guidelines. (17) The final LMP should contain less detail and micro- management 

and produce a generalized guide that addresses public comments and recommendations. (18) DLMP, 

Chapter 1 – Forest-wide Direction, Guidelines for Threatened, Endangered, Proposed, and Candidate 

Species #8, p. 43, wording should be changed to “Inside the Primary Conservation Area, the agency will 

always work with livestock grazing permittees to resolve conflicts and/or change management on cattle 

allotments or portions of cattle allotments with recurring grizzly bear conflicts. If conflicts cannot be 

resolved, livestock management will follow the Conservation Strategy” to add clarity to the statement that 

protect the interests of public land ranchers. (19) More attention should be given to the documented 

trends and their impacts towards the future needs of the forest in the final Plan.

Response

 Management Area 5.2 is assigned to the municipal watershed for the City of Lander. The management 

area emphasizes the protection of water quality including special direction for the management of 

fire. The City of Lander requested that the area be assigned to a management area that allowed the 

full array of multiple-use activities. Though management area direction allows activities such as 

timber harvest and motorized recreation, they will be conducted in a way that protects water quality. 
Final Environmental Impact Statement -- Appendix A

709

Management Area 5.4 is assigned to manage big game crucial winter range. Though management 

area direction allows activities such as timber harvest and motorized recreation, they will be 

conducted in a way that provides for sufficient forage to maintain big game herd objectives. We have 

clarified the wording of the livestock grazing standard.

 Fire is a natural component of the forest ecosystem. The plan includes direction that allows fire to 

play a natural role on the forest. In the cases of unique or valuable resources, there are areas where the 

plan favors other resources over fire. Examples include infrastructure, suitable timber lands, and the 

sawtooth peatbeds.

 We agree, the suggested language would improve the desired condition. We added a variation of the 

suggested language.

 The forest plan supports a wide range of recreation opportunities, all of which provide support to 

local economies.

(5, 6, 9, 13, 16) The plan includes direction for protecting all resources including water and wildlife. The 

plan describes out comes and does not specify how that outcome should be achieved. The decision on 

how something is achieved is made during project planning. Not all direction that protects wildlife is 

found in the wildlife section. For example, direction for protecting aquatic habitats is captured by the 

water standard that requires use of the Watershed Practices Handbook and direction in the vegetation 

section protects key habitat components for wildlife. Each of the plan components of Desired 

Condition, Goals, Objectives, Standards, and Guidelines are used to provide different types of plan 

direction. There is no requirement that each component needs to occur for each resource area. Rather 

the requirement is that the combined components across all the resources provide the direction that is 

needed.

(7) The guidance on page 53 is specific to wildlife and is referenced in the correct place. There is no need 

to list the guidance in multiple places. The plan direction is implemented in its entirety not resource 

by resource.

(8) The large facilities reference in the scenery section would include wind turbines, as well as other 

infrastructure that is not listed.

(10) Authorized use is use for which a valid permit is issued.

(11, 12) Such qualifiers and additional direction could be added for all direction throughout the plan. The 

plan is implemented in its entirety. Direction on protecting wildlife is elsewhere in the plan.

(14) Forest inventory analysis (FIA) is done on a schedule that is independent of Forest Plan Revision 

schedules. There is no opportunity to complete a new FIA inventory at this time. The mapped 

vegetation inventory for the forest has been updated and is used throughout the analysis.

(15) The changes in wildlife habitat are encompassed by the vegetation management need for change 

topic.

(17) We agree this is the basis of the revised plan. Thank you for the comment.

(18) We agree that the plan should clearly tie to the Conservation Strategy Language. The plan contains 

additional direction that is tied to the Biological Opinion for Livestock Grazing on the Forest. We will 

work between draft and final to improve the clarity on where the direction is from in this section.

(19) The EIS does address trends, particularly in how it examines the changes that have occurred in the 

life of the existing plan. The plan is for the next 10 to 15 years; the current analysis of changes should 

be adequate for deciding how to manage the plan during that time period.
Shoshone National Forest Land Management Plan Revision

710

Public Concern #6

The Forest Service should consider all suggestions, recommendations, and comments equally towards 

forest management and not be swayed by any specific special interest group.

Response

The decision maker will consider the full range of public comments and will outline the rationale for the 

decision in the Record of Decision.

Public Concern #7

The Forest Service should make the following change to the DEIS, page 81: the “Effects from Mineral 

and Energy Development” portion is vague and doesn’t include phosphate mining or wind energy 

development.

Response

The discussion is commensurate with the level of activity that is occurring on the Shoshone. There is little 

historic mining on the Shoshone and none is currently ongoing or anticipated. There is also no current or 

anticipated wind energy development.

Public Concern #279

The Forest Service should provide the specifics necessary for proper management for the goals, 

objectives, and standards of guidelines beginning on page 25 of the draft plan. The plan should correctly 

implement the management emphasis of the various DFCs, currently different species are treated the 

same in terms of conflicts in DFCs that have a wildlife emphasis as opposed to those with a resource 

extraction emphasis.

Response

The plan describes outcomes and does not specify how an outcome should be achieved. Site-specific 

analyses will address activities proposed to meet or move toward desired conditions. The management 

approach sections clarify how plan direction may be applied (e.g., for water and soil see pages 26 to 27). 

The decision on how something is achieved is made during project planning.

Management of wildlife species, such as grizzly bear, is provided in the Forest-wide direction.

Subject: 102 - Forest-wide Standards and Guidelines – General

Public Concern #8

The Forest Service should rehabilitate all disturbances from allowed developments, follow Standards 5 

and 6 for sensitive species, and ensure that guidelines are followed as directed in FSM 2621.2 or FSM 

2672.

Response

The forest plan contains direction to mitigate disturbances to soil and water resources from management 

activities. The biological evaluation and biological assessment address sensitive speces and threatened 

and endangered species as directed by Forest Service Manual. The analysis from those documents is 

incorporated in the EIS. Plant collection permits are handled from the regional office according to manual 

direction and are not specifically addressed in the forest plan.
Final Environmental Impact Statement -- Appendix A

711

Public Concern #9

The Forest Service should consider the following changes to the Draft Management Plan (DLMP): (1) on 

page 55, an additional Standard should be included stating, “Stating effective surveys will be utilized to 

track or index management indicator species in order to adequately assess the impacts of forest 

management activities. (2)Clarify the statement “The revision will follow transition language of the 

current planning regulations published in the Federal Register on April 9, 2012 (36 CFR 219.17(b)(3)), 

which allow use of the provisions of a previous version of the regulations published in 1982...Only the 

parts of the 1982 version about preparation or revision of forest plans is applicable” to make sure it is 

compliant with National Forest Management Act.

Response

1. Monitoring requirements for the plan are contained in chapter 3 of the Plan, not in the standards and 

guidelines section.

2. The current planning regulations finalized in 2012 have transition procedures that allow use of the 

prior planning regulation, including its transition procedures. (36 CFR 219.18(b)(3)) In turn, that 

prior planning regulation, finalized in 2000, had transition procedures that permitted the use of the 

1982 version of the regulations for completing plan procedures. (36 CFR 219.35(b) 2000 version) 

However, other portions of the 1982 version (regional planning, project planning) were eliminated by 

the 2000 version (see appendix B to 36 CFR 219.35 2000 version). So only the portions of the 1982 

version that address forest plan revisions or amendments are still in effect through the transition 

procedures of the current regulations.

The commenter is correct all the substantive provisions, requirements, and protections of the 1982 version 

of the regulations must be included, but only those related to doing a forest plan revision, and not regional 

planning or project planning.

Public Concern #10

The Forest Service should include the following in each Alternative to ensure that there is adequate 

balance between economic factors and wildlife habitat protection: (1) Better big game habitat 

information that includes specific protection measures. (2) Reclamation guidelines defined and updated. 

(3) Recreation be considered as a strong use, both in terms of economic and social impacts as other 

diverse uses on the Forest.

Response

By design, the alternatives provide varying balances of resources by responding to the issues differently. 

Alternatives C and D provide greater protection for big game winter range than alternatives E and F. They 

also emphasize non-motorized recreation more. While Alternatives E and F have a greater emphasis on 

motorized recreation. All alternatives contain watershed conservation practices that protect soil and water 

resources.

Subject: 103 - Insufficient Science

Public Concern #11

The Forest Service should not consider blanket statements such as “a managed is good and an 

unmanaged forest is bad” as they are unscientific as well as the idea of continued old growth elimination 

as current data has shown that old growth stands are a rare and valuable resource.

Response

Managed and unmanaged are not inherently good or bad when describing effects. For some management 

areas, forest plan direction is trying to produce desired conditions that do not occur naturally. On those 
Shoshone National Forest Land Management Plan Revision

712

lands, the only way to meet desired conditions is to manage the forest. An example would be the desire to 

reduce fuel loadings adjacent to infrastructure to reduce the risk from fire. The forest plan contains 

direction to maintain mature forests across the landscape. The large amount of unmanaged land on the 

Shoshone has many acres of mature forest.

Subject: 104 - Beyond the Scope

Public Concern #12

The Forest Service should consider keeping hunting and fishing privileges as they are except for trophy 

and out of state hunting/fishing.

Response

Hunting and fishing regulations are determined by the Wyoming Game and Fish Commission and are 

outside the scope of this project.

Public Concern #16

The Forest Service should consider deferring wildlife management as long as state works to keep animals 

protected but must assert its authority to protect animals when other agencies will not along with have 

Game and Fish justify wildlife closures, remapping the Canadian lynx habitat with the re-tooled habitat 

model developed by the USFWS and reconsidered the forest being occupied, and, modifying the forest’s 

wolf management plan.

Response

Hunting (including gray wolves) and fishing regulations are determined by the Wyoming Game and Fish 

Commission and are outside the scope of this project.

Lynx habitat was modeled in 2000, following direction in the Lynx Conservation Assessment and 

Strategy, and is displayed in the biological assessment.

Public Concern #17

The Forest Service should consider prioritizing local contractors for forest work and let the local public 

decide how to run the forest and not tourist input.

Response

The decision on what contractors use to implement plan direction is not decided in the revised Forest 

Plan. Procurement direction and law govern contractor selection which is beyond the scope of the revised 

Forest Plan analysis. The Shoshone is established for all people in the nation and not exclusively for local 

publics. All comments are considered in developing management direction. Local publics generally 

provide very useful comments, because they tend to be more site-specific.

Subject: 105 - Best Science

Public Concern #18

The Forest Service should consider using best and most current science for sustaining fish and wildlife as 

well as energy. This should include using most updated monitoring and mitigation measures, using the 

most current published science, create a science review team, possibly use third party review, and 

incorporate process that allows all new information science to be used as it comes out.
Final Environmental Impact Statement -- Appendix A

713

Response

We used current science in developing forest plan direction. Many commenters identified additional 

science for us to consider. We reviewed submitted literature and incorporated it where appropriate into 

plan development and the analysis.

Subject: 150 - Management Area 1.1 Wilderness - General

Public Concern #19

The Forest Service should consider allowing physical geocaches throughout the entire Shoshone National 

Forest. Geocaching is increasing in popularity and common standards are that the geocaches cannot be 

placed closer than .25 miles apart, except in multi-cache areas, where they will not be within .1 mile of 

each other. Power trails are only allowed in areas that already have defined trails and roadways.

Response

Physical geocaching is allowed under a special use permit to occur in all areas outside of designated 

wilderness. It has been determined that in designated wilderness, a physical geocache is a structure that is 

not needed for the administration of wilderness, and thus, will not be authorized.

Public Concern #20

The Forest Service should consider discussing and revising their Ten-Year Wilderness Stewardship 

Challenge that pertains to wilderness management. In this revision, specific management targets should 

be highlighted, along with how the Forest Service plans on achieving those goals. It is important for the 

Forest Service to ensure that the scores are consistent with what is actually happening in the area.

Response

The Wilderness Ten-Year Challenge is a national initiative that culminates in 2014, and as such, is not 

appropriate for inclusion in a forest plan. Wilderness management targets are addressed in the plan 

through the identified desired conditions, goals, objectives, and standards and guidelines for Management 

Area 1.1.

Public Concern #21

The Forest Service should strive to maintain the Shoshone’s wild character through a critical examination 

of the proposed group size limits and strategies they use to meet their educational missing such as ‘Leave 

No Trace’ camping practices. Limiting group sizes in the wilderness will significantly impact NOLS 

[National Outdoor Leadership School] operation and the students’ experiences.

Response

No group size limits are proposed in the revised Forest Plan. A limit on group size is one of many possible 

management tools listed in the management approach section for Management Area 1.1.

Any change to current group size limits would be analyzed site-specifically and are beyond the plan 

revision process.

Subject: 151 - Management Area 1.1 Wilderness - Desired Condition

Public Concern #23

The Forest Plan should clearly state their educational mission with outfitters, guides, and their clients, 

and use a rating matric to evaluate and prioritize major issues threatening the integrity of the Shoshone’s 

wilderness areas. This should include face-to-face training that is fully refreshed every year. The 
Shoshone National Forest Land Management Plan Revision

714

following sentence should be added to the Desired Conditions, “Education and recreation are recognized 

as fundamental purposes of Wilderness as identified in the Wilderness Act of 1964 (Section 4(b)).”

Response

Major issues and educational needs facing designated wilderness areas are addressed in site-specific 

education plans and Information Needs Assessments that are produced for each wilderness area and are 

not a section within forest plans. Education and recreational activities are covered in the desired 

conditions through the statement “Forest management strategies support recreational and educational 

activities when in alignment with the preservation of wilderness character.”

Subject: 155 - Management Area 1.1 Wilderness - Guidelines

Public Concern #24

The Forest Service should consider eliminating the Recreation Opportunity Spectrum from their analysis 

as Section 504 of the Wyoming Wilderness Act of 1984 prohibits buffer zones surrounding wilderness 

areas. Rather, the Forest Service should be proactive in managing motorized trespassing into wilderness 

areas through winter trail maps, improved signage, and enforcement. A guideline should be added 

requiring (not suggestion) signs be planned in problematic areas. Current problematic areas on the 

Shoshone National Forest are around (1) Absaroka-Beartooth; (2) North Absaroka; (3) Teton; (4) 

Washakie; and (5) Fitzpatrick Wilderness areas.

Response

The revised Forest Plan and the EIS do not create buffers or perimeters around existing wilderness. 

Activities outside of designated or recommended wilderness are governed by the management area 

designation of that area. Effects to wilderness are measured by how any particular project or planning 

effort modifies the wilderness character of a wilderness area.

The requirement for disclosing environmental effects to designated wilderness stems from the National 

Environmental Policy Act (NEPA) of 1969. A 1-mile zone adjacent to wilderness was analyzed for its 

recreation opportunity spectrum setting to compare the effects to wilderness of the different alternatives. 

This effect measurement indicator will be reassessed and a new one may be used between draft and final.

A guideline is already in place addressing wilderness boundary signing at problem areas. Management 

Area 1.1 land adjustment guideline states that “wilderness boundary posting should be maintained at 

recurring wilderness trespass locations and along motorized routes immediately adjacent to the 

wilderness.”

Subject: 156 - Management Area 1.1 Wilderness - Standards for the Pristine 

Wilderness Setting

Public Concern #25

The Forest Service should manage the Fitzpatrick Wilderness as “pristine” rather than “primitive” 

because the official monitoring protocols suggest that the wilderness conditions in the Southern 

Fitzpatrick Wilderness are violating the wilderness non-degradation policy set forth in the area’s assigned 

wilderness setting of “pristine.” Wilderness management area description maps should be included in the 

plan revision.

Response

The desired condition and mapping for both primitive and pristine wilderness settings in the Fitzpatrick 

Wilderness Area are based on our desired management direction for that acre of wilderness. Standards 
Final Environmental Impact Statement -- Appendix A

715

and guidelines are in place in Management Area 1.1 of the plan that addresses maintenance of wilderness 

character in both primitive and pristine settings. Management action if a standard or guideline is exceeded 

is a site-specific action and is beyond the scope of the plan revision.

Subject: 157 - Management Area 1.1 Wilderness - Plan Management 

Approach

Public Concern #26

The Forest Service should ensure that until Congress officially designates an area as wilderness, all 

existing recreational uses continue to be allowed for the Recommended Wilderness areas, unless they 

threaten the wilderness character. Furthermore, non-wilderness activities that can be seen or heard from 

zones that buffer any wilderness area should be allowed to exist according to Section 504 of The Wyoming 

Wilderness Act.

Response

Some existing recreational uses within any recommended wilderness would be affected if an area was 

recommended. Motorized uses for both summer and winter would be prohibited in recommend wilderness 

areas and mechanized would be restricted to system roads and trails. The revised Forest Plan and the EIS 

do not create buffers or perimeters around existing wilderness. Nor do they suggest precluding nonwilderness activities in areas immediately adjacent to wilderness simply because the area is immediately 

adjacent to wilderness. 

Subject: 158 - Management Area 1.1 Wilderness - More of this Management 

Area

Public Concern #27

The Forest Service should consider designating all of the recommended wilderness areas for official 

wilderness status. Areas that are recommended for wilderness should not be dropped from 

recommendation in most cases, but preserved for their pristine qualities that got them the recommended

status. There is significant national and public support for designating all qualifying areas for wilderness 

designations and increasing the number of special interest areas.

Response

Thirty-four areas on the Shoshone were evaluated for potential wilderness. Various alternatives were 

analyzed, including a range of recommended wilderness from 628,800 acres in alternative C to 

194,500 acres in alternative D and 0 acres in alternatives B, E, F and G. Potential areas not recommended 

for wilderness were allocated to other management prescriptions. Alternative F allocates the most acreage 

of potential wilderness to management prescriptions that allow activities that may impact the potential for 

wilderness, followed by alternatives E and A that allocate the second highest, and alternatives B, D and G, 

which allocate the third highest. An alternative was considered that included recommending all areas 

evaluated for wilderness. The wilderness evaluation included in appendix C was reviewed and updated 

between draft and final EIS to clarify the needs analysis. The deciding officer will consider the various 

options along with other comments during the decision process.

Public Concern #28

The Forest Service should consider designating all of the past and present recommended wilderness areas 

and maintaining all wildernesses to preserve them for future generations. No oil/gas development, no 

surface occupancy, no timber production, year-round non-motorized recreation, and no new roads or 
Shoshone National Forest Land Management Plan Revision

716

trails will all aid in preserving the areas wildlife including within climate change, vegetation 

communities, big game winter ranges, seclusion, and watershed.

Response

See PC #27.

Subject: 159 - Management Area 1.1 Wilderness - Less of this Management 

Area

Public Concern #29

The Forest Service should not designate any additional wilderness areas. SCAC, MCD, WSSA, and the oil 

and gas industries all oppose any wilderness additions. A blanket policy of immediately removing all 

vehicle use would create a “de-facto wilderness” area without Congressional approval. With 80% of the 

Shoshone National Forest open to only non- motorized uses, the other 20% should be left open to 

motorized vehicles to include Jeeps, ATV’s, and other forms of mechanized travel. This leaves a small, 

disproportionate amount open for multiple use and limits options for active forest management.

Response

Thirty-four areas on the Shoshone were evaluated for potential wilderness. Various alternatives were 

analyzed, including a range of recommended wilderness from 628,800 acres in alternative C to 

194,500 acres in alternative D and 0 acres in alternatives B, E, F and G. The deciding officer will consider 

the various options along with other comments during the decision process.

Public Concern #30

The Forest Service should not make any new wilderness designations as they will constrain the 

livelihoods of the surrounding communities. Wilderness designations exclude the young, old, disabled, 

and anyone else who is incapable of travelling on foot or is not financially, physically, of poor health, or 

without horses, to have an equal opportunity to enjoy the forest.

Response

See PC #29.

Subject: 190 - Management Area 1.3 – Back country recreation year-round 

non-motorized - General

Public Concern #31

The Forest Service should consider making much of the forest M.A. 1.3 year round non- motorized 

including Clay Butte, Gilbert Creek, Sunlight Basin; Gravel Bar, Beem Gulch, Huff Gulch, and Sheridan 

Pass. This should be done to stop illegal off trail abuse, protect wildlife and wilderness, and maintain the 

area for hikers, climbers, equestrians, and other leave-no- trace and low impact uses for future 

generations.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C, and a high of 887,600 acres available for winter motorized in alternative A to a low of 

103,000 acres in alternative C. The deciding officer will consider the various options along with other 

comments during the decision process.
Final Environmental Impact Statement -- Appendix A

717

Public Concern #32

The Forest Service should consider making the following changes to M.A. 1.3: 1- change the area of 

Deacon Meadows and Ramshorn Basin from management area 1.3 to 3.3A to maintain consistency with 

1986 forest plan and currently allows semi-primitive motorized use; 2- Cross- country travel by oversnow vehicles should continue to be allowed in 1.3 management areas unless there are parcel-specific 

justifications to warrant specific closures.

Response

Management area boundaries were reviewed between draft and final, and were corrected or adjusted 

where appropriate. The deciding officer will consider the various options along with other comments 

during the decision process.

Subject: 191 - Management Area 1.3 – Back country recreation year-round 

non-motorized – Desired conditions

Public Concern #33

The Forest Service should consider maintaining existing year-round non-motorized management areas

Response

See PC #31.

Subject: 194 - Management Area 1.3 – Back country recreation year-round 

non-motorized - Standards

Public Concern #34

The Forest Service should consider having language that refers to trail management standards as 

provided by the National Trail Classification System, FSM 2350, and FSH 2309.18 as identified in the 

Federal Register/Vol. 71, No. 127/Monday, July 3, 2006.

Response

FSM 2350 and FSH 2309.18 will be added under the other guidance section for roads and trails.

Public Concern #35

The Forest Service should support standard 1 and guideline 1 on page 138.

Response

Standard 1 and guideline 1 are included in all action alternatives.

Subject: 197 - Management Area 1.3 – Back country recreation year-round 

non-motorized – Management approach

Public Concern #36

The Forest Service should consider changing the following items away from M.A. 1.3: 1-Phelps Mountain 

Management Area to 3.5 to allow for 13 miles of historic motorized trails; 2-Kirwin and Timber Creek 

Trail to 3.5 since they are historical motorized trails; 3- Historical Trails 602, 603, 605, 626, and 627 

with 100 foot buffer to 3.5 or 3.3C to keep them available for any future changes to Grizzly Bear PCA 

requirement; 4- Jack Creek, Phelps Mountain Area, Deer Creek Trailhead and Kirwin Area to 3.5 to 
Shoshone National Forest Land Management Plan Revision

718

create a OHV linked trail system; 5- areas not currently in inventoried roadless areas should be changed 

from 1.3.

Response

See PC #32.

Public Concern #37

The Forest Service should consider making the following changes: 1-adding Little Popo Agie Canyon 

area to M.A. 1.3 since it is a popular destination for non-motorized use,2-no temporary should be built in 

any overlapping inventoried roadless areas for any reason; 3-no surface occupancy should be added to 

all non-motorized areas.

Response

1. See PC #32. 

2. Roads construction in inventoried roadless follows the Roadless Area Conservation Rule. Roads 

construction and reconstruction are prohibited except in some very limited situations. 

3. Table 113 lists surface occupancy suitability by alternative. The deciding officer will consider the 

various options along with other comments during the decision process.

Subject: 198 - Management Area 1.3 Back country recreation year-round 

non-motorized – More of this 

Public Concern #38

The Forest Service should consider increasing M.A. 1.3 including all 684,800 acres of roadless areas, two 

areas along the steep terrain of the Beartooth Mountain Front, Trout Creek, Wood River, Franc's Peak 

and Deep lake roadless areas, Dick Creek Lakes area, Two Ocean Peak, Wiggins Fork/Double Cabin 

road east to the reservation boundary, the south of Moon Lake jeep trail to Fitzpatrick Wilderness Area, 

West and South of Shoshone Lake to Popo Agie Wilderness Area, Little Popo Agie Canyon area, Beem 

Gulch, and Gravelbar drainages in Sunlight Basin, Bald Ridge, Pat O'Hare Mountain, Sheridan Pass, 

and Togwotee Pass. This should be done to increase solitude, protect wildlife, wilderness, watershed, and 

fisheries, scenic, protect archaeological sites, and help economy of those that rely on non-motorized 

recreation, and illegal ATV use and ATV damage.

Response

Various alternatives for the MA 1.3 allocation were analyzed from a maximum of 455,554 acres in 

alternative A to a minimum of 106,890 acres in alternative C. The deciding officer will consider the 

various options along with other comments during the decision process.

Subject: 199 - Management Area 1.3 Back country recreation year-round 

non-motorized – Less of this

Public Concern #39

The Forest Service should consider having less area closed to motorized recreation including Two Ocean 

Mountain, Togwotee Pass, Brooks Lake, Ramshorn Basin, and Deacon Meadows. This should be done 

since motorized recreation is a big part of what the public uses on the forest and help economy of those in 

motorized recreation business.
Final Environmental Impact Statement -- Appendix A

719

Response

See PC #31.

Subject: 210 - Management Area 1.5A – Clarks Fork of the Yellowstone Wild 

River - General

Public Concern #40

The Forest Service should continue with this management area as outlined in Alternative D, and should 

mention in this area of the plan that the lower segment of Clarks Fork River already has wild and scenic 

river designation.

Response

All action alternatives (B, C, D, E, F, and newly developed G) protect the designated 20.5-mile section of 

the Clarks Fork; the first sentence of the management area theme notes that “In 1990, the Clarks Fork 

Wild and Scenic River Designation Act designated the 20.5-mile segment of the Clarks Fork of the 

Yellowstone River to be included in the National Wild and Scenic Rivers System.” Under alternative C, 

portions of the 20.5-mile National Wild and Scenic River-Desingated segment would be portected under 

MA 1.2.

Subject: 218 - Management Area 1.5A – Clarks Fork of the Yellowstone Wild 

River- More of this

Public Concern #41

The Forest Service should consider increasing management in this area by prohibiting livestock grazing 

within 50 feet of the river, and managing this area as a biological corridor between core protected areas, 

Beartooth Plateau and the Absaroka/Yellowstone regions.

Response

The plan includes standards and guidelines that protect the outstandingly remarkable values for which it 

was designated including a guideline that grazing operating plans include measures to protect these 

values. Management standards and guidelines do not preclude this management area from serving as a 

biological corridor. Corridor connectivity is mentioned on page 29 under vegetative management and also 

in goal #3 on page 55 under management indicator.

Subject: 230 - Management Area 1.6A – High Lakes Wilderness Study Area 

- General

Public Concern #42

The Forest Service should consider not designating High Lakes Wilderness Study Area as wilderness and 

should continue to allow snowmobiling in this area. The area on Beartooth Plateau provides valuable off 

trail snowmobiling experiences that should be continued.

Response

Only alternative C recommends the High Lakes Wilderness Study Area as wilderness. The balance of the 

alternatives include MA 1.6A direction that allows semi-primitive motorized use in the winter. The 

deciding officer will consider the various options along with other comments during the decision process.
Shoshone National Forest Land Management Plan Revision

720

Public Concern #43

The Forest Service should consider designating High Lakes a Wilderness Study Area in the final Forest 

Plan. This area is home to Beartooth Plateau, many alpine lakes, is within the grizzly bear primary 

conservation area, includes area in the Lynx Analysis Area 1, and is home of the Beartooth wolfpack. This 

area should prohibit motorized recreation, and should have no surface occupancy for oil and gas 

development.

Response

High Lakes is a Wilderness Study Area. In compliance with the enabling legislation, summer motorized 

use is prohibited and winter motorized is allowed to the extent and degree that occurred when the area 

was designated. No surface occupancy for oil and gas is authorized in this management area.

Public Concern #44

The Forest Service should consider completing the statute required mapping of the High Lakes 

Wilderness Study Area to include the geographical map boundaries and legal description of this area.

Response

Direction has been included in the plan that will lead to the creation of the legal description. 

Public Concern #45

The Forest Service should consider clarifying actual dates when summer versus winter recreation can 

occur in the Shoshone National Forest as various management areas seem to contradict each other. In 

addition, snowmobiling should be closed in this area after the Beartooth Highway is opened for 

motorized wheel traffic as it is dangerous to have the snowmobilers present with the skiers and 

snowboarders.

Response

1. Summer versus winter recreation dates are a site-specific decision made in travel management and 

may change from area to area based on resource concerns. 

2. Closure of the Beartooth Plateau to snowmobiles once the road is open for wheeled traffic is a sitespecific travel management decision outside the scope of the revised Forest Plan.

Subject: 232 - Management Area 1.6A – High Lakes Wilderness Study Area 

- Goals

Public Concern #46

The Forest Service should consider describing how it is meeting the federal statute from the Wyoming 

Wilderness Act in 1984 which stated that snowmobile use could continue in “the same manner and degree 

as was occurring prior to the enactment of the Wyoming Wilderness Act of 1984.” The Forest Service has 

not monitored snowmobiling rates, and snowmobile use has increased dramatically and gone unregulated 

during this time.

Response

The plan includes direction to monitor snowmobile use in High Lakes Wilderness Study Area to 

determine the current manner and degree of use that is occurring in the area. This information will be 

used in a separate environmental analysis that will be conducted as part of travel management to 

determine what site-specific changes need to be made to address the language in the Wyoming Wilderness 

Act (1984).
Final Environmental Impact Statement -- Appendix A

721

Subject: 250 - Management Area 1.6B - Dunoir Special Management Unit -

General

Public Concern #47

The Forest service should consider designating this area as wilderness as described in Alternative D and 

include the bordering roadless areas (Dunoir, East, West, and South). The pristine wilderness found in 

this area should be kept intact and timber harvest, road creation, oil/gas development, mountain biking, 

and motorized recreation should all be prohibited. As a significant amount of dispersed snowmobiling is 

currently occurring, and a designation of wilderness would change boundaries, improved and increased 

signage and forest user education should be implemented. However, snowmobile access to Trail H (access 

to Austin Peak) should remain open, but with clear trail markers. This area is a critical habitat for the 

grizzly bear, elk, wolves and lynx. This area also contains one heritage site that is an important historical 

paleontological resource.

Response

Alternative D does not recommend this area for wilderness. Alternative C recommends Dunoir, East, 

West, and South for wilderness designation. In compliance with the enabling legislation, winter motorized 

will no longer be allowed in the designated area. The deciding officer will consider the various options for 

this management area along with other comments during the decision process.

Public Concern #48

The Forest Service should consider not designating this area as wilderness. This area was set aside in the 

1972 and 1984 plans and was dropped from wilderness designation by Congress both times. This area 

should be kept open for multiple uses, including bicycles, and should be managed as a back country nonmotorized area.

Response

Alternatives C and D recommend this area for wilderness designation. The balance of the alternatives do 

not include this area for wilderness designation. The deciding officer will consider the various options for 

this management area along with other comments during the decision process.

Public Concern #49

The Forest Service should consider completing the statute required mapping of the Dunoir Special 

Management Unit to include the geographical map boundaries and legal description of this area.

Response

For the preferred alternative, an objective related to the mapping of the Dunoir Special Management Unit 

has been included in the revised Forest Plan.

Public Concern #50

The Forest Service should consider developing the Dunoir Special Management Area. This area would be 

non-motorized and would help in protecting the natural beauty of the area. Increased and improved 

signage is needed to educate forest users about boundaries and recreation opportunities.

Response

All action alternatives provide for non-motorized recreational access. Increased and improved signage is 

beyond the scope of the revised Forest Plan.
Shoshone National Forest Land Management Plan Revision

722

Subject: 270 - Management Area 2.2A – Line Creek Plateau Research 

Natural Area - General

Public Concern #51

The Forest Service should consider recommending this area as a Research Natural Area and possible 

wilderness designation. This area includes habitats not present in other areas of the Shoshone National 

Forest and should be closed to oil and gas leases.

Response

Line Creek Research Natural Area (RNA) is an existing RNA and current designation is maintained in all 

proposed alternatives. RNAs are not managed as wilderness, but under management prescription 2.2a. No 

surface occupancy for development of oil and gas is allowed.

Subject: 275 - Management Area 2.2A – Line Creek Plateau Research 

Natural Area - Guidelines

Public Concern #52

The Forest Service should reword this guideline to state that stocking will continue to be allowed in 

streams and lakes, so that it is consistent with the management approach found on page 54.

Response

Fish-stocking guidelines in the Line Creek RNA are outlined in the 2000 Line Creek RNA Environmental 

Assessment and decision memo. Fish stocking will be allowed only in lakes stocked prior to RNA 

designation.

Public Concern #53

The Forest Service should consider clarifying Guideline #14 in this section. The Desired Conditions state 

that the area will allow non-motorized recreation in the summer, and motorized and non-motorized in the 

winter. However, the guideline only discusses semi- primitive non-motorized. The final plan should reflect 

that motorized recreation opportunities are permitted during the winter as to continue to allow 

snowmobile use in this area.

Response

The direction in Guideline #14 only refers to wheeled motorized recreation on designated routes. Winter 

motorized activity on snow is not addressed in the context of recreation opportunity spectrum. That 

direction is covered in the suitability section of the plan. Over-snow winter motorized use is allowed in 

this area.

Subject: 290 - Management Area 2.3 – Proposed Research Natural Areas -

General

Public Concern #54

The Forest Service should consider designating the eight Research Natural Areas that were identified. 

Bald Ridge and Pat O’Hara areas should also be included for their biodiversity, ecological and 

archeological areas, and wildlife and sensitive species populations that has been identified in the 

Wyoming Natural Diversity Database. These areas should not be open to motorized recreation of any kind 

and not managed as back country recreation.
Final Environmental Impact Statement -- Appendix A

723

Response

The proposed RNAs are represented in the range of alternatives. Alternatives C, D, and G include the 

Bald Ridge and Pat O'Hara areas. The decision maker will take your comments and the comments of 

others into consideration.

Public Concern #55

The Forest Service should clarify how many Research Natural Areas are being proposed. The theme 

states that six areas are being proposed, but the setting states that there are eight being proposed.

Response

The setting noted there were eight potential RNAs. Alternatives propose varying numbers of RNAs. 

Alternative B proposed six RNAs. Eight RNAs are proposed in alternatives C, D, and G. Edits will be 

made to the summary of the analysis of the management situation in the forest plan.

Public Concern #56

The Forest Service should not designate Beartooth Butte as a Research Natural Area if the area would 

then be closed to off-trail snowmobiling. Clarification is needed between Guideline 5 which states that 

semi-primitive non-motorized with over-snow motorized is allowed to occur where already occurring. 

Page 504 on SEIS states over-snow motorized recreation can occur only on designated trails, page 506 

states that existing trails will stay open but motorized use would be prohibited in Beartooth Butte, and 

page 540 states that motorized use is prohibited in RNAs that are outside of wilderness designation. The 

Beartooth Butte area that is outside of the wilderness designation should be classified as back country 

winter motorized or as a travel corridor.

Response

Winter motorized issues in the proposed Beartooth Butte RNA will be addressed by the decision maker. 

Alternative G includes a modified boundary of the Beartooth Butte area for consideration.

Public Concern #57

The Forest Service should manage Beartooth Pass as a summer, non-motorized recreation area that 

prohibits snowmobiles in order to make the area safer for skiing.

Response

Various alternatives were analyzed concerning winter motorized use allocations. These ranged from a 

high of 887,600 acres available for winter motorized in alternative A to a low of 103,000 acres in 

alternative C. The deciding officer will consider the various options along with other comments during 

the decision process.

Subject: 294 - Management Area 2.3 – Proposed Research Natural Areas -

Plan - Standards

Public Concern #896

The Forest Service should include road and trail related standards to prohibit new roads, trails and 

facilities within MA 2.3.

Response

The suitable uses table in chapter 2 of the revised Forest Plan indicates that motorized roads and trails are 

not allowed in MA 2.3.
Shoshone National Forest Land Management Plan Revision

724

Subject: 310 - Management Area 3.1A – Swamp Lake Botanical Area -

General

Public Concern #58

The Forest Service should be aware that a fence was put up last year along the northern boundary of this 

area, and it implies that it is private land. Gates should be established along this fence line to encourage 

access to this area.

Response

Thank you for bringing this fencing concern to our attention. This site-specific issue is outside the scope 

of the scope of the revised Forest Plan analysis.

Public Concern #59

The Forest Service should consider designating the Swamp Lake Botanical Area as a Special Interest 

Area in order to continue its research and science missions.

Response

Swamp Lake Special Interest Area is considered in the range of alternatives presented in the revised 

Forest Plan.

Subject: 330 - Management Area 3.1B – Proposed Little Popo Agie 

Geological Area - General

Public Concern #61

The Forest Service should consider designating the Little Popo Agie as a Special Interest Area because of 

its importance to the plant and animal communities.

Response

The Little Popo Agie Special Interest Area is considered for designation in alternatives B, C, D, and G, as 

discussed in the range of alternatives presented in the EIS.

Subject: 335 - Management Area 3.1B – Proposed Little Popo Agie 

Geological Area - Guidelines

Public Concern #62

The Forest Service should change the wording under Guideline 8 from “semi-primitive” to “semiprimitive motorized.”

Response

The wording for Guideline 8 has been clarified in the final documents.

Subject: 350 - Management Area 3.1C – Proposed Sawtooth Peatbed 

Geological Area - General

Public Concern #63

The Forest Service should consider designating the Sawtooth Peatbed Geological Area as a Special 

Interest Area in order to continue its research and science missions, and should incorporate guidelines 

that state this area is not available for mineral leasing and a stipulation for no surface occupancy.
Final Environmental Impact Statement -- Appendix A

725

Response

The Sawtooth Peatbeds Geological Area is considered for designation in alternatives B, D, and G, as 

discussed in the range of alternatives presented in the EIS. Standards for management of area 3.1C 

include that the area is not suitable for surface development of oil and gas resources. The guideline for 

recreation in alternative G was modified to manage for an adopted recreation opportunity spectrum class 

of non-motorized.

Public Concern #64

The Forest Service should consider revising the following items in regards to the Sawtooth Peatbed 

Geological Area. (1) When discussing the RNA, change wilderness to non-motorized designated areas so 

the recreation opportunities will not change. (2) Reduce the 577 acres to 377 acres, and designate the 200 

acres from the North ridge and East ridge down to the Morrison Jeep Trail as back country access 

corridor.

Response

We developed a new boundary for consideration in alternative G. The decision maker will take your 

comments and those of others into consideration.

Subject: 370 - Management Area 3.3A – Back Country Recreation YearRound Motorized - General

Public Concern #65

The Forest Service should not expand motorized use areas from the current levels, especially in the North 

Fork and South Fork areas as it appears to violate the Shoshone National Forest’s commitment to strive 

for sustainable consumption strategies. The current limited vehicle use on Bald Ridge should be 

eliminated.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C and a high of 887,600 acres available for winter motorized in alternative A to a low of 

103,000 acres in alternative C. The deciding officer will consider the various options along with other 

comments during the decision process.

Public Concern #66

The Forest Service should make the following changes to the Land Management Plan: (1) The goals 

listed on page 164 should be expanded to include changes in commercial and educational group sizes and 

stress flexibility based on size, purpose, and impact upon resource. (2) Under Standards add “...existing 

System road reconstruction...” to Standard 2, page 164 to clarify that if a non-system road exists in this 

management area that is within the 1 mile guideline, it could be reconstructed as long as it was restored 

upon completion of the project. (3) Clarify the difference in acres allocated to the management area that 

were changed from 185,936 to 64,243, and if the 121,693 acre difference remain in motorized use. 

(4) Under Recreation, Guideline 2, the statement “some trails may be restricted to non- motorized use” 

should be removed since 3.3A should be for true motorized use areas.

Response

Group sizes for educational and commercial use are not within the scope of plan revision; they are 

handled site-specifically during the process of issuing a special use permit. Unclassified user-created 

routes that the commenter is calling non-system roads could be available for use as temporary roads, and 
Shoshone National Forest Land Management Plan Revision

726

as such, would then be subject to the guideline on temporary roads. Therefore, no additional guideline is 

needed on non-system roads. While there is a difference in management area 3.3A acres between 

alternatives A and B, the total acres available for motorized use does not change significantly between 

alternatives A and B. Management area 3.3A in the setting provides for both motorized and nonmotorized recreation opportunities. Thus, the recreation guideline that “some trails may be restricted to 

non-motorized use” as motorized and non-motorized uses may be separated to provide a safe experience 

and it is an appropriate guideline that will be retained.

Public Concern #67

The Forest Service should not close any additional lands to year-round motorized recreation as currently 

only a small portion of the forest is open to year-round motorized use.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C and a high of 887,600 acres available for winter motorized in alternative A to a low of 

103,000 acres in alternative C. The deciding officer will consider the various options along with other 

comments during the decision process. See also response to PC #270 regarding travel management 

planning.

Subject: 371 - Management Area 3.3A – Back Country Recreation YearRound Motorized – Desired condition

Public Concern #68

The Forest Service should make a change under Desired Conditions to state that motorized recreation 

should be given a clear and distinct preference over non-motorized uses in all 3.3A managed areas since 

Management Area 3.3A should provide a true backcountry motorized experience for its users.

Response

The wording was originally part of a section that applied to the entire forest. It was removed from this 

management area and moved to the Forest-wide management approach under roads and trails.

Subject: 372 - Management Area 3.3A – Back Country Recreation YearRound Motorized - Goals

Public Concern #69

While the Goals stated for Management Area 3.3 are clear and appropriate, the Forest Service should 

clarify how designating separate non-motorized areas in a year-round motorized area will fit in with 

these goals as currently they are contradictory and do not meet the desired conditions of the management 

area.

Response

The desired condition as written articulates our management intent. The preference for motorized use is 

indicated in the first goal for the management area which is to “Provide year-round motorized recreation 

opportunities.”
Final Environmental Impact Statement -- Appendix A

727

Subject: 377 - Management Area 3.3A – Back Country Recreation YearRound Motorized – Management approach

Public Concern #70

The Forest Service should make the following changes to the Management Plan: (1) Management Areas 

3.3A Back Country Recreation Year-Round Motorized-Theme on page 163, include the following 

changes: “back country motorized recreation areas are managed to provide recreation opportunities on 

trails in a natural appearing landscape while emphasizing the use of vegetation management activities to 

enhance vegetation diversity.” (2) There is a specific area of concern by the WWWA of MA 3.3A in the 

Ramshorn Lakes/Amoretti Park area, south and east of Dickinson Park area and in the Christina Lake 

area for prescriptions as outlined in Alternative B.

Response

(1) We feel that the addition of the statement “while emphasizing the use of vegetation management 

activities to enhance vegetation diversity” to the theme of the management area would change the 

intent. Vegetation management direction is adequately addressed under the setting description and 

guideline #1. 

(2) See PC #32 regarding MA 3.3A mapping.

Public Concern #71

The Forest Service should not allow snowmobiling in any big game winter range areas in Management 

Area 3.3A to protect wintering wildlife. The Forest should ensure that there is no road construction within 

Management Area 3.3A as specified in the Land Management Plan, especially in areas that overlap with 

inventoried roadless areas.

Response

(1) Snowmobiling in 3.3A and other management areas was worked out in partnership with the Wyoming 

Game and Fish Department based on crucial winter range coverages. 

 Standard #2 for MA 3.3A states that “Road construction or reconstruction will only be authorized to 

honor existing rights.” Road construction in inventoried roadless follows the Roadless Area 

Conservation Rule. Road construction and reconstruction is prohibited except in some very limited 

situations.

Subject: 378 - Management Area 3.3A – Back Country Recreation YearRound Motorized – More of this

Public Concern #72

The Forest Service should increase or maintain current year-round motorized areas, not decrease the 

amount of acres as currently 80% of the forest is designated Wilderness or other roadless areas and avoid 

crowding and increased resource damage by cramming motorized use into smaller areas and provide 

access to the forest for those who are unable to due to physical condition. Designated trail routes through 

existing wildlife ranges should remain with the creation of trails if new winter ranges are created. 

Togwotee Pass and Brooks Lake should be kept open for winter motorized use.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C and a high of 887,600 acres available for winter motorized in alternative A to a low of 
Shoshone National Forest Land Management Plan Revision

728

103,000 acres in alternative C. Existing trails through winter range remain in all alternatives.The deciding 

officer will consider the various options along with other comments during the decision process. 

Subject: 379 - Management Area 3.3A – Back Country Recreation YearRound Motorized – Less of this

Public Concern #73

The Forest Service should decrease the amount of the forest currently opened to year-round motorized 

recreational use, create no new motorized trails, limit motorized vehicle use, and keep the following areas 

non-motorized: Little Pop Agie Canyon area, Wiggins Fork, Double Cabin area, Sunlight, Dead Indian, 

Elk Creek, Beem Gulch, Huff Gulch, Gravelbar, Company Creek, Trail Creek, Lodgepole Creek, Crandall 

area, and Ed Young Basin to reduce noise, illegally created trails, and protect wildlife and pristine 

environments.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C and a high of 887,600 acres available for winter motorized in alternative A to a low of 

103,000 acres in alternative C. Projected motorized trail miles vary also by alternative from 32 miles in 

alternatives A and C to a high of 92 miles in alternative F. The deciding officer will consider the various 

options along with other comments during the decision process.

Public Concern #74

The Forest Service should consider changing the area north of the Christina Lake Road and back to the 

wilderness boundary and the area south of the Moon Lake Jeep Trail including the north aspect and west 

ridge of Union Peak to MA 1.3 or MA 3.3B to restrict motorized vehicles, as it is an excellent summer 

moose habitat and ensure that non-motorized recreation is not disturbed by motorized traffic.

Response

See response PC #32 regarding boundary adjustments.

Subject: 390 - Management Area 3.3B – Back Country Recreation Summer 

Non-Motorized with Winter Motorized - General

Public Concern #75

The Forest Service should consider increasing the areas to management area 3.3B as much as possible 

for summer non-motorized and increased demand for winter motorized.

Response

Various alternatives and acreages of management area 3.3B were analyzed from a high of 86,413 acres in 

alternative B to a low of 3,157 acres in alternative C. The deciding officer will consider the various 

options along with other comments during the decision process.

Subject: 392 - Management Area 3.3B – Back Country Recreation Summer 

Non-Motorized with Winter Motorized - Goals

Public Concern #77

The Forest Service should consider adding a goal to reduce unauthorized motorized travel.
Final Environmental Impact Statement -- Appendix A

729

Response

Reducing unauthorized motorized travel is a broader issue than just associated with Management Area 

3.3B. As such, it is addressed on a Forest-wide basis in the roads and trails section through a goal of 

“Resource impacts from use of unauthorized motorized routes are eliminated, along with the unauthorized 

route.” See also response to PC #270 regarding travel management planning.

Subject: 394 - Management Area 3.3B – Back Country Recreation Summer 

Non-Motorized with Winter Motorized - Standards

Public Concern #78

The Forest Service should consider adding existing System road reconstruction... to Standard 2 (page 

166) to clarify that if a non-system road exists in this management area it could be reconstructed as long 

as it was restored upon completion of the project.

Response

Non-system roads could be available for use as temporary roads, and as such, would then be subject to the 

guideline on temporary roads. Thus, no additional guideline is needed for non-system roads.

Subject: 397 - Management Area 3.3B – Back Country Recreation Summer 

Non-Motorized with Winter Motorized – Management approach

Public Concern #79

The Forest Service should consider the following: 1- not allowing winter motorized use in big game 

winter range that is within M.A. 3.3B since big game crucial winter ranges are sensitive and crucial to 

the survival of these species and [2] not allow any road construction in any inventoried roadless areas 

that overlap with M.A. 3.3B.

Response

(1) See response to PC #71 item 1. (2) See response to PC #37 item 2.

Subject: 398 - Management Area 3.3B – Back Country Recreation Summer 

Non-Motorized with Winter Motorized – More of this

Public Concern #80

The Forest Service should consider having much area open to winter motorized use and not closing any 

areas to take away varying recreational options.

Response

Various alternatives were analyzed concerning motorized winter use allocations. These ranged from a 

high of 887,600 acres available for winter motorized in alternative A to a low of 103,000 acres in 

alternative C. Existing trails through winter range remain in all alternatives. See also response to PC #270

regarding travel management planning. The deciding officer will consider the various options along with 

other comments during the decision process.

Public Concern #81

The Forest Service should consider adding the following to M.A. 3.3B: 1- area immediately north and 

east of Morrison Road; 2- East Fork of the Wind River area east of Dubois.
Shoshone National Forest Land Management Plan Revision

730

Response

See response to PC #32.

Subject: 399 - Management Area 3.3B – Back Country Recreation Summer 

Non-Motorized with Winter Motorized – Less of this

Public Concern #82

The Forest Service should consider not having winter motorized travel especially Two Ocean Mountain 

and Sublette Pass for the benefit of cross country skiers and snow-shoe users.

Response

In the various alternatives two options for the Two Ocean area were analyzed. Alternatives A, B, E, and F 

would kept this area open to all uses, and alternatives C and D would close the area to winter motorized 

use. The deciding officer will consider the various options along with other comments during the decision 

process.

Subject: 410 - Management Area 3.3C - Back Country Recreation Summer 

Motorized with Winter Non-Motorized - General

Public Concern #84

The Forest Service should address the following concerns in regards to skier and snowmobile user 

interactions within the Two Ocean, Togwotee Pass and other multiuse areas: (1) Potential for physical 

conflicts between the two user groups. (2) High marking puts a stress on the snowpack along steep slopes, 

which can create avalanche hazards for skiers. (3) Snowmobile tracks harden and are snowed over 

creating safety hazards for skiers. (4) There is too much traffic in these corridors during weekends, which 

increase the likelihood of collisions between skiers and snowmobiles.

Response

See response to PC #82.

Public Concern #85

The Forest Service should make the following changes to the Land Management Plan: (1) Add 

“...existing System road reconstruction...” to Standard 2 to clarify that a non-system road could be 

reconstructed as long as it was restored upon project completion. (2) Provide a map of the winter 

motorized recreation area within the Dunoir.

Response

Non-system roads could be available for use as temporary roads and as such would then be subject to the 

guideline on temporary roads thus no additional guideline is needed on non- system roads. All of the 

Dunoir management area is proposed to be closed to winter motorized use to be consistent with the 

enabling legislation. No further map is needed as a management area map is included in the document.

Public Concern #86

The Forest Service should not designate the areas west of Sinks Canyon to Shoshone Lake and to north of 

Cyclone Pass as Winter Non-Motorized since it would create an area which has historically been used by 

backcountry snowmobilers and is not easily accessible my non- motorized users and make much of the 

area inaccessible to the public.
Final Environmental Impact Statement -- Appendix A

731

Response

See response to PC #80.

Public Concern #87

The Forest Service should not close the Two Ocean Mountain area to snowmobiles as proposed in 

Alternatives C and D and leave it open to multiple winter recreation uses.

Response

See response to PC #82.

Subject: 417 - Management Area 3.3C – Back Country Recreation Summer 

Motorized with Winter Non-Motorized – Management approach

Public Concern #88

The Forest Service should make the following changes to the Land Management Plan: (1) On page 167, 

under Management Area 3.3C –Back country recreation summer motorized with winter non-motorized –

Theme include the following changes: “Back country recreation areas are managed to provide back 

country recreation opportunities in a natural appearing landscape while emphasizing the use of 

vegetation management activities to enhance vegetation diversity.” (2) Changing Historic Trails 602, 

603, 605, 626, and 627 from MA 1.3 to MA 3.3C or MA3.5 to ensure that motorized travel options will be 

available for the future.

Response

We feel that the addition of the statement “while emphasizing the use of vegetation management activities 

to enhance vegetation diversity” to the theme of the management area would change the intent. Vegetation 

management direction is adequately addressed under the setting description and guideline #1.

Within the Grizzly Bear Primary Conservation Area (PCA), generally, management areas 3.A, 3.3C, 

3.5A, and 3.5C are not used. The revised Forest Plan does not encourage expansion of motorized use 

within the PCA, because of the existing secure habitat direction.

Public Concern #89

The Forest Should clarify how road management is to be planned when inventoried roadless areas 

overlap with backcountry year-round non-motorized, backcountry year-round motorized, backcountry 

summer non-motorized, and backcountry summer motorized. The Forest should clarify the following in 

MA 3.3C: (1) Page 4, Map 6: MA 3.3C and 3.5 prescriptions in the Carter Mountain Area. (2) Page 7, 

Map 6: MA 3.3C in the East Fork Area. (3) Page 8, Map 6: MA 3.3C in the Shoshone Lake/Cyclone 

Pass/Pete’s Lake area.

Response

The desired conditions and management approach in both inventoried roadless areas and Management 

Area 3.3C articulate how road management is planned. Under the inventoried roadless section it states 

that desired conditions for inventoried roadless is guided by the desired conditions of the underlying 

management area. Under the management approach for inventoried roadless it states “The management 

approach for inventoried roadless is generally guided by the management area to which the individual 

roadless area is allocated. Management direction is sometimes more restrictive than the direction in the 

Roadless Area Conservation Rule. In other cases, the specific direction is less restrictive. In those cases, 

the roadless rule direction is followed. For MA 3.3C (1-3) see response to PC #32. See also response to 

PC #270 regarding travel management planning.
Shoshone National Forest Land Management Plan Revision

732

Subject: 418 - Management Area 3.3C – Back Country Recreation Summer 

Motorized with Winter Non-Motorized – More of this

Public Concern #90

The Forest Service should establish more quality terrain, winter non-motorized areas, especially 

Togwotee Pass, Two Ocean Peak, Brooks Peak area, Breccia Peaks, and Beartooth Pass as it provides 

easy access for non-motorized use and the current multiuse of the areas make it difficult for skiers to have 

a peaceful recreational experience as well as pose a potential safety hazard. The Woody Creek Trail just 

south of Cooke City should also be managed as winter non-motorized for safety reasons.

Response

Various alternatives for winter non-motorized use (MA 3.3C) were analyzed from a low of 4,563 acres in 

alternative F to a maximum of 98,030 acres in alternative E. The deciding officer will consider the various 

options along with other comments during the decision process. See also response to PC #82.

Subject: 419 - Management Area 3.3C – Back Country Recreation Summer 

Motorized with Winter Non-Motorized – Less of this

Public Concern #91

The Forest Service should consider keeping open all areas that are currently open to winter motorized use 

including snowmobiling. This should include all roadless areas, Togwotee Pass, Brooks Lake, High Lakes 

Study Area, Two Ocean Mountain, Beartooths, Brecciae Cliffs, Sublet Pass, Jade Lakes, Austin Peak, 

Bonneville Meadows, Jules Bowl, Area west of Sinks Canyon: Shoshone Lake and to north of Cyclone 

Pass. Perhaps switch area designations to 3.3B.

Response

See response to PC #80.

Public Concern #92

The Forest Service should consider not expanding any ATV and snowmobile areas including unofficial 

expansion and focus more on patrolling to keep the unofficial expansion from occurring since there are 

enough motorized trails. The Forest Service should perhaps consider perhaps switching to 3.3B in 

alternatives C and D and keep areas open to just non-motorized use.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C and a high of 887,600 acres available for winter motorized in alternative A to a low of 

103,000 acres in alternative C. Projected motorized trail miles vary also by alternative from 32 miles in 

alternatives A and C to a high of 92 miles in alternative F. The deciding officer will consider the various 

options along with other comments during the decision process.

Subject: 430 - Management Area 3.5 – Back Country Recreation and Forest 

Restoration - General

Public Concern #93

The Forest Service should clarify why Beem Gulch, Huff Gulch and Sulfur Lake are included in 

Management Area 3.5. Currently Huff Gulch and Sulfur Lake have access only through private property 

and Beem Gulch is steep, heavily forested and not suitable for motorized use.
Final Environmental Impact Statement -- Appendix A

733

Response

These areas were allocated to management area 3.5, because they are within inventoried roadless that has 

previously been managed. The desired condition in the plan is to manage the vegetation in these areas 

consistent with the Roadless Rule. The modified preferred alternative will include direction that clearly 

states how motorized public recreation will be managed in management area 3.5.

Public Concern #94

The Forest Service should add to the description of MA 3.5 that motorized trail construction, 

maintenance, and use is allowed of existing routes even in roadless areas. The Forest should also verify 

that motorized vehicle use conforms to the Comprehensive Plan and not allow any additional motorized 

routes and focus solely on vegetative treatment to prevent any impact to wildlife or the environment.

Response

The suitable uses discussion for recreation opportunities, roads, and trails in the beginning of chapter 2 of 

the revised Forest Plan indicates the motorized trails are permitted n MA 3.5 and that they can be 

maintained. Additional road construction in inventoried roadless is generally not allowed under the 

Roadless Rule, so there will be no further road construction in MA 3.5. The key component of the desired 

condition for MA 3.5 is to manage the vegetation in these areas consistent with the Roadless Rule.

Public Concern #95

The Forest Service should make the following changes to the Land Management Plan: (1) Under Desired 

Conditions include the following additional language in the 2nd sentence of the first paragraph 

(underlined): Snowmobiling is not allowed in big game winter range areas except in areas of existing 

snowmobile routes and play areas. (2) Under Desired Conditions include the following additional 

language in the fourth paragraph (underlined): Improvements to enhance recreation opportunities may 

include parking areas and informational, interpretive, motorized trail construction, motorized trail 

development, motorized trail maintenance, and directional signs, but improvements are minimal. (3) 

Update Standard 2 to state that there is an exception for over-the-snow vehicles.

Response

Management area 3.5 is being subdivided into motorized and non-motorized areas to clarify what areas 

allow motorized activity and what areas do not allow motorized areas. The associated plan direction will 

be clarified.

Public Concern #897

The Forest Service should change the theme of MA 3.5 to emphasis a desire to restore impaired forest 

elements and processes so that natural processes from herein out dominate. Additional goals should be 

added to promote aquatic connectivity, diminish fragmentation by obliterating unneeded roads and 

tracks, remove invasive species and enable natural processes including those at the landscape scale such 

as fire, floods, and predation.

Response

The decision maker will consider the public comments requesting additional management goals. 

Management area 3.5 is being subdivided into motorized and non-motorized areas so that it is clear what 

areas allow motorized activity and what areas do not allow motorized areas. The associated plan direction 

will be clarified.

See also responses to PCs #95 and #96.
Shoshone National Forest Land Management Plan Revision

734

Subject: 431 - Management Area 3.5 – Back Country Recreation and Forest 

Restoration – Desired condition

Public Concern #96

The Forest Service should consider making the following changes to 3.5 Desired Conditions: 1-

increasing the acreage of Management Area 3.5 to be consistent with the need for additional ecosystem 

restoration, 2-add in red “Improvements to enhance recreation opportunities may include parking areas 

and informational, interpretive, motorized trail construction, motorized trail development, motorized trail 

maintenance, and directional signs, but improvements are minimal.”

Response

The decision maker will consider the public comments requesting additional acres of management area 

3.5 in addition to other public comments in making the final decision. Restoration activities can also be 

conducted in back country management areas 3.3A, 3.3B, and 3.3C. See PC #95.

Subject: 434 - Management Area 3.5 – Back Country Recreation and Forest 

Restoration - Standards

Public Concern #97

The Forest Service should consider making the following changes to 3.5 Standards: 1- define motorized 

trail info in red; 2- Prohibit new System road construction or existing road reconstruction unless needed 

to honor existing rights; 3- Allows new system motorized trail construction, development, and existing 

trail reconstruction.

Response

See response to PC #95. The suitable uses section and the inventoried roadless section include the 

direction on roads for inventoried roadless areas, which includes the portions that are management area 

3.5.

Subject: 437 - Management Area 3.5 – Back Country Recreation and Forest 

Restoration – Management approach

Public Concern #98

The Forest Service should consider splitting 3.5 into two groups, 3.5a for vegetation treatment and 3.5b 

for motorized use since they are two very different concepts and to better benefit users and wildlife.

Response

The modified preferred plan will include direction that clearly shows where motorized activity is allowed 

in MA 3.5 and where it is not.

Public Concern #99

The Forest Service should consider making all of Rattlesnake Mountain and Carter Mountain M.A. 3.5 to 

allow for snowmobile use in winter, additionally change trails Jack Creek, Deer Creek, Trail Creek, 

Timber Creek, Phelps Mountain, trails 602, 603, 605, 626, and 627 in sunlight basin and Kirwin areas 

due to historical nature and to make a good network for ATV use.
Final Environmental Impact Statement -- Appendix A

735

Response

Alternatives A and F open both these areas to motorized recreation. The decision maker will consider the 

public comments requesting more of these acres in addition to other public comments in making the final 

decision.

Public Concern #100

The Forest Service should consider need for lower short-term visual conditions in order to increase 

ecosystem resiliency and forest health.

Response

The plan contains a guideline in the scenery section that allows for temporary reductions in scenery to 

meet plan goals and objectives.

Public Concern #101

The Forest Service should consider to specifically stating how MA 3.5 active management projects would 

be conducted especially in the following areas: Sunlight Crandall area, Carter Mountain area, Franc’s 

Peak and Wood River IRAs, Ramshorn Lakes/Amoretti Park area, Wolf Creek Trailhead, Bonneville Pass, 

East Fork Area, and the Shoshone Lake/Cyclone Pass/Pete’s Lake area.

Response

See responses to PCs #98 and #94

Subject: 438 - Management Area 3.5 – Back Country Recreation and Forest 

Restoration – More of this

Public Concern #102

The Forest Service should considering increasing the acres of Management Area 3.5 in Alterative B, 

which would result in more acres in the semi-primitive, motorized ROS Class.

Response

Alternatives E and F both have more acres of semi-primitive motorized recreation opportunity spectrum 

(ROS) acres. The decision maker will consider the public comments requesting more of these acres in 

addition to other public comments in making the final decision.

Subject: 439 - Management Area 3.5 – Back Country Recreation and Forest 

Restoration – Less of this

Public Concern #103

The Forest Service should consider changing Gravelbar from 3.5 to 1.3 since ATV’s can already get close 

enough for vegetation treatment from Sunlight Creek and keep the Gravelbar area from getting impacts to 

wildlife and solitude.

Response

Alternatives C and D allocate the Gravelbar area to MA 1.3. The decision maker will consider that 

allocation along with allocations requested by other public comments in making the final decision.

Public Concern #104

The Forest Service should consider deleting M.A. 3.5 since forest should not open up backcountry to 

motorized recreation use.
Shoshone National Forest Land Management Plan Revision

736

Response

Alternative C provided an alternative that prohibited motorized activity in back country areas (inventoried 

roadless areas). The decision maker will consider this option along with other public comments that want 

motorized opportunity in roadless areas in making a final decision.

Subject: 450 - Management Area 3.6A – Continental Divide National Scenic 

Trail - General

Public Concern #76

The Forest Service should consider the following: 1- North of Brooks Lake motorized winter use must 

conform to paragraph IV.B.6b (6) of the Comprehensive Plan; 2- Brooks Lake through U.S. 26/287 

corridor motorized vehicle use must conform to paragraph IV.B.6b of the Comprehensive Plan; 3-

Sheridan Pass to Leeds Creek motorized winter use must conform to paragraph IV.B.6b of the 

Comprehensive Plan; 4- Brooks Lake to U.S. 26/287 Corridor neither motorized nor mechanical (bicycle) 

use should be authorized at any time; 5- Pelham Lake to Sheridan Pass motorized winter use must 

conform to paragraph IV.B.6b(6) of the Comprehensive Plan;.

Response

Winter motorized use and bicycle use on the Continental Divide National Scenic Trail (CDNST) is 

consistent with the 2009 Comprehensive Management Plan. Snowmobile use is allowed on the CDNST 

where it is consistent with the applicable land management plan; is allowed in accordance with 36 CFR 

Part 212, Subpart C, on National Forest System lands or is allowed on public lands; and the use will not 

substantially interfere with the nature and purposes of the CDNST. Bicycle use is also allowed on the 

CDNST (16 U.S.C. 1246c) if the use is consistent with the applicable land and resource management plan 

and will not substantially interfere with the nature and purposes of the CDNST. The nature and purposes 

of the CDNST are to provide for high-quality scenic, primitive hiking and horseback riding opportunities 

and to conserve natural, historic, and cultural resources along the CDNST corridor. Both limited winter 

snowmobile use and mechanical (bicycle) use do not interfere with this nature and purpose.

Public Concern #105

The Forest Service should make the following changes to the Forest Plan and DEIS: (1) On page 120 of 

the Plan under Management Area acres, identify the acres associated with MA 3.6A and 3.6B (2) On page 

475 of the DEIS, Executive Order 13195 is not listed, add Executive Order 13195.95. (3) On page 476 of 

the DEIS, list the Continental Divide National Scenic Trail (CDNST) Comprehensive Plan as an Other 

Authority (FSM 2353.01d). (4) The Forest needs to follow the direction in the 2009 CDNST 

Comprehensive Plan Chapter III and FSM 2353.42 and 2353.44(b) Part 1 to provide for the management 

and development of the CDNST. (5) On Page 480 of the DEIS, FSM 2353.44 references need to be 

completed. (6) On Page 496 of the DEIS, effects need to be disclosed for other potential CDNST MA 

corridors. (7) The proposed CDNST MA 3.6 MA directions do not provide for the nature and purposes of 

the CDNST and needs to be modified. (8) On page 506 of the DEIS, a Supplemental Plan and DEIS may 

be need to be completed in order to address cumulative effects based on MA 3.6A direction. (9) The 

Forest should address the needs for volunteer work on the CDNST in the Forest Plan. (10) Forest Service 

should address the discrepancy displayed in Table 23 on page 126 and the standard and guidelines for the 

management area and should consider removing “may be restricted in big game crucial winter range 

because over-the-snow vehicles are an exception in crucial winter range” (11) The Forest Service should 

address the last paragraph of the affected environment section for the CDNST (page 480) and consider 

changing it to “The management area emphasis for the CDNST corridor will determine the appropriate 

scenery objective and recreation opportunity spectrum class. Therefore alternatives will be analyzed 

using the Scenery Management and Recreation Opportunity Spectrum systems”. (12) The Forest Service 
Final Environmental Impact Statement -- Appendix A

737

should consider addressing the CDNST on Page 558 under scenery resources similar to the discussion 

provided for scenic byways because scenery is not adequately addressed.

Response

(1) A map of the CDNST and Nez Perce corridors will be included in the plan.

(2) Executive order 13195 which furthers the purposes of the National Trails System Act of 1968, as 

amended (16 U.S.C. 1241−1251), the Transportation Equity Act for the 21st Century (Public Law 

105-178), and other pertinent statutes, to achieve the common goal of better establishing and 

operating America's national system of trails will be added to the DEIS.

(3) The CDNST Comprehensive Plan will be added to the recreation regulation and policies section of 

DEIS.

(4) The management area direction, standards, and guidelines in the plan comply with both the 2009 

CDNST Comprehensive Management Plan and FSM 2353.42 and 2353.44(b) Part 1.

(5) FSM 2353.44 does not need to be added as the overarching FSM 2300 is referenced which includes 

2353.44.

(6) Analysis of the potential re-routes of the CDNST is a site-specific analysis that is not appropriate for 

this revised forest plan analysis. If these potential re-routes move forward a site-specific analysis will 

be done to analyze the effects of the new corridor.

(7) The MA 3.6A plan direction through appropriate standards and guidelines, desired condition, and the 

management approach does provide for the nature and purposes of the CDNST which is to provide 

for high-quality scenic, primitive hiking and horseback riding opportunities and to conserve natural, 

historic, and cultural resources along the CDNST corridor.

(8) The cumulative effects for the CDNST are addressed in the DEIS recreation section. If any potential 

re-routes are moved forward, then they will be analyzed site-specifically at that time, and if needed, 

the plan would then be amended to incorporate MA 3.6A direction to a new corridor.

(9) The need for volunteers on the CDNST is outside of the scope of the revised Forest Plan analysis. The 

Forest will continue to work with partnerships and volunteer opportuntiies as they arise.

(10) See response to PC #130.

(11) The last section of the affected environment is appropriately worded as “The management area 

emphasis of each of the alternatives may have effects to the Scenery Management System as well as 

the Recreation Opportunity Spectrum class that may affect the CDNST.”

(12) The desired condition for scenery is addressed for the CDNST by identifying that the desired 

Scenic Integrity Objective (SIO) is high to very high depending on the trail segment. The alternatives 

were then analyzed based on the acres of MA 3.6A within the corridor that met a high to very high 

SIO. These ranged from alternative C which had the most acres in high and very high at 50 percent to 

alternative E which had the least acres in high and very high at 24 percent.

Public Concern #106

The Forest Service should create a Continental Divide National Scenic Trail corridor from Sheridan Pass 

to Brooks Lake and coordinate with the Bridger-Teton National Forest for potential effects towards forest 

management as portions of the route may be located on the Bridger-Teton. The Management Area should 

be located close to the following points: Sheridan Pass, Lava Mountain, Two Ocean Mountain, Togwotee 

Pass, and Brooks Lake with the boundary following the topographic features to the extent possible while 

being at least one- half mile wide on each side of the CDNST travel route. The Forest Service should 

consider managing the corridor under goals and standards set out in MA 3.6 prescription. The Forest 

Service should consider revising the plan to describe the management area and should map the area and 

provide trail prescriptions such as trail class and managed uses.
Shoshone National Forest Land Management Plan Revision

738

Response

The revised Forest Plan establishes a corridor within 0.50 mile of the centerline of the existing trail 

location. This corridor is set aside and described as MA 3.6A.

Public Concern #107

The Forest Service should manage the Continental Divide National Scenic Trail (CDNST) in accordance 

to the National Trails System Act and the CDNST Comprehensive plan and the prescriptions for National 

Scenic and Historic Trails are appropriately found Page 118 Management Area Category 3.

Response

The management area direction, standards, and guidelines in the plan comply with both the 2009 CDNST 

Comprehensive Management Plan and the National Trails System Act.

Public Concern #108

The Forest Service should adhere to Standard 4 under Recreation and to ensure that sections of the 

Continental Divide National Scenic Trail do not follow improvements to motorized trails.

Response

Standard #4 states that “Existing snowmobile use is allowed. New sections of the Trail will not be located 

coincidently with snowmobile trails.”

Public Concern #109

The Forest Service should consider revising Map 41 to address the discrepancy of not being identified as 

MA 3.6 on any of the alternative maps included on the DEIS and because the alternative maps should 

include all of the locations drawn on Map 41.

Response

A map will be added that shows where there the 3.6A management direction will apply. 

Public Concern #110

The Forest Service should consider adopting management strategies that encourage non- motorized 

winter recreation in the CDNST to include Togwotee Pass.

Response

The management direction in MA 3.6A that allows existing snowmobile use to continue on the CDNST 

will continue. The decision maker will consider the public comments in making the final decision.

Public Concern #124

The Forest Service should review all provisions for roads and trails to ensure consistency with Forest 

Service Manual (FSM) 2353.44b and the Comprehensive Plan (IV.B.5.c). Motor vehicles by the general 

public should also be prohibited on the Continental Divide National Scenic Trail in every ROS category 

unless an exception applies.

Response

See responses to PC #111 and #118 item (7)

Public Concern #267

The Forest Service should make a change on Page 47 of the DEIS that erroneously identifies that 

prescribing a non-motorized Continental Divide National Scenic Trail (CDNST) corridor as being outside 
Final Environmental Impact Statement -- Appendix A

739

the scope of the DEIS. The Forest should follow the 2009 CDNST Comprehensive Plan Chapter III and 

Forest Service Manual 2353.42 and 2353.44(b) for establishing a Management Area for the CDNST.

Response

As noted on EIS pages 47 through 48, existing motorized segments will require site-specific analysis 

before any changes are made. Changes to the CDNST are considered site-specific projects and will be 

addressed in project planning. See also response to PC #76 regarding management of the Continental 

Divide National Scenic Trail.

Subject: 451 - Management Area 3.6A – Continental Divide National Scenic 

Trail - Desired Condition

Public Concern #111

The Forest Service should make the following changes to the plan: (1) Further examination of the 

“compatible” non-motorized recreational opportunities along the Continental Divide National Scenic 

Trail (CDNST), especially areas of the trail that are open for bicycles and motorized vehicles. (2) On 

page 128 of the DEIS, the direction for roads and trails suitable uses should be modified to the direction 

found in FSM 2353.44b parts 10 and 11. (3) The Shoshone Plan needs to follow the 2009 CDNST 

Comprehensive Plan Chapter III and FSM 2353.42 and 2353.44(b) part 1 instead of the 1998 EA.

Response

(1) The plan allows both bicycle and motorized use where consistent with the Comprehensive 

Management Plan and where these uses do not interfere with the nature and purposes of the CDNST. 

A decision to restrict these uses if they become inconsistent would be a site-specific analysis.

(2) The plan is consistent with both the Comprehensive Management Plan and FSM 2353.44b parts 10 

and 11. Motorized use by the general public is generally prohibited unless that use is consistent with 

the applicable land management plan and is designated in accordance with 36 CFR part 212, Subpart 

B and the vehicle class and use we allowed on that segment of the CDNST was constructed as a road 

prior to November 10, 1978. Bicycle use is also allowed where consistent with the Comprehensive 

Management Plan and where these uses do not interfere with the nature and purposes of the CDNST.

(3) The plan is consistent with the CDNST Comprehensive Management Plan and FSM 2353.44b as 

indicated in responses to PCs #105 through #110.

Public Concern #112

The Forest Service should provide high-quality scenic, primitive hiking and horseback riding 

opportunities and to conserve natural, historic, and cultural resources along the Continental Divide 

National Scenic Trail (CDNST) corridor with a minimum width of 0.05 mile on either side of the CDNST. 

Management should be consistent with primitive or semi-primitive non- motorized Recreation 

Opportunity Spectrum class. Low intensity vegetation management should be utilized to maintain long 

term goals and stewardship objectives of the CDNST corridor.

Response

The desired condition of MA 3.6A CDNST is the same as requested and does include a corridor 0.50 mile 

from centerline of the trail. Guideline #2 indicates managing for the ROS class of the management area in 

which the trail occurs. Standard #5 requires, where possible, that new or relocated sections be in an ROS 

class of primitive or semi-primitive non-motorized. Vegetation management is covered under guideline #1 

which allows cutting or removal of trees under circumstances to reduce fuel loads and fire risk, curtailing 

insect attack, salvaging dead trees to enhance scenic views, or maintaining wildlife habitat diversity.
Shoshone National Forest Land Management Plan Revision

740

Subject: 452 - Management Area 3.6A – Continental Divide National Scenic 

Trail - Goals

Public Concern #113

The Forest Service should make the following changes to the Forest Plan: (1) Objectives for the CDNST 

in the Goals for Management Area 3.6A (p 173) should read As revised, it should read: “Provide highquality scenic, primitive hiking, and horseback riding opportunities and conserve natural, historic, and 

cultural resources along the Trail corridor,” to acknowledge the historical and cultural resources that 

should be considered in unit planning. (2) Remove the last five words of the Proposed Goal 2 for 

Management Area 3.6, “relocate the Trail off motorized routes as time and resources allow,” since the 

entirety of the trail will eventually be off of roads for its entire length, so the goal of the Trail being off 

motorized route is clear. (3) On page 17, Continental Divide National Scenic Trail the following quote 

should be added, “The nature and purposes of the CDNST are to provide for high-quality scenic, 

primitive hiking and horseback riding opportunities and to conserve natural, historic, and cultural 

resources along the CDNST corridor,” as directed in the Comprehensive Plan and FSM 2353.42. (4) On 

page 174, Recreation Goal 2 should provide for the nature and purposes of the CDNST by implementing 

the direction in the 2009 CSNST Comprehensive Plan Chapter III and FSM 2353.42 and 2353.44(b) part 

1.

Response

(1) And to conserve natural, historic, and cultural resources will be added to Goal #1.

(2) We will delete “as time and resources allow” from Goal #2.

(3) Statement was changed to match MA 3.6A Goal #1.

(4) Standard #5 (second one under recreation) states “Where possible, new or relocated sections of the 

Trail will be located within areas mapped with an ROS setting of primitive or semi-primitive nonmotorized.” This is in line with section IV.B.1b.1 of the 2009 Comprehensive Plan.

Public Concern #114

The Forest Service should allow volunteer crews the opportunity to complete and maintain work needed 

on the Continental Divide National Scenic Trail.

Response

See response to PC #105 item 9.

Subject: 453 - Management Area 3.6A – Continental Divide National Scenic 

Trail - Objectives

Public Concern #115

The Forest Service should make corrections to the Scenic Integrity Objectives as needed on Tables 140 

and 141 since they are not consistent with the narrative on page 495. On Page 173, The Forest Service 

should consider revising the objectives to very high to moderate without being tied to ROS classifications 

because the Recreation Opportunity Spectrum areas do not seem to be a part of the management area 

allocations.

Response

We will correct errors in this section between text and info in tables 140 and 141. The tie of the SIO to the 

ROS is not necessary and was dropped. The range for the SIO was changed from very high to high to be 

consistent with the national direction for the CDNST.
Final Environmental Impact Statement -- Appendix A

741

Public Concern #116

The Forest Service should complete the Continental Divide National Scenic Trail travel route through the 

MA.

Response

A trail route currently exists through the MA and was established in 1998. Any site-specific reroutes of 

specific sections would be analyzed in separate future efforts.

Subject: 454 - Management Area 3.6A – Continental Divide National Scenic 

Trail - Standards

Public Concern #117

The Forest Service should make the following changes in the Forest Plan: (1) On page 173, Standards 

need to be established that support the goals of the Continental Divide National Scenic Trail (CDNST). 

(2) On page 173, the Recreation Standards should address the direction in FSM 2353.44(b)(1) as they are 

currently inconsistent with the Comprehensive Plan and Policy. (3) If the standard for snowmobile use 

conforms to FSM 2353.44b, then the restriction regarding colocation of the Trail with snowmobiles can 

be deleted.

Response

(1) Six standards and four guidelines have been established for the CDNST that support the goals of the 

CDNST. The recreation standards and guidelines do address direction in FSM 2353.44(b)(1) and are 

not inconsistent with the Comprehensive Plan or Policy. 

 While the standard for snowmobile use conforms to FSM 2353.44b it is our desire that the two uses 

be separated to prevent future conflicts hence the direction not to collocate future trails locations with 

snowmobile trails.

Public Concern #118

The Continental Divide National Scenic Trail (CDNST) is a Concern Level 1 Travelway and needs to be 

managed as follows: (1) Ensuring that all management activities meet the Scenic Integrity Objective of 

High or Very High. (2) Recreation Manage for the ROS Class of Primitive and Semi-Primitive NonMotorized, except motor vehicle use is allowed if such use is in accordance with the CDNST 

Comprehensive Plan direction (Chapter IV.6). (3) Permits for Special Uses Activities will not be 

authorized unless the activity contributes to the nature and purposes of the CDNST. (4) Reconstruction 

and maintenance of the CDNST travel route will be designated Trail Class 3, pack and saddle stock with 

no new system road construction or reconstruction unless there is a valid existing right. (5) There should 

be no surface occupancy for mineral leases, no permit issuance for the removal of mineral materials, and 

there should be a consideration for withdrawals for areas with locatable mineral findings. (6) The Forest 

Service should not move the Continental Divide National Scenic Trail off of existing motorized routes as 

addressed in Standard 6 unless the new location offers equivalent or superior scenic, historic, natural, or 

cultural values. Standard 6 should be re-written as “If motorized use that has been allowed becomes 

incompatible with management of the Trail, the conflict will be resolved after consideration of 

alternatives in a site-specific planning process.” (7) The provision in Table 26 that would allow new 

primitive roads in a semi-primitive motorized portion of MA 3.6 should be removed as it conflicts with 

Section 7 of the NTSA prohibiting the use of motorized vehicles on post-1978 roads by the general public. 

(8) Enhance the CDNST environment, fish and wildlife habitat improvements are allowed along with 

vegetation management activities that should enhance the scenic quality, meet trail construction and 

maintenance needs, and manage fuels through timber harvest, prescribed burning, and wildland fire 

activities. (9) The management area is classified as unsuitable for timber production and hauling or 
Shoshone National Forest Land Management Plan Revision

742

skidding along the CDNST route is prohibited along with the creation of landings or temporary roads. 

(10) Wildland fire management should consist of suppression strategies that minimize impact on CDNST 

values with no heavy equipment line construction on the CDNST allowed with restorative measures 

prescribed after fire suppression or fire use projects are completed. (11) The CDNST should be well 

identified with standard signs and markers and located and maintain developed campsites and privies 

where there is a need for overnight use and facilities are needed to protect Forest resources and 

ecological health. (12) The degree of contrast for management actions must range from none to weak in 

the foreground and from none to moderate in the middleground and background.

Response

(1) Direction in the revised Forest Plan for the scenic integrity objective (SIO) is to manage for high to 

very high in primitive to semi primitive ROS classes and moderate to high in roaded natural ROS 

classes. The decision maker will consider adjusting in an alternative for the final decision.

(2) Direction in the revised Forest Plan is to manage for the ROS the trail route that currently falls in with 

a standard included that requires new or relocated trail sections to be in primitive or semi-primitive.

(3) Special uses will be permitted unless they conflict with the nature and purpose of the trail, but will not 

have to contribute to the nature and purpose.

(4) The goal of this management area is to provide high-quality hiking and horseback opportunities. 

Reconstruction or maintenance of a CDNST travel route will not change the designated existing trail 

class. Road construction or reconstruction is controlled by the most restrictive direction of either the 

MA 3.6A or if more restrictive, the management area that the 3.6A corridor crosses.

(5) A standard will be added addressing surface occupancy in MA 3.6A.

(6) Relocated portions of the CDNST would have to make sure they met the nature and purpose. 

Relocation of the trail would require a site-specific analysis of the effects to the CDNST.

(7) The Comprehensive Plan direction cited limits motorized use of the CDNST to pre-1978 roads, but 

allows roads in semi-primitive to cross the CDNST at intervals of no more than 0.5 mile, which is the 

standard included in the revised Forest Plan.

(8) We agree with this statement.

(9) Hauling and skidding are not a forest plan-level decision, but identifying lands suitable and unsuitable 

for timber production is. Any vegetation management proposal would go through site-specific 

analysis where hauling and skidding along the route would be addressed.

(10) A guideline will be added to address fire management activities along the CDNST.

(11) Signing direction is present in guideline #3 under recreation.

(12) Visual quality specifics are not addressed in forest planning, but are part of the specific SIO (high, 

very high, etc.) which is part of the plan direction.

Public Concern #119

The Forest Service should adhere to Standard 4 under Recreation and to ensure that sections of the 

Continental Divide National Scenic Trail do not follow improvements to motorized trails

Response

Discussion in the management approach addresses the issue of the location of CDNST and motorized 

routes.
Final Environmental Impact Statement -- Appendix A

743

Public Concern #120

The Forest Service should have the DRMP’s standards for competitive events, non-motorized outfitter and 

guide activities, and over-snow winter activities be re-written to say: “Allow [activities] only if they do 

not interfere with the nature and purposes of the Trail.”

Response

Suggestion was considered. We will retain our current wording as we think it better reflects our intent.

Subject: 455 - Management Area 3.6A – Continental Divide National Scenic 

Trail- Guidelines

Public Concern #121

The Forest Service should make the following changes to the Forest Plan: (1) In the first guideline of 

Management Area 3.6A, after authorization for cutting or removal of trees are given, “after 

environmental review” should be added to the guideline. (2) Guideline 2 should be revised to eliminate an 

ambiguity with respect to which management area is intended, the word “management” should be deleted 

in this guideline. (3) On page 174, Guideline 4 should reflect the direction in the Continental Divide 

National Scenic Trail (CDNST) and FSM 2353.42 and 2353.44(b) part 1.

Response

(1) Cutting or removal of trees in the case of this guideline would always require a site-specific analysis 

as part of the authorization process, so additional wording is not needed.

(2) There is no ambiguity in guideline number 2. As stated in the guideline that section of the CDNST 

will be managed for the ROS class of the management area the corridor crosses.

(3) Guideline 4 in conjunction with standard 5 reflects direction in the Comprehensive Plan and Policy.

Public Concern #122

The Forest Service should allow vegetation to be altered to enhance recreational opportunities, provide 

scenic vistas, conserve natural historic and cultural resources, and to maintain or improve endangered, 

threatened, and sensitive species habitats.

Response

Guideline 1 under vegetation provides direction when vegetative management could occur. 

Public Concern #123

The Forest Service should consider withdrawals for areas with a history of locatable mineral findings, 

allow commercial livestock and implement Best Management Practices for their management, and should 

allow partners and volunteers to assist in Continental Divide National Scenic Trail programs.

Response

For minerals see response to PC #118 item (5). Grazing is allowed is MA 3.6A and would follow the 

guidelines and standards under the grazing section of the plan. See PC #105 item (9) regarding volunteers.
Shoshone National Forest Land Management Plan Revision

744

Subject: 457 - Management Area 3.6A – Continental Divide National Scenic 

Trail - Management Approach

Public Concern #125

The Forest Service should consult with the Bridger-Teton National Forest during the planning process as 

some segments may best be located west of the Continental Divide.

Response

Relocation of the CDNST to a specific location is a site-specific analysis during which coordination and 

consultation with affected units would occur.

Public Concern #126

The Forest Service should make protection of the land resource the primary consideration in establishing 

and maintaining the trail to provide hikers and riders a high quality recreation experience along the 

Continental Dive while maintaining a constant respect for the natural environment. Partners and 

volunteers should be involved and contribute to the CDNST with a CDNST Unit Plan being completed 

within five years.

Response

The primary purpose of establishing and maintaining the CDNST comes from the Comprehensive Plan 

and enabling legislation, which states that the nature and purpose of the CDNST is to provide for highquality scenic, primitive hiking and horseback riding opportunities, and to conserve natural, historic, and 

cultural resources along the CDNST corridor. See response to PC #105 item (9) regarding volunteers.

Public Concern #127

The Forest Service should make the following changes to the DEIS: (1) A supplemental DEIS should be 

created to analyze all the potential corridor routes on Map 41 and disclose the effects of revised MA 3.6A 

direction on other resources. (2) On page 495, potential effects to Scenic Integrity and identified 

Recreation Opportunity Spectrum class effects for all of the CDNST MA corridors should be provided. (3) 

A Supplemental Draft Plan and supplemental DEIS should be issued to identify cumulative effects based 

on MA 3.6A directions that is consistent with the National Trails System Act.

Response

See response to PC #105 item (6).

Public Concern #128

The Forest Service should narrow the provision to trail relocation under Management Approach to only 

trails relocated due to conflict versus any CDNST corridor which is relocated and should be applied to 

only trails developed directly by CDNST management activities or funding. The Forest should also revise 

the statement of management uses so that the measurement is related to visual quality or scenic quality 

experiences versus to non-motorized experiences within a half mile of the trail.

Response

The intent of the discussion of incompatible uses under the management approach is to cover the broad 

span. Narrow the scope to just trail reconstruction would not meet our intent. A non-motorized experience 

is a significant part of the nature and purpose of the CDNST, and thus, should continue to be listed in the 

first sentence of the management approach.
Final Environmental Impact Statement -- Appendix A

745

Subject: 460 - Management Area 3.6A – Continental Divide National Scenic 

Trail - Monitoring

Public Concern #129

The Forest Service should ensure that the land management plan also “establish a monitoring program to 

evaluate the condition of the CDNST in the management area.” Forest Service Manual (FSM) 2353.44b 

1.c.

Response

Required monitoring of the CDNST will be added to the revised Forest Plan.

Subject: 470 - Management Area 3.6B – Nez Perce (Nee-Me-Poo) National 

Historic Trail - General

Public Concern #130

The Forest Service should update Table 23 on page 126 since the table contents for over- snow motorized 

vehicles are different than the standards and guidelines for Management Area 3.6B. The Forest should 

specifically remove the “may be restricted in big game crucial range” text because over-the-snow 

vehicles are an exception in crucial winter range.

Response

Table 23 was reviewed with the standard and guideline for MA 3.6B. This management area includes a 

corridor 0.50 mile from centerline. Over-snow and snowmobile use is allowed in this management area 

unless it overlaps with crucial winter range, where it may be restricted. The decision maker will consider 

the public comments in making the final decision.

Subject: 490 - Management Area 4.2 – Scenic Byways, Scenic Areas, 

Vistas, and Travel - General

Public Concern #131

The Forest Service should consider adding the following verbiage to the Theme and Setting description in 

this section, “These corridors allow the Forest to address the fastest growing use on the SNF; which is 

OHV use. Increased OHV use coupled with the very popular use of site seeing and driving for pleasure 

make it vital that existing travel corridors, both road and trail, remain open for travel management. These 

corridors will also reduce conflicts and improve safety by providing loop trails for OHV users separate 

from vehicles. In addition, travel corridors reduce the number of unauthorized user made trails which are 

often used to reestablish an old existing loop route.” Clarification should also be added to the paragraph 

on the bottom of page 180 to say, “In addition to the eight travel corridors mentioned above, four other 

travel routes...”

Response

Motorized use is clearly identified as a suitable use for this management area. These travel corridors are 

open and used by a wide variety of different modes of travel and one specific mode should not be singled 

out or highlighted over any other mode. Commenter misread the presentation. There are eight travel 

corridors. Four are scenic byways and four are other travel routes.

Public Concern #132

The Forest Service should consider making the following revisions to this section: (1) make motorized 

vehicle use conform to Paragraph IV B.6Bb of the Comprehensive plan for Brooks Lake through 
Shoshone National Forest Land Management Plan Revision

746

US26/287 corridor; (2) ensure that travel corridors listed in Alternative A are maintained at or above 

current levels; and (3) treat the Cody to East Gate corridor separately in this Plan as it is important as a 

buffer to the park and possessed many scenic qualities.

Response

(1) Where MA 4.2 and the CDNST overlap in the Brooks Lake through US 26/287 corridor the MA with 

the most restrictive requirements rules thus management in this overlap would conform to the 

Comprehensive Management Plan for the CDNST. 

(2) Alternative A did not have specific travel corridors like proposed in the new plan. Alternative A had 

larger areas emphasizing rural and roaded natural recreation opportunity spectrum settings where as 

all the other alternatives have the new MA 4.2 which focuses on scenic and recreational opportunities. 

(3) The Cody to the East Gate corridor has many scenic qualities and is a scenic byway included in MA 

4.2 along with our other byways and major scenic travel routes.

Subject: 510 - Management Area 4.3 – Back Country Access Corridor -

General

Public Concern #133

The Forest Service should designate the Clay Butte Area as Management Area 1.3 Back Country NonMotorized because of the important recreational and scenic values of the Clay Butte area and should 

classify the portion of Forest Road 142 passing through the area and leading to the Clay Butte Lookout as 

"4.3-Back Country Access Road."

Response

Back country motorized MA 1.3 acres range from the most in alternative A to the least in alternative C. 

Back country access corridors range from the most in alternative B to the least in alternative F. The 

deciding officer will consider the various options along with other comments during the decision process.

Subject: 517 - Management Area 4.3 – Back Country Access Corridor -

Management Approach

Public Concern #134

The Forest Service should classify the Morrison Road within the Proposed Sawtooth Peatbed Special 

Interest Area as Management Area 4.3 – Back Country Access Corridor and the area immediately north 

and east of the road as Management Area 3.3B – Back Country Winter Motorized.

Response

The boundary of MA 3.1C the Sawtooth Peatbed Special Interest Area has been adjusted to conform to 

the Morrison Jeep Trail on the northeast in alternative G. The area adjusted out of MA 3.1C was 

designated 3.3B.

Public Concern #135

The Forest Service should change the designation of the Morrison Jeep Trails 119 and 120 to MA 4.3 to 

ensure that access is preserved f or future generations.

Response

The Morrison Jeep Trail is designated as a 4.3 management area
Final Environmental Impact Statement -- Appendix A

747

Public Concern #136

The Forest Service should change the designation of Historical Trails 602, 603, 605, 626, and 627 to MA 

3.5 or MA 3.3C on Map L. to ensure access for future generations.

Response

Within the Grizzly Bear Primary Conservation Area (PCA), generally management areas 3.A, 3.3C, 3.5A, 

and 3.5C are not used. The plan does not encourage the expansion of motorized use within the PCA, 

because of the existing secure habitat direction.

Subject: 530 - Management Area 4.5A – Proposed Kirwin Historical Area -

General

Public Concern #137

The Forest Service should make the Kirwin Historical Area as a new special interest area because of its 

protection of plant and animal communities and keep the place difficult to access for the general public.

Response

In the various alternatives, two options for the Kirwin area were analyzed. Alternatives B, C, D, and E 

would designate Kirwin as a special interest area. Alternatives A and F would not. The deciding officer 

will consider the various options along with other comments during the decision process.

Subject: 538 - Management Area 4.5A – Proposed Kirwin Historical Area 

More of area

Public Concern #138

The Forest Service should make the Kirwin Historical Area as a new special interest area and increase its 

size and merge with the Double D Ranch because of its because of its historical and educational 

potential, preserving use for future generations. Designation as a special interest area will also increase 

tourism and contribute to the local economy.

Response

In the various alternatives, two options for the Kirwin area were analyzed. Alternatives B, C, D, and E 

would designate Kirwin as a special interest area. Alternatives A and F would not. The deciding officer 

will consider the various options along with other comments during the decision process. Adjustments to 

the Kirwin Management Area and Double D Ranch were looked at and made between draft and final.

Subject: 550 - Management Area 5.1 – Managed Forests and Rangelands -

General

Public Concern #139

The Forest Service should consider how this management area increases the risk of disturbance 

vulnerability from insects, fire, and a changing climate.

Response

The DEIS discusses the risk to the forest from insects, fire, and a changing climate. It also displays to the 

degree that there is an effect how management area allocations impact that risk. MA 5.1 is allocated from 

approximately 3 percent of the forest in alternative C to 22 percent in alternative F and approximately to 7 

percent of the forest in the preferred alternative.
Shoshone National Forest Land Management Plan Revision

748

Public Concern #140

The Forest Service should consider taking the following information from the current forest plan and 

including it in the new plan: (1) “Production and utilization of large round wood of a size and quality 

suitable for saw timber.” (2) “Apply intermediate treatments to maintain growing stock level standards.” 

(3) Written direction that emphasized cultural treatments such as precommercial thinning.

Response

Wood fiber is included in the theme, because it represents a broader array of forest products than 

sawtimber. This responds to other commenters who wanted a broader reference. The desired conditions 

for MA 5.1 reference sawtimber as a specific product. The plan direction indicates the desired conditions 

that are wanted and the stocking and volume guidance is based upon the use of precommercial treatments. 

The plan does not direct specific methods. The management approach will be edited to include language 

indicating timber stand improvement treatments are used.

Subject: 551 - Management Area 5.1 – Managed Forests and Rangelands -

Desired condition

Public Concern #141

The Forest Service should consider modifying the desired conditions to say, “Age class diversity is evenly 

distributed across age classes up to rotation length.” The comparison to age class diversity on 

“unmanaged areas” should be deleted, as it is speculative.

Response

We reworded the sentence to improve clarity.

Subject: 558 - Management Area 5.1 – Managed Forests and Rangelands -

More of This

Public Concern #142

The Forest Service should consider allocating the most productive acres of the 43,000 substantially 

altered acres to this management area, as well as including Two Ocean Mountain in this management 

area.

Response

Alternatives E and F allocate portions of the 43,000 acres to MA 5.1 and alternatives B, E, and F allocate 

Two Oceans to MA 5.1. The decision maker will consider the public comments requesting more 5.1 in 

addition to other public comments in making the final decision.

Subject: 559 - Management Area 5.1 – Managed Forests and Rangelands -

Less of this

Public Concern #143

The Forest Service should consider not designating the following areas as management area 5.1: (1) 

Pelhand Lake to Trout Lake. This area should have no timber harvesting or new road construction and 

the US 26/287 corridor should be relocated off motorized routes. An alternate corridor could be made 

west of the divide, down Pink Creek and past Moccasin Basin. (2) The CDNST in Salt Creek Basin should 

be restricted to non-motorized use. (3) The Lean-to Creek area, Pole Creek, and upper part of Wayne’s 

Creek. These areas have a significant number of dead trees from the beetles, and the remaining trees 
Final Environmental Impact Statement -- Appendix A

749

provide coverage for elk. This is a prime foot hunting area and is known to be a location of grizzly dens 

and wolf presence.

Response

The final location of the Continental Divide Trail on non-motorized routes will be evaluated after the plan 

decision in a project-specific NEPA document. The decision maker will consider the suitability of the 

existing route and alternative routes and the need for future flexibility in making the final plan decision.

The decision maker will consider comments on how the Pole Creek and surrounding area should be 

managed along with other public comments in making a final decision. The revised Forest Plan does not 

make any decisions on addition of motorized routes in specific areas. It only identifies the general 

suitability of that option. Project-specific decisions that look at site-specific factors will determine if any 

specific additions are made.

Subject: 570 - Management Area 5.2 – Public Water Supply – Water Quality 

Emphasis - General

Public Concern #144

The Forest Service should consider ways to protect water quality by creating a sampling plan that 

includes administrative areas, cabins, resorts, ski areas, etc. and having management actions for ensuring 

these areas are complying with maintaining water quality. The SNF must place highest priority on 

watershed values given that much of the forest is highly erosive volcanic soil.

Response

The forest plan contains direction on protecting water quality, by implementing the Watershed 

Conservation Practices Handbook. The State of Wyoming requires the forest to follow our Watershed 

Conservation Practices Handbook as the agreed upon method for meeting state best management 

practices (BMPs). The forest plan also contains water and soil goals. The monitoring section of the plan 

contains actions to ensure soil and water goals are being protected.

Public Concern #145

The Forest Service should consider developing specific plans to monitor water quality. These plans 

should include an objective for maintaining the Wyoming Stream designations, monitoring the water 

quality as it leaves the forest, conservation district watershed management plans, coordinating the 

monitoring with the State of Wyoming BMP program, and using the BLM's plan to manage watershed 

water quality.

Response

See PC #144.

Public Concern #146

The Forest Service should consider providing an assessment of the potential for organic loading impacts 

to drinking water supplies associated with municipal watersheds for Cody, Wood River, and Lander

Response

This is a site-specific analysis issue and is beyond the scope of the revised Forest Plan analysis.
Shoshone National Forest Land Management Plan Revision

750

Public Concern #895

The Forest Service should include standards and guidelines to minimize ground disturbances and road 

densities, disallow off-road vehicle use as much as possible and stipulate no surface occupancy in 

municipal watersheds, MA 5.2.

Response

Management Area 5.2 is assigned to the municipal watershed for the City of Lander. The management 

area emphasizes the protection of water quality including special direction for the management of fire. 

The City of Lander requested that the area be assigned to a management area that allowed the full array of 

multiple-use activities. Though management area direction allows activities such as timber harvest and 

motorized recreation, it will be conducted in a way that protects water quality.

Subject: 590 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - General

Public Concern #147

The Forest Service should maintain groomed and ungroomed snowmobile trails in existing and new 

wildlife winter range areas.

Response

All alternatives except alternative C maintain existing groomed and ungroomed snowmobile trails in 

wildlife crucial winter range. The decision maker will consider public comment that want that direction 

along with other public comment in making the final decision.

Public Concern #148

The Forest Service should allow snowmobile use, especially around Sinks Canyon and Fairfield Hill, 

during the time when most wildlife are at lower elevations since wildlife will not be disturbed during 

those times. Closures may also limit access to the land we own there.

Response

Alternatives B, E, and F allow snowmobile access in winter range around Sinks Canyon and Farifield 

Hill. The decision maker will consider the public comments that want the access maintained along with 

other public comments that want the access restricted in making the final decision.

Public Concern #149

The Forest Service should consider the effects of climate change on natural resources and Management 

Areas 5.1 and 5.4 since disturbances, particularly from insects and fire, are likely to increase and there is 

a clear risk to these management areas.

Response

The effects of climate change on vegetation management and associated disturbances from insects and 

fire are discussed in the FEIS.

Public Concern #150

The Forest Service should be flexible with oil and gas developments and not implement No Surface 

Occupancy restrictions on all big game winter range because expected levels of development are low and 

mitigations can be developed at the project level.
Final Environmental Impact Statement -- Appendix A

751

Response

Alternatives E and F allocate fewer acres of wildlife winter range to no surface occupancy (NSO) for oil 

and gas development. The decision maker will consider the public comments requesting more and less 

acres of NSO for oil and gas development in addition to other public comments in making the final 

decision.

Public Concern #151

The Forest Service should ensure that No Surface Occupancy stipulation does not preclude exploration 

activities.

Response

The final plan will include direction that clearly differentiates between exploration and development and 

how any plan direction applies to the two activities.

Public Concern #153

The Forest Service should clarify that although the DEIS summary contains the statement "Big game 

crucial winter range will be managed to reduce disturbance from motorized use", the preferred alternative 

allows winter motorized use within big game crucial winter range where the WGFD indicates current use 

levels are not negatively impacting wintering big game.

Response

The revised Forest Plan will contain language cleary indicating that motorized winter use is allowed on 

some crucial winter range where Wyoming Game and Fish Department (WGFD)determines use levels are 

not negatively affecting big game.

Public Concern #154

The Forest Service should establish and protect wildlife by limiting or restricting mineral exploration and 

development and motorized vehicle use and/or establishing No Surface Occupancy stipulations in all 

crucial big game winter range (as mapped by the Wyoming Fish and Game Department) and in 

Inventoried Roadless Areas. In addition to protecting big game and diversity, protection of winter ranges 

provides prey for grizzlies and wolves, viewing and Inventoried Roadless Areas. In addition to protecting 

wildlife, these measures would provide prey for grizzlies and wolves, promote wildlife viewing and 

hunting, jobs for local outfitters and income for local businesses.

Response

Alternatives B, C, and D provide differing restrictions on oil and gas development and motorized 

recreation on crucial winter range and inventoried roadless areas. The decision maker will consider the 

public comments requesting that winter range and roadless areas be allocated to NSO and motorized 

recreation be restricted in addition to other public comments in making the final decision.

Public Concern #155

The Forest Service should strengthen standards and guidelines to protect sensitive wildlife species by 

using measurable standards.

Response

The biological evaluation presents the species conservation measures used to protect sensitive species. 

The interdisciplinary team did an additional review between draft and final to verify that the conservation 

measures are represented within plan direction. During plan implementation each project includes a 

biological evaluation that addresses how conservation measures are addressed for the specific project.
Shoshone National Forest Land Management Plan Revision

752

Public Concern #156

The Forest Service should ensure that possible lynx and wolverine habitats are not harmed by winter 

recreation management restrictions.

Response

The effects of winter motorized recreation on Canada lynx and wolverine are discussed in the EIS pages 

155 through 157 and 192 through 193.

Public Concern #157

The Forest Service should not reclassify the area from Wiggin's Fork/Double Cabin road east to the Wind 

River Indian Reservation Boundary as motorized use because the area contains several extremely 

important big game migration routes in addition to critical winter range. Motorized use in this area 

would result in displacement of big game, declines in herd numbers, disturbances to key wintering and 

migration grounds, loss of hunting opportunities and adverse effects to the local economy.

Response

Alternatives C and D allocate this area to management areas that do not allow motorized activity. The 

decision maker will consider the public comments requesting less area to remain non-motorized in 

addition to other public comments in making the final decision.

Public Concern #158

The Forest Service should ensure that habitat characteristics required by Wyoming's Species of Greatest 

Conservation Need and federally threatened species remain intact by, at a minimum, conducting 

presence/absence surveys during appropriate seasons to ensure timber harvest practices do not 

negatively impact sensitive wildlife species.

Response

To address concerns regarding sensitive species and their habitat, the Draft Forest Plan, developed Goal 1. 

p. 47. In addition, the concern regarding wildlife surveys was addressed under management approach p. 

50 (Draft Forest Plan).

Public Concern #159

The Forest Service should implement best management practices to benefit sensitive wildlife species.

Response

The plan contains direction, including standards and guidelines, to protect sensitive species.

Public Concern #160

The Forest Service should re-write the fifth paragraph on p. 284 to clarify that the big game crucial 

winter range timing stipulations on the Forest is December 1 to April 30.

Response

The draft plan identified for all alternativestiming restriction dates of December 1 to April 30 on big game 

crucial winter range.

Public Concern #161

The Forest Service should change Standard 3, pages 20 and 60 (Management Challenges, Grazing, 

Species of Local Concern) to read “Providing forage to maintain big game herd objectives is a priority in 

the management of crucial winter range used in common by livestock and big game.”
Final Environmental Impact Statement -- Appendix A

753

Response

We reworded the standard to clarify the intent.

Public Concern #162

The Forest Service should add the phrase “within elk herd population objectives” after the word “elk” to 

Conservation Measure 7 (Ch.3 Affected Environment, Species of Local Concern, Rocky Mountain Elk, 

Desired Condition, p. 285).

Response

We agree and will make change.

Public Concern #163

The Forest Service should initiate feedgrounds only after consultation with all potential stakeholders in 

order to limit disease, habitat degradation, and management costs.

Response

The plan contains no proposals or direction to initiate feed grounds on the Shoshone. 

Public Concern #164

590-18 The Forest Service should consider how drought and long-term stochasticities factor into 

assessment of crucial winter range (p. 190 DLMP).

Response

Drought is considered in managing forage on wildlife winter. Under the management approach for 

grazing there is a discussion on managing winter ranges during drought. This, along with additional plan 

direction under grazing and Management Area 5.4 direct that on winter range forage is managed to 

provide for big game populations.

Public Concern #165

590-19 The Forest Service should add mule deer to the discussion of Managed big game crucial winter 

range (p. 193, Management Area 5.4, DLMP) or explain why the species is not discussed.

Response

We changed the wording to include mule deer.

Public Concern #166

The Forest Service should consider implementation of the mapped acreages instead of the acres discussed 

in paragraph 3 because Map 15 shows less Elk crucial winter range and calving range discussed in the 

third paragraph.

Response

We will change the text in the referenced paragraph in the FEIS. We will also correct the map display in 

the FEIS.
Shoshone National Forest Land Management Plan Revision

754

Subject: 591 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - Desired Condition

Public Concern #167

The Forest Service should adjust the MA 5.4 boundary to eliminate the area in T43N R109W sections 17-

20 from the MA because the area has never been designated as winter range and has been used for over 

30 years for snowmobiling, hunting, fishing, hiking, and camping.

Response

The area is mapped as winter range and has been for some time. All alternatives allow hunting, fishing, 

hiking, and camping in this area. Alternative F maps that area as MA 5.1. Alternative B maps the area as 

MA 5.4 and allows snowmobiling in the area. The decision maker will consider this comment along with 

other comments that would like the area to be closed to snowmobiling in making the final decision.

Public Concern #168

The Forest Service should take recent and potential future changes into account during the planning 

process, especially when describing insect activity and five needle pine decline and fire risk.

Response

The EIS describes how changing conditions are affecting insect epidemics, white pine, and fire risk.

Public Concern #169

The Forest Service should establish a new guideline for Roads and Trails for Management Area 5.4 to 

state: “Established roads and trails through winter range will be open to wheeled and over-snow vehicle 

travel as needed to provide access to non-winter range lands beyond the winter range.”

Response

The plan direction under local species of concern allows existing snowmobile use on trails and play area 

in crucial winter range. Based on public comment, that direction will be clarified and referenced with the 

plan direction for MA 5.4. In addition, a map will be included to display the clarified direction.

Public Concern #170

The Forest Service should ensure that the ungroomed Horse Creek area snowmobile trails which follow 

roadways in the Horse Creek vicinity as well as north to the Double Cabin area can continue to pass 

through MA 5.4.

Response

Direction will be included in the revised Forest Plan to indicate that designated snowmobile trails in 

crucial winter range areas will be open to snowmobiling.

Public Concern #171

The Forest Service should remove the small parcel of winter range with a snowmobile trail from the Lava 

Mountain Lodge area (formerly Pinnacle Buttes Lodge) because the winter range area is very small and 

wildlife have been using the area with the existing snowmobile use from adjacent private land as well as 

with the lodge traffic.

Response

See PC #167.
Final Environmental Impact Statement -- Appendix A

755

Subject: 592 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - Goals

Public Concern #172

The Forest Service should modify Goal 1, Species of Local Concern, p. 59 to include "Minimize human 

disturbance in big game crucial winter range to levels commensurate with maintaining big game 

populations within state designated population goals and objectives" so this goal will not be 

misinterpreted and wrongly applied.

Response

The goal does not imply that any specific action would be taken. Any restrictions or changes in 

management would be addressed through a project analysis and public comments. Other places in the 

plan tie plan direction to meeting big game population goals and objectives. The additional qualification 

is not needed in the goal.

Subject: 594 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - Standards

Public Concern #173

The Forest Service should change the wording of Standard 3, Species of Concern, to read: "Forage use 

conflicts between big game and cattle will be evaluated on a case-by-case basis".

Response

The standard was reworded to clarify the intent.

Subject: 595 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - Guidelines

Public Concern #174

The Forest Service should recognize that we support guideline 6.

Response

Thank you for your support. The decision maker will consider this support in addition to other comments 

in making the final decision.

Public Concern #175

The Forest Service should note on page 60, Standards for Species of Concern, number 4, that exceptions 

to the stipulations are possible in some circumstances.

Response

The referenced direction is a guideline not a standard. The reference to exceptions to the guideline has 

been incorporated into the text of the guideline. In addition, the management approach for species of local 

concern further discusses how exceptions are addressed.
Shoshone National Forest Land Management Plan Revision

756

Subject: 597 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - Management Approach

Public Concern #176

The Forest Service should prohibit all human presence whenever there may be any level of potential 

disturbance from off-road or off-trail non-motorized uses within winter range because studies have shown 

that the impacts upon wintering wildlife are often greater from a person walking or someone on skis or 

snowshoes that it may be from motorized recreation. (http://www.snowmobileinfo.org/snowmobile-accessresources.aspx

Response

The rationale for selecting the 30 percent threshold for secure habitat is discussed in the DEIS under 

Species of local concern/Rocky mountain elk/Desired Condition.

Public Concern #177

The Forest Service should explain the rationale for the 30% threshold for security habitat.

Response

See response to PC #176.

Public Concern #178

The Forest Service should add “in coordination with livestock grazing permittees” to the sentence on p. 

193 that states “On a case-by-case basis, commercial livestock use levels in some pastures or allotments 

may be reduced to ensure adequate forage remains.”(DLMP, CH 2, Management Area Direction, 

Management Area 5.4)

Response

The change improves the presentation. The suggested change or something similar will be made in the 

final plan.

Public Concern #179

The Forest Service should revise the final LMP to allow snowmobile trail routes to be changed or even 

newly created when driven by other forest management actions.

Response

Nothing in the forest plan prevents snowmobile trails to be changed or new trails to be added in crucial 

winter range consistent with the exemptions allowed by the forest plan. Any such changes would be 

addressed in a site-specific project-level analysis that would evaluate any proposals.

Subject: 598 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - More of this

Public Concern #180

The Forest Service should revise Management Area direction to include both the area between homestead 

property (HES226) and the Sulphur Camp property of the same owners in MA 5.4.

Response

Alternative C allocates this area to MA 5.4. The decision maker will consider this comment along with 

other comments on winter range in making the final decision.
Final Environmental Impact Statement -- Appendix A

757

Public Concern #181

The Forest Service should protect the whole Absoroka front in order to protect big game winter range 

since if these areas were lost, substitutes could not be found.

Response

Alternative C provides the maximum amount of protection to winter range from motorized use and other 

management activities. The decision maker will consider this comment along with other comments 

suggesting how winter range should be managed in making a final decision.

Public Concern #182

The Forest Service should use HE/HS analyses to refine and further quantify Standards and Objectives 

(B-T NF 2012, Rowland 2000, 2005).

Response

Habitat effectiveness (HE) and Habitat suitability (HS) standards are addressed in table 11 and the 

associated HE/HS standards and guidelines under the wildlife section in the plan.

Public Concern #183

The Forest Service should ensure that winter travel management on big game winter range and travel at 

other times in sensitive wildlife areas (DLMP, p. 61, Guideline #9) is consistent with management on 

adjacent federal lands (e.g., Bureau of Land Management)

Response

See response to PC #1.

Public Concern #184

The Forest Service should ensure that management of crucial big game winter range on SNF lands is 

consistent with management of crucial big game winter range on adjacent public lands so that big game 

populations have adequate habitat to sustain them during that critical season of the year and over time.

Response

See response to PC #1.

Public Concern #185

The Forest Service should define “adequate quantity” as it relates to forage on big game crucial winter 

range (DLMP, p. 62).

Response

Such a definition will vary depending upon site-specific conditions and wildlife populations. That 

determination will be made during plan implementation and development of allotment management plans 

for livestock grazing.

Public Concern #186

The Forest Service should define a new Management Area, such as MA 3.54 in the Medicine Bow Forest 

Plan, to provide for big game crucial winter range in a more natural and undisturbed setting because big 

game are sensitive to road traffic and other disturbances and their winter ranges should be closed to 

snowmobiling and open roads.
Shoshone National Forest Land Management Plan Revision

758

Response

In the alternatives, many acres of the winter range on the Shoshone are allocated to back country 

management areas with little vegetation management (such as MA 1.3) that do not allow motorized 

activities or roads. These allocations would be similar to the management area you describe. Alternatives 

D and C allocate progressively more of the winter range to these types of management areas. The decision 

maker will consider the public comments requesting that motorized activity and vegetation management 

be restricted on winter range in addition to other public comments in making the final decision.

Subject: 599 - Management Area 5.4 – Managed Big Game Crucial Winter 

Range - Less of This

Public Concern #187

The Forest Service should consider that designation of new winter range areas may affect access to the 

national forest for all landowners in the private land tracts in that area.

Response

Alternative F does not include winter range restrictions and alternative B includes exemptions to winter 

range closure in many of the areas adjacent to private lands. The decision maker will consider those 

alternatives and these comments along with other comments on management of winter range in making a 

final decision.

Public Concern #188

The Forest Service should implement the mapped acreages (Map 15, p. 282) for elk crucial winter range 

and elk calving rather than the acreages discussed in the third paragraph since the mapped acreages 

appear to be larger.

Response

See response to PC #166.

Public Concern #189

The Forest Service should keep areas currently not open to summer motorized use as non- motorized in 

summer since summer use tends to create resource damage and unauthorized routes. Specific areas to 

consider maintaining as summer non-motorized include the area west of Shoshone Lake and east of the 

Popo Agie Wilderness and Moon Lake. The Forest Service should change the designation of the 

Telephone Draw/Castle Rock area on the Wind River Ranger District to 3.38 to make the area available 

for winter motorize travel, but not allow the potential future expansion of OHV trails beyond the roads in 

existence now. Maintaining the areas around the backcountry access corridors as non-motorized in the 

summer will discourage unauthorized travel and resource damage.

Response

Alternatives C and D keep more of the back country areas closed to summer motorized activity. 

Alternative F opens the Telephone Draw area to winter motorized activity. The decision maker will 

consider those alternatives along with other comments on motorized use in making a final decision.
Final Environmental Impact Statement -- Appendix A

759

Subject: 610 - Management Area 8.1 – Developed Recreation Areas -

General

Public Concern #190

The Forest Service should include the following as goals in Management Area 8.1 – Developed 

Recreation Areas: All established campgrounds, picnic grounds, and other facilities on the SNF will 

remain open; and campground reconstruction goals for the North Fork of the Shoshone River will 

increase.

Response

We do not feel is it is appropriate to set a goal in the forest plan that establishes whether existing facilities 

will be closed or whether new ones will be built. Decisions connected to large capital improvements will 

be based upon site-specific factors and addressed through appropriate public processes. Reconstruction 

goals for a specific corridor or area are a site-specific decision and are outside the scope of the revised 

Forest Plan analysis.

Public Concern #191

The Forest Service should include the following as objectives in Management Area 8.1 – Developed 

Recreation Areas: Double the campground reconstruction objective from one to two in order to meet the 

demand for larger recreation vehicle campsites and to encourage additional tourism activities; include at 

least one campground reconstruction in the North Fork of the Shoshone River; and reconstruct one

campground and/or trailhead to accommodate summer access to motorized loop trails.

Response

With the reduction of funding available for campground reconstruction and the large number of 

campgrounds already modernized in the past few years, a goal of “at least” one campground 

reconstruction project during the life of the plan was determined to be appropriate. Reconstruction goals 

for a specific corridor or area are a site-specific decision and are outside the scope of the revised Forest 

Plan analysis. Access and infrastructure for motorized use is also a site-specific decision that will be 

addressed once loop trail opportunities are site-specifically identified.

Public Concern #192

The Forest Service should use the plan to acknowledge the importance of developed recreation areas 

(Management Area 8.1) and ski-based resorts (Management Area 8.2) facilities as potentially powerful 

informational and educational interpretive opportunities for National Forest System users on a variety of 

topics, including wildlife, vegetation, or watershed management.

Response

The desired condition statement for MA 8.1 lists interpretation as an output. In addition, a guideline 

suggests infrastructure that is needed for information and interpretation at trailheads.

Subject: 611 - Management Area 8.1 – Developed Recreation Areas -

Desired Condition

Public Concern #193

The Forest Service should consider developing a disc golf course in a portion of the front country where it 

would not negatively impact resources or existing recreational uses.
Shoshone National Forest Land Management Plan Revision

760

Response

Disc golf facilities are more of the urban-type of recreational activities that the Forest Service does not 

provide. Developing site-specific facilities such as a disc golf area is outside of the scope of the revised 

Forest Plan.

Subject: 630 - Management Area 8.2 – Ski-Based Resorts - General

Public Concern #194

The Forest Service should classify Wild Iris, Beaver Creek, and Willow Creek ski areas as No Surface 

Occupancy because surface occupancy would destroy the wild and remote feeling of these places, and 

increase danger to recreationists.

Response

NSO or no surface occupancy is being looked at and adjusted between draft and final. The deciding 

officer will consider the various options along with other comments during the decision process.

Subject: 650 - Management Area 8.6 – Administrative Sites - General

Public Concern #195

The Forest Service must evaluate facilities for the National Register of Historic Places (NRHP) and work 

with the Wyoming SHPO to develop a memorandum of agreement to mitigate any adverse effects prior to 

disposal of facilities because some administrative facilities have played significant roles in the 

development of the National Forest and, therefore, have the potential to be eligible for listing in the 

NRHP.

Response

Federal actions that could include disposal of excess facilities require consultation with the SHPO and a 

determination of eligibility.

Subject: 670 - Miscellaneous - Attachments

Public Concern #196

No PC statement needed.

Response

Attachments provided were reviewed by the analysis team and considered for this analysis.

Subject: 671 - Miscellaneous - Incorporate by reference other comments

Public Concern #197

No PC statement needed.

Response

Information incorporated by reference in comments was reviewed by the analysis team and considered for 

this analysis.
Final Environmental Impact Statement -- Appendix A

761

Subject: 672 - Miscellaneous - Information Requests

Public Concern #198

No PC statement needed.

Response

The DEIS and supporting documents are available via the forest website.

Subject: 675 - Monitoring - General

Public Concern #201

The Forest Service should include a discussion of recommended best management practices in the DEIS 

and provide implementation guidelines for such practices. Without these guidelines the range of 

alternatives considered in the DEIS is deficient and should be revised. During the monitoring stage the 

Forest Service should apply the proper mitigation and diligently follow the directions. This action is 

needed to minimize adverse impacts a much as possible.

Response

Best management practices are discussed in the management approach section for water and soil in the 

Draft Forest Plan. The best management practices contained in forest Service Handbook 2509.25 

Watershed Conservation Practices Handbook are incorporated by reference in the Draft Forest Plan.

Public Concern #202

The Forest Service should make monitoring a priority for enforcement and monitoring of plan decisions. 

Failure to making monitoring a priority is not only irresponsible but could also lead to adverse situations 

later.

Response

The Draft Forest Plan, chapter 3, describes the forest monitoring strategy. Monitoring items described in 

this chapter will regularly assess the effects of implementing the forest plan. 

Public Concern #203

The Forest Service should make monitoring water quality mandatory. Monitoring should be done at least 

once a year more frequently in more critical areas. Monitoring standards should be quantifiable stating 

what is acceptable and what isn’t. Failure to develop these standards is not being environmentally 

conscience.

Response

The revised Forest Plan, chapter 3, describes the requirements for the Forest to monitor water quality. 

Watershed improvement projects are monitored on an annual basis. Soil disturbance, stream health and 

aquatic and riparian health are monitored on a 3- to 5-year basis.

Public Concern #204

The Forest Service failed to include the monitoring section in Chapter 3.

Response

Chapter 3 of the revised Forest Plan contains the forest monitoring strategy.
Shoshone National Forest Land Management Plan Revision

762

Public Concern #205

The Forest Service should make monitoring a priority. If there is a shortfall in the budget is should not 

affect monitoring. Monitoring is one of the most important actions on National Forest System lands. 

Monitoring should be an agency committed action to help determine if the Forest is actually meeting the 

Plan’s goals and objectives regardless of constraints.

Response

Monitoring of forest management effects is mandated in the 1976 National Forest Management Act. 

Chapter 3 of the revised Forest Plan contains the Forest strategy for monitoring forest plan 

implementation.

Public Concern #206

The Shoshone National Forest should consider organizing a steering committee or something similar. 

This has been implemented on the Bighorn National Forest and is working to the interest of all 

stakeholders. Steering Committee members can help Forest personnel in monitoring forest plan and 

project implementation, in evaluating biological, social, and economic impacts; and by identifying 

amendment needs and proposed solutions.

Response

The Shoshone intends to continue meeting with cooperating agencies during plan implementation. We 

added wording to the monitoring plan section of the forest plan about holding bi-annual meetings.

Public Concern #207

The Forest Service should eliminate all population monitoring requirements in the Revised Plan and, 

instead base any monitoring requirements on analysis of changes in the quantity and quality of the know 

habitat for the four species. The habitat should be monitored because that will provide the basis for 

population trends.

Response

Chapter 3, the monitoring chapter of the Draft Forest Plan includes a monitoring item for the habitat 

condition and trends for management indicator species. Population trends for management indicator 

species will also be monitored, as this is required by the 1982 Planning Rule. The forest may also use 

other available data sources, for example Wyoming Game and Fish data, for some monitoring 

information.

Public Concern #208

The Forest Service should not manage for MIS species populations, or habitat. MIS species are selected 

for monitoring, not for individual species management. We do not believe that any of the goals, standards, 

or guidelines on pages 55 and 56 of the Draft Plan are appropriate, nor do we believe the assumption of 

MIS presence and the requirements outlined in paragraph 1 of Management Approach on page 56 of the 

Draft Plan are appropriate.

Response

The Forest Service is required to monitor management indicator species populations and habitat by the 

1982 Planning Rule. The decision maker will consider the public comments in making the final decision.
Final Environmental Impact Statement -- Appendix A

763

Public Concern #209

The Forest Service should delete the reference to monitoring SOLC population trends. The Forest Service 

is not required to monitor population trends of species of local concern, as stated on p 12, paragraph 4. 

The Monitoring Plan, see page 191, does not include population monitoring for SOLCs.

Response

The 1982 Planning Rule requires the Forest Service to “manage to maintain viable populations of existing 

native and desired non-native vertebrate species in the planning area.” The Shoshone intends to monitor 

the population trends of species of local concern as one measure of our success in “managing to maintain 

viable populations.” The monitoring driver on page 215 of the Draft Plan will be changed from 

monitoring secure habitat for big game to monitoring the population trends of species of local concern.

Public Concern #210

The Forest Service should streamline the Monitoring Program outlined in Chapter 3.

Response

The monitoring strategy detailed in the Draft Plan, chapter 3 was designed to be compliant with both the 

1982 Planning Rule and the 2012 Planning Rule.

Public Concern #211

The Forest Service should revise its discussion in the DLMP, Chapter 3 page 179, Monitoring, 

Monitoring Strategy – “Evaluate the data: Resource managers will evaluate the data collected, with the 

goal of answering the monitoring questions, and determine if changes are needed in plan direction or 

outputs.” This implies some type of bias, prefer the use of ‘analyze’ versus ‘evaluate’. The adaptive 

management approach here is good.

Response

We agree. The wording on page 203 will be changed from “evaluate” to “analyze.”

Public Concern #212

The Forest Service should consider rewording the Monitoring Strategy section in Chapter 3 page 179 

DLMP, Establish monitoring priorities: Criteria from the goals and objectives are used to establish 

priorities for monitoring within the expected program of work and budget constraints. The Forest Service 

should provide the public with the monitoring priorities so that we acquire a feel for SNF management 

priorities. Many sections lack quantifiable Objectives and Standards, making the monitoring program 

addressed in Table 28 a little vague and unclear. The Forest Service should list tangible expectations via 

quantifiable Objectives and Standards and an associated monitoring plan in an effort to build public trust 

and acceptance. Without quantifiable Objectives, Standards and Guidelines it will be impossible to 

measure success/progress. As a result the DLMP loses tangible meaning and public trust.

Response

The goals and objectives from which the monitoring priorities were derived were developed in concert 

with the public during the plan revision process. Where possible, quantifiable objectives were established 

for resource areas. The monitoring strategy was designed to be compliant with both the 1982 Planning 

Rule and the 2012 Planning Rule.
Shoshone National Forest Land Management Plan Revision

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Public Concern #213

The Forest Service should consider collecting baseline population information or historical population 

indices along with detailed monitoring strategies to assess the effects of forest management activities on 

management indicator species (MIS).

Response

The Forest will use existing population data for management indicator species. With implementation of 

the plan monitoring strategy, the Forest will begin gathering additional population data on management 

indicator species. These data will be used to assess the effects of forest management activities on 

management indicator species.

Public Concern #214

The Forest Service should consider deleting the reference to HSS 5 on page 280 because it is not 

appropriate or necessary for MIS. The Forest Service should consider not designating any HSS 5 on 

suited timberlands.

Response

The reference to HSS 5 has been clarified as a conservation measure noted under the desired condition. 

The analysis has been added to clarify red-breasted nuthatch, which are strongly associated with mature to 

older forest habitat structural stages. For the issue of mature stands on suitable timber land, see the 

response to PC #355.

Subject: 676 - Monitoring - Annual Monitoring and Evaluation Report

Public Concern #215

The Forest Service should reconsider the frequency of their water quality checks. Monitoring of water 

quality BMPs needs to be conducted annually. The Forest Service should coordinate with the State of 

Wyoming BMP monitoring program, adopting a similar format as the Air Quality monitoring see on page 

183. Adopting the State of Wyoming BMP monitoring program could be more cost effective.

Response

The Forest has a memorandum of understanding with Wyoming Department of Environmental Quality 

(DEQ) that outlines expectations for implementing best management practices. Best management 

practices are needed to validate water quality protection during management activities. 

Subject: 677 - Monitoring - Components of the Monitoring Strategy

Public Concern #216

The Forest Service is not responsible for estimating population trends of MIS species as described on 

Page 190 of the Forest Plan.

Response

See response to PC #208.

Public Concern #217

The Forest Service should consider raising the benchmark for trail maintenance. If snowmobile trail 

maintenance is included in the definition of System trails, it alone would be over the 15% benchmark for 

minimum trail maintenance. For this reason we believe the 15% benchmark is too low since all other trail 

classifications should also receive some minimum level of annual maintenance to be properly managed.
Final Environmental Impact Statement -- Appendix A

765

Response

Objective #2 calls for maintenance to occur on at least 15 percent of our trail system annually. This 

amount is the minimum we would like to meet based on historical and projected funding and targets.

Subject: 680 - Monitoring and Evaluation

Public Concern #218

The Forest Service should update how it defines what the DFCs should be. Currently they are based on 

hard numbers generated by traditional forestry (commodity/timber harvest) goals that supersede vague, 

unmonitorable and unaccountable, contradictory promises of habitat management that follow. The result 

is a systematic devaluing of the unique ecosystem of which this Forest is a part.

Response

The desired conditions for the revised Forest Plan are tiered to the strategic goals of the USDA Forest 

Service including: “Restore, sustain, and enhance the nation’s forests and grasslands; provide and sustain 

benefits to the American people; conserve open space; and sustain and enhance outdoor recreation 

opportunities.”

Public Concern #219

The Forest Service should require their Wilderness rangers to do yearly inventories collecting detailed 

information. Specific data collection criteria should be explained to rangers so the appropriate field data 

is collected and meaningful decisions can be made to maintain wilderness qualities, and accurately meet 

the required scores for the Ten-Year Challenge.

Response

Monitoring drivers and frequency of reporting for wilderness character are addressed in the monitoring 

section of chapter 3. Specifics on how the data are collected are not forest plan-level direction and are 

typically articulated in project-specific monitoring protocols.

Public Concern #220

The Forest Service should revise the standards and guidelines in the LMP with respect to monitoring. It 

will be difficult to manage and monitor effects of management actions in relationship to stated objectives 

and goals given the lack of quantifiable standards and guidelines in the LMP.

Response

See response to PC #212.

Public Concern #221

The Forest Service should delete Goals, Standards, Guidelines, and Management Approach for 

Management Indicator Species on pages 33 and 34 of the LMP, and from the direction for various 

management areas. The Forest Service should also delete requirements for population monitoring from 

the Monitoring Plan, and that you delete discussion of management requirements for management 

indicator species from Appendix 3. The Forest Service should modify pages 274 to 281 of the DEIS to 

simply discuss the species selected as MIS and their habitat needs, and that you delete all discussion of 

management effects on management indicator species in the DEIS.

Response

See response to PC #208.
Shoshone National Forest Land Management Plan Revision

766

Public Concern #222

The Forest Service should measure the number of acres of treatments designed to increase aspen and 

willow instead of measuring the number of acres of aspen and willow every 5 years. The Forest Service 

should also place whitebark pine on a 5 or 10 year monitoring cycle. These modifications in inventory 

should net a cost savings.

Response

Our desired condition is to have increased acres of aspen and willow. While management treatments are 

one way to achieve that increase, wildfire and other natural processes are another way that those cover 

types can change. For this reason, we will measure the acres of the cover types and not just our treatment 

acres. We agree that it would be beneficial to change the monitoring cycle from 1 year to 5 years for 

whitebark pine.

Public Concern #223

The Forest Service should identify and secure the appropriate funds for fish and wildlife monitoring and 

mitigation, including compensation if necessary or required. Ensure that funds designated and intended 

for fish and wildlife management are not redirected to other causes. Failure to secure and obligate funds 

needed for the development and implementation of a monitoring and mitigation plan could result in the 

loss of the necessary funds to implement needed monitoring and mitigation.

Response

The Forest Service annual budget allocation process includes funds for resource monitoring each year.

Public Concern #224

The Forest Service should establish and update regularly a system of tracking commitments, in plans or 

agreements, along with any actions contrary to those commitments. Organization is vital for successful 

completion.

Response

Forest projects are monitored through project implementation tracking. Agreements are monitored 

through the Forest Service’s grants and agreements processes.

Public Concern #225

The Forest Service should ensure that laws, regulations and policies intended to conserve and protect fish 

and wildlife during energy development are not abdicated or abridged. Fish and wildlife habitat should 

not be sacrificed for energy development.

Response

See response to PC #854.

Public Concern #226

The Forest Service should establish a process for annual review and adjustments of actions that affect fish 

and wildlife. An adaptive management strategy is appropriate if based on established adaptive 

management guidelines and science. Adapting the management as needed strategy will provide the 

optimum habitat.

Response

Chapter 3 of the revised Forest Plan describes a monitoring strategy for fish and wildlife. Information 

gathered from monitoring can inform adjustments or adaptations to forest plan implementation.
Final Environmental Impact Statement -- Appendix A

767

Public Concern #227

The Forest Service should assure that mitigation and monitoring based on new scientific information is 

implemented in the energy development process. This will prevent from making unnecessary changes 

later.

Response

Mitigation and monitoring for site-specific energy development would be established at the project level 

at the time the project proposal is analyzed.

Subject: 700 - DEIS Chapter 1 - Purpose and Need

Public Concern #228

The Forest Service should study, develop and describe appropriate alternatives, such as the intermediate 

approach developed by the NAPgA to address the Purpose and Need, because the alternatives currently 

analyzed in the DEIS represent only the extremes of the spectrum of the potential actions and create all or 

nothing scenarios.

Response

Alternatives considered in the DEIS were developed in response to issues raised and considering available 

information.

The FEIS includes an alternative considering the best management practices to allow pack goat use on the 

forest. Pack goat movements may be controllable; however, there is a risk of free-ranging bighorn sheep 

coming into contact with pack goats. This alternative carries a risk of introduction of Pasterurella spp. 

through interaction of free-ranging bighorn sheep with pack goats. Although the risk of disease 

transmission is low to very low, even one disease transmission event could be catastrophic to a core native 

bighorn sheep herd. (See Risk Analysis of Disease Transmission between Domestic Sheep and Goats and 

Rocky Mountain Bighorn Sheep, Shoshone National Forest 2012.) Due to the potential for disease 

transmission, this alternative was dismissed from detailed analysis.

Subject: 701 - DEIS Chapter 1 - Proposed Action - General

Public Concern #229

The Forest Service should maintain a strong measure of flexibility for public lands management because 

budgets will likely decrease, while the cost of fire suppression will surely increase in the coming years, 

and disturbance to the Forest, whether caused by fire, insects, or mechanical treatment, will be 

unavoidable.

Response

The revised Forest Plan sets the framework for future management actions. Implementation of future 

management actions, whether program planned or in response to natural disturbances to the forest, is 

flexible and depends upon future budget allocations.

Subject: 702 - DEIS Chapter 1 - Decision Framework - 1982 Planning Rule

Public Concern #230

The Forest Service should consider revising the plan to include the requirements in CFR 219.12€ to meet 

the 1982 Rule procedural requirements in order to construct a full range of alternatives because monetary 

benchmarks were not addressed in response to major resource issues.
Shoshone National Forest Land Management Plan Revision

768

Response

A present net value benchmark was completed between draft and final.

Subject: 704 - DEIS Chapter 1 - Public Involvement – General

Public Concern #231

The Forest Service should include a slideshow in future public outreach events to highlight some of the 

amazing lands and waters that are within the National Forest because the Plan public outreach sessions 

held in Lander only included poster-sized presentations with too much printed text and not enough photos 

to represent the forest and the issues.

Response

Thank you for the feedback and suggestion for more effective public communication. We will consider 

providing more visual material (e.g., slide shows) for presentations at future public meetings.

Subject: 710 - DEIS Chapter 1 - Revision Topics – General

Public Concern #232

The Forest Service should have included fire risk, economics, and motorized travel as revision topics in 

the Draft Plan because they are timely and appropriate given the amount of recent local attention to 

these.

Response

Revision topics were selected upon both the need for change from the existing forest plan and strong 

public interest in how the revised plan will answer these questions. The topics were identified repeatedly 

in public meetings held across the forest and by the Government Cooperators Work Group from 2001 

through 2010, and validated during the scoping period in late 2010 (Summary p. viii; DEIS page 5). The 

draft plan provided management direction for fire and fuels (pages 66 through 70) and wildfire risk and 

fuels management were addressed under disturbance processes in the DEIS (pages 342 through 365).

Subject: 711 - DEIS Chapter 1 - Recreation Uses and Opportunities

Public Concern #233

The Forest Service should address the Continental Divide National Scenic Trail (CDNST), including a 

discussion on the need to site the corridor and provide for appropriate management direction to achieve 

the nature and purposes of this National Scenic Trail (FSH 1909.12 11.15), in the Special Areas and 

Designations, on page 8 of the DEIS, because it is a Congressionally Designated Area, and it would 

clearly link the CDNST to the Purpose and Need for Action and Revision Topics sections of the DEIS.

Response

Revision topic selection was briefly described in the DEIS (page 5). The revision topic discussion at 

DEIS page 8 pertains to new special areas and designations. The Continental Divide National Scenic Trail 

(CDNST) was established in 1978 and is addressed in the revised Forest Plan as Management Area 3.6A, 

which includes appropriate management direction.

A map will be added to depict where the CDNST 3.6A management direction will apply. (See also the 

response to PC #109.)
Final Environmental Impact Statement -- Appendix A

769

Subject: 713 - DEIS Chapter 1 - Vegetation Management

Public Concern #234

The Forest Service should emphasize cheatgrass control, as described on page xii of the DEIS, because it 

would prevent conversion of sagebrush to cheatgrass.

Response

Cheatgrass control falls under invasive species management, discussed in the DEIS at pages 378 through 

390. The draft plan includes management direction for invasive species, including cheatgrass, at pages 63 

through 65. The DEIS notes at page 131 that sagebrush is protected in all alternatives to maintain habitat 

conditions for sage-grouse. Sage-grouse are a sagebrush-obligate species; effects to this habitat are at 

pages 227 through 232 under the greater sage-grouse discussion.

Subject: 716 - DEIS Chapter 1 - Commercial Livestock Grazing

Public Concern #235

The Forest Service should change the wording in the following statement appearing in Revision Topics, 

Commercial Livestock Grazing, page 19 of the DEIS from “should” to “may” because the capability and 

suitability analysis is merely a broad-scale model and not specific enough to determine which areas 

“should” be available for commercial livestock grazing: “Two aspects of commercial livestock grazing 

will be addressed in the revised forest plan. The first- what areas of the Shoshone should be available for 

commercial grazing....”

Response

The revision topics were developed with public input and discussed at public meetings held across the 

Forest and by the Government Cooperators Work Group from 2001 through 2010. The topics are a 

summary of concerns. For more thorough discussion, see the livestock grazing discussion under the 

People and Communities – Goods and Services section in the DEIS (pages 395 through 419). Pages 395 

through 397 discuss various acts, laws, executive orders, and policies that guide management of 

rangeland resources and commercial livestock grazing on National Forest System lands. Between the 

release of the DEIS and completion of the FEIS, the commercial grazing capability acres were reviewed 

and recalculated to reflect corrections and adjustments

Subject: 730 - Other - General

Public Concern #15

The Forest Service should consider adding a list of acronyms to the EIS and spelling out acronyms at 

beginning of each chapter along with making headings stand out more such as with numbers and split up 

chapter 3 into multiple chapters to help stop confusion.

Response

A list of acronyms was provided at page v. of the DEIS and will be located at page vi of the FEIS. To help 

the reader, the first use of acronyms will be spelled out at the beginning of each chapter.

Public Concern #152

The Forest Service should use adaptive management thinking and evaluation of conditions to alter 

potential impacts throughout the DLMP.
Shoshone National Forest Land Management Plan Revision

770

Response

Adaptive management is a common practice that will be used in plan implementation.

Subject: 732 - Other - Climate Change Scorecard - General

Public Concern #236

The Forest Service should disclose its climate change adaptation and mitigation policy, by resource, in 

the plan revision documents because the documents, as they are currently written, ignore climate change.

Response

The plan monitoring section noted additional practices that may be considered to respond to climate 

change at pages 260 through 261. The DEIS discussions considered information in Climate Change on the 

Shoshone National Forest, Wyoming (USDA 2012) and discussed anticipated effects by resource. (e.g., 

see pp.21, 61 through 62, 83, 103 through 104, 137 through 138, 320)

Subject: 733 - Other - Multiple Use

Public Concern #237

The Forest Service should only manage for multiple use at an appropriate scale because too many 

national forests have been negatively impacted by trying to do so at too small of a scale, and it is 

impossible for all uses to occur within the same area.

Response

As noted in the comment, it is impossible for all uses to occur within the same area. Multiple-use 

management is considered across the entire forest through identification of different management areas, 

managed for different mixes of uses.

Public Concern #238

The Forest Service should create a balanced plan that respects multiple use and sustained yield principles 

because it is essential to provide diverse opportunities.

Response

We developed alternative G in response to input on the draft plan to provide a balanced approach for 

managing the forest.

Subject: 750 - DEIS Chapter 2 - Alternatives Considered - General

Public Concern #239

The Forest Service should revise all of the proposed alternatives as they have not proved that they have 

studied, developed, and described appropriate alternatives for recommended action as required by 42 

USC 4332(2). Furthermore, the alternatives presented lack science based decision making, details 

regarding adaptive management, and do not address alternate possibilities that fall between the extremes 

of what has been described.

Response

The majority of the comments related to this concern statement center around eliminating pack goat use in 

native bighorn sheep herd areas. The Forest Service reflected the current level of goods and services 

provided by the unit, and analyzed that as the existing condition or no-action alternative (as previously 

required under 36 CFR 219.12(f)(7)).
Final Environmental Impact Statement -- Appendix A

771

Although the risk of disease transmission is low to very low, even one disease transmission event could be 

catastrophic to a core native bighorn sheep herd. (See Risk Analysis of Disease Transmission between 

Domestic Sheep and Goats and Rocky Mountain Bighorn Sheep, Shoshone National Forest 2013.) See 

also response to PC #228 regarding pack goats.

Public Concern #240

The Forest Service should reconsider all alternatives to include: greater protection of the forest, systems, 

and biological diversity; protection of mule deer and other wildlife and their habitat; and improved 

protection for fish and wildlife. The alternatives should identify a corridor for primitive and semiprimitive non-motorized use according to FFSA 2353.44(b)(1); and should provide more differences 

between the alternatives in regards to grazing and forest related employment data. More change is needed 

than what is proposed in Alternatives A and B.

Response

Alternatives C and D propose recommending additional wilderness designations with emphases on nonmotorized back country (see Summary ix-x). See responses to PCs #105 and #106 pertaining to FSM 

2353.44(b)(1) for the Continental National Scenic Trail.

Public Concern #241

The Forest Service should reconsider all alternatives to include: preservation of the Lander Front and 

Dubois area to prevent oil and gas surface occupancy; no surface occupancy on all Inventoried Roadless 

Areas and wilderness areas; the impact on animals from drilling in the winter ranges; improved 

protection for the big game habitat that will maintain their function and population numbers, update 

definitions for reclamation guidelines, and consider recreation as a strong use both socially and 

economically.

Response

Alternative G incorporates changes to suitability for oil and gas development in response to public 

comments received on the DEIS. Under alternative G, National Forest System lands where adjacent 

owners (primarily BLM and State Land) preclude surface occupancy were determined not suitable for oil 

and gas surface occupancy.

Public Concern #242

The Forest Service should reconsider alternatives so that the forest is not closed to pack goats. Although 

Alternatives E and F allow pack goats in the forest, the Forest Service should consider revising 

Alternative B and use Best Management Practices and mitigation measures. Alternative A represents no 

change, and should continue to allow pack goats, as in the 1986 forest plan. Alternatives B through D fail 

the MUSYA (Multiple Use Sustained Yield Act), and don’t meet the NFMA (National Forest Management 

Act) requirements, as they eliminate pack goats. There is a need for an alternative that allows pack goats; 

separates their classification from herd goats, and focuses on disease prevention between pack goats and 

bighorn sheep.

Response

See response to PC #228 regarding pack goats. The temporary closure to pack goats would expire under 

alternative A. Information from the Risk Analysis of Disease Transmission between Domestic Sheep and 

Goats and Rocky Mountain Bighorn Sheep Shoshone National Forest 2013 was considered for this 

analysis (USDA Forest Service 2013).
Shoshone National Forest Land Management Plan Revision

772

Public Concern #889

The Forest Service considered 3 alternatives that were not compliant with the Roadless Area 

Conservation Rule (RACR).

Response

Alternatives discussed in the July 2012 DEIS were developed to address the Revision Topics with the 

then-current direction for Wyoming. See response to PC #13 for alternatives compliant with the RACR.

If a non-compliant alternative was selected, future site-specific analyses would ensure propsed activities 

were compliant with the RACR per the October 1, 2012 Supreme Court decision. 

Public Concern #890

The Forest Service should consider an alternative that provides management direction to restore the 

roaded and damaged portions of the IRAs to a roadless condition.

Response

Alternative C allocates all inventoried roadless areas to management prescriptions that prohibit motorized 

activity and scheduled vegetation harvest. Under that alternative, existing roads and motorized trails in 

inventoried roadless areas would be closed and rehabilitated.

Subject: 751 - DEIS Chapter 2 - Alternative A

Public Concern #243

The Forest Service should consider adopting Alternative A for the final forest plan. Those who have been 

responsible for the forest have done an excellent job and the success of their management should be noted 

in the final plan.

Response

Support for alternative A noted.

Public Concern #244

The Forest Service should consider adopting Alternative A for the final plan, with some revisions in 

regards to oil and gas. No more wilderness designations should be made, there should be an increase in 

motorized trails, 250,000-450,000 more acres should be made available for logging, action should be 

taken in regards to the pine beetle, and oil/gas leasing and surface occupancy should be permitted on 

forest lands that are adjacent to BLM lands.

Response

Support for alternative A, with select revisions, noted.

Alternatives A, B, E, F, and G do not include additional wilderness recommendations.

All alternatives would maintain the existing motorized trails, and alternatives D, G, B, E, and F propose 

additional motorized trails.

Alternatives B, C, D, E, F, and G include additional acres identified as suitable for timber production. 

Opportunities to increase areas suitable for timber production are limited by the amount of existing 

designated wilderness areas, lands that are rocky or have steep slopes, vegetation types, or conflicts with 

management direction.
Final Environmental Impact Statement -- Appendix A

773

Under alternative G, National Forest System lands where adjacent owners (primarily BLM and state land) 

preclude surface occupancy were determined not suitable for oil and gas surface occupancy. Alternative G 

provides a balanced response to the issues raised during revision, continues management that is working, 

and includes allocations designed to respond to public comments received on the DEIS including 

modifying management direction for oil and gas surface occupancy to be harmonious with adjacent BLM 

management plans for parcels along the Forest boundary. Alternative G is similar to alternative B. The 

main differences include additional acres of winter motorized recreation outside of crucial winter range, 

changes to summer motorized recreation, changes to suitability for oil and gas development, and 

modification to special areas.

Public Concern #245

The Forest Service should adopt the portion of Alternative A that designated the Washakie Management 

Area for semi-primitive recreation. This will prevent trail damage, abuse, trash, and noise pollution in the 

forest.

Response

Support for alternative A noted.

Public Concern #246

The Forest Service should consider adopting either Alternative A or Alternative B because there will be 

no changes to the access and use of the forest, which will result in maintaining the greatest value for the 

majority of forest users.

Response

Support for alternative A or B noted

Subject: 752 - DEIS Chapter 2 - Alternative B 

Public Concern #247

The Forest Service should adopt Alternative B as it creates the best balance in supporting multiple use 

and protecting the resources of the forest. The Forest Service should consider the effects of tourism for 

local communities and the increased revenues that support the economy.

Response

Support for alternative B noted.

Public Concern #248

The Forest Service should adopt Alternative B under the following conditions: (1) off-trail snowmobiling 

opportunities will not be hindered, and all existing trails and off-trail areas will remain open (The Forest 

Service can use best available technology to address noise, pollution, and horsepower of snowmobiles); 

(2) The Lava Mountain Area, Ramshorn Basin/Deacon Meadows, Sink Canyon, North of Cyclone, Pass 

Brecciae Cliffs, Sublet Pass, Jade Lakes, Austin Peak, Bonneville Meadows, Jules Bowl, Togwotee, Two 

Ocean Mountain, Brooks Lake Area, The Beartooths, and High Lakes Wilderness Study Areas will not be 

closed; and (3) mountain bike and ATV use continue to be permitted. It is important that the Forest 

Service keeps areas available for motorized recreation and does not designate more wilderness so that it 

can manage the forest for multiple use in order to meet the needs of all forest users. .

Response

Support for alternative B noted, along with three conditions.
Shoshone National Forest Land Management Plan Revision

774

(2) Snowmobiling opportunities – existing designated snowmobile trails are proposed to be kept open. 

See response to PC #697.

 See response to PC #82. 

 Alternatives A, B, E, and F do not recommend additional wilderness designations. Motorized 

recreation opportunities were discussed in the recreation section in chapter 3, and a comparison 

between the alternatives is provided in table 18.

The deciding officer will consider the various options along with other comments during the decision 

process.

Public Concern #249

The Forest Service should adopt Alternative B for their final plan with the key change of incorporating 

DuNoir SMU (East, West, and South), Franc’s Peak, Wood River, and Trout Creek as wilderness areas. 

The preferred alternative should have the highest standards for the forest, protecting the resources, 

limiting motorized recreation, increasing special designations (Pat O’Hara and Bald Ridge Mountains) 

and limiting oil and gas development.

Response

Support for alternative B noted, with suggestions that include elements incorporated in alternatives C and 

D. Alternatives C and D propose wilderness recommendations and eight proposed research natural areas. 

Alternative C would seasonally limit motorized use on existing trails and proposes a reduction in 

snowmobile trails (see recreation section of EIS).See also response to PC #698 pertaining to motorized 

use

Public Concern #250

The Forest Service should only adopt Alternative B for their final plan with the following changes to its 

position towards oil and gas development. Oil/gas/energy development should be allowed in the forest; 

road construction should be permitted in NSO high oil/gas areas; geophysical exploration activities on 

NSA lands should be permitted on a case by case basis; controlled surface use, timing and NSO 

restrictions found in the plan should not be applicable to current leases, and should be utilized where 

beneficial.

Response

Support for alternative B noted, with changes to oil and gas development. Alternative A includes the most 

acres allowing surface occupancy, followed by alternatives F, E then B. 

Public Concern #251

The Forest Service should adopt Alternative B because it benefits domestic sheep grazing and bighorn 

sheep habitat in part due to the prohibition of pack goats, and is overall a good plan for the big game 

winter range.

Response

Support for alternative B noted.

Public Concern #252

The Forest Service should not adopt Alternative B as their final plan as it does not offer enough 

protection for the forest. It lacks in fish and wildlife protection; decreases management direction on the 

impacts of roads, trails, and land use authorizations; permits surface occupancy in key areas (Bald Ridge, 

Dead Indian Hill, Chief Joseph Scenic Hwy, Beartooth and Absaroka Corridors); does not designate any 
Final Environmental Impact Statement -- Appendix A

775

new wilderness; and increased motorized recreation in the Wind River and Washakie districts. The Forest 

Service should ensure that some areas outside of the designated wilderness areas are left as backcountry 

non-motorized areas.

Response

Nonsupport of alternative B as a final plan, due to not enough protection for the forest noted. Fish and 

wildlife protection were provided in the draft plan through standards and guidelines for water and soil 

(pp.24 through 27), which also incorporates the Watershed Condition Framework (USDA Forest Service 

2011c) and fish and wildlife species (pp. 38 through 63) and within the management area direction, with 

some management areas focused on providing specific habitat elements (e.g., MA 5.4 big game crucial 

winter range). Anticipated effects were discussed in chapter 3 of the DEIS by resource.

Figure 2 in the EIS (Summary p. x), displays the management area allocation proposed with the various 

alternatives, management areas 1.1, 1.1A, 1.3, 1.5A, 1.6A, and 1.6B offer wilderness and back country 

non-motorized areas on 86 percent under alternative C to 67 percent under alternative F. Alternatives C 

and D include additional recommended wilderness.

Public Concern #253

The Forest Service should not adopt Alternative B as their final plan as it decreases the accessible 

motorized acres down to 20% for the entire forest. These lands should not be designated as backcountry 

non-motorized, as they prohibit over snow motorized recreation, thereby limiting winter motorized use of 

the forest.

Response

We reviewed motorized winter access in response to comments received on the draft plan, and we 

developed alternative G in response to comments on the draft plan and DEIS. Alternative G is similar to 

alternative B. One of the main differences is the inclusion of additional acres of winter motorized 

recreation outside of crucial winter range, in addition to changes to summer motorized recreation.

Public Concern #254

The Forest Service should consider reevaluating the map for Alternative B to include the following: 1) 

Moving the game winter area up the valley so that the east end would be at the very eastern end of the 

Roaring River Subdivision. 2) Showing the trail access to Lava Mountain Lodge. This trail route should 

be flexible since the public route is undesirable and the private route is not guaranteed.

Response

See response to PC #154 regarding big game winter range and trail access to Lava Mountain.

Public Concern #255

The Forest Service should consider adopting a combination of Alternatives B and D. Together, these 

alternatives support wildlife, habitat, motorized and non-motorized recreation, and enforce/monitor 

motorized use so that no new trails get created. Both alternatives provide for light livestock use that will 

protect winter forage for wildlife along with benefits to big game, fisheries, water quality, and habitat, 

while also reducing invasive plant species.

Response

Support for adopting a combination of alternatives B and D noted. The decision maker will consider the 

public comments in making the final decision.
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Subject: 753 - DEIS Chapter 2 - Alternative C 

Public Concern #256

The Forest Service should consider adopting Alternative C for the final plan as it offers the best 

conservation of the forest resources through expanding the wilderness designations, decreasing motorized 

trails, prohibiting livestock grazing on big game crucial winter range, protects grizzly, lynx, and provides 

low likelihood of disease transmission between elk and domestic livestock; contains the desired 

consistency with the roadless rule, enforces no surface occupancy on all roadless areas and permits a 

reasonable amount of oil and gas development and timber production. This alternative appears to be the 

best alternative that will meet some of the needs of all of the users of the forest.

Response

Support for alternative C noted.

Public Concern #257

The Forest Service should consider adopting Alternative C for the final plan, with the following changes: 

(1) No surface occupancy should be added to the SNF land that lies around the BLM border and areas 

around Dubois; (2) Increased enforcement of trail expansion and motorized trails; (3) Increasing 

wilderness designations to include Windy Mountain, Carson Lake, Little Popo Agie, Pass Creek, 

Togwotee Pass, North Boundary, and Reef; and (4) increased restriction or complete elimination of oil 

and gas development on the forest land.

Response

Support for adopting alternative C noted with four conditions.

(1) No surface occupancy to SNF land around BLM border – Many comments identified issues with the 

preferred alternative not matching management on adjoining BLM and state lands, particularly for oil 

and gas management. Those comments are being addressed between draft and final. The modified 

preferred alternative will include changes to make management more consistent as appropriate.

(2) Increased enforcement of trail expansion and motorized trails − Various alternatives were analyzed 

concerning motorized use allocations. These ranged from a high of 823,900 acres available for 

summer motorized in alternative F to a low of 322,400 acres available in alternative C and a high of 

887,600 acres available for winter motorized in alternative A to a low of 103,000 acres in alternative 

C. The deciding officer will consider the various options along with other comments during the 

decision process.

(3) Increasing wilderness designations − Only Congress can pass legislation to create, or designate 

wilderness. In 2008 (edited 2013), 34 areas on the Shoshone were evaluated for potential wilderness. 

This process included three tests—capability, availability, and need. Capability is defined as the 

degree to which the area contains the basic characteristics that make it suitable for wilderness 

designation without regard to its availability for or need as wilderness.

(4) Various alternatives were analyzed including a range of recommended wilderness from 628,800 acres 

in alternative C to 194,500 acres in alternative D to 0 acres in Alternative B. Potential areas not 

recommended for wilderness were allocated to other management prescriptions. Alternative F 

allocates the most acreage of potential wilderness to management prescriptions that allow activities 

that may impact the potential for wilderness, followed by alternative E and A that allocates the second 

highest, and alternative B and D which allocates the third highest. The deciding officer will consider 

the various options along with other comments during the decision process.
Final Environmental Impact Statement -- Appendix A

777

(5) The consideration of no oil and gas development on the forest was addressed in an alternative 

eliminated from detailed analysis in the DEIS. The alternatives prohibit surface occupancy for oil and 

gas development on varying acres of the forest. Alternative C allows development on only 7 percent 

of the forest. The decision maker will consider the public comments requesting little or no oil and gas 

development on the forest in addition to other public comments in making the final decision.

Public Concern #258

The Forest Service should consider adopting a combination of Alternatives C and D which support 

conservation, additional wilderness areas, increased Wild and Scenic River designations, protection of 

roadless areas, improved and increased migration corridors, winter range, and minimal oil and gas 

development. These alternatives also provide the best levels of summer and winter motorized recreation 

and prevent snowmobile disturbance to wolverine denning.

Response

Support for alternatives C and D noted. 

Subject: 754 - DEIS Chapter 2 - Alternative D 

Public Concern #259

The Forest Service should consider adopting Alternative D for their final plan as it provides a good 

balance of conservation, motorized and non-motorized recreation, minimal oil and gas development, 

protection of big game winter range (no snowmobiling), good vegetation management, supports the 8 

Research Natural Areas and wilderness designations.

Response

Support for alternative D noted.

Public Concern #260

The Forest Service should consider adopting Alternative D for the final plan, with the following changes: 

(1) Ensure that timing restrictions are in place on all big game crucial winter ranges, (2) Designate all 

possible Research Natural Areas possible on the forest to ensure maximum diversity; (3) Reduce timber 

production to wood that is dead; (4) Additional wilderness designations; (5) Improved signage and 

enforcement forest wide; and (6) Ensure there is no new motorized recreation in IRAs and non-motorized 

winter recreation in Sunlight Pass, Togwotee Pass, and Two Ocean Mountain; (6) development of oil and 

gas should not be a part of this plan.

Response

Support of alternative D with changes noted. 

(1) Timing restrictions on big game crucial winter range is discussed within the elk analysis (DEIS pages 

285 through 288) and affected acres summarized by alternative in tables 74 and 77; 

(2) Alternatives C and D consider inclusion of eight research natural areas, followed by alternatives B 

and E with six and three, respectively. The DEIS discusses research natural areas at pages 535

through 544; 

(3) Reducing timber production to wood that is dead was considered but eliminated from detailed 

analysis because it is not responsive to other forest health and vegetative diversity goals. 

(4) Alternatives C and D include recommending additional wilderness areas; 
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(5) The Forest Service continually strives to curb illegal off-road vehicle (ORV) or off-highway vehicle 

(OHV) use through education, signage, and enforcement and by providing quality ORV and OHV use 

where management area direction allows for such use; 

(6) Alternatives B, C, and D comply with the Roadless Rule; 

(7) The decision maker will consider the public comments requesting little or no oil and gas development 

on the forest in addition to other public comments in making the final decision.

Subject: 755 - DEIS Chapter 2 - Alternatives E 

Public Concern #261

The Forest Service should consider not adopting Alternatives E or F. These alternatives are inconsistent 

with the roadless rule and legislation of non-motorized/non-mechanized use in the wilderness. They 

degrade crucial wildlife range and provide too much winter motorized recreation. Alternatives E and F 

have a negative effect on cross country ski safety, water quality, soil productivity, vegetation, and wildlife. 

Additionally, Alternative E inappropriately supports industrial use of the forest over tourism, and 

Alternative F provides the least amount of protection for transmission between domestic livestock and elk 

within crucial winter range. This alternative is also likely to adversely affect lynx critical habitat by 

increasing snowmobile use.

Response

Non-support of alternatives E and F noted. Effects of these alternatives are discussed in chapter 3 of the 

EIS. See response to PC #263 regarding timing restrictions on big game crucial winter range.

Public Concern #262

The Forest Service should consider implementing Alternative E or F if no other alternatives are 

developed, and should not be closed to goat packing.

Response

Support for alternatives E and F noted. See response to PC #228 regarding pack goats. 

Subject: 763 - DEIS Chapter 2 - Exclude human presence in crucial big 

game winter range 

Public Concern #263

The Forest Service should protect big game crucial winter range by limiting human presence to the area.

Response

Timing restrictions on big game crucial winter range is discussed within the elk analysis (DEIS pages 285 

through 288) and affected acres summarized by alternative in tables 74 and 77. An alternative was 

considered, but eliminated from detailed study that would exclude human presence and disturbance in 

crucial big game winter range.

Subject: 764 - DEIS Chapter 2 - Add additional special interest areas

Public Concern #264

The Forest Service should use the Shoshone National Forest, a Region of the US Forest Service, or the 

conterminous United States for areal comparison or reference, not the Greater Yellowstone Region as it 

seems limiting and inappropriate.
Final Environmental Impact Statement -- Appendix A

779

Response

The spatial and temporal boundaries used in analysis vary and are discussed by resource. The Greater 

Yellowstone Area is used as the analysis area for appropriate resources (e.g., grizzly bear).

Public Concern #265

The Forest Service should create more Special Interest Areas to highlight unique ecological areas within 

the forest including the addition of the Deep Lake Slide as it may be the largest rock slide in the 

conterminous United States and could provide an important resource for studying mass wasting events by 

students and scientists. The Forest should also consider include Two Ocean Mountain, Bald Ridge, Pat 

O’Hara Mountain, and Breccia Peaks as potential Special Interest Areas.

Response

Special interest areas were discussed in the DEIS at pages 545 through 550. It is noted the Deep Lake 

Slide area was not considered for special interest area designation due to its location within a management 

area that allows adequate protection. The deciding officer will consider the various options along with 

other comments during the decision process.

Subject: 765 - DEIS Chapter 2 - Undesignated wilderness areas, research 

natural areas, special interest areas 

Public Concern #266

The Forest Service should provide information on how the Special Interest Areas are chosen and if there 

is a limit to how many Special Interest Areas can be nominated and/or selected in the Plan.

Response

Forest resource specialists followed Forest Service Manual 2372, Forest Service Handbook 1909.12, and 

36 CFR 294.1 guidance for establishing and managing special interest areas. The guidelines are not 

prescriptive on a specific number of minimum or maximum areas to consider.

Subject: 767 - DEIS Chapter 2 - Pro-recreation

Public Concern #268

The Forest Service should consider opening up the forest to limited or no restrictions to recreation for 

freedom and income.

Response

A pro-recreation alternative was considered but eliminated from detailed analysis. The resource analyses 

note the numerous laws and administrative framework the Forest Service is required to address. 

Recreation opportunities will continue to be available as noted in the DEIS; motorized and non-motorized 

opportunities are summarized in table 18 near the end of chapter 2, and discussed in more detail in 

chapter 3.

Subject: 768 - DEIS Chapter 2 - Changes to travel management

Public Concern #269

The Forest Service should consider changing the designation of all 1981 motorized trails around 

Kirwin/Franc’s Peak and Sunlight to M.A. 4.3 or M.A. 3.5 and include 100 ft. buffer so they can be part of 

travel management process.
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Response

Alternatives that included changes to travel management were considered but eliminated from detailed 

analysis. The Forest intends to complete a travel management analysis sometime after the decision on the 

revised Forest Plan.

Public Concern #270

The Forest Service should consider not delaying the travel management plan and begin travel 

management planning within two years after the Record of Decision is singed for the Forest Plan revision 

since it would costly, inefficient, and should be included in the Forest Plan revision.

Response

See response to PC #269 regarding alternatives considered. The decision maker will consider suggestions 

for timing of travel management planning in this decision and future planning efforts

Public Concern #898

The Forest Service should complete a travel analysis, identify a minimum road system, and identify a list 

of unneeded roads for decommissioning or conversion as part of the revised plan effort.

Response

Alternatives that included changes to travel management were considered but eliminated from detailed 

analysis. The Forest intends to complete a travel management analysis following the decision on the 

revised Forest Plan.

Public Concern #901

The Forest Service should more clearly articulated in the LRMP their duty to designate motorized trails 

and areas to minimize impacts to forest resources and other users as required by Executive Order 11989 

and 36 CFR 212.55 and recently affirmed in a federal court decision (see Idaho Conservation League v. 

Guzman, 2011 WL 447456 (D. Idaho Feb. 4, 2011))

Response

The other guidance section in the forest plan includes a reference to 36 CFR 212.5 Travel Management.

Public Concern #902

The Forest Service should work towards a sustainable road system by: a) minimize impacts to resources 

and other users from off-road vehicles in plan components and provide direction for removing illegal 

routes, especially in IRAs and other areas of importance to the environment and backcountry recreation; 

and b) manage for quality recreation and take a hard look at the consequences of significantly undermaintaining the transportation system, and how road densities impact resources and the quality of the 

recreational experience.

Response

The revised Forest Plan desired condition and goals for roads and trails include direction on minimizing 

impacts to resources and addressing unauthorized routes. The alternatives contain a mix of different 

allocations for motorized recreation. The analysis addresses how those different allocations impact 

different types of recreation activities. The deciding officer will consider the various options along with 

other comments during the decision process.
Final Environmental Impact Statement -- Appendix A

781

Subject: 770 - DEIS Chapter 2 - No oil and gas surface occupancy Forestwide

Public Concern #271

The Forest Service should consider oil and gas surface occupancy forest wide including big game winter 

range and inventoried roadless areas and not just in non-motorized areas in order to protect wildlife and 

keep the forest beautiful.

Response

See response to PC #688 regarding consideration of oil and gas surface occupancy.

Subject: 780 - DEIS Chapter 2 - New Alternatives

Public Concern #272

The Forest Service should consider different alternatives that support Multiple Use Sustained Yield Act 

and/or a Forest Health Alternative that reflect forest changes between 2006 and 2010.

Response

There is a variation across the alternatives on how different resources are emphasized. Alternative C 

emphasizes non-motorized recreation and less commodity production, while alternative F emphasizes 

motorized recreation and commodity production. The other alternatives are arrayed between the two 

extremes. Forest health considerations and responses to changes in vegetation conditions in the last 

10 years are incorporated into all the alternatives to some degree. The most aggressive responses are 

included in alternative F.

Subject: 800 - DEIS Chapter 3 - Affected environment and environmental 

effects – General

Public Concern #273

The Forest Service should make the following changes to the DEIS: (1) The Forest should "discuss at 

appropriate points in the final [EIS] any responsible opposing view which was not adequately discussed 

in the draft [EIS] and ... indicate the agency's response to the issues raised" and "insure the professional 

integrity, including scientific integrity, of the discussions and analyses" included in its EIS. (2) In areas of 

the DEIS where relevant information for assessing impacts is incomplete or unavailable the Forest must 

include the information if the costs of obtaining the information is not exorbitant. If the information 

cannot be obtained due to high costs or the means of obtaining are unknown, then agency must include in 

the EIS: (a) a statement that such information is incomplete or unavailable; (b) a statement of the 

relevance of the incomplete or unavailable information to evaluating reasonably foreseeable significant 

impacts on the human environment; (c) a summary of existing credible scientific evidence which is 

relevant to evaluating the reasonably foreseeable significant adverse impacts on the human environment; 

and (d) the agency's evaluation of such impacts based upon theoretical approaches or research methods 

generally accepted in the scientific community. (3) The current disease model is largely dependent on 

assumptions, which should be studied and proven to be relied upon in the EIS. (4) The effects of mountain 

goats and their contribution to disease in the Shoshone should be considered in the EIS. (5) The final 

DEIS and Land Management Plan should be drafted without reliance on the Risk Assessment Disease 

Transmission (RADT) Committee’s and Payette Principle Committee’s findings and conclusions as the 

findings were prohibited by a previous legal decision against the Forest Service. (6) The DEIS must be 

adjusted to reflect that the majority of rangelands on the Shoshone are meeting desirable conditions for 

bird species and maintaining current permitted areas for grazing is not likely to change conditions. (7) 
Shoshone National Forest Land Management Plan Revision

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Page 12, Vision, paragraph 5- it is recommended that sentence one is modified as follows; “Forested 

ecosystems ... while providing habitat for viable populations ... species” and the second sentence 

modified as; “Populations of Sensitive species are stable ... toward recovery,” (8)There is a discrepancy 

in the total miles of snowmobile trails in the DEIS vs. the Land Management Plan, the discrepancy should 

be corrected in the final EIS and Plan.

Response

(1) Response to comments on the DEIS will be provided in the FEIS; 

(2) Within the resource discussions under the “Methodology” heading, the information considered, the 

spatial and temporal context for effects analysis, and incomplete and unavailable informationcan be 

found; 

(3-5) Available relevant information was considered for this analysis. DEIS Page 213 noted to see the 

Risk Analysis of Disease Transmission Between Domestic Sheep and Goats and Rocky Mountain 

Bighorn Sheep, Shoshone National Forest, 2012.; 

(6) Chapter 3 in the wildlife discussions for various bird species, potential effects from livestock grazing 

are noted. Edit suggestions on wording and capitalization will be reviewed by a writer/editor for the 

final documents; 

(7) Edit comments on sentences and capitalization will be reviewed by a writer/editor for final 

documents;

(8) The discrepancy in the total miles of snowmobile trails in the EIS and Plan will be corrected in the 

final documents.

Public Concern #274

The Forest Service should keep management needs consistent with BLM lands and resource management 

for neighboring areas. The Forest management should make best efforts to protect resources from mining, 

logging, grazing, and other activities that may impact the environment.

Response

See responses to PCs #1 and #688 regarding management direction coordination between Forest Service 

lands and BLM lands.

Public Concern #275

The Forest Service should remove the soil types listed in the R2 Capability/Suitability direction and 

unsuitable lands such as high recreation areas and water supplies.

Response

The timber capability analysis did address soil types that needed to be withdrawn from capable acres. The 

withdrawals for slope and elevation also result in the removal of some types. The percentage of land that 

is encompassed by recreation areas and water supplies is very small and would be the same for all 

alternatives. It was decided that this level of detailed analysis was not necessary for tcomparing 

alternative effects. These small site-specific areas are addressed within the forest plan direction and are 

more appropriately analyzed during plan implementation in project-level analyses.
Final Environmental Impact Statement -- Appendix A

783

Subject: 801 - DEIS Chapter 3 - Resource protection measures

Public Concern #276

The Forest Service should follow the alternatives for best management practices, conservation, and 

mitigation measures to protect and maintain the wild and natural beauty of the forest wildlands and 

wildernesses and protect them for future generations. Protecting roadless areas increase tourism to the 

region and have a positive impact to the local economy. There should be equal protection along both 

sides of the Forest boundary for fragile lands flanking the Absarokas and Beartooths and in the Wiggins 

Fork Management Area outside Dubois. The Forest should also require No Surface Occupancy to 

inventoried roadless areas and wildlife crucial winter ranges to protect the natural environment.

Response

See responses to PCs #144, #327, and #278 regarding best management practices.

Public Concern #277

The Forest Service needs the DEIS to discuss mitigation measures and define them as follows: (1) 

Avoiding the impact altogether by not taking a certain action or parts of an action; (2) Minimizing 

impacts by limiting the degree or magnitude of the action and its implementation; (3)Rectifying the 

impact by repairing, rehabilitating, or restoring the affected environment; (4) Reducing or eliminating the 

impact over time by preservation and maintenance operations during the life of the action; (5) 

Compensating for the impact of replacing or providing substitute resources or environments.

Response

This analysis addresses programmatic management direction in the forest plan. The management 

approach sections in the forest plan clarify how plan direction may be applied. Mitigation for site-specific

proposals is developed during site-specific analyses of proposed actions.

Public Concern #278

The Forest should discuss the best management practices in the DEIS and include any alternatives that it 

would implement in such practices.

Response

See DEIS page 64. The water and soil, legal and administrative framework section notes that resource 

protection measures include Forest Service Handbook, Region 2 Watershed Conservation Practices 

Handbook (found at: http://www.fs.fed.us/cgi- bin/Directives/get_dirs/fsh?2509.25!r2) and Forest Service 

National Best Management Practices (collectively referred to as: Forest Service Regional and National 

BMP Directives). See responses to PC #327. See response to PC #144 regarding plan direction.

Public Concern #280

The Forest Service should consider the following suggestions for wildlife management on the Shoshone 

National Forest: (1) The Forest should protect the area’s wildlife by using Wyoming’s Game and Fish 

data regarding crucial winter ranges and to decide when and where winter motorized uses can occur on 

this winter range. (2) The Forest should also ensure that possible lynx and wolverine habitats are not 

harmed by winter recreation allocations. (3) Protecting the Dunoir area as wilderness with no motorized 

us or surface occupancy will contribute to lynx and wolverine protection.

Response

(1) Wyoming Game and Fish data were used in the analysis regarding winter motorized use in winter 

range areas; 
Shoshone National Forest Land Management Plan Revision

784

(2) Chapter 3 of the DEIS includes discussions on effects to lynx (pages 152 through 157) and wolverine 

(pages 190 through 193). The DEIS notes how the various alternatives incorporate the direction in the 

Northern Rockies Lynx Management Direction (USDA Forest Service 2007) at pages 155 through 

156; 

(3) Alternatives C and D recommend the Dunoir area for wilderness designation.

Public Concern #281

The Forest Service should make best efforts to protect roadless areas as an asset for backcountry use and 

critical wildlife habitat by enforcing the restriction of OHV and ATV use to these areas. The following 

areas should be enforced roadless areas: Little Pope Agie Canyon area, west and south of Shoshone Lake 

to the Pope Agie Wilderness Area, south of Moon Lake jeep trail to Bridger-Teton National Forest and 

Fitzpatrick Wilderness Area, Sheridan Pass area to Bridger-Teton National Forest, and Wiggins Fork east 

to the boundary of the Wind River Indian Reservation should all be enforced roadless areas protected 

from motorized travel.

Response

Alternatives C and D protect the most areas for roadless characteristics. The deciding officer will consider 

the various options along with other comments during the decision process. See also response to PC #689 

regarding motorized use allocations and enforcement of off-road vehicles or off-highway vehicle use 

restrictions.

Public Concern #282

The Forest Service should set aside, protect, and study Bald Ridge and Pat O’Hara Mountain due to their 

unique ecological communities.

Response

Alternatives C, D, and G proposed including Bald Ridge and Par O’Hara Mountain as new research areas. 

The decision maker will consider the public comments in making the final decision.

Subject: 802 - DEIS Chapter 3 - Environmental consequences

Public Concern #283

The Forest Service needs to ensure the NEPA process is followed and the scientific integrity of an EIS by 

considering the appropriate studies and data and that the EIS evaluates environmental effects which 

include, cultural, economic, and social where they effects are direct, indirect, or cumulative.

Response

Available economic information was reviewed and considered during this analysis, see DEIS social and 

economic section starting at page 576. Methodology and incomplete and unavailable information are 

discussed at pages 577 through 580.

Public Concern #284

The Forest Service should change the direction of impacts listed in the DEIS under Environment 

Consequences from to the forest to the local communities supported by the activities as a consequence of 

the Plan and should identify the impacts as “potential adverse impacts.” which is more in keeping with 

the intent of NEPA. It is quite irrelevant which ROS classification or particular use(s) occurs directly 

adjacent to any wilderness area. Such consideration and perspectives should therefore be eliminated and 

discounted from all impacts analysis as the final EIS and Plan are developed.
Final Environmental Impact Statement -- Appendix A

785

Response

Estimated social and economic impacts were summarized on pages 597 through 604 (see comparison 

tables 170, 171 and 172). Information has been updated to display anticipated impacts from alternative G.

The DEIS at pages 486 through 487 discusses the recreation opportunity spectrum as providing a 

framework for analyzing changes to recreation settings as a result of potential management activities 

under each alternative.

Subject: 803 - DEIS Chapter 3 - Cumulative effects summary table - General

Public Concern #285

The Forest Service should ensure that the EIS provide enough information concerning other area projects 

and their impacts to allow the decision-maker to decide whether or how to alter the proposed project to 

lessen cumulative environmental impacts.

Response

A summary of past, present, and foreseeable projects and plans are noted at the beginning of chapter 3, 

with summary information displayed in tables 19 and 20. Cumulative environmental impacts are 

considered by resource.

Subject: 804 - DEIS Chapter 3 Climate change –General

Public Concern #287

The Forest Service should consider linking best available science and conservation in order to assess 

climate change impacts in order sustain ecosystems, diversity, and minimized impacts from management 

and climate change. Things to consider include how the forest should be managed to prepare for climate 

change by protecting intact ecosystems (e.g., roadless areas) to facilitate climate-forced wildlife 

migrations and carbon dense ecosystems (e.g., mature forests) for long-term carbon storage while 

reducing existing stressors to enable adaptation of species (and, in the aggregate, ecosystems).

Response

Climate change was discussed in the DEIS (pages 21, 61 through 62).Climate change literature applicable 

for the Shoshone National Forest was considered during the analysis and preparation of Climate Change 

in the Shoshone National Forest, Wyoming: A Synthesis of Past Climate, Climate Projections, and 

Ecosystem Implications (Rice et al. 2012), which was incorporated into the various resource discussions 

in chapter 3 of the DEIS. Vegetation monitoring is included in chapter 3 of the revised Forest Plan.

Public Concern #288

The Forest Service should consider protecting and increasing wild lands and stopping or at least 

minimizing oil and gas leasing, motorized recreation, large scale timber harvest, and road construction in 

order to move away from fossil fuels and not be adding to global warming/climate change.

Response

Alternatives C and D offer the fewest acres available for active management disturbance. See also 

response to PC #287 regarding climate change.

Public Concern #289

The Forest Service should consider emphasizing fuels reduction projects, timber harvest and aspen 

restoration in order to minimize fire and impacts of climate change can be mitigated
Shoshone National Forest Land Management Plan Revision

786

Response

Alternatives F, E, A, and B offer a range of acres available for active management. See also response to 

PC #287 regarding climate change.

Public Concern #290

The Forest Service should consider using the Pika as Management Indicator Species for climate change 

in the Alpine environment since the Forest does not have one.

Response

Management indicator species are designed to address the monitoring of forest plan implementation on 

species and associated habitats. There is very little direction in the plan that leads to management activity 

in alpine habitats. Management indicator species are not the appropriate way to monitor climate change. 

TSeveral sensitive plants that occur in alpine habitat are addressed in the revised Forest Plan direction. 

These species, along with other monitoring efforts, will provide ways to monitor the effects from climate 

change.

Public Concern #291

The Forest Service should consider more planning opportunities for protecting watersheds and aquatic 

resources from climate change.

Response

See response to PC #287 regarding climate change. 

Public Concern #292

The Forest Service should consider using TU’s CSI climate change studies, other USFS studies, 

University of Wyoming studies, and others in discussions within each alternative for describing potential 

effects.

Response

See response to PC #287 regarding climate change. 

Public Concern #293

The Forest Service should consider using “Climate Change in the Shoshone National Forest, Wyoming: A 

Synthesis of Past Climate, Climate Projections, and Ecosystem Implications” (Rice et al. 2012) as basis 

for much of its discussions and to enhance the topic of climate change in the Forest Plan including 

specific projections and more ecosystems analyzed in the main report and all alternatives.

Response

The suggested document was considered and cited in the resource analyses discussion in chapter 3 of the 

DEIS. See also response to PC #287 regarding climate change. 

Subject: 810 - Water and Soil - Resource – General

Public Concern #294

The Forest Service should protect the Wind River Valley ecosystem and other wilderness because they are 

clean water sources and for their beauty.
Final Environmental Impact Statement -- Appendix A

787

Response

Forest Service soil and water management activities are guided by FSH 2509.25, Region 2 Watershed 

Conservation Practices Handbook, and Forest Service National Best Management Practice directives. 

These management practices documents are cited in the revised Forest Plan and EIS.

Public Concern #295

The Forest Service should consider erosion control before making any designs or changes in dealing with 

motorized used to minimize unnatural soil erosion on the forest.

Response

Erosion control is addressed in best management practices and Standard 2 of soil and water guidelines. 

Forest Service soil and water management activities are guided by FSH 2509.25, Region 2 Watershed 

Conservation Practices Handbook, and Forest Service National Best Management Practice directives. 

These management practices are cited in the revised Forest Plan and EIS

Public Concern #296

The Forest Service should make the following changes: 1-in Background section on page 24 “Watershed 

condition is integral to all aspects of resource management and use. Good watershed management 

maintains the productive capacity of soils, protects water quality and quantity and timing, sustains native 

species, provides beneficial uses, and reduces the threat of flood damage to Forest Service infrastructure 

and downstream values,” 2-specify in soils section what the how exactly the soils will be maintained or 

improved, and 3-on Page 69, water quality, 151 paragraph add language that discusses the impacts from 

cutting trees to increase water yield to water quality.

Response

(1) The wording addition relative to water timing was not added. Timing is generally beyond the control 

of management activities, unless water storage systems are in place. We believe the tie to quality and 

quantity is sufficient. 

(2) The revised Forest Plan identifies the desired condition to maintain soil productivity. This is 

commonly done by applying best management practices, which are referenced in the plan direction. 

Any more specificity is determined during plan implementation and the development of site-specific 

project plans. 

(3) Impacts of cutting trees are discussed in the timber section of the EIS. Those impacts are similar, 

regardless of the purpose for which the trees are being cut.

Public Concern #297

The Forest Service should consider protecting soil and water from mineral development.

Response

Soil and water resources are provided protection through following FSH 2509.25, Region 2 Watershed 

Conservation Practices Handbook, and Forest Service National Best Management Practice directives. 

These management practices are cited in the revised Forest Plan and EIS. 

Public Concern #298

The Forest Service should consider not allowing private water rights to forest water sources and not 

allow the creation of water storage for hydroelectric power
Shoshone National Forest Land Management Plan Revision

788

Response

Management of private water rights is a site-specific issue, outside the scope of the revised Forest Plan 

analysis. In response to changes to water rights proposed by local governments and others, the Forest 

Service will work with local governments and state agencies to help move forward in ways that best 

protect existing water rights, community interests, and public land resources.

Public Concern #299

The Forest Service should address water quality impacts from chemicals and other pollutions since it was 

not addressed in the DLMP and chemical exposure increases from higher motorized use and energy 

development.

Response

This is a site-specific issue and is beyond the scope of the revised Forest Plan analysis. Forest Service soil 

and water management are guided by FSH 2509.25, Region 2 Watershed Conservation Practices 

Handbook, and Forest Service National Best Management Practice directives. These management 

practices are incorporated into the revised Forest Plan and EIS.

Public Concern #300

The Forest Service should consider OHV use as less of impact in stream sedimentation than livestock or 

runoff from road construction or burn areas since OHV crossings don’t necessarily churn up a lot of 

sediment and forest evaluation doesn’t identify any areas where OHV is a major source of stream 

sedimentation.

Response

This is a site-specific issue and is beyond the scope of the revised Forest Plan analysis. Forest Service soil 

and water management activities are guided by FSH 2509.25, Region 2 Watershed Conservation Practices 

Handbook, and Forest Service National Best Management Practice directives. These management 

practices are cited in the revised Forest Plan and EIS. 

Public Concern #301

The Forest Service should preserve and maintain clean water for wildlife migration routes.

Response

Soil and water concerns are the same across the entire Forest. Forest Service soil and water management 

activities are guided by FSH 2509.25, Region 2 Watershed Conservation Practices Handbook, and Forest 

Service National Best Management Practice directives. These management practices are incorporated into 

the revised Forest Plan and EIS.

Public Concern #302

The Forest Service should consider scientifically sound use of culverts.

Response

The use of culverts follows direction found in FSH 2509.25, Region 2 Watershed Conservation Practices 

Handbook, and Forest Service National Best Management Practice directives. These management 

practices are cited in the revised Forest Plan and EIS.

Public Concern #303

The Forest Service should avoid building of roads or trails over the headwaters drainages that lead into 

Buffalo Bill Reservoir since the reservoir has such a high siltation rate.
Final Environmental Impact Statement -- Appendix A

789

Response

This is a site-specific issue and is beyond the scope of the revised Forest Plan analysis. Forest plan 

standards and guidelines cite FSH 2509.25, Region 2 Watershed Conservation Practices Handbook, and 

Forest Service National Best Management Practice directives, designed to protect soil stability and water 

quality.

Public Concern #304

The Forest Service should consider not increasing OHV use since wildlife require soil stability and water 

quality and OHV use would disrupt this for the wildlife.

Response

This issue is beyond the scope of this revision analysis effort. Travel management, including OHV use 

will be analyzed in a separate future analysis effort. Forest plan standards and guidelines are designed to 

protect soil stability, water quality, and wildlife habitat

Public Concern #305

The Forest Service should consider including a map of all ground water resources of the Shoshone 

National Forest to include the following: 1) major aquifers and their characteristics;2) location and 

extent of recharge areas; 3; Characterization of source water protection zones; 4) location of shallow and 

sensitive aquifers; 4) location of existing and potential underground sources of drinking water; 6) 

Incorporate the 2011 data from Wyoming Water Development Commission’s and Wyoming State

Geological Surveys (and 2003) ; 7) and incorporate the Wyoming Groundwater Vulnerability Assessment 

Handbook (SDVC Report 98-01, 1998) as a resource for developing maps of aquifer sensitivity and 

identifying shallow groundwater aquifers susceptible to contamination. Information regarding source 

water protection zones designated by the State of Wyoming is available on the State's Department of 

Environmental Quality website at http://deq.state.wy.us/wqd/www/SWP%20WHP/Documents/02560-

doc.pdf.

Response

Mapping of all ground water resources is beyond the scope of the revised Forest Plan analysis.

Public Concern #306

The Forest Service should consider addressing and elaborating on how the proposed management area 

allocations provide for future activities that might affect water quality in the Clarks Fork of the 

Yellowstone to the confluence with Crazy Creek and how the project design criteria could mitigate 

impacts to be consistent with the Montana Total Maximum Daily Load requirement that address 

impairment in Wyoming. The Forest Service should consider identifying any impaired stream segments 

downstream for the forest, and whether activities could exacerbate or improve condition on impaired 

segments. The Forest Service should consider indicating that the water Quality is not known for many 

miles of rivers and streams within the watershed within the Forest and analyze how alternatives might 

affect water quality in CWA Section 303(d) listed segments and other water bodies regardless of 

impairment or assessment status.

Response

Regarding the 303(d) impaired stream segment of the Clarks Fork of the Yellowstone, restoration targets 

and total maximum daily loads (TMDLs) developed reflect conditions necessary to meet Water Quality 

Standards and, most importantly, to support applicable beneficial uses. Recently the Wyoming Water 

Quality Assessment and Impaired Waters List (2012 Integrated 305(b) and 303(d) Report) noted 
Shoshone National Forest Land Management Plan Revision

790

improvements in water quality of this segment and stated “The Montana TMDLs have satisfied the CWA 

requirements for Wyoming and these impaired reaches have been placed in Category 4A.”

Regarding impaired stream segments that are not within the bounds of the Shoshone National Forest, but 

are within watersheds that are on the Forest: The Forest Service has been a participant in both watershed 

planning efforts as well as TMDL processes for segments within shared watersheds.

Subject: 812 - Water and Soil - Methodology

Public Concern #307

The Forest Plan should include measures to move watershed in the Functioning at Risk category in the 

Functioning Properly category. There should be additional information on where Watershed Condition 

Framework information could be found. And additional discussion on design criteria and BMPs that will 

be used to protect water quality.

Response

The revised Forest Plan contains direction indicating the desire to have watersheds in a properly function 

condition. In addition, reference is made to the Watershed Condition Framework which is used to record 

watershed conditions and to track actions conducted to improve priority watersheds. A link is provided to 

additional information.

On the issue of providing additional information on best management practices and design criteria in the 

FEIS, an appendix was added that provides a general overview of the information included in the 

Watershed Conservation Practices Handbook, The handbook is the repository for best management 

practices references in the revised Forest Plan. Per the Region 2, Watershed Conservation Practices 

Handbook (FSH2509.25), the Forest Service must comply with Federal, state, and local water quality 

laws and rules, coordinate actions that affect water quality with states, and control nonpoint source 

pollution (Section 313). The Forest Service must apply best management practices, considering local 

factors, to control nonpoint source pollution and meet water quality standards (Sections 208, 303, and 

319). State-classified water uses, and the water quality they need, must be sustained to comply with the 

anti-degradation policy, unless states decide that vital economic and social development justify impacts 

(40 CFR 131.12). This handbook along with the National Best Management Practices for Water Quality 

Management on National Forest System Lands provides design criteria for protecting soil and water 

resources. The direction in the Watershed Conservation Practices Handbook is incorporated by reference 

into the forest plan as a standard that requires appropriate design criteria from the handbook to be used 

during plan implementation.

Subject: 813 - Water and Soil - Affected environment

Public Concern #308

The Forest Service should consider discussing the current conditions from soil survey data since the plan 

only mentions that soil survey began in the 1980s.

Response

The Shoshone National Forest soil survey was completed in 2007. This will be clarified in the FEIS.

Public Concern #309

The Forest Service should consider that energy development and increased off road vehicle use will 

increase impacts to soil and water resources since DEIS says alternatives have only little to no negative 

effects will occur from them.
Final Environmental Impact Statement -- Appendix A

791

Response

This is a site-specific issue and is beyond the scope of the revised Forest Plan analysis.

Subject: 814 - Water and Soil - Desired condition

Public Concern #310

The Forest Service should consider keeping natural water systems and not impacting it for livestock or 

open water recreation.

Response

The Forest provides opportunities and resources for a variety of uses. This also applies to water systems. 

Water systems in wilderness are generally in a natural condition. Alternatives with more wilderness (such 

as Alt C) would maintain more water systems in a natural condition. Even in areas where water is used for 

other uses, the watershed conditions are in good condition on the Shoshone. The decision maker will 

consider this input along with that from others in making a decision.

Public Concern #311

The Forest Service should clarify if it has done the assessment of present and potential productivity of the 

land as required by Forest and Rangeland Renewable Resources Planning act of 1974.

Response

The assessment of inquiry is beyond the scope of the revised Forest Plan analysis. The most current 

assessment, Future of America’s Forests and Rangelands: Forest Service 2010 Resources Planning Act 

Assessment is available at: http://www.fs.fed.us/research/publications/gtr/gtr_wo87.pdf.

Subject: 815 - Water and Soil - Direct and indirect effects include general 

effects

Public Concern #312

The Forest Service should consider more in depth discussion of groundwater impacts from oil and gas 

development, consequences to the soil environment based on soil inventories , and watershed conditions 

since plan only say impacts are minor and is not addressed in Alternatives discussion of consequences, 

nor are what is being done to improve is discussed.

Response

This is a site-specific issue and is beyond the scope of the revised Forest Plan analysis.

Subject: 817 - Water and Soil - Climate change

Public Concern #313

The Forest Service should consider climate change when analyzing negative impacts to water since 

ground and surface water is required for agriculture, human consumption, wildlife, and energy 

development.

Response

Climate change in relation to soil and water concerns is addressed in the EIS on page 83. Rice et al. 

(2012) describe the potential effects in detail.
Shoshone National Forest Land Management Plan Revision

792

Subject: 818 - Water and Soil - Incomplete and unavailable information

Public Concern #314

The Forest Service should clarify how many watersheds are functioning at risk since page 65 says 3% 

and page 71 says 11%. The Forest Service should consider addressing and clarifying the additional 

information, data, and analysis, or discussions in the FEIS based on the EPA rating.

Response

This wording will be clarified in the final decision.

Subject: 819 - Water and Soil - Monitoring

Public Concern #315

The Forest Service should consider making requirements baseline water monitoring plan and water 

quality analysis in order to keep sedimentation low and keep good water for the communities that get 

from the forest.

Response

Forest Service soil and water management activities are guided by FSH 2509.25, Region 2 Watershed 

Conservation Practices Handbook, and Forest Service National Best Management Practice directives. 

These management practices are incorporated into the revised Forest Plan and cited in the EIS.

Subject: 831 - Water and Soil - Desired Condition

Public Concern #316

The Forest Service should make the following change on page 24: Productive soils and sustainable 

ecosystems are maintained when soil impacts, such as erosion, displacement, compaction, burning, and 

nutrient drains, are managed by best management practices within historic range.

Response

We don't think it is appropriate to add the qualification “within historic range.” The concept of historic 

range is not considered a good management objective because of shifts that are occurring in climate and 

disturbance regimes.

Subject: 832 - Water and Soil - Goals

Public Concern #317

The Forest Service should make the following changes on page 24: All groundwater and surface waters 

meet State of Wyoming water quality standards to fully support State of Wyoming designated uses and are 

of sufficient quality and timing to support surrounding communities, municipal water supplies, and 

natural resources. Groundwater and surface water quantity, quality, and timing are consistent with 

landscapes that are managed for stand size and composition consistent with Historic Range of Variation 

(HRV).

Response

We believe the focus on quality and quantity addresses all that is needed. We have limited control of 

timing and timing is a subset of the quantity.
Final Environmental Impact Statement -- Appendix A

793

We don't think it is appropriate to add the goal tied to historic range of variation. The concept of historic 

range is not considered a good management objective because of shifts that are occurring in climate and 

disturbance regimes.

No change was made. The existing goal meets management intent.

Subject: 833 - Water and Soil - Objectives

Public Concern #318

The Forest Service should establish quantifiable standards for water and soil as well as clear objectives 

that address the restoration of functioning at risk watersheds to a functioning properly condition since the 

draft plan is lacking for water and soil while they exist for other resources. If a full restoration of 

watershed cannot occur during the life of the Forest Plan, then it should be noted in the EIS and the 

objective should be modified.

Response

We added additional information in the EIS and forest plan about the watersheds functioning at risk. 

There is information in the management approach that addresses how they will be addressed in plan 

implementation. The objectives for those areas are being handled in the context of the Watershed 

Condition Framework outside the revised Forest Plan and we think it is best to address the objectives 

within that context.

Subject: 835 - Water and Soil - Guidelines

Public Concern #319

The Forest Service should add the following paragraphs to the guidelines. 1-Page 26, under paragraph 4 

–Fire and Fuels: Fire and fuels management strategies are designed to approximate the HRV for the 

watershed. Active vegetation management, as well as prescribe fire, is a tool preferred over 

indiscriminate wildfire until natural fire regimes can be restored. 2- On page 26 create a section entitled 

Roads and include the following new paragraph: Road management includes the use of temporary roads 

and road ―rollup potential for temporary roads

Response

Direction on fire and fuels management and use of temporary roads is found in the fire and roads sections 

of the revised Forest Plan.

Public Concern #320

The Forest Service should define and increase stream buffers for native trout species for the protection of 

aquatic resources and health of the watershed ecology and should also identify measures used for the 

protection of groundwater and aquifers within oil and gas leasing areas and avoid surface disturbance to 

sensitive soils and slopes greater than 30%.

Response

Identifying specific protection measures for oil and gas leasing activities is a site-specific issue and is 

beyond the scope of the revised Forest Plan analysis. Forest Service soil and water management activities 

are guided by FSH 2509.25, Region 2 Watershed Conservation Practices Handbook, and Forest Service 

National Best Management Practice directives.

These management practices are incorporated into the revised Forest Plan and cited in the EIS.
Shoshone National Forest Land Management Plan Revision

794

Subject: 836 - Water and Soil - Management Approach

Public Concern #321

The Forest Service should make the following changes to Management Approach on page 26:Watershed 

improvement/restoration projects include activities focused on water quality, quantity, and timing, 

riparian and stream ecosystem function, soil productivity, and maintaining or restoring resilient 

vegetation conditions. Five examples include : 1) Implementing best management practices to filter 

sediment from runoff from roads and trails before it enters water courses and riparian areas2) 

Eliminating cheatgrass to restore soil productivity3) Stabilizing stream banks adjacent to infrastructure4) 

Active vegetation management and fire management that approximate HRV, and 5) restoring vegetation 

conditions impacted by intense wildfire or severe insect epidemics.

Response

Suggested changes are not made. Watershed improvement or restoration projects are generally focused on 

water quality, not quantity and timing. The sugested fourth item was not added. The list specifically 

identies those items that are factors in determining whether a watershed is functioning at risk. The 

suggested fourth item is a tool for addressing those factors.

Public Concern #322

The Forest Service should identify the current and/or proposed management actions that will be taken to 

improve the conditions of the watersheds that have some impacts or are functioning at risk.

Response

Individual watershed improvement projects are a site-specific issues and are is beyond the scope of the 

revised Forest plan analysis. Forest Service soil and water management activities are guided by FSH 

2509.25, Region 2 Watershed Conservation Practices Handbook, and Forest Service National Best 

Management Practice directives. These management practices are incorporated into the revised Forest 

Plan and cited in the EIS.

Public Concern #323

The Forest Service should make sure that "soil capabilities, potentials and limitations are appropriately 

considered in designing management activities" in the grazing capability and suitability analysis.

Response

The livestock grazing capability and suitability analysis was reviewed and updates made accordingly in 

the FEIS. Forest Service soil and water management activities are guided by FSH 2509.25, Region 2 

Watershed Conservation Practices Handbook, and Forest Service National Best Management Practice 

directives. These management practices are incorporated into the revised Forest Plan and cited in the EIS.

Subject: 850 - Riparian/Wetlands - Resource - General

Public Concern #324

The Forest Service should consider the effects on wetlands and riparian areas when considering the 

future use of motorized vehicles on the forest.

Response

The Shoshone Forest does consider the effects on wetlands and riparian areas when addressing the future 

use of motorized vehicles on the forest. Direction and guidance is provided in the Region 2 Watershed 

Conservation Practices Handbook primarily in section 12 which is referenced in the revised Forest Plan in 
Final Environmental Impact Statement -- Appendix A

795

standards for water and soil, pages 25 and 26. The DEIS referenced the Region 2 Watershed Conservation 

Practices Handbook in chapter 3, section:Water and Soil, Resource Protection Measures on page 64. The 

handbook can be found at: http://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsh?2509.25!r2.

Other related wetland and riparian direction and guidance is provided in both Forest Service Manual and 

Handbook Directives (i.e., FSM 2500 and FSH 2509.25), Executive Orders, and the National Best 

Management Practices for Water Quality on National Forest System Lands (FS-990a). These documents 

are referenced in the water and soil section of chapter 3 in the EIS.

Forest Service Handbook 7709.56 addresses road location and 7709.56b chapter 2 addresses road design. 

They are referenced in the roads section of chapter 3 in the revised Forest Plan. 

Subject: 852 - Riparian/Wetlands - Methodology

Public Concern #325

The Forest Service should consider the following in wetland and riparian management (1) Not lumping 

riparian and wetland areas together as wetlands may not occur within recognized riparian zones. (2) 

Define fens distinctly from other kinds of wetlands and map them for planning land management 

activities. (3) Recognize temporary wetlands under the Plan as they are at the most risk and could be 

adversely affected in management actions. (4) Under Goal 8, page 33 aspires to have riparian and 

wetland habitats in "proper functioning condition" but this term does not relate to 4 service requirements 

his methodology is well below the level needed to provide water quality wildlife habitat or fisheries.

Response

(1) Wetlands are part of riparian habitat. Forest Service Manual 2509 defines Riparian Ecosystems as a 

transition area between the aquatic ecosystem and the adjacent terrestrial ecosystem; identified by soil 

characteristics or distinctive vegetation communities that require free or unbound water. Wetlands are 

defined as areas that are inundated by surface or ground water with a frequency sufficient to support 

and that, under normal circumstances, do or would support a prevalence of vegetation or aquatic life 

that requires saturated or seasonally saturated soil conditions for growth and reproduction. Wetlands 

generally include swamps, marshes, bogs, and similar areas such as sloughs, potholes, wet meadows, 

river overflows, mud flats, and natural ponds. Although wetlands are defined as part of riparian 

habitat they are identified and managed separately on the Forest. 

(2) Fens are considered a type of wetland. Fens are further defined and management direction is given in 

R2 FSH 2631.3. Inventory work has started in the Beartooth Mountain portion of the Forest. 

Continuation of this work is discussed in the revised Forest Plan Sensitive species goal number 6

(page 45). 

(3) Wetlands are defined as mentioned in item (1) above. 

(4) Goal 8, p 33. We will delete properly functioning from the sentence to reduce confusion.

Subject: 853 - Riparian/Wetlands - Affected environment

Public Concern #326

The Forest Service should add or refer to monitoring information to support the discussion of riparian 

habitat improvement in Chapter 3 of the Plan.

Response

Forest riparian monitoring consists of annual range allotment inspections and field monitoring. Riparian 

conditions are also updated during the Range Environmental Analysis process and then incorporated into 
Shoshone National Forest Land Management Plan Revision

796

the Forest riparian condition data base. Best management practices site visits are conducted annually for 

selected range allotments and timber harvest activities including roads and stream crossings. Stream 

habitat surveys are periodically conducted by the hydrology and fisheries staff. All of this information is 

used to determine riparian condition on the Forest.

Subject: 876 - Riparian/Wetlands - Management approach

Public Concern #327

The Forest Service should discuss how riparian areas and wetlands will be protected from undue impacts 

and provide goals, objectives, and standards for wetlands and include seasonal and isolated wetlands and 

prohibit insecticide and herbicide use. Stronger buffers or setback establishments should be included.

Response

Management measures and design criteria for protecting riparian and wetland habitat is described in detail 

in the Region 2 Watershed Conservation Practices Handbook, primarily in Section 12 which is referenced 

in the Draft Plan in standards for water and soil, pages 25 and 26. In the EIS it is reference d in chapter 3, 

water and soil, resource protection measures on page 64. It can be found at: http://www.fs.fed.us/cgibin/Directives/get_dirs/fsh?2509.25!r2.

Chemical use management activities on National Forest System lands are guided by FSH 2509.25, 

Region 2 Watershed Conservation Practices Handbook, and Forest Service National Best Management 

Practice directives. These management practices are cited in the soil and water section of chapter 3 of the 

EIS.

One of the primary land management strategies is to use management techniques that simulate natural 

processes, which includes disturbances. Periodic disturbance is an integral part of natural process on the 

landscape that is required for long-term sustainability of aquatic ecosystems (Kreutzweiser et al. 2012). 

These land management activities result in acceptable short-term disturbances with proper 

implementation, administration, and compliance of forest plan standards, guidelines, Region 2 Watershed 

Conservation Practices Handbook and other Federal and State land management direction. These shortterm disturbances result in long-term benefits to the riparian ecosystem and the biota that use them 

including Yellowstone cutthroat trout. This approach is discussed in the draft Forest Plan in chapter 1, 

aquatic species on page 3 and the DEIS, chapter 3, environmental consequences, page 310.

Creating riparian buffer protection zones and setbacks for all management activities delays succession, 

reduces vegetative diversity and nutrient productivity, and increases the chances for large-scale fires 

substantially outside the natural range of variability (Van de Water and North 2012). Researchers felt that 

the current “hands-off” management approach for riparian habitat management under the Northwest 

Forest Plan will continue on an altered trajectory of ecological processes and have undesirable long-term 

consequences (Messier et al. 2012).

Rather than blanket setbacks and riparian buffers 0.5 mile wide, the draft plan proposes management 

activities, where appropriate, that simulate natural processes as much as possible. Buffers and setbacks 

may be used where and when appropriate and adjusted to fit the conditions including landscape. 

Additionally, very few of the riparian areas in the Absaroka geology (which comprises two-thirds of the 

Forest and contain most of the Yellowstone cutthroat trout and mountain sucker habitat) are 0.5 mile 

wide. This is because the drainages in the volcanic geologies are typically steep and incised due to natural 

geologic conditions. We have substantial riparian management direction contained in various resource 

areas within the proposed forest plan. The primary management reference for riparian habitat is section 12 

of the Region 2 Watershed Conservation Practice Handbook, which is referenced the DEIS chapter 3, 
Final Environmental Impact Statement -- Appendix A

797

water and soil, resource protection measures on page 64. The handbook can be found at: 

http://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsh?2509.25!r2. With proper implementation, 

administration, and compliance, riparian habitat and the species that use them will be adequately 

protected.

Chemical use management activities on National Forest System lands are guided by FSH 2509.25, 

Region 2 Watershed Conservation Practices Handbook, and Forest Service National Best Management 

Practice directives. These management practices are cited in the Forest Plan and DEIS.

Public Concern #328

The Forest Service should address the following: (1) The draft Land Management Plan does not 

acknowledge livestock damage to willows. (3) Address the impacts of conifer removal to sensitive bird 

species and that conifer encroachment may be exaggerated in some areas. (2) The amount of acres of 

willows that can be restored by working with WGFD to constrain or limit the trapping and local 

eradication of beavers.

Response

Livestock damage to willows is discussed in the DEIS on page 125. Acceptable livestock use levels for 

willow are found in the draft plan, chapter 1, guidelines for vegetation, commercial livestock grazing #4, 

5 on pages 34 and 35. Willow use and potential effects are included in the Watershed Conservation 

Practices Handbook in section 12.1 which can be found at: http://www.fs.fed.us/cgibin/Directives/get_dirs/fsh?2509.25!r2 and the Region 2 Rangeland Training Handbook.

The effects of conifer removal to sensitive birds is discussed in the DEIS on pages 194 through 208. 

revised Forest Plan goal #8, page 47 addresses beaver habitat condition. Objective 3 for sensitive species 

on page 48 of the plan discusses beaver expansion. The management approach for aquatic habitat is 

discussed on page 259. In the revised Forest Plan, on page 51, collaborating with Wyoming Game and 

Fish Department on species population management is discussed.

Subject: 900 - Air Quality Resource –General

Public Concern #329

The Forest Service should provide for more backcountry non-motorized use because motorized use has 

adverse effects including degradation of air, water, and snow, disturbance to wildlife, and noise, pollution 

and safety issues that disrupt the quality of non-motorized use. The Forest Service should consider and 

address the importance of air quality in the tourism and recreation experience.

Response

Non-motorized back country recreation opportunties are provided in all alternatives (see EIS chapter 3, 

recreation section). Goals for air quality in the revised Forest Plan include 

• “Air quality meets Clean Air Act and Wilderness Act requirements and Environmental Protection 

Agency-approved Wyoming air quality standards.” 

• “Air quality is stable or improving in Class 1 airsheds on the Shoshone.”

Public Concern #330

The Forest Service should update page 99 of the DEIS to reflect that winter motorized use is retained in 

alternative B, and conduct a general conformity analysis for any project emissions occurring in an area 

designated as nonattainment or maintenance for the NAAQS, and note that if future activities in the 
Shoshone National Forest Land Management Plan Revision

798

nonattainment area trigger the need for a general conformity analysis, then the general conformity 

analysis for such future activities would be included in the USFS's project-specific NEPA analysis

Response

The FEIS will be updated to reflect that winter motorized use is retained in alternative B and it will be 

noted as a guideline in the plan that any future activities in the nonattainment area would trigger the need 

for a general conformity analysis. The nonattainment areas fall within wilderness so such future activities 

are not anticipated.

Public Concern #331

The Forest Service should protect the Shoshone National Forest from the air and water pollution created 

by drilling, mining and unlimited exploitation by employing management direction to mitigate the 

impacts.

Response

The revised Forest Plan contains direction for protecting soil, water, and air resources consistent with the 

Clean Water and Clean Air Acts. In addition, during plan implementation, any specific mining or leasing 

proposed actions would be evaluated and site-specific mitigation measures would be developed specific 

to the proposal to protect soil, water, and air resources.

Public Concern #332

The Forest Service should maintain or provide more wilderness to protect air-sheds.

Response

The Shoshone has 60 percent of its acreage in designated wilderness. In large part, the Shoshone is a nonmotorized, back country forest. Alternatives C and D propose additional wilderness recommendations. 

The revised Forest Plan includes goals to protect and improve the air quality in Forest airsheds.

Public Concern #333

The Forest Service should provide specific plans to monitor water and air quality and add a standard 

with the objective of maintaining Wyoming stream designations.

Response

This is addressed in the monitoring section in chapter 3 of the revised Forest Plan. Maintaining Wyoming 

stream designation is stated as goal 3 (page 23, forest plan); and soil and water standard number 1 (page 

25);

Subject: 901 - Air Quality - Legal and administrative framework

Public Concern #334

901-1 The Forest Service should add No Surface Occupancy stipulations to lands adjacent to BLM lands 

that have no oil and gas availability in order to support the Clean Air Act, 42 U. S. C. , 7475(d) (2) (B) 

and that the FEIS include a discussion regarding the USFS's plans to address the CAA and 40 CFR 93

“Subpart B” General Conformity requirements for emissions from USPS-authorized activities in the 

UGRB Ozone Nonattainment Area.

Response

We are aware that a general conformity analysis could be required for future development that might 

occur within the boundaries of the Upper Green River ozone nonattainment area. Any air quality analysis 
Final Environmental Impact Statement -- Appendix A

799

conducted as part of a future project-level NEPA analysis will be conducted in accordance with the 

national air quality memorandum of understanding and will include a general conformity analysis if one 

is required. A discussion of the Forest’s plans for complying with conformity analysis requirements has 

been added to the EIS.The Forest will include a discussion in the FEIS regarding plans to address general 

conformity requirements for emissions in nonattainment areas.

Subject: 907 - Air Quality - Climate change

Public Concern #335

The Forest Service should consider conserving Shoshone National Forest lands for future generations 

and to curb the onslaught of global warming due to removing clean atmosphere from our planet.

Response

See PC #331.

Subject: 923 - Air Quality - Objectives

Public Concern #336

The Forest Service should establish standards for air quality that are quantifiable and measurable and 

that include the measurements that will be taken (p.28 DLMP).

Response

Ambient air quality standards are prescribed by State and Federal statute. These standards appeared in the 

DEIS on page 85. The standards must be met and compliance with these standards is evaluated with 

monitoring data. Pages 90 through 92 present recent monitoring data collected near the Shoshone 

National Forest. In addition, the Environmental Protection Agency has promulgated the Regional Haze 

Rule, which sets quantifiable visibility goals for all 156 Class I areas in the United States, including those 

located in the Shoshone National Forest (the North Absaroka, Washakie, and Fitzpatrick Wildernesses). 

Progress toward the visibility goals for these wildernesses is measured by the IMPROVE visibility 

monitoring network. This program is discussed in the EIS on pages 93 through 96 and data from 

representative monitors are presented.

Subject: 950 - Vegetation - Resource - General

Public Concern #337

The Forest Service should consider enhancing guidelines in the forest plan to provide adequate direction 

for management of forest vegetation in regards to harvesting, maintaining oldgrowth, pathogens, insect 

epidemics, wildfire, native wildlife, and livestock grazing. Table 4 of the forest plan and Table 29 of the 

DEIS do not reflect the current age class distribution by cover type especially for conifers considering the 

recent fires and insect epidemic. A separate table is needed to provide evidence of the shift in age class 

diversity by cover type reflecting the recent insect epidemic and fires. The forest service should also 

evaluate the development of new merchandizing methods of forest products. These actions are needed 

because it would provide direction for the quantity and type of management needed to help move the 

forest towards the desired conditions while taking into account the impacts of the recent insect epidemic. 

New methods of merchandizing forest products would help local markets remain viable.

Response

The vegetation data used in the analysis have been updated to reflect the changes during the last 10 years 

from fire and insects. The timber yield tables were adjusted to simulate the effect from the ongoing insect 
Shoshone National Forest Land Management Plan Revision

800

epidemics. The effects analysis considers the current and future impacts from changes in fire regimes and 

insect epidemics. It is not the purpose of the forest plan to evaluate new merchandizing methods of forest 

products. The revised Forest Plan contains language to indicate that we will respond to the demand for 

new products.

Public Concern #338

Forest types across the Shoshone NF have moved away from their natural condition (dominated by large 

swaths of mature to late-successional forest) into an unhealthy fragmented state which hinders the 

viability of many species such as the fisher, pine martin, lynx, brown creeper and others. Desired 

conditions should address the proportion of the landscape targeted for management of the different plant 

community types, based on long-range range of natural variability. Desired conditions should maintain 

and protect the biological diversity (tree species and wildlife) in the Shoshone National Forest while 

considering the effects of drought and climate change. Snags should be retained in post-fire stands and be 

expressed as a goal with standards-based thresholds in the plan. Additional forest disturbance will exceed 

what the forest can support. These actions are needed to preserve wildlife species richness and viability in 

low elevation forested lands and move the forest towards its historic variability

Response

Only a small percentage of the forest is actively managed. Most of the disturbance that happens on the 

forest is naturally occurring. The majority of the forest will remain in an unmanaged state. The desired 

conditions for vegetation indicate how much of each cover type is desired on the forest. The revised 

Forest Plan contains direction for retaining snags in managed areas. Currently there is no shortage of 

snags on the forest.

Public Concern #339

The Forest Service should consider maintaining the current levels of harvesting and oil and gas 

production because any increase in harvesting or oil and gas production will reduce the quality of the 

visitors’ desire for a pristine experience.

Response

Alternatives B, C, and D all project total timber harvest below current harvest levels. No increase in oil 

and gas development is projected in any of the alternatives. The decision maker will consider these 

alternatives along with other comments in making a final decision.

Public Concern #340

The Forest Service should update its approach of wilderness management using best available science. 

The Forest Service should increase management of the forest, rangelands, big game crucial winter range 

and reduce livestock usage. This is needed because the Shoshone NF needs to ensure the viability of the 

big game populations which promotes tourism the mainstay of the Cody, WY economy.

Response

The portion of the Forest actively managed in the alternatives varies widely between alternative C and 

alternative F, which manages over twice as many acres as alternative C. No active management can occur 

in designated wilderness areas. Within this range, the alternatives provide habitat for big game 

populations to meet Wyoming Game and Fish population objectives. The decision maker will consider 

comments on increasing area of active management along with other comments asking for less active 

management in making a final decision.
Final Environmental Impact Statement -- Appendix A

801

Public Concern #341

What is an example of the Forest Service’s plan for early detection and planned response when 

encountering new invasive species?

Response

With respect to invasive species (plant, pathogen, vertebrate, or invertebrate species), rapid responses are 

defined as the quick and immediate actions taken to eradicate, control, or contain infestations that must be 

completed within a relatively short time to maximize the biological and economic effectiveness against 

the targeted invasive species. Depending on the risk of the targeted invasive species, rapid response 

actions may be supported by an emergency situation determination and emergency considerations would 

include the geographic extent of the infestation, distance from other known infestations, mobility and rate 

of spread of the invasive species, threat level and potential impacts, and available treatments. 

Public Concern #342

The Forest Service should consider a conservative approach to land management in the sagebrush steppe 

habitats. The Forest Service should consider including in the forest plan requiring a minimum retention of 

150 linear feet per acre of coarse wood debris. The Forest Service should consider including in the forest 

plan provisions for retaining not less than 10 snags per acre throughout the Forest. These actions are 

needed because the sagebrush steppe ecosystem is home to many rare or declining wildlife species.

Response

The revised Forest Plan contains direction to maintain and protect sagebrush habitat, including specifics 

on protection from fire and invasive species. The desired conditions for snag densities across the forest 

are generally above 10 snags per acre. In the small portion of the forest that is actively managed, a lower 

density is specified. Currently there are high densities of snags across the forest. In managed areas of the 

forest, the plan contains guidance on maintaining a minimum level of down woody debris.

Public Concern #343

The Forest Service should offer proof that supports their claim that forest cover and species diversity 

have increased or have remained similar to historic distribution?

Response

In the EIS under the vegetation section there is a section titled “Comparison of current cover type 

distribution to historic distribution” that explains the conclusion on the current vegetation distribution. 

Though there are dramatic changes occurring from insect and fire disturbances, those changes do not 

change what is desired in the future. What is changing is the starting position. These changes are 

increasing diversity by moving the forest away from a landscape dominated by large expanses of mature 

forest.

Public Concern #344

The Forest Service should consider making the following changes:

The Forest Service should change “annual estimate” to “average annual” for TSPQ and ASQ. On pages 

118-120 of the Forest Service discusses vegetation structure components. The last paragraph on page 119 

regarding the effects of the insect epidemic on 70 percent of the conifer stands on the Shoshone NF 

appears to trump all other discussion on pages 118 and 119. If the large shift in age class distribution is 

occurring because of the widespread insect epidemic, why spend any time discussing those other “minor” 

trends?
Shoshone National Forest Land Management Plan Revision

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It states on page 119 that Table 29 shows the shift from older forests to younger forests. Data in Table 29 

does not show the shift from older forest to younger forests as mentioned in the previous page.

The Forest Service should consider deleting paragraph 5 on page 120 of the DEIS. It is a repeat of the 

information provided in the first paragraph of page 120.

The Forest Service should consider including discussion and rationale about how and why there are 

differences between Tables 28 and 32 of the DEIS and what is the justification behind those changes.

The Forest Service should delete the fourth paragraph reference on page 280 of the DEIS forthe 

designation of old growth late successional forest. Habitat is not appropriate or necessary or 

management indicator species. The Forest Service should not designate suitable timberlands as old 

growth or late successional habitat.

The Forest Service should have as much specificity on the impacts of livestock grazing as it does when 

identifying snags per acre.

The Forest Service conflates the issue of streambank stability with streambank alteration. This section 

deals with annual move on use criteria so a long-term parameter such as streambank stability is 

inappropriate. Streambank alternation is the appropriate measure here. (pg. 315 DEIS)

On page 132 of DEIS, the Forest Service should call cheatgrass an invasive species not a noxious weed.

Response

The change was not made to average annual for TSPQ and annual sale quantity (ASQ) . The EIS numbers 

are providing an estimate of effects. They do not establish any direction. The Forest Plan is where the 

direction is established and it is written there to provide management flexibility.

Discussing the minor as well as the major changes helps to put the minor changes into context.

The table 29 reference was not meant to justify the statement. It was just a reference to the table. The 

reference was removed to avoid confusion.

Paragraph 5 was deleted.

Table 32 in the EIS is incorrect. It should match table 1 from the revised Forest Plan. That table is more 

aligned with table 29 in the EIS. Table 32 will be replaced.

We will take a look at the reference to late successional forest. This language may not be exactly right. 

For issue of mature stands on suitable timber land see PC #355.

Range data are provided in chapter 3 of the EIS as well as a more detailed breakdown in appendix F. 

We will revise the sentence to say “invasive species.”

Public Concern #345

The Forest Service should review tables 103, 104, 105 and 106 for accuracy and consistency. Specifically 

are the acres in Table 104 and the costs in revenues in Table 105 calculated on an annual or decadal 

basis? Is the volume in Table 103 only from suited timberlands, or does it also include volume from OVM 

lands? Also, we are confused about which volumes in Table 103 are in MCF and which are in CCF
Final Environmental Impact Statement -- Appendix A

803

Response

See PC #636.

Subject: 953 - Vegetation - Affected environment 

Public Concern #346

The Forest Service should consider revising as the forest plan where it states that ”riparian vegetation 

composition and structure are similar to what would be expected with natural disturbance process”. The 

forest plan needs to contain direction on how to treat riparian areas.

Response

The direction in the Watershed Conservation Practices Handbook referenced in the standards section for 

soil and water contain direction for managing riparian areas.

Public Concern #347

The Forest Service should consider revising the vegetation discussion on pages 106-139 of the DEIS as it 

appears to be out-of-date. Additionally, the Desired Conditions in Table 1 and Table 3 of the Draft Plan 

likely cannot be achieved and will prove to be much more constraining to on-the-ground implementation 

than anticipated in the DEIS. The DEIS is not showing the shift in age classes resulting from the insect 

epidemic and therefore fails to address impacts on management decisions.

Response

The EIS discussion on vegetation is updated to reflect the impacts from recent insect epidemics and 

wildfire. The current condition is based upon recent updated vegetation inventories. Appendix B to the 

EIS contains information on the update. Though insects and fire are changing the current vegetation 

condition, those changes do not change what is desired in the future. What is changing is the starting 

position not where we want to end up.

Subject: 954 - Vegetation - Affected environment - Rangeland

Public Concern #348

The Forest Service should consider the existing monitoring data and the current conditions of rangeland 

and expound on the positive trends when analyzing other resources and resource uses.

Response

Existing montoring data is used to present the current effects of livestock grazing on the forest. That 

information is presented in the rangeland discussion in the EIS. Livestock grazing has the potential to 

impact forest resources and that potential is portrayed in the EIS effects discussion. The effects discussion 

also indicates that with the implementation of best management practices and other grazing management 

those effects are mitigated. The EIS effects discussion also points out some areas that need improvement 

from past impacts.

Subject: 955 - Vegetation - Affected environment - Cover types

Public Concern #349

The Forest Service should consider using fire not harvesting as the desired method of managing for 

species composition and age class diversity within aspen stands. The forest plan should manage for the 

retention of mature aspen stands and to allow aspen stands to be overtaken by conifers, creating a mixed 

aspen-conifer woodland of superior value to wildlife. The Forest Service should monitor aspen stands 
Shoshone National Forest Land Management Plan Revision

804

that are within grazing permit boundaries to prevent excessive damage resulting from over grazing or 

trampling. These actions are needed to provide age and size class diversity within aspen stands for forest 

health and wildlife species that desire early, mid, or late seral habitat.

Response

Aspen is not a commercial species on the Shoshone. Any management activity for aspen would be strictly 

for the purpose of benefiting aspen. The revised Forest Plan includes direction that both mechanical and 

fire treatments are used to enhance aspen. The plan contains direction to maintain a diversity of age 

classes for aspen.

Public Concern #350

The Forest Service should clarify the benefits of management techniques versus wildfire for the purposes 

of aspen restoration. Aspen restoration through management is safer and easier to regulate the intensity 

of disturbance. Even though aspen is a non-commercial species, its importance on commercial lands 

should not be underrated. Single use of commercial lands is a sure way to continually perpetuate conflict.

Response

The discussion in the EIS is specific to management on suitable timber lands and does not imply that any 

management technique is preferable across the forest. Being that suitable timber lands are generally 

accessible, the use of mechanical treatments is commonly more feasible. In addition, given the 

accessibility of suitable timber lands, wildfire is generally controlled easier and as such wildfire is less of 

a factor in perpetuating aspen on suitable timber lands.

The statement in the management approach about balancing aspen restoration activities against the need 

to provide commercial species on suitable timber lands was placed in response to some publics that 

believe this should be considered. It does not imply single use on suitable timber lands, but reflects that 

one of the primary purposes is to manage for commercial species.

Subject: 957 - Vegetation - Affected environment - Unique habitats

Public Concern #351

When evaluating impacts to some riparian areas from livestock grazing the Forest Service should use 

photos less than 10 years old. Current impacts must be determined by more recent aerial photos or more 

current monitoring information. If estimating impacts in the field, the Forest Service should use a 

quantifiable method not ocular estimates when evaluating environmental impacts of utilization by 

livestock. In order to make the best judgement concerning impacts to riparian area the most recent photos 

are essential for having up to date information. Similarly, when evaluating impacts in the field, a 

quantifiable method is better than an ocular estimate.

Response

The vast majority of riparian site-monitoring photographs and data collected within livestock grazing 

allotments is more recent than 10 years. Both quantitative and ocular methods are used to monitor riparian 

areas, depending on the sites’ existing condition, type, and resource issues involved.

Subject: 958 - Vegetation - Desired condition

Public Concern #352

The Forest Service should better define what “desired conditions” are to help define the desired 

management techniques to achieve the desired goals. The Forest Service should also, develop a 
Final Environmental Impact Statement -- Appendix A

805

quantifiable means of measuring management indicators. By doing so the Forest Service would develop 

goals and a method for determining their success in moving towards their desired goals.

Response

The revised Forest Plan direction, particularly desired conditions, is somewhat general in nature to allow 

for flexibility. More specificity is in the underlying plan components, which provide additional direction. 

The assessment of site-specific conditions and situations is done at the project level. The plan is not 

intended to include direction for each possible situation, but rather to provide a framework within which 

the site-specific project analysis is done.

Public Concern #353

The Forest Service needs to explain how achieving the desired percentages by cover type will affect the 

cover type percentages within suitable timberlands. The Forest Service should maintain the current 

combined acreage of Douglas-fir, spruce/fir, and lodgepole pine on suited timberlands.

Response

The only way that cover type desired conditions could impact suitable lands is if the plan directed that 

type conversion should occur. There is no such direction in the revised Forest Plan. The plan direction is 

to maintain a mix of cover types that is based upon site capability.

Subject: 959 - Vegetation - Direct and indirect effects

Public Concern #354

The Forest Service should conduct an objective investigation of the potential adverse effects of thinning 

and forest manipulation in this ecosystem including their effects on old forests and the wildlife that 

depend on old forests.

Response

The effects of potential management actions are discussed in the EIS. Harvest levels in any of the 

alternatives represent a very small percentage of the Shoshone. All alternatives, except F, project harvest 

of well under 1,000 acres a year, and alternative F is about 1,200 acres a year.

Subject: 962 - Vegetation - Direct effects - Vegetation structure components

Public Concern #355

The Forest Service may not be able to manage 5 to 15% of each forest type with long, 150 year for 

lodgepole pine (LP) and 200 year rotation for all other species, especially in MA 5.1. These desired 

conditions may not be achieved due to beetle epidemics and fire and would result in reduced outputs. 

Inventory data is not precise enough to achieve desired conditions in DEIS Table 3.

Response

The desired condition should be easily achievable. It does not require that 5 to15 percent of the suitable 

timber lands be in an old age class, but rather that 5 to 15 percent of all lands be in an old age class. The 

guideline associated with the desired condition is tied to watershed boundaries. Watersheds are never 

entirely made up of suitable timber lands. There are commonly inclusions of steep lands, inaccessible 

areas, visually sensitive areas, and other management areas that are not suitable timber that can provide 

older stands. It would generally not be necessary to manage suitable timber lands on long rotations to 

meet the old age class desired condition.
Shoshone National Forest Land Management Plan Revision

806

Public Concern #356

The Forest Service should place more emphasis on habitat management through mechanical means to 

create a diverse and mixed age forest and grassland mosaic.

Response

On managed lands, mechanical treatments are a key component in plan implementation. That direction is 

reflected in the revised Forest Plan.

Subject: 965 - Vegetation - Climate change

Public Concern #357

The Forest Service should include projected climate change effects, including longer summers, shorter 

winters and changes in water runoff timing. These changes could affect extent and location of wildlife 

habitat and may affect species dependent on various vegetation types.

Water availability for agriculture, municipal, and recreation use could impact residents, tourists, and 

local economies.

Response

The effects of climate change on vegetation are discussed in the EIS. See also response to PC #287.

Subject: 966 - Vegetation - Incomplete and unavailable information

Public Concern #358

The Forest Service DEIS, should cite scientific studies that support “disturbance effects may aid White 

Bark Pine restoration”.

Response

The referenced guidance Whitebark Pine Strategy for the Greater Yellowstone Area provides such 

support.

Subject: 967 - Vegetation - Monitoring

Public Concern #359

The Forest Service should clarify in PLAN Chapter 3 if monitor techniques refers to the old range 

condition classes of poor, fair, good, and excellent.

Response

It refers to that technique or something similar. The revised Forest Plan isn’t going to provide a specific 

technique. It just indicates that range condition should be monitored. Techniques can change as new 

science becomes available.

Public Concern #360

The Forest Service should add moth sites/moths, harvested big game gut piles, and vegetation/climate to 

White Bark Pine cone production as key grizzly bear food sources to DLMP page 210.
Final Environmental Impact Statement -- Appendix A

807

Response

Only certain grizzly bear food items that can be impacted by land management activities will be 

monitored. Moth sites, already monitored by the Interagency Grizzly Bear Study Team, could be added to 

the monitoring plan. Gut piles are not a result of land management activities.

Public Concern #361

The Forest Service should monitor White Bark Pine natural regeneration, use a 5 or 10 year monitoring 

cycle and measure treatment acres designed to increase aspen, willow and WHITE BARK PINE to 

determine vegetation health.

Response

Whitebark pine is being extensively monitored. Some of the latest information is the referenced guidance 

Whitebark Pine Strategy for the Greater Yellowstone Area. We are monitoring cover type rather than 

treatment acres, because some of the changes we hope to get are from natural fire impacts and other 

natural succession. We agree it would be a good idea to change the monitoring cycle from 1 year to 5

years for whitebark pine.

Subject: 981 - Vegetation - Desired condition

Public Concern #362

The Forest Service should justify and explain the desired conditions percent in plan Table 1, page 31. 

These figures appear to be low and not science based and that the Vision, Goals and Objectives seem to 

be moving toward a Desired Future Condition(DFC) defined by outdated forestry practices, at the cost of 

other important natural resources..

Response

The desired condition numbers for cover type are based upon current conditions and an assessment of the 

mix of past cover types. Specifically for aspen, it is based upon information that the reduction for aspen 

cover type is less than other forests. A section will be added to appendix B of the EIS to explain the 

development of the numbers.

Public Concern #363

The Forest Service should document recent historic patch size in more discrete groups, 250 acres would 

be a desired patch size.

Response

We don’t agree that the patch size for desired conditions should change to 250 acres. Patch size will tend 

to be smaller on managed lands because of the limits on the size of harvest units. We also don’t agree that 

there should be a goal that back country management areas should have patch sizes similar to managed 

lands. Natural processes will dominate in the back country areas as opposed to managed lands. No 

changes were made.

Public Concern #364

The Forest Service should not manage age class distributions using a ―preservation strategy such as 

presented in the Guidelines for Vegetation #7. Instead, age class distributions should be maintained 

through stand growth projections.

Response

The guideline does not prescribe a preservation strategy. See PC #355.
Shoshone National Forest Land Management Plan Revision

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Public Concern #365

The Forest Service should include the following changes on page 30: Forest vegetation exists in a 

diversity of age classes and variable patch size across the Shoshone. In areas that receive no or 

infrequent vegetation management actions (management area categories 1, 2, and 3), natural processes 

such as fire and insects are the predominant disturbances that influence stand structure and landscape 

patterns and patch size. It is desirable to move the vegetation of management category 3 (backcountry 

and Inventoried Roadless Areas) into stand structures and landscape patterns similar to management 

categories 4, 5, and 8. This can be accomplished through prescribed fire as well as mechanical treatment 

using temporary roads for access.

Response

We don’t agree with the goal that back country management areas should have patch sizes similar to 

managed lands. The desired condition is for natural processes to dominate in the back country, which will 

result in a more variable patch size.

Public Concern #366

The Forest Service should revise the out-of-date Vegetation discussion and description on DEIS pages I06 

-139 is, and the Desired Conditions in Table 1 and Table 3 of the Draft Plan. These conditions cannot be 

achieved and will prove to be much more constraining to on-the- ground implementation than anticipated.

Response

See PC #347.

Public Concern #367

The Forest Service should revise desired conditions in table 3. These conditions will become an 

unintended liability when planning forest management projects.

Response

The desired conditions are a long-term goal, and though fires and insect epidemics may make it difficult 

to meet them in the short term, projects can still be implemented to begin the process of moving toward 

the desired condition. The revised Forest Plan does not require that the conditions be met in the short 

term.

Public Concern #368

The Forest Service should review current and desired age class distribution and cover type conditions to 

account for insect epidemics and fire effects to ensure desired conditions and predicted timber outputs can 

be achieved.

Response

See PC #587.

Public Concern #369

The Forest Service should not reduce combined Douglas-fir, spruce/fir, and lodgepole pine cover type 

acreage on suitable timberlands.

Response

See PC #353.
Final Environmental Impact Statement -- Appendix A

809

Public Concern #370

The Forest Service should describe how suitable timberlands management would be affected by the 

Desired Percentages by Cover Type across the entire Shoshone NF as shown in DEIS page 31, Table I.

Response

See PC #353.

Subject: 982 - Vegetation - Goals

Public Concern #371

Goal 2 on page 33 talks about restoring cover types that are declining do to succession to conifer. Drop 

the succession to conifer qualifier. It doesn't matter why they are declining.

Response

We agree that the qualification is not needed the goal will be changed.

Public Concern #372

On page 118 of plan change the text to say the Forest Service should restore and maintain a diverse range 

of ecosystems including aspen, White Bark Pine, sagebrush and willow cover types, properly functioning 

riparian areas, rangelands to favor native species, and resist invasive species, and lodgepole pine patch 

size within historic range of variability.

Response

The text on page 118 is a general summary of direction that is specified later in the revised Forest Plan. 

There is no need for it to be as complete as the direction it references. No change is made.

Public Concern #373

The Forest Service should manage lodgepole and other forest type stand size within historic range of 

variability in management categories 3, 4, 5 and 8.

Response

There is difficulty in trying to achieve a natural range of variability for stand size on managed lands 

because of the NFMA limits on the size of harvest units, particularly for even-aged treatments. Whether 

the treatment occurs in larger patch sizes or smaller patch sizes, the impacts on water production would be 

similar. No change was made.

Public Concern #374

The Forest Service should rewrite Goal #2, Page 33, to include: “On non-suited timberlands, manage 

conifer forest types to maintain or expand aspen, willow, grassland, and sagebrush cover type.”

Response

Cover types are managed for the lands that are capable of supporting them. Aspen, willow, and sagebrush 

cover types are not classified as suitable timber lands. Where conifer succession is encroaching on these 

habitats, it is appropriate to remove them. The management approach in the revised Forest Plan contains 

language that the trade-off between commercial and non-commercial species should be considered on 

suitable timber lands. The suggested change was not made.
Shoshone National Forest Land Management Plan Revision

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Public Concern #375

The Forest Service should quantify White Bark Pine natural regeneration through a monitoring program 

rather than focusing on restoration. White Bark Pine (WHITE BARK PINE) is evolving to deal with dieoffs.

Response

Whitebark pine is a sensitive species and is already being extensively monitored on the Forest. See 

Whitebark Pine Strategy for the Greater Yellowstone Area referenced in the vegetation section of the 

revised Forest Plan.

Public Concern #376

The Forest Service should plant or use other mitigation after prescribed fires and wildland fires to 

maintain native plant communities and reduce risk of conversion to cheatgrass or other invasive plant 

dominated systems.

Response

After a wildfire, a Forest burned area rehabilitation (BAER) team assesses watershed effects. These 

watershed assessments include management of invasive species. This is a site-specific issue and is beyond 

the scope of the revised Forest Plan analysis.

Subject: 983 - Vegetation - Objectives

Public Concern #377

The Forest Service should justify the need to increase aspen cover type by 10,000 acres, and leave 

language open so more than 2500 acres can be mechanically treated for restoration.

Response

The objective is based upon moving the current distribution of aspen toward the desired conditions in the 

next 10 to 15 years. The 10,000 acres represents an almost 50 percent increase in current acreage. Based 

upon comments received, the objective was increased. There is language in the vegetation management 

approach that indicates the desire to accelerate achieving desired conditions for aspen.

Public Concern #378

The Forest Service should restore historic fuel loading, landscape patterns and stand age classes in 

Management Areas 3, 4, 5, and 8.

Response

Objectives for fuel loadings are addressed in the fire section of the revised Forest Plan. The requested 

direction is found in other plan components.

Public Concern #379

The Forest Service management should increase aspen age class diversity since the majority of stands are 

mature.

Response

The plan desired condition for aspen is to manage for a variety of age classes.
Final Environmental Impact Statement -- Appendix A

811

Public Concern #380

The Forest Service should increase aspen acreage but not in MA 5.1 where it would conflict with 

providing forest products.

Response

See PC #374.

Public Concern #381

The Forest Service should justify the low goal or emphasize the need to restore considerably more than 

750 acres of whitebark pine due to unprecedented and probable white pine blister rust mortality. It is 

doubtful that treating only 750 acres would stabilize, or reverse whitebark pine decline. This objective 

makes it appear that opportunity is limited by seedling availability; although science supports 

disturbance may promote blister rust resistant seedlings.

Response

The objectives for whitebark pine are based upon the strategy outlined in Whitebark Pine Strategy for the 

Greater Yellowstone Area, the reality that dollars will be limited for restoration during the next 10 to 15 

years, and the general inaccessibility of whitebark pine stands. The objective was reviewed and has been 

raised. The objective is based upon what we feel is achievable now. If the situation changes, we can 

change the objective. The desired condition statement for whitebark pine sets the true measure of what we 

want to achieve.

Public Concern #382

The Forest Service should describe if Forest-wide direction for Invasive species, Objectives and 

Standards acres are based on assessments or inventories? This is not clear.

Response

Inventories for both aquatic and terrestrial invasive species have been conducted on the forest. Both the 

analysis and revised Forest Plan direction are based upon those inventories. 

Public Concern #383

The Forest Service, DLMP, page 18, Forest Health, Resolution, Vegetation Goals and Objectives should 

maintain a diverse range of age-classes within all plant community types.

Response

This direction is included as part of the desired condition direction. We don’t feel it is necessary to also 

include this direction as an objective.

Subject: 984 - Vegetation - Standards

Public Concern #384

The Forest Service should increase vegetation management acres objectives if they are not based on an 

assessment or inventory. Acres identified in vegetation Objectives 1, 2 and 4 seem low for the 2.4 M acre 

Forest.

Response

The objectives are based upon comparing the existing conditions to the desired conditions and assessing

what can realistically be achieved in the next 10 to 15 years. The objectives do not create a limit on what 

can be achieved if the situation changes. The goal is always to achieve the desired condition.
Shoshone National Forest Land Management Plan Revision

812

Public Concern #385

The Forest Service should use prescribed fire and suppression techniques in tandem with mechanical 

treatment to manage fire severity and size.

Response

Fire is addressed in the fire section of the revised Forest Plan. We added some language on use of 

mechanical treatments in the management approach for fire.

Public Concern #386

The Forest Service should better describe where a Standard is referencing (depending upon) a Guideline 

in USDA, The Forest Service, DLMP, page 49, Standards for Sensitive Species, Standard #11 - “Retain 

large diameter snags and roost trees for cavity-nesting birds and bats as described in the vegetation 

section.” The use of Standards and Guidelines in this document is most confusing.

Response

Standards and guidelines are both to be achieved in implementing the revised Forest Plan. There is no 

difference in whether we want to achieve the intent of the direction. The difference is whether any 

modification to them will be documented in a plan amendment and a NEPA document or in a NEPA 

document alone. Direction where it is envisioned that there may be extenuating circumstances requiring 

flexibility and site-specific variation in achieving the purpose of the direction are more commonly placed 

as guidelines. In this case, the direction that snags be retained for species is a standard, because that is not 

variable. The snag guideline in the vegetation section is more about how to retain the snags. That situation 

is much more variable and, because of the desire to maintain flexibility, it is included as a guideline.

Public Concern #387

The Forest Service, DLMP, page 49, Guidelines for Sensitive Species - should be Standards for 

conservation of the species, their wording is more stringent than Guidelines.

Response

Both standards and guidelines are to be achieved in implementing the revised Forest Plan. There is no

difference in whether we want to achieve the intent of the direction. The difference is whether any 

modification to them will be documented in a plan amendment and a NEPA document or in a NEPA 

document alone. Directions where it is envisioned that there may be extenuating circumstances requiring 

flexibility and site-specific variation in achieving the purpose of the direction are more commonly placed 

as guidelines.

Public Concern #388

The Forest Service should develop more Standards with quantifiable language addressing the major 

vegetation communities.

Response

See PC #387.

Public Concern #389

The Forest Service EIS Vegetation Guidelines 5, 7, 8, 9 have quantifiable language and should be moved 

to Standards.

Response

See PC #387.
Final Environmental Impact Statement -- Appendix A

813

Public Concern #390

The Forest Service should limit timing restrictions for elk calving to instances where there is a 

demonstrated need for a specific project area.

Response

Alternatives with less timing restrictions are considered in the EIS. The decision maker will consider 

comments supporting less timing restrictions along with public comments supporting more in making the 

final decision. The revised Forest Plan does include management direction for exceptions and mitigation 

for projects to improve winter range vegetation conditions.

Public Concern #391

The Forest Service should combine Standards #I and #2, and retain the following language from Standard 

#2-"will be on a case by case basis when good data support the action".

Response

The standards are separated because the certainty of the elk parturition data on the different areas varies. 

The wording was specifically developed based upon the difference. No change was made.

Subject: 985 - Vegetation - Guidelines

Public Concern #392

The Forest Service should use genetic rust-resistant White Bark Pine seedlings for plantings. It is a huge 

economic waste to collect seed, raise, and plant non-resistant seedlings.

Response

Currently, the quantity of rust-resistant seed is insufficient to meet all reforestation needs. Once there is 

adequate seed, only rust-resistant seedlings will be planted.

Public Concern #393

Until rust-resistant seedling become available, to insure natural selection against rust and to maintain 

important cone production, The Forest Service should emphasize natural regeneration for White Bark 

Pine restoration.

Response

Natural regeneration is used in many areas, but is not always adequate. In those cases, seedlings are 

planted to meet reforestation objectives.

Public Concern #394

The Forest Service vegetation standards should be more quantity specific. The guidelines stating that 

livestock grazing impact should not occur in fens, does not eliminate livestock grazing in fens. None of 

these are standards they are all guidelines.

Response

The guidelines concerning fens establish that livestock grazing is not planned or desired in these 

vegetation types, but recognizes that occasionally some incidental use may occur.

Public Concern #395

The Forest Service should define “unit,” and What is a “moderate level” of streambank stability under 

Draft Land Management Plan, Chapter 1- Forest-wide Direction, Guidelines for Vegetation, p.35.
Shoshone National Forest Land Management Plan Revision

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Response

In terms of rangeland management, unit and pasture are used interchangeably. “A moderate level “of 

streambank stability refers to its ability to resist impact and remain intact and functioning. It is one level 

of measurement used in the Greenline Stability Index monitoring method.

Public Concern #396

The Forest Service DLMP should include the revised Plan requirement for “Older” age class on suitable 

lands. It should be “0,” and “Middle” age class and should be clarified as 20 to 80 years for lodgepole 

pine, and 20 to 120 years for spruce/fir and Douglas-fir.

Response

See PC #355.

Public Concern #397

The Forest Service should delete Guideline #7, which requires 10% “Older Age Class” by watershed, 

because it cannot be achieved, due to beetle epidemics and fires effects, and it is even more restrictive 

than Table 10.

Response

See PC #355.

Public Concern #398

The Forest Service should delete Table 5, a summary of Table 30, because Table 30 is not relevant for the 

Shoshone NF. THE FOREST SERVICE DLMP Vegetation Guideline #8 is adequate for snag retention in 

timber harvest areas.

Response

Table 5 applies to unmanaged lands and helps to quantify the desired condition for snags. Guideline 8

applies to lands where management activities take place. There is no conflict between the two, and table 5

would not impact activities suitable timber lands. We don’t see the need to delete the table.

Public Concern #399

The Forest Service should delete Guideline #7 it is not necessary since desired age class distribution is in 

Table 3.

Response

Guideline #7 is necessary to help define how the desired condition will be achieved. Also see PC #355.

Public Concern #400

The Forest Service should not include two different measures of age class distribution, one based on 

percentage of management areas 4, 5 and 8 and the other based on percent of forested acres within 6th 

level watersheds. There is no reason to include two different measures of age class distribution.

Response

These are not two different measures of the same thing. The desired condition provides the overall 

guidance on what is to be achieved. Guideline #7 provides additional direction of how achievement of 

that desired condition is to be considered during project planning. The interdisciplinary team believes that 

both pieces of direction are needed to achieve the desired condition.
Final Environmental Impact Statement -- Appendix A

815

Public Concern #401

The Forest Service should consider natural regeneration options as well as planting for restoring White 

Bark Pine.

Response

See PC #393.

Public Concern #402

Some Vegetation and Forest Products Guidelines under Forest-wide Direction for Vegetation, 

(specifically those indicating when livestock should be removed from a unit and snag density 

requirements), appear to be Standards not guidelines. The Forest Service should change these Guidelines 

to Standards.

Response

See PC #387.

Public Concern #403

The Forest Service should change the revised The Forest Service Plan requirement for “Older” age class 

on suitable lands, it should be “0,” and “Middle” age class should be clarified as 20 to 80 years for 

lodgepole pine, and 20 to 120 years for spruce/fir and Douglas-fir forest types.

Response

See PC #355.

Public Concern #404

The Forest Service should delete Guideline #7, which requires 10% “Older Age Class” by watershed, be 

because it cannot be achieved, due to beetle epidemics and fires effects, and it is even more restrictive 

than Table 10.

Response

See PC #355.

Public Concern #405

The Forest Service should add these words to DLMP page 60, Guidelines #4 and #5 - "will be on a case by 

case basis when good data support the action".

Response

The best data are currently being used for crucial winter range designations. The revised Forest Plan 

direction allows exceptions for projects that improve winter range conditions. The plan also contains 

direction in the management approach for local species of concern to work with Wyoming Game and Fish 

to address shifts in winter range.

Public Concern #406

The discussion in the second paragraph on page 123 for Lands Suitable for Timber Production is 

applicable to the Forest Service.

Response

Thank you for the comment.
Shoshone National Forest Land Management Plan Revision

816

Public Concern #407

The Forest Service should add a Guideline stating an intent to salvage merchantable sawtimber from 

natural events such as wildfire, blowdown, insects, and disease on suited timberlands, plus other lands 

suited for timber harvest when consistent with MA direction.

Response

See PC #654.

Subject: 986 - Vegetation - Management approach

Public Concern #408

It is important that the Forest Service create dependable and stable supplies (sustained yield) of timber if 

local industry is to remain viable and continue to be an available vegetative

Response

The revised Forest Plan contains goals and objectives to supply forest products over time.

Public Concern #409

The Forest Service plan should increase forest health treatments to reduce catastrophic fire risk and 

provide dead and dying timber products for economic benefit.

Response

The plan goals and objectives are for managing both fire and insect epidemics.

Public Concern #410

The Forest Service plan should provide management direction that would replace invasive Kentucky 

bluegrass types with native plant communities in wetland-riparian areas.

Response

This is a site-specific issue and is beyond the scope of the revised Forest Plan analysis.

Public Concern #411

The Forest Service plan will maintain and enhance aspen vegetation types that are appropriate for the 

forest.

Response

Thank you for the support

Subject: 1000 - Species Diversity - General

Public Concern #412

The Forest Service should prioritize greater wildlife, prey and predator alike, and wildlife habitat 

protection, including corridors and healthy ecosystems, because animals rely on protected areas for 

survival, seeing wildlife on the Shoshone moves people, and hunting is an economic driver for the 

surrounding communities.

Response

All alternatives provide for maintaining the viability of species on the forest as well as providing other 

resources. Some alternatives, such as C and D, place a greater emphasis of providing for wildlife species 
Final Environmental Impact Statement -- Appendix A

817

that prefer more secure habitat. The decision maker will consider those alternatives and these comments 

along with other comments on management in determining how much emphasis to place on wildlife in 

making a final decision.

Public Concern #413

The Forest Service should maintain current hunting regulations because it's important to keep 

populations from exceeding their carrying capacity.

Response

The State of Wyoming manages hunting regulations, not the Forest Service. Management of hunting 

regulations is outside the scope of this decision.

Public Concern #414

The Forest Service should address wildlife population viability to ensure their existence for posterity.

Response

Providing for wildlife viability is a key objective in the regulations that govern preparation of the revised 

Forest Plan. The analysis in the EIS addresses wildlife population viability for all alternatives. In addition, 

a biological assessment and evaluation are prepared for the preferred alternative that addresses viability.

Public Concern #415

The Forest Service should protect bison and bison habitat.

Response

See response to PC #412. Bison were not identified during forest plan development as an animal needing 

specific habitat requirements that weren’t already identified for other wildlife species such as elk and 

bighorn sheep. Bison habitat along the North Fork of the Shoshone will be maintained with the 

implementation of revised Forest Plan direction identified under Species of Local Concern, revised Forest 

Plan pages 59 through 63.

Public Concern #416

The Forest Service should simplify Management Indicator Species direction so that it is possible to 

implement.

Response

We believe that the plan direction for management indicator species is achievable.

Public Concern #417

The Forest Service should strengthen big game and ungulate habitat protections, including winter range 

security, calving/breeding areas, migration routes, transitional areas and stopover areas because big 

game is particularly affected as its habitat is compromised by development.

Response

All alternatives provide some level of protection for big game including protection of calving areas, 

reduced disturbance during winter on crucial winter range, and management to accommodate big game 

passage. Alternatives C and D provide greater protection through increased acres designated to 

management areas with less active management than alternatives E and F. Varying levels of protection 

have different trade-offs in providing other resource opportunities. The decision maker will consider 
Shoshone National Forest Land Management Plan Revision

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comments on what level of big game protection should be provided along with other comments in making 

a final decision. 

Public Concern #418

The Forest Service should protect biodiversity, particularly insects and plants, because plants and insects 

of the Shoshone National Forest hold pharmaceutical promise to benefit future generations of Americans 

through advanced medicine.

Response

Large areas of the Shoshone receive little active management and are primarily in a natural condition. All 

of the alternatives maintain biodiversity.

Public Concern #419

The Forest Service should specify in “Past, Present, and Future” Land Use Change Question 16 the ways 

in which, and extent to which, human activities outside of protected areas are altering ecological 

processes and biodiversity inside of protected areas.

Response

On a Forest-wide scale other than motorized use, human recreation use has not been identified as having a 

cumulative effect on wildlife. In specific isolated areas, it may have an impact, but at the scale of the 

revised Forest Plan analysis, it was not considered significant.

Public Concern #420

The Forest Service should strengthen bear and wolf habitat protection in order to support populations 

leaving Yellowstone National Park boundaries and to keep the larger ecosystem intact.

Response

Best available science provided the foundation for grizzly bear and gray wolf habitat conservation (see 

biological assessment and biological evaluation). All alternatives provide some level of protection for the 

grizzly bear and gray wolf. Some alternatives, such as C and D, provide greater protection than E and F. 

The decision maker will consider comments on what level of protection should be provided.

Public Concern #421

The Forest Service should increase non-game wildlife protection by strengthening plan standards and 

guidelines to protect wildlife species, including retention of large-diameter snags and roost trees.

Response

The revised Forest Plan includes direction for protecting wildlife species. Plan direction was developed 

within the context that less than 10 percent of the Forest is actively managed. The vegetation includes a 

specific guideline for maintaining snags within the timber harvest project areas.

Public Concern #422

The Forest Service should select MIS species that inform, guide and monitor wildlife diversity rather than 

those that support management direction, such as red-breasted nuthatches and non-native trout that 

tolerate fragmentation and degraded aquatic conditions, respectively.

Response

The management indicator species selection process isoutlined in the revised Forest Plan, appendix 3, 

pages 279 through 282. Rationale for not selecting other species is includeded in the project record. 
Final Environmental Impact Statement -- Appendix A

819

Public Concern #423

The Forest Service should emphasize protection of lower-elevation forested lands that provide habitat for 

many resident and migrating wildlife species.

Response

The revised Forest Plan includes direction for maintaining all forest types including those found at lower 

elevations. Alternatives provide varying levels of wildlife emphasis. The decision maker will consider 

these comments along with other comments in making a final decision.

Public Concern #424

The Forest Service should maintain the number of proposed management indicator species at four and 

not require “Forest-wide estimates of population trends for each management indicator species” as 

stated on page 56 of the draft plan.

Response

The provisions of the 1982 regulations, under which we are preparing this plan, indicate that “Population 

trends of the management indicator species will be monitored and relationships to habitat changes 

determined.”

Public Concern #425

The Forest Service should include consider the following: (1) Include a brief summary of the cumulative 

effects of management programs on all wildlife species. (2) Discuss if and how snowmobiles are having 

adverse effects on sheep. (3) Use the most current published science in all fish and wildlife decisions, 

particularly with energy development. (4) Incorporate science- based mitigation when making decisions 

about fish and wildlife management and energy development. (5) Utilize a third-party review of 

development and mitigation proposals. (6) Establish a qualified “science review team” and engage 

science-based organizations for fish and wildlife management and development decisions.

Response

The effects, including cumulative effects of the alternatives on a suite of wildlife species including 

federally threatened, endangered and proposed, regional forester sensitive species, management indicator 

species, and species of local concern were analyzed in the EIS. These species represent a multiple of 

species that use similar habitat.

Management effects on bighorn sheep habitat are discussed in the EIS pages 213 through 216. Guidelines 

for winter motorized use on bighorn sheep crucial winter range are identified in the revised Forest Plan 

page. 60.

The wildlife management approach sections in the revised Forest Plan identify how best available science 

is incorporated into management actions on the Shoshone. The identification of a third party review or 

science review team is outside the scope of forest plan revision.

Public Concern #426

The Forest Service should include population level triggers identified for each Management Indicator 

Species and adaptive management protocols designed to effectively plan for negative changes and 

impacts.
Shoshone National Forest Land Management Plan Revision

820

Response

The revised Forest Plan identifies that management indicator species populations will be monitored. The 

assessment and evaluation of any trends will be made in the 5-year evaluation reports. The plan does not 

predetermine what level of population change triggers a change in the plan or what that change should be. 

Those determinations are made with the information gathered at that time.

Public Concern #427

The Forest Service should reconsider its proposed reduction of the number of Management Indicator 

Species, include objectives and quantifiable standards for MIS, and change the wording on page 55 of the 

draft to read: “MIS will be evaluated and reported in context with trends in habitat conditions.”

Response

The change in management indicator species in consistent with the latest guidance on designation of 

managment indicator species. The number of management indicator species is not synonymous with what 

habitats are being protected. There are over 30 wildlife species and over 40 plant species representing 

numerous habitats that are being provided for in the forest plan direction. The suggested language is 

included in the management approach.

Public Concern #428

The Forest Service should promote the guidelines shown on page 60 of the draft to standards.

Response

The difference between a standard and guideline is discussed in the revised Forest Plan pages 23 through 

24. Guidelines for species of local concern identified in the plan pages 60 through 61, did not meet the 

rigor for becoming a standard.

Public Concern #429

The Forest Service should establish wildlife and fisheries impacts thresholds, including indicators, and 

establish and annually apply policy to mitigate or curb impacts and prevention methods to maintain 

wildlife and fish numbers.

Response

The revised Forest Plan establishes direction on how to implement the plan and also identifies items to 

monitor to gauge that implementation. Assessment of monitoring and what should be done as a result of 

that assessment occurs separately. The plan does not predetermine what actions should be taken.

Public Concern #430

The Forest Service should make the following changes: (1) reference and include elements of the 

Wyoming State Wildlife Action Plan in the forest plan. (2) Make the final plan more coherent since at the 

moment it is confusing. (3) Clarify which sensitive species will actually receive management 

consideration (4) note the following issues: Appendix 3 of the draft LMP “displays the emphasis species 

selected” on the SNF. Table 31 Selected Emphasis Species lists 28 terrestrial sensitive species; one of 

them is shown to ‘not occur’ on the SNF, and at least 5 others are shown as ‘not confirmed’. Elsewhere 

we are told: “In 2012, 34 terrestrial and 3 aquatic wildlife species...shown on the regional forester’s 

sensitive species list occur or have the potential to occur on the SNF” (LMP, p. 46). Which sensitive 

species that have the potential to occur on the SNF were excluded in this Plan revision, and why? What 

species were considered but not selected? This information should be disclosed. Appendix 3 (p. 266) 

states: “For a description of the process used to select these species and a summary of those considered 

but not selected, refer to the project record for the Emphasis Species Categories document.” When I 
Final Environmental Impact Statement -- Appendix A

821

inquired about obtaining the Emphasis Species document, I was told by N. Bryan Armel (email 

11/16/2012) that: “The wording in the document is not quite correct. The document being referred to is 

Appendix 3 in the Plan. At one point the complete document wasn’t going to be included in the plan and 

the wording didn’t get adjusted once we decided to put the whole document in the appendix.” If Appendix 

3 is “complete document”, it certainly does not describe the process used to select species, nor does it 

show which species were considered but dropped. An example of a sensitive species that occurs on the 

SNF that is not included by Table 31 (with no explanation) is provided in Attachment 1 of this letter 

(American three-toed woodpecker). (5) Table 31 is frequently contradicted by information in the DEIS. 

(6) Many of the Habitat descriptors in Table 31 are do not accord with LMP Table 47. (6) Fix problems 

with stating the occurrence and habitat of sensitive species (Appendix 3 LMP) because of the potential for 

ignoring species and their habitat needs. (7) The Plan draft needs to do a stronger job of summarizing 

and presenting habitat information, (8) should clarify if the database mentioned on page 50 of LMP exists 

and was used to make the plan. (9) The Alternatives in the Draft RMP/EIS must recognize the impacts of 

gas and oil development on wildlife.

Response

(1) Wyoming’s State Wildlife Action Plan is referenced in the draft forest plan under management 

approach on page. 61, but is not referenced under the sensitive species section. It has been added to 

sensitive species also.

(2) Edits have been made where appropriate to clarify plan information.

(3) All sensitive species receive management consideration and that is discussed in the biological 

evaluation. Not all sensitive species received specific standards or guidelines.

(4) The revised Forest Plan page 46 was corrected to reflect the number of sensitive species analyzed in 

the biological evaluation.

We corrected the wording in the draft EIS on page 266 to reflect that the document used to disclose 

the selection process for management indicator species only is in the project record. All other species 

selected to be emphasis species are discussed in appendix 3.

The American three-toed woodpecker is no longer on the regional forester’s sensitive species list, and 

thus, was not analyzed in the biological evaluation.

(5-6) Table 31 in appendix 3 in the DEIS has been corrected to be consistent with the wording used in the 

EIS.

(6-7) Species habitat-specific information is included in the biological assessment and biological 

evaluation, which are part of the project record.

(8) The database currently used and reflected in the revised Forest Plan, management approach, page 50 is 

maintained by the University of Wyoming, Natural Diversity Database. There is no guarantee in the 

future that this same database will be used, thus, no change is needed in the revised Forest Plan.

(9) Those species impacted by oil and gas development along with other management actions, and the 

effects on these species are disclosed in the EIS.

Public Concern #431

The Forest Service should avoid or minimize management activities that result in the creation of edge 

environments or negative edge effects.
Shoshone National Forest Land Management Plan Revision

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Response

The effects of edge creation are not a Forest-wide issue, thus it was not brought forward during the 

revised Forest Plan analysis. The effects of management activities that impact species by edge habitat will 

be analyzed at the site-specific or project-level analysis.

Public Concern #432

The Forest Service should correct the wording for Alternative C to reflect that commercial livestock 

grazing would be eliminated from elk and bighorn sheep crucial winter ranges as designated by the 

Wyoming Game and Fish Department, but not eliminated from all big game winter ranges (see page 38 of 

the DEIS).

Response

The effects analysis in the EIS was corrected to analyze commercial livestock grazing on big game crucial 

winter range by all alternatives.

Subject: 1001 - Species Diversity - Terrestrial wildlife

Public Concern #433

The Forest Service should consider providing additional support to grouse populations since they seem to 

be declining.

Response

Ruffed grouse are included as a management indicator species in the draft forest plan page 54.

Public Concern #434

The Forest Service should incorporate the Starkey Project conducted by the Oregon Department of Fish 

and Wildlife and the USDA Forest Service at the Starkey Experimental Forest and Range for additional 

material on motorized recreation effects to deer and elk.

Response

We revised the effects from motorized use on big game in the FEIS to include some results from the 

Starkey Experimental Forest and Range.

Public Concern #435

The Forest Service should use HE/HA analyses conducted with best available science, such as models 

developed by Sawyer et al (2001), Rowland (2000, 2005) B-T NF (2012), and Hillis (1991), before 

management activities such as energy development, motorized access, expanded recreational activities 

and vegetation management in order to better manage migration routes, stop over areas, and transitional 

habitats in order to assure the long term health and survival of big-game species.

Response

Shoshone National Forest biologists determined that a habitat effectiveness model (HE) was not needed 

because most herd units were over objective and the landscape lacks open roads. One of the biggest 

impacts to elk on the Forest is during hunting seasons, therefore, the focus in the revised Forest Plan is to 

provide adequate security during hunting seasons. Elk herds on the Shoshone show a preference for 

migration into Yellowstone National Park and wilderness, lessening the importance of HE values in the 

summer.
Final Environmental Impact Statement -- Appendix A

823

Public Concern #436

The Forest Service should consider using the red squirrel as the Management Indicator Species to 

indicate upper-elevation conifer zones, and to reflect logging and fuel treatments affecting mature 

conifers, for the following reasons: Red Squirrels depend completely on cone- producing conifers and 

inhabit local areas rather than migrating; midden-density monitoring can be used to quantify squirrel 

presence in belt transects; and they are an important food source for grizzly bears.

Response

In the January 2012 preliminary draft Forest Plan, the red squirrel was identified as a potential 

management indicator species for lodgepole pine. After public comment, the habitat concern changed 

from lodgepole pine to mature conifer and snags. During the final management indicator species selection 

process, it was determined that the red-breasted nuthatch was a more appropriate species for this habitat.

Public Concern #437

The Forest Service should base winter closures on available data showing the number of animals using 

the proposed closure area.

Response

We are using Wyoming Game and Fish’s winter range classification data, which is based upon survey 

information. Because of the variation that can occur over time, flexibility is built into the plan for us to 

work with Wyoming Game and Fish to make adjustments if on-the-ground conditions change.

Public Concern #438

The Forest Service should consider focusing on habitat preservation due to continuing and future climate 

change, forest health, wildlife stress, and loss of habitat from fires and energy development.

Response

Large areas of the Shoshone are not actively managed. Alternative F has 10 percent of the forest classified 

as suitable timber lands. For all other alternatives, approximately 5 percent of the forest is classified as 

suitable timber lands.

Public Concern #439

The Forest Service should consider preserving the best pure genetically buffalo available and stop killing 

wolves.

Response

The State of Wyoming manages wildlife populations. The Forest Service manages wildlife habitat. 

Wildlife population management is outside the scope of this decision.

Subject: 1002 - Species Diversity - Legal and administrative framework

Public Concern #857

The Forest Service should delete “assume sensitive species presence “on page 50 of the Land 

Management Plan as it goes beyond the Forest Service’s legal obligations.

Response

The management approach of assuming presence of a species is followed by “or implement surveys to 

achieve adequate detection probabilities....”
Shoshone National Forest Land Management Plan Revision

824

It is not be possible to survey for all species in all habitat areas. Where species habitat relationships are 

understood, it is reasonable to assume presence when analyzing potential impacts.

Subject: 1003 - Species Diversity - Methodology

Public Concern #440

The Forest Service should plan for ecological sustainability using a broad suite of measurable biological 

indicators such as ecological integrity.

Response

The revised Forest Plan includes direction for providing species habitat. Plan direction was developed 

within the context that less than 10 percent of the forest is actively managed. Much of the forest is 

unmanaged where natural processes prevail.

Subject: 1004 - Species Diversity - Wildlife Corridors

Public Concern #441

The Forest Service should protect the Clarks Fork River corridor connecting the Beartooth Plateau with 

the Absaroka/Yellowstone region and the Union Pass corridor connecting the Absaroka/Yellowstone with 

the Wind River since these are some of the most important wildlife habitat on the Forest.

Response

The alternatives have a range of managed lands with alternatives C and D having more back country nonmotorized areas and alternatives E and F having more managed lands. The decision maker will consider 

these comments which recommend managing more corridors under non-motorized management areas 

along with other comments in making a final decision.

Public Concern #442

The Forest Service should include no surface occupancy stipulations or timing restrictions to protect 

ungulate migration routes.

Response

The alternatives allow different levels of oil and gas development on big game ranges. Alternatives C and 

D provide the greatest area that does not allow surface development for oil and gas. The decision maker 

will consider comments on limiting oil and gas development on big game ranges along with other 

comments in making a final decision.

Public Concern #443

The Forest Service should state which specific linkage areas are necessary to improve connectivity for 

wide-ranging species such as wolverine, lynx, wolves, and grizzly bears.

Response

Habitat availability, distribution, and connectivity for these species on the Shoshone is addressed in the 

EIS, biological evaluation, and biological assessment. The conservation assessments for these species 

address connectivity across the broader landscape. The EIS analysis uses the information in the 

conservation assessments. Identification of specific linkage areas and how they improve connectivity is 

beyond the scope of the revised Forest Plan analysis.
Final Environmental Impact Statement -- Appendix A

825

Subject: 1010 - Threatened endangered proposed candidate species -

General

Public Concern #444

The Forest Service should revise the T&E, Proposed, and Candidate Species section to include strategic 

vision and eliminate vague and ambiguous wording such as “ maintain or improve” which contrast with 

hard timber objectives which do not support efforts to “maintain” limiting habitat.

Response

Strategic vision is provided in the management approach section and tiers to the individual conservation 

strategies and recovery plans for the various threatened and endangered species (revised Forest Plan pages 

44 through 45).

Public Concern #445

The Forest Service should allow snowmobiles since they do not disturb animals other than grizzly bears 

and wolves.

Response

Snowmobiles are allowed in certain management areas (revised Forest Plan pages 126 through 129).

Public Concern #446

The Forest Service should be sensitive to leasing in terms of disease transmittal and forage availability to 

threatened and endangered species.

Response

The analysis considered the impact of domestic sheep and goat presence in bighorn sheep habitat, and we 

incorporated appropirate management constraints into the revised Forest Plan. No other disease 

transmissions from domestic livestock to threatened and endangered species were identified as a concern.

Public Concern #447

The Forest Service should protect threatened, endangered and sensitive species at the project and district 

levels and should not allow projects that adversely affect sensitive species habitat if occupancy is 

unknown.

Response

The process for analyzing effects to threatened, endangered, and sensitive species is provided in Forest 

Service Manual 2670 and used in the revised Forest Plan page 50. Management projects will be analyzed 

on a site-specific basis, and are outside of the scope of the revised Forest Plan analysis.

Public Concern #448

The Forest Service should include the three-toed woodpecker in the list of sensitive species in the Forest 

Plan since it is a R2 sensitive species.

Response

Although the American three-toed woodpecker was once on the Region 2 sensitive species list, after 

analysis from the forests in the region it was determined the species no longer required sensitive species 

conservation. This species was removed from the Region 2 sensitive species list in the December 28, 

2011, sensitive species update.
Shoshone National Forest Land Management Plan Revision

826

Public Concern #449

The Forest Service should not merely maintain the status quo, but should comply with the ESA by using 

all available methods to recover ESA listed species.

Response

Goals for threatened and endangered are discussed on revised Forest Plan page 40, and include recovery 

of the species under the Endangered Species Act.

Public Concern #450

The Forest Service should consider doing the following: (1) reword Forest-wide Direction, Guidelines for 

Threatened, Endangered, Proposed, and Candidate Species #8, Page 43, Chapter 1, to align more closely 

with the Conservation Strategy, using the following wording: "Inside the Primary Conservation Area, work 

with livestock grazing permittees to resolve conflicts and/or change management on cattle allotments or 

portions of cattle allotments with recurring conflicts. If conflicts cannot be resolved, livestock 

management will follow the Conservation Strategy." (2) acquire and assemble accurate information on the 

habitats for each of the ‘emphasis sensitive species. (3) On Page 44, “Management approach” and 

Section 7should be rewritten to conform to the Forest Service’s legal obligations. (4) Comments related to 

quantification of monitoring and standards are lacking as it relates to sensitive, indicator, or federally 

listed species. (5) On Page 46 it states “The regional forester designates sensitive species if population or 

habitat is trending downward or if little information is available on population or habitat trends.” this 

should be changed since having little information on a species does not necessarily imply they are 

“sensitive”.

Response

(1) The management approach for threatened and endangered species, (revised Forest Plan, page 46), 

noted grizzly bear habitat will be managed using the Final Conservation Strategy for the Grizzly Bear 

in the Greater Yellowstone Area. We reworded this guideline for clarity.

(2) Relevant information on habitats for analyzed species was reviewed and included in the management 

approach for sensitive species in the revised Forest Plan on page 50.

(3) The intent is not to quote the exact wording out of every legal act or document, but to state that the 

acts and documents will be used as required to guide the management.

(4) The revised Forest Plan identifies the items to be monitored. Additional specificity on how that 

monitoring will occur is developed as part of revised Forest Plan implementation. This allows more 

flexibility and for protocols and methods to be changed when new information is available.

(5) Direction for sensitive species comes from the regional forester which is followed in this revised 

Forest Plan.

Public Concern #451

The Forest Service should note that there is no Appendix 1 in the Draft Land Management Plan, Chapter 

1- Forest-wide Direction, Guidelines for Threatened, Endangered, Proposed, and Candidate Species #7, 

p. 43.

Response

Appendix 1 in the revised Forest Plan is found on page 250.

Public Concern #452

The Forest Service should exercise caution with management activities that could temporarily or 

permanently decrease secure habitat for sensitive species and result in ESA listing.
Final Environmental Impact Statement -- Appendix A

827

Response

Management restrictions in sensitive species habitat were considered and displayed in the revised Forest 

Plan pages 48 through 50.

Public Concern #453

The Forest Service should seek full recovery for grizzly bear and wolf populations across all suitable 

habitats throughout the SNF and should conserve dispersal corridors and target viable populations for 

both species of more than 50 breeding individuals (Ne) and more than 500 total individuals in each 

population to maintain genetic viability and provide a sufficient breeding population to avoid inbreeding 

depression for both species.

Response

Grizzly bear and gray wolf habitat are managed with best available science including the appropriate 

species conservation strategy or recovery plans (revised Forest Plan, pages 41 through 46).

Subject: 1020 - Threatened endangered proposed candidate species - Gray 

wolf

Public Concern #454

The Forest Service should revise guideline #5, page 43 to reflect current science regarding limiting 

factors of wolf den sites.

Response

We used best available science for Guideline 5, page 43, however the biological assessment was updated 

to include current den site literature. This guideline has been relocated to the sensitive species section 

upon delisting of the wolf.

Public Concern #455

The Forest Service should protect wolves and other predators because they are keystone species.

Response

Wolves and other species considered predators and their habitat conservation are addressed in the revised 

Forest Plan, pages 38 through 46.

Public Concern #456

The Forest Service should revise Table 8, DLMP, page 39 to reflect the delisting of the gray wolf.

Response

We revised this table and moved gray wolves to the sensitive species section.

Public Concern #457

The Forest Service should identify areas of core gray wolf use, including denning areas for each pack, 

and target these areas for road closure in order to maintain habitats most suited to the persistence of 

viable populations of wolves on the SNF.

Response

We addressed denning area restrictions in the revised Forest Plan with Guideline 5 (page 43) and Standard 

2 (page 48). Gray wolf direction is located under the sensitive species section in the revised Forest Plan.
Shoshone National Forest Land Management Plan Revision

828

Public Concern #458

The Forest Service should address the impacts of recreational wolf hunting and provide standards to 

minimize impacts on the overall viability of wolf populations.

Response

Recreational hunting, including for wolves is beyond the scope of this analysis. Management of gray wolf 

habitat is addressed in management approach, on page 45 in the revised Forest Plan. We will include 

Wyoming’s Wolf Management Plan in the revised Forest Plan.

Public Concern #459

The Forest Service should consider wolves for special classifications within Forest Service policy, in part 

to counteract the lack of any management by the state in the predator area.

Response

Gray wolf management is addressed in the revised Forest Plan on pages 38 through 45. The gray wolf 

will be moved to the sensitive species section because it’s been delisted.

Public Concern #460

The Forest Service should adopt provisions prohibiting wolves from being killed on the forest during 

denning season and pup rearing season except in response to legitimate conflicts with livestock or people.

Response

See response to PC #458.

Subject: 1030 - Threatened endangered proposed candidate species -

Canada lynx

Public Concern #461

The Forest Service should eliminate snowmobile use in lynx habitat.

Response

Snowmobile use in lynx habitat is addressed under Guideline 15, revised Forest Plan page 44, and is 

consistent with the direction in the Northern Rockies Lynx Management Direction.

Public Concern #462

The Forest Service should place restrictions, such as those listed in Brunnel et al. (2006), on snowmobiles 

in lynx conservation areas because snowmobiles impact lynx survival and population viability.

Response

The document (Brunnel et al. 2006) is not site-specific to the Shoshone National Forest. It does 

investigate the potential impacts that coyotes using snowmobile trails to access deep snow areas may have 

on lynx. The biological assessment will be edited to include this literature. See also response to PC #461.

Public Concern #463

The Forest Service should reassess and remap Canada lynx habitat on the Shoshone National Forest 

DEIS using the habitat model developed by the U.S. Fish and Wildlife Service.
Final Environmental Impact Statement -- Appendix A

829

Response

Mapping of lynx habitat is discussed in the EIS pages 152 through 153, including the mapping of critical 

habitat by the Fish and Wildlife Service.

Public Concern #464

The Forest Service should replace Goal 4 on page 40 of the draft plan with the following statement 

because the potential for lynx conservation on the Shoshone National Forest is questionable: "Adhere to 

the Northern Region Lynx Amendment Management Direction and actively participate in efforts to review 

the occupied status of the SNF as new information becomes available."

Response

The Northern Rockies Lynx Management Direction amended forest plans in March 2007. Direction in the 

revised Forest Plan retains the 2007 Amendment as is. No change to Goal 4 is needed. We edited the 

revised Forest Plan, page 45, to note under the management approach for Canada lynx, “Actively 

participate in efforts to review the occupied status of the Shoshone NF as new information becomes 

available.”

Public Concern #465

The Forest Service should reassess the effects of compacted snow routes on Canada lynx using best 

available science, and Kolbe et al. (2007), in particular, who found no evidence that compacted snow 

routes increase competition from other species to levels that adversely affect lynx populations.

Response

The document (Kolbe 2007) is not site-specific to the Shoshone National Forest. It does investigate the 

potential impacts that coyotes using snowmobile trails to access deep snow areas may have on lynx. We 

considered Kolbe 2007 and included it as a reference in the biological assessment.

Public Concern #466

The Forest Service should not increase snowmobile use in the Wyoming High Lakes Wilderness Study 

Area or allow motorized use in the Union Pass area in order to protect Canada lynx critical habitat and 

to reduce the potential for negative effects to lynx.

Response

The effects of snowmobile use on Canada lynx is discussed in the EIS on page 155 and in detail in the 

biological assessment. The decision maker will consider the public comments in making the final 

decision.

Public Concern #467

The Forest Service should revise Appendix Table 3 because it incorrectly identifies early successional 

conifers as lynx habitat types and, therefore, does not reflect the best available science.

Response

We agree, and we changed lynx habitat to “Mature forest and dense young conifers.”

Public Concern #468

The Forest Service should use the revision process as an opportunity to revisit decisions and direction in 

the Northern Rockies Lynx Amendment for the Shoshone NF, and either incorporate the entire Northern 

Rockies Lynx Amendment into the Plan or open up NRLA direction to modification and exclude lands 

suitable for timber production from lynx habitat.
Shoshone National Forest Land Management Plan Revision

830

Response

Amending the entire Northern Rockies Lynx Management Direction is outside the scope of this project.

Public Concern #469

The Forest Service should make sure the description of Canada lynx habitat shown in Plan Table 8 and 

DEIS Table 35 is consistent and the more accurate description in Table 35 be used.

Response

See response to PC #467.

Public Concern #470

The Forest Service should correct “8 to 12 percent” written in paragraph 6 of page 153 because it 

appears to be an error.

Response

The literature cited in the EIS page 153 is correct for the 8 to 12 percent and is from page IV-2-14

(WGFD 2010)

Public Concern #471

The Forest Service should exclude suitable timber production lands from lynx habitat designations and 

delete the following statement from page 154 of the draft plan because of the small percentage of suited 

timberlands and the low number of acres harvested annually: "timber harvest" is "a primary risk factor" to 

Canada lynx habitat.

Response

Amending the Northern Rockies Lynx Management Direction is outside the scope of this project. The 

Northern Rockies Lynx Management Direction, which is incorporated into the revised Forest Plan pages 

41 through 44, analyzed the effects of land management activities on lynx habitat including timber 

harvesting, therefore the EIS included timber harvesting and its effects on lynx habitat.

Public Concern #472

The Forest Service should delete the last sentence in paragraph 1 on page 154, and the second paragraph 

under Canada lynx on page 45 of the proposed plan should be deleted because paragraph 3 states, “there 

is no conclusive evidence that, if competition exists between lynx and other predators, it exerts a 

population-level threat on lynx.”

Response

The sentence in the revised Forest Plan on page 154 does not refer to lynx competitors having a 

population-level threat on lynx; it simply states groomed trails may allow access to lynx competitors. 

Public Concern #473

Given that population trend data for lynx are unavailable for the Shoshone National Forest, the Forest 

Service should develop special standards and guidelines prioritizing conservation for lynx critical 

habitat, including preclusion of timber harvest in important spruce/fir habitat and a snowmobile ban, 

because snowmobile trails create travel ways for coyotes, the most important lynx competitor.

Response

Specific standards and guidelines for Canada lynx are in the revised Forest Plan pages 41 through 44. The 

effects of timber harvesting and snowmobile trails on lynx are analyzed in the biological assessment. 
Final Environmental Impact Statement -- Appendix A

831

Public Concern #474

The Forest Service should prioritize lynx recovery, protect and improve lynx habitat and dispersal 

corridors, and provide passage structures.

Response

Canada lynx habitat protection, for recovery, is emphasized in the revised Forest Plan pages 38 through 

44. 

Subject: 1040 - Threatened endangered proposed candidate species -

Grizzly bear 

Public Concern #475

The Forest Service should prioritize protection of the grizzly bear and grizzly bear habitat by preventing 

logging and the creation of additional motorized trails within it because motorized trails degrade grizzly 

bear habitat and increase human/grizzly conflicts, and the grizzly bear is an important bellwether species, 

indicating the health of the entire ecosystem.

Response

Grizzly bear habitat protection, for recovery, is emphasized in the revised Forest Plan pages 38 through 

44. The effects of land management activities are addressed in the DEIS pages 174 through 180 and in 

more detail in the biological assessment.

Public Concern #476

The Forest Service should not construct a zip line within the Sleeping Giant Ski Area because it is located 

within prime grizzly bear habitat.

Response

The Sleeping Giant Project is a site-specfici analysis outside the scope of the revised Forest Plan analysis.

Public Concern #477

The Forest Service should not focus on additional grizzly bear and grizzly bear habitat protection 

because grizzly range expansion has reduced the amount of forest users, negatively impacting the local 

economy.

Response

Management of grizzly bear habitat is discussed in the revised Forest Plan on pages 33 through 45, and is 

consistent with the Final Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Area. 

Public Concern #478

The Forest Service should loosen restrictions outside the Primary Conservation Area for grizzly bear 

management because the Greater Yellowstone Ecosystem population is biologically recovered according 

to the U.S. Fish and Wildlife Service, Montana Fish, Wildlife, and Parks, and Wyoming Game and Fish 

Department.

Response

See comment to PC #477. Standards developed in the revised Forest Plan on pages 41 through 42 for 

grizzly bears and their habitat, focuses mainly on the primary conservation area (PCA) and not areas 

outside of the PCA.
Shoshone National Forest Land Management Plan Revision

832

Public Concern #479

The Forest Service should modify the following statements in the Draft Land Management Plan because it 

would offer forest commercial users more flexibility as grizzly bear populations expand and recover: 

“desired distribution and abundance of threatened, endangered, proposed and candidate species are 

maintained,” on page 38 of the DEIS should be modified to, “desired distribution and abundance of 

threatened, endangered, proposed, and candidate species, reflective of effective habitats and confirmed 

historic distribution on the SNF are maintained”; and “Restrict permitted activities at moth sites until a 

comprehensive site management plan is developed,” on page 39 of the DEIS should be modified to, 

“Allow permitted activities to occur at moth sites until a comprehensive site management plan assists the 

Forest in developing decisions regarding potential restrictions based on best available science.”

Response

Habitat for threatened and endangered species is managed according to established and approved 

recovery plans and conservation strategies (revised Forest Plan page 38) which is the desired condition 

the Forest wants to reach. The Forest is taking a conservative approach regarding moth site management 

until a strategy for these sites is developed (revised Forest Plan page 45)

Public Concern #480

The Forest Service should remove the word “outside” from the following statement in Guideline 8 on 

page 41 of the Draft Land Management Plan because it would allow management direction to employ 

more restrictive measures within the Primary Conservation Area (PCA), yet provide more flexibility to 

livestock operators outside the PCA: “Inside and outside the Primary Conservation Area, cattle 

allotments or portions of cattle allotments with recurring conflicts that cannot be resolved through 

modification of grazing practices may be placed under long-term non-use agreements or retired as 

opportunities arise with willing permittees.”

Response

See response to PC #477. Under the Final Conservation Strategy for the Grizzly Bear in the Greater 

Yellowstone Area the Shoshone has an obligation to manage grizzly bear habitat in the primary 

conservation area and adjacent areas where occupancy is anticipated and acceptable (Conservation 

Strategy age 5).

Public Concern #481

The Forest Service should permanently close existing inactive, vacant grazing allotments, particularly the 

vacant sheep allotments because livestock grazing poses the largest conflict with grizzly bears.

Response

A guideline for vacant allotments was displayed in the Draft forest plan on page 73. A guideline for 

allotments with reoccurring grizzly bear/livestock conflicts appears in the revised Forest Plan page 43.

Public Concern #482

The following areas should be managed as MA 1.3, backcountry non-motorized, because they are located 

within the Primary Conservation Area, are heavily utilized by grizzly bears throughout the spring through 

fall, and motorized routes are key factors in grizzly bear conflicts and deaths: Sunlight Basin; Gravel Bar, 

Beem Gulch, and Huff Gulch on the south side of Sunlight Road.

Response

See response to PC #31.
Final Environmental Impact Statement -- Appendix A

833

Public Concern #483

The Forest Service should not allow oil and gas surface development in in Primary Conservation Areas 

or occupied grizzly habitat because it increases the chances of human- bear conflicts and further reduces 

the already small percentage of their historical range available to them.

Response

Standard 12 in the revised Forest Plan, page 42, does not allow surface occupancy for mineral 

development in primary conservation areas.

Public Concern #484

The Forest Service should permanently close sheep and cattle allotments, inside and outside of the 

Primary Conservation Area, particularly in the following allotments, because they are high-conflict areas 

where grizzlies have died as a result: Bench, Beartooth/Face of the Mountain, Table Mountain, Dunoir, 

Ramshorn/ParqueCreek/Horse Creek, Wiggins Fork and Wind River Allotments.

Response

The effects of livestock grazing on grizzly bears were discussed in the DEIS pages 167 and 176 through 

179. A guideline for allotments with reoccurring grizzly bear/livestock conflicts appears in the revised 

Forest Plan on page 43, and has been reworded for clarity.

Public Concern #485

The Forest Service should protect grizzly bear army cutworm moth sites by not encouraging public access 

to them because of the decline of additional primary grizzly food sources, such as the white bark pine and 

cutthroat trout, and the potential for disturbance to moth sites by public access.

Response

Access to army cutworm moth sites is a concern of the Shoshone that is addressed in the revised Forest 

Plan Standard 7, page 41, and under management approach, grizzly bears, page 45. 

Public Concern #486

The Forest Service should emphasize proper sanitation techniques and implement food storage 

requirements in suitable grizzly habitat throughout the Shoshone National Forest because it would reduce 

conflicts between grizzly bears and humans.

Response

Food storage requirements are already mandatory on the entire Shoshone National Forest for all activities 

that require a permit. This will be added to the biological assessment. In the revised Forest Plan, 

Guideline 16 on page 44 was developed to allow food storage infrastructure to be installed on the entire 

Forest.

Public Concern #487

The Forest Service should define what “other management tools” it will use to minimize conflicts in the 

grizzly bear PCA, otherwise, these other management tools will never be applied as a result of direction.

Response

As discussed in the draft forest plan, management approach, grizzly bears, page 45, not defining “Other 

management tools” allows the Shoshone the flexibility for adaptive management or best available 

science, or both, to determine later what these tools might be.
Shoshone National Forest Land Management Plan Revision

834

Public Concern #488

The Forest Service should verify the status of the grizzly bear and gray wolf listed as G4/S1 on page 146

and specify what it means.

Response

The G4/S1 Nature Serve ranking for grizzly bear and gray wolf listed on page 146 of the draft forest plan 

is correct. These rankings are discussed below table 35 in footnote 1 on page 146 of the draft forest plan.

Public Concern #489

The Forest Service should change the language to minimize conflicts with grizzly bears in the following 

sections to reflect grizzly bear presence on the entire forest, rather than in just the Primary Conservation 

Area because grizzly bears have recently been documented on the Washakie Ranger District: Page 41, 

Standards for T&E Species Table, line 6; and Guidelines 6 and 16 on pages 43 and 44.

Response

Management of grizzly bear habitat is discussed in the revised Forest Plan on pages 33 through 45 and is 

consistent with the Final Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Area, 

which was adopted for the revised Forest Plan. To ensure grizzly bear habitat is managed outside of the 

primary conservation area (PCA), in the revised Forest Plan, Guideline 4 on page 42, Guidelines 6 and 8

on page 43, and Guideline 16 on page 44 were developed.

Public Concern #490

The Forest Service should maintain a functioning, robust population of white bark pine (WBP), and must 

include the literature and reasoning for harvesting WBP within the final land management plan because 

long term analysis for loss of WBP has led the courts to use WBP as a reason to continue listing the 

grizzly bear as endangered.

Response

See responses to PC #358, #361, and #381 regarding whitebark pine.

Public Concern #491

The Forest Service should continue adhering to the Grizzly Bear Conservation Strategy after grizzly bear 

recovery and delisting.

Response

Grizzly bear habitat will be managed using the Conservation Strategy or best available science (revised 

Forest Plan, management approach, page 45.

Public Concern #492

The Forest Service must realize that under the Grizzly Bear Conservation Strategy it has agreed to “no 

net increase” in development or in the footprint of existing development within a Primary Conservation 

Area.

Response

In the revised Forest Plan, Guideline 11, p. 42 deals with development in the grizzly bear primary 

conservation area and is consistent with the Final Conservation Strategy for the Grizzly Bear in the 

Greater Yellowstone Area.
Final Environmental Impact Statement -- Appendix A

835

Public Concern #493

The Forest Service should emphasize, but not place sole focus on the maintenance of the four key grizzly 

bear food sources (white bark pine seeds, army cutworm moths, ungulates, and spawning cutthroat trout) 

identified in the guidelines on page 42 of the draft plan draft plan because grizzly bears are adaptable 

omnivores and focusing on four food sources is not a reliable method to ensure population viability.

Response

Management of grizzly bear habitat is discussed in the draft forest plan pages 33 through 45 and is 

consistent with the Final Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Area, 

which was incorporated for the revised Forest Plan.

Public Concern #494

Instead of encouraging public use at grizzly bear moth sites, the Forest Service should increase its grizzly 

bear interpretive and educational efforts near Sylvan Pass at the east gate, where there are typically 

roadside bears in the summer months, by adding summer seasonal staff to keep both people and bears 

safe.

Response

Access to army cutworm moth sites is a concern of the Shoshone that is addressed in the draft forest plan 

Standard 7, page 41 and under management approach, grizzly bears, page 45. In the draft forest plan, 

Standard 6 deals with minimizing grizzly bear/human conflicts using information and education and is an 

integral part of the Final Conservation Strategy for the Grizzly Bear in the Greater Yellowstone Area. 

Interpretive and educational efforts may be considered in a site-specific effort, which outside the scope of 

the revised Forest Plan analysis.

Public Concern #495

The Forest Service should perform Section 7 consultation for all projects with potential to affect grizzly 

bears or their habitat, including lands outside of the Primary Conservation Area.

Response

The Endangered Species Act requires consultation on listed species when their habitat(s) may be affected, 

no matter the location of the habitat (revised Forest Plan, management approach, page 44). The Forest 

Service consults with the U.S. Fish and Wildlife Service for projects with the potential to affect listed 

species or their habitats.

Public Concern #496

To minimize contact and confrontation between the public and grizzly bears, the Forest Service should 

abandon its support for public access sites to observe foraging grizzly bears and use video cams and livestream via FS website instead.

Response

Access to army cutworm moth sites is a concern of the Shoshonethat is addressed in the revised Forest 

Plan Standard 7 on page 41, and under management approach, grizzly bears, page 45.

Public Concern #497

The Forest Service should increase the amount of wilderness and roadless areas for grizzly bear 

protection because roads negatively impact grizzly bears.
Shoshone National Forest Land Management Plan Revision

836

Response

Roads and their effects on grizzly bears is discussed in the EIS pages 174 through 175. See reponse to PC 

#27 regarding recommended wilderness areas.

Public Concern #498

The Forest Service should not allow snowmobiles in grizzly bear denning habitat or key bear habitats, 

such as avalanche chutes, winter ranges, mature white bark pine stand and army cutwork moth sites, 

because it could negatively affect grizzly bear foraging and increase the potential for human-bear 

conflicts.

Response

Winter motorized use and its effects on grizzly bears is discussed in the DEIS on page 175. The decision 

maker will consider the public comments in making the final decision.

Subject: 1050 - Forest Mammals - American marten

Public Concern #499

The Forest Service should remove or modify language on page 186 of the DEIS to reflect findings that 

coyotes did not require compacted snow routes to access winter snowshoe hare habitat (Kolbe et al. 

2007).

Response

The sentence in the EIS on page 186, “Greater winter travel via snowmobiles could theoretically alter 

snow conditions and allow low-elevation predators to access more winter habitat due to snow 

compaction” acknowledges a potential of predator access. The document (Kolbe 2007) is not site-specific 

to the Shoshone National Forest. It does investigate the potential impacts that coyotes using snowmobile 

trails to access deep snow areas may have on lynx. The biological assessment considered and included 

this literature.

Public Concern #500

The Forest Service should maintain the marten as a focal species for mature and overmature (old growth) 

forests.

Response

Focal species is not a category under the planning regulations being used to revise our forest plan. 

American marten is included in the sensitive species category in the revised Forest Plan.

Subject: 1070 - Forest Mammals - Northern American Wolverine

Public Concern #501

The Forest Service should cite relevant science if they plan to use the 2007 Northern Rockies Lynx 

Management Direction (NRLMD) for wolverine management since that direction was never intended for 

wolverine management.

Response

The EIS does not say that lynx direction is being used to manage for wolverine. The EIS is an effects 

analysis that points out that implementation of lynx direction will also benefit wolverine habitat.
Final Environmental Impact Statement -- Appendix A

837

Public Concern #502

The Forest Service should use the best available science in managing wolverine denning areas and 

should not eliminate snowmobile use without consideration of eliminating other winter activities and 

without assessing whether these activities have had adverse effects on wolverine denning in the past.

Response

There is no direction in the revised Forest Plan that snowmobiling would be restricted for wolverine dens. 

The EIS points out that this was something that may be considered. Any such consideration would be 

subject to a site-specific decision made at the project level with the latest information and science. For the 

FEIS, wolverine is now being analyzed as a proposed species. The latest information indicates that 

snowmobiling is not a risk factor for wolverine. Therefore, the revised Forest Plan will not have any 

specific direction to restrict snowmobiling in wolverine denning habitat. As before, project plans may 

consider the impact of snowmobiling on wolverine dens in a site-specific analysis.

Public Concern #503

The Forest Service should make the recovery of wolverines a top priority on the SNF and provide for the 

large, remote areas that the species requires.

Response

Large expanses of the Shoshone are unmanaged and provide remote areas without management activity or 

other disturbances. Alternatives C and D provide the greatest areas of remote habitat. The decision maker 

will consider comments asking for greater areas of remote habitat along with other comments in making a 

final decision.

Public Concern #504

The Forest Service should conduct analyses to determine which roadless areas are most important for 

core wolverine habitat and movement corridors, close these areas to motorized use, and develop site 

specific conservation plans.

Response

See response to PC #503.

Public Concern #506

The Forest Service should determine the effective population (Ne ) of breeding adults necessary to 

maintain viable wolverine populations using accepted scientific formulae, and then make a determination 

that “excess” numbers of wolverines above this threshold are actually present in order to make a 

determination that individuals may be lost without threatening overall population viability. The Minimum 

Viable Population levels currently accepted are a Ne of at least 50 breeding adults.

Response

Determining the effective population level for such a large-ranging low-density species as the wolverine 

is more appropriate at a planning level much larger than one national forest. This is beyond the scope of 

the revised Forest Plan.

Subject: 1090 - Forest Birds - Boreal Owl

Public Concern #507

The Forest Service should explicitly plan for the viability of the boreal owl throughout potentially suitable 

habitat on the Forest.
Shoshone National Forest Land Management Plan Revision

838

Response

Large expanses of the Shoshone are unmanaged and provide extensive areas of late successional habitat. 

Management activity that could impact owl habitat occurs on less than 10 percent of the forest. 

Alternatives C and D provide the greatest areas of habitat, while alternative F provides the least. The 

decision maker will consider comments asking for more owl habitat along with other comments in 

making a final decision.

Subject: 1100 - Forest Birds - Northern Goshawk

Public Concern #508

The Forest Service should delete Standard 1 for sensitive species, page 48, since there is a large amount 

of habitat for the goshawk on the Forest, inventories to document goshawks are expensive, and NFMA 

only requires that the species viability be assured.

Response

Though overall risk to the species is low, the goshawk is still a sensitive species that requires some 

attention and management. The relatively modest requirements in the revised Forest Plan, will not 

significantly impact timber operations, while still maintaining a minimum level of protection for the 

goshawk.

Public Concern #509

The Forest Service should modify Standard 8 for sensitive species (p. 48) to reflect long-term 

sustainability or habitat availability at the Forest scale or delete it.

Response

See response to PC #508.

Public Concern #510

The Forest Service should delete Standard 7 for sensitive species; it would be impossible to enforce 

because actions detrimental to one species would be beneficial to others and actions adverse in the short 

term could be beneficial in the long term. The standard would limit habitat restoration options, increase 

NEPA costs, and make the SNF vulnerable to litigation.

Response

The trade-offs between different species can be addressed at the project planning stage. The standard 

requires that the impacts be analyzed and considered which needs to be done in the biological evaluation. 

We changed the wording to clarify the intent.

Public Concern #511

The Forest Service should establish standards and guidelines that require surveying and monitoring prior 

to activities like fuel treatments, logging, or gas leasing to determine what sensitive species are in the 

area and exactly where they are.

Response

The management approach describes how the presence of sensitive species will be considered during sitespecific project planning.
Final Environmental Impact Statement -- Appendix A

839

Public Concern #512

The Forest Service should strengthen the standard to “identify alternate and replacement nest stands of 

comparable habitat quality” and should prohibit management activities that are likely to impact the 

suitability of nesting habitat.

Response

The revised Forest Plan includes direction for protecting goshawks that was developed within the context 

that less than 10 percent of the Forest is actively managed. The risk impact to goshawks from timber 

harvest is minimal. The revised Forest Plan direction provides an appropriate level of protection, given 

the level of risk.

Public Concern #513

The Forest Service should reference the regional conservation assessment and other current literature in 

the LMP, manage the goshawk at a landscape scale, and provide a means for 1) estimating existing 

suitable nesting habitat and 2) managing conifer forests to provide adequate nesting and foraging habitat 

across the forest landscape in lower elevation forests where goshawks are known to nest.

Response

Current literature for the goshawk and all other sensitive species is listed in the biological evaluation 

prepared for this project. Large expanses of the Shoshone are unmanaged and provide remote areas 

without management activity or other disturbances. Alternatives C and D provide the greatest areas of 

remote habitat. Standards and guidelines in the revised Forest Plan provide an appropriate level of 

protection, given the level of risk to the species.

Subject: 1120 - Grassland/Sage Mammals - Rocky Mountain bighorn sheep 

Public Concern #514

The Forest Service should consider not banning pack goats in the forest as a means to stop disease spread 

to Bighorn Sheep since pack goats are not like other domestic goats, pack goats are tethered at night and 

monitored by humans, pack goats are trained, GPS tracking collars on pack goats, pack goats have 

pathogen testing, there is permitting for pack goat trips, designation of corridors for pack goats, Bighorn 

can catch diseases from other animals on and off the forest, wolves may be more of an impact on Bighorn 

population that disease, hunting could be more of an impact on Bighorn Population, pack goat

elimination goes against multiple use, habitat change may be more of an impact, there is no requirement 

to enhance Bighorn population, pack goats are less impactful on the environment than other pack 

animals, can set up mitigation measures for to prevent pack goats from spreading disease, an outright ban 

can cause a ripple effect amongst other forests, allows those that cannot walk easily to see the 

backcountry

Response

Alternatives E and F in the FEIS do propose to allow pack goat use in bighorn sheep habitat. The effects 

of these alternatives along with the other alternatives is disclosed in the FEIS.

Public Concern #515

The Forest Service should provide scientific research used for the EIS to document that disease 

transmission occurs between pack goats and bighorns, provide information that shows there are no 

mitigation measures, show information on other possible causes for Bighorn population decline, explain 

how it will meet that standard of and what is authorized use from statement “do not allow recreational 

pack goat use in core native bighorn sheep ranges, except for authorized use,” should explain its 
Shoshone National Forest Land Management Plan Revision

840

“concern” in the Draft LMP and DEIS and indicate the scientific information supporting that concern, 

and describe the guidelines in the LMP that explain how forest will manage risk from pack goats.

Response

The Bighorn Sheep Disease Risk Assessment (USDA Forest Service 2012) prepared for the DEIS 

contains all of the literature used to prepare that document. The risk assessment is part of the project 

record. Authorized use refers to pack goat use that is authorized by a Forest Service permit. Standards in 

the revised Forest Plan developed for sensitive species, including the bighorn sheep, are expected to 

reduce the risk of disease transmission between domestic goats and bighorn sheep.

Public Concern #516

The Forest Service should consider a moratorium on Bighorn Sheep Hunting and view other threats, such 

as predators and competition with other species to do analysis of impacts to bighorn sheep of the 

Shoshone Land Management Plan Revision, have domestic sheep and/or goat use not overlap with 

bighorn sheep even if that includes banning pack goats completely to stop spread of disease, if any 

treatment is discovered it should be implemented immediately, close bighorn sheep crucial winter range 

to humans, work with The Wyoming Wild Sheep Foundation, and protect the Bighorn Sheep since past 

and future hunting brings in money to the economy.

Response

Hunting and fishing regulations are determined by the Wyoming Game and Fish Commission and are 

outside the scope of this project. All of the alternatives provide for some level of protection that reduces 

the risk of contact between domestic sheep and bighorn sheep. Alternatives B, C, and D reduce the risk of 

contact and the potential for transmission more than the other alternatives. The decision maker will 

consider those alternatives and these comments along with other comments on management in making a 

final decision. Standards for big game crucial winter including bighorn sheep are disclosed in the revised 

Forest Plan on page 59.

Public Concern #517

The Forest Service should consider making the following changes:1- define and give time frame to 

improvements of habitat; 2- define the critical time period that human access would be limited in bighorn 

sheep wintering areas; 3- logic is wrong since occupied wolf habitat does not eliminate bighorn sheep 

habitat; 4- the statement that closest portion of the remnant Temple Peak herd is about 28.9 km from the 

domestic sheep allotments on the Shoshone is false and additionally, the map of ‘occupied’ habitat relied 

on for this analysis is highly inaccurate; 5-on page 208 remnant herd, this is not a true “classification” of 

the Wyoming Game and Fish Department; 6-On Page 209 sheep herds, it should be included with pack 

goats; 7-on Page 209 blanket statement sheep in Yount’s Peak herd are non-migratory is incorrect; 8-

page 212 the statement “Suitable bighorn sheep habitat within these domestic sheep allotments on the 

Shoshone is very limited as a vast majority of the land is forested and within occupied habitat of gray 

wolves”since wolves don’t make habitat unsuitable; 9-page 214 say closure for the 26 km buffer is to 

protect foraying bighorn sheep from coming into contact with pack goat; 10-page 214 is an opportune 

place to discuss the Wyoming Statewide Bighorn/Domestic Sheep Interactions Working Group's work and 

publications; 10- elaborate on the problems the Trout Peak Bighorn Sheep Herd has.

Response

(1) Habitat improvement projects identified in the revised Forest Plan are dependent upon budgets that 

are determined independently from this planning process. It is expected that habitat improvements 

would occur within the life span of the planning document.
Final Environmental Impact Statement -- Appendix A

841

(2) Management activities that disturb big game, including bighorn sheep, should be restricted from 

December 1through April 30 (revised Forest Plan, page 60).

(3) The map used to identify occupied bighorn sheep habitat and domestic sheep allotments is the best 

available information.

(4) The EIS was edited to remove “by the WGFD.”

(5) The EIS was edited under Francs Peak Bighorn Sheep Herd to say “No pack goat use occurs within 

this core native herd range.”

(6) The EIS was edited to include the language about the Yount’s Peak Bighorn Sheep Herd. 

(7) The EIS was edited to remove the reference to wolves on the Temple Peak Herd.

(8) The EIS was edited removing the buffer language since the Forest Service has no authority on other 

public or private lands.

(9) The Wyoming State-wide Bighorn Sheep/Domestic Sheep Interaction Working Group and its 

recommendations are referenced under management approach, sensitive species in the revised Forest 

Plan on page 52.

(10) The information on the Trout Peak Herd was updated to 2012 Wyoming Game and Fish data.

Subject: 1125 - Grassland/Sage Mammals Disease

Public Concern #518

The Forest Service should not prohibit pack goats in bighorn sheep habitat as there is not enough 

scientific evidence to support disease transmission. The Forest should provide potential mitigation 

measures, such as health certification, and conduct further studies and research to determine if pack goat

presence in bighorn sheep habitat and comingling result in disease transmission. The Forest should 

consider protection measures, including tethering or fencing instead of the prohibition of domesticated 

goats from bighorn sheep habitats.

Response

All alternatives provide some level of protection for maintaining viability of bighorn sheep, as well 

providing other resources. Some alternatives, such as A, E and F, allow for domestic pack goat use in core 

native bighorn sheep habitat. The decision maker will consider comments to determine what level of risk 

of contact in core native bighorn sheep habitat should be allowed.

Public Concern #519

The Forest Service should prohibit domestic sheep and goats in bighorn sheep habitat to reduce the 

chance of disease transmission and to not allow the establishment of buffer zones to act as a method to 

manage disease transmission.

Response

See responses to PC #517 and #518.

Public Concern #520

The Forest Service should utilize domestic sheep allotments outside of bighorn sheep range as forage 

reserves and/or allotments which could host relocated domestic sheep and follow the recommendations 

from the Wyoming Statewide Domestic Sheep/Bighorn Sheep Interaction Working Group (IWG) 

pertaining to additional management consideration to achieve separation between domestic sheep and 

goats and bighorn sheep.
Shoshone National Forest Land Management Plan Revision

842

Response

The only two remaining domestic sheep allotments on the Shoshone are still active but currently in a nonuse status. The Wyoming State-wide Bighorn Sheep/Domestic Sheep Interaction Working Group and its 

recommendations are referenced under management approach, sensitive species in the revised Forest Plan 

on page 52.

Public Concern #521

The Forest Service should consider adapting the recommendations in the Cody brucellosis management 

action plan developed by the Wyoming Governor's Brucellosis Coordination Team and Wyoming Game 

and Fish Department under all alternatives.

Response

The Wyoming Governor’s Brucellosis Coordination Team Management action plans are already 

incorporated as discussed in the revised Forest Plan age 62.

Subject: 1130 - Grassland/Sagebrush Birds - Brewer’s sparrow and Sage 

sparrow

Public Concern #522

The Forest Service should make a change to Ch. 3, Affected Environment. Brewer’s Sparrow and Sage 

Sparrow, Risk Factors, on page 218 to state that livestock grazing is not a risk factor to sparrows, but 

specific livestock grazing management may be a risk factor.

Response

The word “management” is already used in that same sentence which implies livestock grazing 

management. No change needed in the sentence.

Subject: 1160 - Grassland/Sagebrush Birds - Greater sage-grouse affected

Public Concern #523

The Forest Service should make the following changes to the Land Management Plan: (1) In Goal 7, page 

47 the word contiguous should be looked at as there is no scientific evidence that sagebrush was ever 

continuous under natural disturbances, or can be sustained over time and the addition of, “-to the degree 

possible considering other resource values” should be made to the sentence. (2) Connect with the local 

sage-grouse working groups around the forest to fill in gaps in population estimates or trends that are 

missing in the DEIS for inclusion into the final Land Management Plan.

Response

Discussion regarding the use of unfragmented habitat by sage-grouse is documented in the biological 

evaluation prepared for this project. No wording change is needed. The Shoshone is a minor player in the 

sage-grouse arena as it contains no core habitat and contains some late-summer brood-rearing habitat 

only. Additional population data for the Shoshone were not needed for this analysis.

Public Concern #524

The Forest Service should take into account the impacts of coal-bed methane natural gas and deep well 

fields to leks when establishing buffers in the Draft EIS as the current .25 mile buffer is insufficient to 

adequately conserve breeding sage-grouse as determined by past research. The Forest should also be sure 

that all Alternatives apply analysis using the best and most current science and include mitigation and 

monitoring guidelines set forth by the CEQ in 2011. Increased levels of protection need to be considered 
Final Environmental Impact Statement -- Appendix A

843

in all of the RMP/EIS Alternatives regarding crucial winter habitats as research has demonstrated that 

sage-grouse will avoid otherwise suitable wintering habitats once the habitat has been developed for 

energy production, even after lek buffers have been applied. The Forest must implement the right 

conservation practices in the right locations to preclude the need to list the species as threatened or 

endangered.

Response

The Shoshone has no known sage-grouse leks at the time of this writing. Should a lek be located on the 

forest, during proposed management actions, site-specific mitigation measures will be developed using 

best available science.

Subject: 1190 - Grassland/Sagebrush Birds - Short-eared owl

Public Concern #525

The Forest Service should remove “livestock grazing” from the discussion on fragmentation from Ch. 3. 

Affected Environment. Short-eared Owl, Risk Factors on page 240 as disturbances from new range 

improvements may cause fragmentation, grazing itself does not.

Response

Since “management” is used in the same sentence as livestock grazing, the sentence implies livestock 

grazing management can fragment the habitat. A more detailed analysis is contained in the biological 

evaluation that is part of the project record.

Subject: 1270 - Riparian Amphibians - Boreal western toad

Public Concern #526

The Forest Service should consider that the species names of boreal toad and northern leopard frog have 

changed Boreal Toad is Anaxyrus boreas borease and northern leopard frog is Lithobates pipiens.

Response

The scientific name for boreal toad (Anaxyrus boreas boreas) was correct in the DEIS; but the northern 

leopard frog has been corrected in the FEIS.

Public Concern #527

The Forest Service should consider clarifying and/or changing the following: 1-the claim that the boreal 

toad, Columbia spotted frog, and northern leopard from “all occupy similar habitat” is misleading; 2-

Why do spotted frogs and leopard frogs receive scant or no further mention after paragraph 6 in Chapter 

3 and really only mention Boreal Toads; 3- how ‘assessing the impact of non-native trout on amphibian 

populations” provide a conservation measure; 4- how conservation measures incorporated into the forest 

plan goals, objectives, standards and guidelines; 5-better demonstrate where amphibians occur and what 

might constitute ‘high value’; 6- why does Table 68 limits consideration to spruce/fir and aspen; 7-Table 

68 and the conclusions based on it require revision, using accurate information; 8-there is a false premise 

that toads exist ‘at higher elevations which makes the conclusion inaccurate; 9-“Although impacts could 

occur if timber sale activities occurred around a currently extant yet unknown population or breeding 

site, it is unlikely that this would occur due to historic knowledge and continued survey requirements and 

conservation measures.” (P. 263) is an illogical sentence due to sparse knowledge of current populations; 

10- clearly state continued survey requirements” for amphibians; 11- management goals, requirements, 

standards, etc., are not written adequately to address the unique habitat needs of amphibians; 12- The 
Shoshone National Forest Land Management Plan Revision

844

limited language regarding amphibians on page 51 (DLMP) fails to adequately address amphibian 

populations.

Response

The three amphibian species discussion has been edited to more consisely disclose their affected 

environment and effect in the EIS.

Edits were made to the statement in the EIS page 263 to clarify the meaning. The information in table 68

of the EIS will be reviewed for accuracy.

The revised Forest Plan, page 50, management approach, outlines the process for site-specific project 

analysis where by “when in suitable habitat, assume sensitive species (includes amphibians) presence or 

implement surveys to achieve adequate detection....”

Conservation measures for amphibians taken from the biological evaluation were incorporated into the 

revised Forest Plan. In addition, the watershed practices handbook (Forest Service Handbook 2509.25) 

mentioned in the revised Forest Plan page 51 and Forest Service Manual 2631.3 (DEIS p. 142) provide 

for riparian, wetland and fen protection to the benefit of amphibian species.

Public Concern #528

The Forest Service should consider these sensitive amphibian species are at unusually high risk and in 

need of protection measures compared to most of your other sensitive vertebrates due to: lack of known 

occupied sites and the disappearance of these known populations would be a significant conservation 

issue, diseases including those spread by non-native trout, rotenone piscicide will kill amphibian larvae, 

fuel treatment activities, and wild-land fire. Due to these issues there is a real possibility that some or all 

of these sensitive amphibian species could be extirpated at the district levels or the Forest level.

Response

See response to PC #527.

Public Concern #529

The Forest Service should consider maintaining adequate cover components from any management 

activities and conservation measures for both staff and boaters to limit the spread of aquatic diseases.

Response

See response to PC #527. Aquatic invasive species and their effects from management activities proposed 

in all of the alternatives are discussed in the EIS pages 310 through 319.

Public Concern #530

The Forest Service should consider the following Recommendations for sensitive amphibians, to include 

in standards and guidelines: 1-Highlight the need to identify and protect isolated and non-perennial 

wetlands, including pools, marshes, seasonally wet meadows, spring and seeps;

2-Establish buffer areas around amphibian habitat for various management activities, as recommended 

by the Region Species Conservation Assessments. These vary from 100' to 2.5 miles; 3-Include measures 

to protect amphibian sites from fire retardant chemicals, which can be deadly; 4-Establish standards for 

the height of sedge/grass to be maintained in wetland areas grazed by livestock; 5-Stipulate the survey 

requirements for amphibians in management project areas; 6-Advise the need to clean and disinfect 

footwear and gear to avoid spreading amphibian diseases; 7-Maintain a database on amphibians on the 

SNF that can be easily accessed, used, and updated by your specialists.
Final Environmental Impact Statement -- Appendix A

845

Response

See responses to PC #527 and PC #529. Determining survey and disinfectant protocol for amphibian 

species is outside the scope of this document. The current database for wildlife species is managed by the 

Wyoming Natural Diversity Database out of the University of Wyoming.

Subject: 1290 - Riparian Amphibians - Northern leopard frog

Public Concern #531

The Forest Service should consider that managing aquatic habitat alone does not provide adequate 

protection for amphibians on the SNF especially the Northern Leopard Frog, since populations are 

thought to be declining.

Response

See response to PC #527.

Subject: 1300 - Caves and mines mammals - Fringed myotis

Public Concern #532

The Forest Service should consider adding language about that White-nose syndrome since it is 

expanding westward and has decimated populations of certain bat species in the eastern and central U.S

Response

Region 2’s White-nose Syndrome Response Plan is referenced in the revised Forest Plan on page 53 and 

in the EIS on pages 144, 188, and 267. White-nose Syndrome is also discussed in the biological 

evaluation prepared for the revised Forest Plan.

Subject: 1340 - Management Indicator Species - Ruffed Grouse

Public Concern #533

The Forest Service should consider in section 9.8 RUFFED GROUSE, 9.8.1 Draft Land Management 

Plan included mechanical treatments as another tool in aspen regeneration and treatments and not just 

fire and should support the revision of 18 to 4 Management Indicator Species.

Response

Mechanical treatment in 2,500 acres of aspen habitatis listed as an objective in the EIS page 34.

Public Concern #534

The Forest Service should consider justifying how Ruffled Grouse can by a Management Indicator 

Species since they cyclical population changes that has nothing to do with Aspen stands, is regularly 

hunted, and there is no historical demographic data are available to use as a basis for monitoring.

Response

The management indicator species selection process was outlined in the revised Forest Plan, appendix 3, 

pages 279 through 282. Rationale for not selecting other species is listed in the project record. A 

monitoring protocol that we found being used in Minnesota will be modified for use on the Shoshone.
Shoshone National Forest Land Management Plan Revision

846

Subject: 1360 - Management Indicator Species (MIS) - Red-breasted 

nuthatch

Public Concern #535

The Forest Service should provide better justification or reconsider the choice of selecting the redbreasted nuthatch as a management indicator species due the fact that the species’ population can 

fluctuate widely based on conditions elsewhere in the western United States without being driven by local 

management actions as noted on page 278 of the DEIS.

Response

In the January 2012 draft forest plan. The red squirrel was identified as a potential management indicator 

species for lodgepole pine. After public comment, the habitat concern changed from lodgepole pine to 

mature conifer and snags. During the final management indicator species selection process it was 

determined that the red-breasted nuthatch was a more appropriate species for this habitat. The 

management indicator species selection process is outlined in the revised Forest Plan, appendix 3, pages 

279 through 282. Rationale for not selecting other species is listed in the project record.

Subject: 1390 - Species of local concern - Rocky Mountain elk

Public Concern #536

The Forest Service should make the following changes to the Draft Management Plan: (1) Under Desired 

Conditions on page 57, Minimize human disturbance in big game crucial winter range. We suggest SNF 

officials consider changing that wording to: ―”Minimize human disturbance in big game crucial winter 

range to levels commensurate with maintaining big game populations within state designated population 

goals and objectives. (2) For Standards 1 and 2 on page 60, the timing restrictions for elk calving be 

limited to instances where there is a demonstrated need for a specific project area and recommend 

combining Standards #1 and #2, retaining the following language from Standard #2; “will be on a case 

by case basis when good data support the action.” (3) On page 60, incorporate the following language 

into Guidelines #4 and #5; “will be on a case by case basis when good data support the action”. (4) The 

Plan should include an analysis of Habitat Effectiveness and Habitat Security associated with each 

alternative to evaluate existing conditions and potential impacts. (5) The Plan should include calving 

research by Arthur Middleton and Matt Kaufman that discusses pregnancy rates and calf mortality.

Response

(1) Minimizing human disturbance on big game crucial winter range (Goal 2, revised Forest Plan) not 

only benefits elk and deer, but also those species that utilize big game for their survival. No change is 

needed.

 The Shoshone worked cooperatively with Wyoming Game and Fish to determine documented 

parturition areas on the Forest that justified the timing restrictions. 

 The results are the limited areas identified in the revised Forest Plan on page 60. All other areas are 

more flexible and are included in Standard 2 on page 60. We edited the EIS page 293 to include the 

timing restriction dates selected in the revised Forest Plan (December 1 through April 30).

The Shoshone worked closely with the Cooperators during plan revision to identify areas of existing 

winter motorized use that occurred on big game crucial winter range. Exceptions to motorized use on 

crucial winter range were identified and incorporated into management area allocations in the revised 

Forest Plan.

 The Shoshone wildlife biologists felt that a habitat effectiveness model (HE) was not needed because 

most herd units are over objective and the landscape lacks open roads. One of the biggest impacts to 
Final Environmental Impact Statement -- Appendix A

847

elk on the Shoshone is during hunting seasons, therefore, the focus in the revised Forest Plan is to 

provide adequate security during hunting seasons. Elk herds on the Shoshone show a preference for 

migrating into Yellowstone National Park and wilderness, lessening the importance of HE values in 

the summer. Impacts of the various alternatives to elk security are analyzed in the EIS pages 285

through 291.

 The Middleton and Kaufman studies were considered and added where appropriate to the elk analysis 

in the EIS.

Public Concern #537

The Forest Service should make the following changes to the DEIS: (1) Include in the DEIS that livestock, 

under properly managed grazing systems, are a tool that may improve forage conditions for elk. (2) Table 

75 of the DEIS does not display timing restrictions for motorized use for each alternative; the Forest 

should provide the information and disclose the areas that will be impacted by these restrictions. (3) 

Under Affected Environment. Species of Local Concern, Rocky Mountain Elk, and page 288 add the 

following language: “The disease known as Brucellosis is caused by the bacteria Brucella abortus and is 

transmitted when a susceptible animal contacts and ingests bacteria following the abortion or stillbirth 

from an infected female. Exposure of a susceptible animal to the bacteria elicits an antibody immune 

response that can be detected (with varying degrees of accuracy) following one to several unique blood 

tests. When several or more animals are tested from a population within a given time period, this provides 

an index of exposure (but not infection) to the bacteria. This mathematical proportion of exposure (i.e., 

those animals that are antibody-positive divided by the sample population) is commonly referred to 

as'seroprevalence. ”

Exposure of elk to brucellosis was first documented at the National Elk Refuge in 1933, and since then, 

has been documented in elk attending all 22 Wyoming state-operated winter feedgrounds on the adjacent 

Bridger-Teton National Forest, as well as winter free-ranging elk from western Wyoming, northeastern 

Idaho, and southern Montana. Seroprevalence of brucellosis in elk attending Wyoming winter 

feedgrounds averages about 25% and generally declines to levels less than 10% in winter free-ranging 

elk throughout the Greater Yellowstone Area. However, winter free-ranging elk habituating lands of the 

Shoshone National Forest in Wyoming, particularly those areas north of Lander and Dubois, have had 

seroprevalence levels as high as 22%.

It has long been recognized that elk of the Greater Yellowstone Area are a reservoir of brucellosis. 

Despite the use of winter feedgrounds, strain 19 vaccination, and several other best management 

practices, the threat of spillover from elk to domestic livestock has been realized and confirmed several 

times in the past decade. As elk herds of the Shoshone National Forest have continued to grow and utilize 

winter habitats in similarity to winter feedgrounds, it is likely that these elk will maintain elevated 

seroprevalence and also pose a threat to adjacent livestock operations. Most recently, this particular 

threat was realized following confirmed spillover of brucellosis from winter free-ranging elk of the 

Shoshone

National Forest to adjacent livestock on private lands. Whether from elk attending feedgrounds or winter 

free-ranging, elk-to-livestock transmission events have caused economic and logistical constraints for 

livestock producers and induced time-consuming policy changes at state and federal levels.

Alternative C would provide the least potential transmission of brucellosis with domestic livestock. 

Alternative C would minimize disturbance to wintering elk, making it more likely they would remain on 

all Forest winter ranges, including crucial winter range. Without some type of

timing restriction on elk crucial winter range, there is the potential of elk moving off the Forest to 

adjacent private property, increasing the opportunity for elk to intermingle with livestock. Alternative F 
Shoshone National Forest Land Management Plan Revision

848

would provide the greatest opportunity of transmission with domestic livestock because it proposes no 

timing restrictions on disturbing activities in elk crucial winter range,

thereby providing the least amount of protection from disturbance during the critical winter months. 

Alternatives D, B, E, and A would provide disturbance free habitat in a descending order from the most to 

least, but all would provide more protection from winter disturbance then Alternative F."

Response

The benefits to elk by livestock grazing are mentioned in the EIS on page 411.

Timing restrictions (December 1 through April 30) on crucial winter range for motorized use did not 

change by alternative, which appears in the revised Forest Plan on page 60. We edited the EIS page 293 to 

include the timing restriction dates selected in the revised Forest Plan.

We agree and added the language on brucellosis that was provided. 

Public Concern #538

The Forest Service must recognize the importance of migratory routes necessary between critical areas 

for elk and that oil and gas exploration activities can not only remove productive habitat, but create 

migration barriers.

Response

See response to PC #442.

Public Concern #539

The Forest should increase enforcement efforts to reduce unauthorized motorized traffic for elk habitat 

conservation and limit human access to elk calving and wintering areas to reduce potential disturbance 

during these critical time periods. The Forest should follow Standard 1 for Species of Local Concern in 

the Draft Management Plan.

Response

The forest plan contains direction on maintaining secure habitat and protecting big game ranges from 

motorized recreation. The issue of amount of enforcement is a budget-related issue that is beyond the 

scope of the Revised Forest Plan analysis.

Public Concern #540

The Forest Service should make the best attempt at managing elk habitats with the following: (1) Restrict 

logging of forest patches in the primarily open areas that compromise winter range. (2) Reduce open road 

densities to preserve habitat quality, create smaller home ranges and create higher elk survival rates. (3) 

Withdraw winter range areas from oil and gas development to reduce calf abandon rates. (4) Human 

activities should be prohibited on elk winter ranges between November 15 and April 30 to not impact elk 

distributions.

Response

See response to PC #417. The decision maker will consider comments on what level of big game 

protection should be provided along with other comments in making a final decision. 
Final Environmental Impact Statement -- Appendix A

849

Subject: 1400 - Species of local concern - Mule deer

Public Concern #541

The Forest Service should consider increasing mixed mountain shrub habitats at mid-elevation, enhance 

transition range between winter and summer ranges, have liquids collected in pipelines rather than stored 

at well pads and hauled off with tanker trucks, and limit human access in winter range to help with 

survival.

Response

We edited the revised Forest Plan to include a goal of improving mixed mountain shrub habitats.

As stated in the draft forest plan on page 63, Recommendations for Development of Oil and Gas 

Resources within Important Wildlife Habitats will be used to provide guidance during mineral 

development.

Public Concern #542

The Forest Service should consider that wells, compression stations, and associated roads can lead to 

avoidance/displacement and habitat loss for mule deer thus moving the mule deer to agricultural areas 

leading to more problems.

Response

See response to PC #541.

Public Concern #543

The Forest Service should take into consideration the migration corridors of mule deer when planning 

and enacting developments since impacts to the corridor could lead to isolation issues with mule deer.

Response

See response to PC #541.

We edited the EIS to include language about rangeland fences and their potential impacts to big game.

Subject: 1410 - Species of local concern - Moose

Public Concern #544

The Forest Service should consider adding the following for Moose: 1-in conservation measures add 

monitoring component to assess the health and vigor of riparian, deciduous shrub habitats; 2-in 

conservation methods include reclamation i.e. prescribed fire and reclamation for habitat; 3-on page 297 

add “and livestock grazing permittees” after Wyoming Game and Fish Department; 4- add an additional 

guideline concerning moose and wildfire and consult with the Bridger-Teton National Forest and 

Wyoming Game and Fish Department.

Response

(2) Monitoring of site-specific habitat improves such as those in moose habitat will be developed at the 

project level and is outside the scope of this document.

(3) The EIS was edited to include reclamation to the conservation measure.

(4) The allotment planning in willow communities discussed in the EIS page 297 already includes the 

livestock grazing permittee.
Shoshone National Forest Land Management Plan Revision

850

(5) The revised Forest Plan page 62 discusses wildland fire in big game habitat. Consultation with 

Wyoming Game and Fish and adjacent national forests will occur when applicable.

Public Concern #545

The Forest Service should consider limiting human access in the wintering habitat of moose due to its 

below objective population size in the forest.

Response

Big game crucial winter range, including that for moose, restricts management activities from 

December 1 through April 30 (revised Forest Plan, page 60).

Subject: 1450 - Aquatic, Riparian and Fisheries Resources - General

Public Concern #546

The Forest Service should set aside money to stock all of the lakes in and around Strong Creek Basin with 

trout to provide employment opportunities.

Response

Stocking lakes outside of wilderness is the primary responsibility of the Wyoming Game and Fish 

Department. Stocking of lakes inside the wilderness is conducted in accordance with the Wilderness Act. 

Therefore, this comment is outside the scope of this planning document.

Public Concern #547

The Forest Service should include grizzly bear, lynx, and other riparian species (i.e. northern dipper and 

water shrew) to the Draft Land Management Plan as other potentially impacted species from snowmaking

operations.

Response

The effects of snowmaking on wildlife species is addressed in the FEIS and not in the revised Forest Plan. 

In the revised Forest Plan, Management Area 8.2, Guideline 12 on page 199, is intended to address 

snowmaking at the site-specific, project scale.

Public Concern #548

The Forest Service should establish 0.25 mile buffers along sensitive waters including intermittent and 

ephemeral streams occupied by sensitive fish species for portions of the year to protect important 

spawning and brood-rearing habitat; should examine the effects to fisheries both native and wild trout, 

including streams containing conservation populations of Yellowstone cutthroat trout ; should also make 

best efforts to prevent the decrease of Yellowstone cutthroat trout and other sensitive species populations 

from habitat fragmentation and degradation, maintaining long-term hydrologic and riparian function, 

channel stability, and the spread of invasive species through the placement and removal of barriers; and 

finally should also detail how the monitoring of barrier removal/installation is conducted.

Response

About half of the Forest is in non-wilderness lands that may be actively managed for various resources 

consistent with the mission of the Forest Service. One of the primary land management strategies is to use 

management techniques that simulate natural processes, which includes disturbances. Periodic 

disturbance is an integral part of natural process on the landscape required for long-term sustainability of 

aquatic ecosystems (Kreutzweiser et al. 2012). These land management activities result in acceptable 

short-term disturbances with proper implementation, administration, and compliance of forest plan 
Final Environmental Impact Statement -- Appendix A

851

standards, guidelines, Region 2 Watershed Conservation Practices Handbook and other Federal and State 

land management direction. These short-term disturbances result in long-term benefits to the riparian 

ecosystem and the biota that use them, including Yellowstone cutthroat trout and mountain suckers.

Creating riparian buffer protection zones and setbacks for all management activities delays succession, 

reduces vegetative diversity and nutrient productivity, and increases the chances for large-scale fires 

substantially outside the natural range of variability (Van de Water and North 2012). Researchers felt that 

the current “hands-off” management approach for riparian habitat management under the Northwest 

Forest Plan will continue on an altered trajectory of ecological processes and have undesirable long-term 

consequences (Messier et al. 2012). Other “setbacks” that are proposed in the revised Forest Plan such as 

dispersed camping near streams and lakes, oil and gas, or other development activities are based on 

various land management directions, field observations and incorporate the unique geologies, and stream 

and lake habitat types found on the forest. Buffers and setbacks, when utilized, generally are not a “one 

size fits all” situation as suggested by the commenter due to the unique geologies and stream habitat types 

on the Forest. Buffers and setbacks generally do not simulate natural processes, which includes 

disturbances. Additionally, the buffers and setback widths (0.25 mile on either side of the stream for a 

total of 0.5 mile wide) proposed by the commenters generally do not fit the unique geologies, steep 

topography and habitat types found on the Forest. This is especially true for the Absaroka Volcanic 

geology that makes up about two-thirds of the Forest. Stream drainages in the volcanic geologies are 

typically steep and incised due to natural processes. Rather than blanket setbacks and riparian buffers 0.5 

mile wide, the revised Forest Plan allows management activities, where appropriate, that simulate natural 

processes as much as possible. Buffers and setbacks may be used where and when appropriate, fitting the 

landscape and situation. We have substantial riparian management direction contained in various resource 

areas within the proposed forest plan and analyzed in the EIS. This approach is primarily discussed in the 

draft forest plan in chapter 1, aquatic species on page 3 and the DEIS, chapter 3, environmental 

consequences, page 310. The primary reference for riparian habitat management is the Region 2 

Watershed Conservation Practice Handbook, Section 12. The handbook can be found at: 

http://www.fs.fed.us/cgi-bin/Directives/get_dirs/fsh?2509.25!r2. With proper administration and 

compliance, riparian habitat and the wide array of species that are associated with it will be protected.

We work closely with Wyoming Game and Fish Department (WGFD) on Yellowstone cutthroat trout 

population and habitat restoration and protection. The Forest is part of the Yellowstone cutthroat trout 

rrangewide working group with various geographic management units (GMUs) identified. Two GMUs are 

partially on the Forest: The Bighorn and Upper Yellowstone GMUs. From these documents and 

interagency coordination, we developed a list, updated annually, of potential management activities on the 

Forest to help restore Yellowstone cutthroat troup populations and habitat. The coordination efforts are 

noted in the Yellowstone cutthroat section of the revised Forest Plan and in chapter 3 of the EIS.

Public Concern #549

The Forest Service should examine effects on route sustainability and potential for sedimentation into 

water sources and other water quality concerns.

Response

Effects of roads and trails on water resources were considered and discussed in chapter 3 of the EIS. 

Management activities are guided by the Region 2 Watershed Conservation Practice Handbook, 

referenced in chapter 3 in the water and soil and fisheries sections. The handbook can be found at: 

http://www.fs.fed.us/cgi- bin/Directives/get_dirs/fsh?2509.25!r2.
Shoshone National Forest Land Management Plan Revision

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Public Concern #550

The Forest Service should consider the following recommendations for amphibian management: (1) It is 

important to acknowledge that amphibians are more sensitive to changes in water quality than trout and 

rely on different habitats, both aquatic and terrestrial. (2) Add at least one species of amphibian to the 

Management Indicator List (MIS) as none are currently present and will be an indicator to both aquatic 

and terrestrial environments. (3) Diseases that affect amphibians are completely different from those 

found in fish and must be consider in riparian management. (4) Amphibians and trout do not mix well, a 

healthy trout population does not indicate a healthy amphibian population. (5) Add more amphibian 

specific language to the “sensitive species” chapter of the Management Plan as well as the need to 

maintain the terrestrial component of riparian areas. (6) There should be more emphasis on the 

importance of keeping currently trout-free streams and ponds free of troy if they support healthy 

amphibian populations.

Response

(1-6) The effects to amphibians including water quality and diseases is addressed in the biological 

evaluation prepared for the revised Forest Plan. Amphibians were initially considered in the 

management indicator species process (Otto 2011), but were not selected as it was determined that 

watershed conservation practices included in the draft forest plan (management indicator species, 

management approach, stream trout, page 56) for the five trout species, will maintain or improve 

habitat for amphibian species. In the draft forest plan, sensitive species section, management 

approach, aquatic species, page 51, the effects to amphibians due to introduction of trout is 

analyzed at the site-specific project level.

Public Concern #551

The Forest Service should consider the following recommendations for riparian management: (1) Forest 

personnel should ground –truth riparian areas to ensure that buffers provide adequate protection. (2) The 

Forest Plan should include measures that guarantee that livestock will be reduced or excluded from 

riparian areas using methods that do not require the development of fences, which can obstruct wildlife 

passage. (3) Road density in floodplain areas should be minimized and all illegally created motorized 

trails should be closed to prevent impacts to riparian areas. (4) A Forest wide Standard should be placed 

making all areas within 100 yards of fens No Surface Disturbance zones to protect the fens from timber 

harvest, mineral development, and road building. (5) The Forest Plan should include measures to move 

watershed in the Functioning at Risk category in the Functioning Properly category. (6) The Forest 

should provide enhanced protection for watersheds with pure populations of rare and native fishes, 

including the Yellowstone cutthroat trout and mountain sucker.

Response

(1) See PC response #548 regarding riparian buffers.

(2) Fences are authorized and an integral part of livestock management on National Forest System lands 

and is outside the scope of this document 

(3) See PC #324 regarding roads in riparian areas. 

(4) See PC #325 regarding management of fens. 

(5) The revised Forest Plan contains direction indicating the desire to have watersheds in a properly 

functioning condition. In addition, reference is made to the Watershed Condition Framework, which 

is used to record watershed conditions and to track actions conducted to improve priority watersheds. 

(6) Yellowstone cutthroat trout and other sensitive fish species are identified and considered when 

conducting land management activities.
Final Environmental Impact Statement -- Appendix A

853

Subject: 1452 - Aquatic, Riparian and Fisheries Resources - Methodology

Public Concern #552

The Forest Service should consider in the Land Management Plan (LMP) that either non-native trout 

indicate degraded biological conditions on the SNF or provide a sound argument why

‘properly functioning habitat’ in this ecosystem should include non-native aquatic species since stream 

trout is defined to include non-native trout species.

Response

Non-native trout are part of the stream trout proposed as a management indicator species for aquatic 

habitat. Historic native trout stream species on the Shoshone National Forest included Yellowstone 

cutthroat trout and mountain whitefish. Distribution was limited to about half of the potential stream 

habitat on the Forest due to numerous natural barriers that blocked upstream fish migration and 

colonization. Many streams and lakes on the Forest were subsequently planted with various non-native 

and some native trout. Due to the introduction of non-native fish species, and habitat modification or 

degradation range-wide, conservation populations of Yellowstone cutthroat trout have been significantly 

reduced and are now confined to less than half of their historic range on the Forest. Conversely, the 

amount of stream miles currently with trout (both native and non-native) on the Forest has about doubled 

from these fish introductions since white settlement. Almost all potential fish stream habitat is now 

occupied by some type of stream game trout.

Current stream game trout species on the Forest include Yellowstone cutthroat trout, Snake River 

cutthroat, rainbow trout, rainbow-cutthroat hybrids, brook, brown, lake trout, and arctic grayling.

From a management indicator species perspective, the stream trout that would be most sensitive to habitat 

disturbances and occur in many areas of the Forest are cutthroat trout, rainbow trout, and their hybrids. 

Brook trout are the most common stream species on the Forest, but are somewhat more tolerant of poorer 

habitat conditions of all the game trout species. Brown trout are generally found in low densities in some 

of the lower stream reaches on the Forest near the boundary and are more tolerant to habitat disturbances, 

but not as much as brook trout. Lake trout and arctic grayling are rare in Shoshone streams. Although 

some species are more tolerant of poorer habitat conditions their numbers, condition and distribution in 

conjunction with relevant habitat characteristics are good indicators of stream conditions.

Through working cooperatively with Wyoming Game and Fish Department (WGFD) and Forest 

monitoring we have good historic and current information on stream game trout species distribution, 

densities and condition. Although mountain whitefish are in the trout family, WGFD generally does not 

closely monitor this species.

Stream game trout species generally would show more cumulative land management effects than lake fish 

species since streams drain watersheds that these fish occupy.

In conclusion, we have good long-term information for stream game trout. We have no other good 

management indicator species information for stream or riparian species on the Forest. At this point, any 

other information would be costly and timely to obtain and we would not have historical information for 

comparison. As a result, we propose to use the appropriate aquatic habitat condition indicators in 

combination with the appropriate management indicator species stream game trout information to 

determine the condition and trend of stream and riparian aquatic habitats.

Also see (Otto 2011) on the rationale and selection of Forest management indicator species.
Shoshone National Forest Land Management Plan Revision

854

Subject: 1453 - Aquatic, Riparian and Fisheries Resources - Affected 

environment

Public Concern #553

The Forest Service should consider not having trout as the sole Management Indicator Species (MIS) for 

riparian since it goes against showing the diversity, value, and vulnerability and how management will 

affect riparian.

Response

See response to PC #552.

Subject: 1454 - Aquatic, Riparian and Fisheries Resources - Desired 

condition

Public Concern #554

The Forest Service should consider removing the statement in Ch. 3, Affected Environment. Effects from 

Livestock and Big Game Grazing, Aquatic Resources, p. 315 “As the livestock numbers and use increase, 

we will begin to reach the upper limits of acceptable use and potential for adverse aquatic resources 

effects, especially if additional allotments and use were added,” since adding additional allotments and 

increasing use does not equate to an adverse effect on aquatic resources if livestock grazing is managed 

well.

Response

The identified statement in chapter 3, affected environment,. effects from livestock and big game grazing, 

aquatic resources, (previously DEIS page 315) has been changed to “As the livestock numbers and use 

increase, we may begin to reach the upper limits of acceptable use and potential for adverse aquatic 

resources effects, especially if additional allotments and use were added,” since adding additional 

allotments and increasing use does not equate to an adverse effect on aquatic resources if livestock 

grazing is managed well.

Public Concern #555

The Forest Service should consider not allowing non-native species of fish in the forest since it is not a 

desired condition and disrupts the natural ecosystem.

Response

Management of fish species on the Forest outside wilderness is the primary responsibility of the WGFD. 

In wilderness, we follow the guidance provided in the Wilderness Act. We work closely with WGFD and 

encourage management and restoration of native fish species whenever possible.

Subject: 1455 - Aquatic, Riparian and Fisheries Resources - Direct and 

indirect effects

Public Concern #556

The Forest Service should consider making a strong discussion on protections for aquatic species and 

impacts from mineral and energy development and their support roads on aquatic species.
Final Environmental Impact Statement -- Appendix A

855

Response

The Forest does address potential effects from roads and potential minerals development in chapter 3 of 

the EIS. See various sections of the Region 2 Watershed Conservation Practice Handbook that is cited in 

chapter 3. The handbook can be found at: http://www.fs.fed.us/cgibin/Directives/get_dirs/fsh?2509.25!r2.

Subject: 1459 - Aquatic, Riparian and Fisheries Resources- Monitoring

Public Concern #557

The Forest Service should consider explaining How will you ‘guide and monitor’ the many terrestrial 

wildlife species that depend on riparian and wetland habitats by using fish as an indicator?

Response

See response to PC #552.

Subject: 1476 - Aquatic, Riparian and Fisheries Resources - Management 

Approach

Public Concern #558

The Forest Service should consider not allowing Wyoming Game and Fish Department and others to 

plant game fish in wilderness since it does not lead to untrammeled wilderness.

Response

See response to PC #555.

Public Concern #559

The Forest Service should fix the citation on page 53 since it is Montana Fish Wildlife Parks, 2010.

Response

We corrected the note citation in the revised Forest Plan.

Subject: 1500 - Rare Plants - Resource – General

Public Concern #560

The Forest Service should recognize the importance of the Shoshonea population on Bald Ridge. It is the 

world's largest population of this plant species, and since the whitebark pine stand where it occurs 

burned over a decade ago, this area serves as a natural laboratory to evaluate the disturbance response 

of this keystone species at its lower elevation limits.

Response

These comments will be considered along with others by the decision maker. The potential Bald Ridge 

Research Natural Area is considered in the range of alternatives presented in the revised Forest Plan. 

Shoshonea pulvinata is a Region 2 sensitive species and management is addressed in both the EIS and 

Revised Forest Plan in the sensitive species sections.
Shoshone National Forest Land Management Plan Revision

856

Subject: 1600 - Fire and Fuels Management - Resource General

Public Concern #561

The Forest Service should stop prescribed burning. Because it releases mercury into the air and causes 

health problems such as lung cancer, heart-attacks, strokes, pneumonia, allergies, and asthma attacks.

Response

The Forest conducts prescribed fires in accordance with the air quality standards established by the 

Environmental Protection Agency and Wyoming Department of Environmental Quality. This includes 

being issued a permit by the Wyoming Department of Environmental Quality to burn; burning when 

smoke dispersal conditions are favorable to ensure air quality standards are not violated; notifying 

jurisdictional fire authorities and nearby public of planned prescribed burning; and post-burn monitoring 

and reporting.

Public Concern #562

The Forest Service should not be logging timber during an insect epidemic because there is a chance you 

are cutting timber that is resistant to the insects.

Response

In areas where the epidemic is occurring, the most common silvicultural practice is to conduct salvage or 

sanitation harvests. Salvage harvest only removes the dead trees, while sanitation harvests remove those 

trees that are already weakened or most suceptible to attack. The remaining healthy trees remain and 

perpetuate the stand. Management activities, including logging, will be analyzed in site-specific analyses, 

outside the scope of this forest plan revision analysis.

Public Concern #563

The Forest Service should continue efforts to enhance vegetation and healthy tree growth in beetle killed 

sections of the forest. This is needed because of extreme potential for fires from beetle killed trees.

Response

Fire and fuels’ Goals 4, 5, and 6 (revised Forest Plan, page 67) along with Objectives 1, 2, and 3 (revised 

Forest Plan, page 68) allow for continued efforts to manage vegetation to reduce the risk to resources and 

other values from unwanted wildfire. In addition, goals and objectives for insect and disease provide 

direction for managing vegetation to enhance vigor and growth.

Public Concern #564

The Shoshone NF should conduct prescribed burns within areas of beetle killed trees. The Forest Service 

should allow nature to take its course. The Forest Service should use fire as a restorative tool rather than 

using more expensive methods of vegetative restoration. Prescribed burning will remove at a controlled 

rate the additional ground fuels associated with beetle killed trees and free up money for fighting wildfires 

in a WUI or for weed control and erosion control after wildfires and include a reference to the 

Interagency Prescribed Fire Planning and Implementation Procedures Guide to provide additional 

information to the public. Additionally the forest should warn hunting and recreation public when 

prescribe burning.

Response

The Forest has and proposes to continue to use a mix of tools to reduce hazardous fuels and to maintain or 

restore ecosystems. This includes using mechanical treatments and prescribed fires in areas where using 

wildfire to accomplish resource benefits is not practical. Managing naturally ignited wildfires to 
Final Environmental Impact Statement -- Appendix A

857

accomplish resource benefits on a landscape scale is currently authorized under the current forest plan and 

is proposed to continue in the revised Forest Plan. Desired condition, goals, objectives and standards 

(revised Forest Plan, pages 66 through 70) described in the fire and fuels section provide guidance and 

direction that allow for the use of a variety of tools to accomplish vegetation, restoration, and protection 

objectives. The public is notified when prescribed burning is planned during site-specific implementation.

Public Concern #565

The Forest Service should cut down on timber sales. Current climatic changes, forest health, and the loss 

of habitat from fires are compelling reasons to preserve habitat. Slash from timber sales will put a lot of 

fine fuel on the ground. If a wildfire got started it would destroy more habitat.

Response

Silvicultural prescriptions that are prepared for all timber harvesting projects include objectives and 

methods for treating slash from harvesting operations to reduce the amount of fuel available to burn in a 

wildfire. In general, loss of habitat from wildfires burning on the Shoshone National Forest has not been 

an issue. In the past, wildfire has been an important tool for maintaining and restoring vegetation and 

wildlife habitats. Resource protection and benefit goals, objectives, standards, and guidelines for wildlife, 

vegetation, and other resources have been identified throughout the revised Forest Plan as well as 

potential effects documented in multiple sections of the EIS. In addition, alternatives C and D reduce the 

amount land available for suitable timber production and harvesting.

Public Concern #566

The Forest Service should utilize all the tools available and the best available science to manage the 

Shoshone NF. Timber harvesting, fuels treatments, and prescribed burning should be implemented where 

needed to promote a healthy forest, enhance wildlife habitat, and reduce fire severity. The Forest Service 

when considering management options should make fire protection the basis for management decisions. 

Proper management through logging, mechanical fuels treatment and fire help to maintain a diversely 

aged forest and provide varied habitat and reduce the threat of wildfire where possible. These actions are

needed to help move watershed conditions to their respective Historic Range of Variation. . Additionally 

the forest should clarify since the information for accepted and predicted changes to vegetation is not 

presented well in the current Draft, and is not documented as required by the 1982 Planning Rule.

Response

The Forest has used and proposes to continue using a mix of tools to reduce hazardous fuels and to 

maintain or restore ecosystems and to accomplish protection objectives where high-valued resources and 

developments are present. This includes using mechanical treatments and prescribed fires in areas where 

using wildfire to accomplish resource benefits is not practical. Desired condition, goals, objectives and 

standards described in the fire and fuels section (revised Forest Plan, pages 66 through 70) provide 

guidance and direction that allow for the use of a variety of tools to accomplish vegetation, restoration, 

and protection objectives.

All wildfires are evaluated relative to land management goals and objectives which include protection 

objectives and opportunities to accomplish resource benefits. All wildfires receive a management 

response based on the values at risk, costs, potential for success and threats to public and firefighter 

safety. These items are addressed in more detail in the fire and fuels section of the revised Forest Plan 

(Goals 1, 2 and 3 on page 67; Standards 1 through 6 on page 67; and management approach on page 69).

Potential changes and effects to vegetation and watershed conditions are discussed in detail in the EIS.

See response to PC #373 regarding natural range of variability.
Shoshone National Forest Land Management Plan Revision

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Public Concern #567

The Forest Service should develop management methods that are light on the land. There needs to be a 

reduction of impacts on the natural processes of wildlife, ecology and fire.

Response

Standards and guidelines along with the implementation of best management practices for all land 

management activities have been developed and are documented in multiple locations throughout the 

revised Forest Plan. During site-specific analysis proposed management methods will be reviewed for 

site-specific conditions.

Public Concern #568

The Shoshone NF should reconsider the proposed WUI boundaries. These boundaries are out of scale 

with WUIs seen on other national forests, where the WUI might reach a half-mile or so back into national 

forest lands. Map 20 shows the WUI extending the entire width of the national forest west of Dubois to the 

forest’s western edge (at least 20 miles wide when measured from Dubois), and south of Lander (where it 

also extends the entire width of the national forest). How can this be justified? Is the Forest Service really 

intending to thin and log all of this country?

What will this manipulation have on native wildlife? How much will all this cost? How will you do this 

without building roads? Will there be a loss of tree species diversity; will subalpine fir and spruce be 

largely eradicated as ‘ladder fuels’? How will you prevent establishment of invasive plant species 

following so much disturbance? How often will you have to repeat the thinning to prevent the trees and 

brush from getting re-established? What evidence do you have that this won’t in fact increase fire danger, 

due to drying of the forest floor, increased wind through the opened forest, and re-growth of brush in 

clearings? What size trees will be removed? How will you deal with all the logs and slash? Do these kinds 

of areas really make people safer from wildfires?

The plan states that “Past fire suppression policies have resulted in vegetation changes and have allowed 

fuels to develop to higher than natural levels in some areas on the Shoshone.” What scientific evidence do 

you have that fuel levels are “higher than natural levels”? Which specific areas are you referring to?

The objective to “reduce hazardous fuel ratings on 100,000 to 250,000 acres” is also alarming. This is an 

enormous amount of acreage to treat. The plan should present scientific evidence that reduction of 

“hazardous fuels” will affect wildfire spread and intensity. It should also discuss, in detail, what exactly 

these treatments will be, where they will be, how they will be accessed, and what their effects will be on 

wildlife, invasive species, soils, riparian zones, wilderness qualities, and scenic values. No mechanical 

treatments should take place in inventoried roadless areas, wilderness study areas, wilderness areas, or 

research natural areas.

Response

The wildland urban interface (WUI) boundaries in the revised Forest Plan were derived from the 

Community Wildfire Protection Plans (CWPP) for Fremont, Hot Springs, and Park Counties. These plans 

were prepared by the Counties and not by the Forest Service. The recommendation for communities to 

prepare CWPPs stems from the Healthy Forest Restoration Act (HFRA). The HFRA helps facilitate 

expedited administrative procedures and improved coordination between Federal agencies and local 

communities in planning and implementing fuel reduction projects. The development of a CWPP includes 

designation of WUI areas which helps identify priority areas for hazardous fuels treatments near at-risk 

communities. The designation of the WUI boundaries in the CWPPs and display of the boundaries in the 

revised Forest Plan do not translate to a decision that the Forest Service plans to thin and log all or most 

of the areas. The goals and objectives in the revised Forest Plan for vegetation and hazardous fuels 
Final Environmental Impact Statement -- Appendix A

859

provide guidance on how many acres are likely to be treated. Management areas designated in the revised 

Forest Plan provide direction on what type of treatments may occur and where. General descriptions of 

priority areas for treatment are also noted in the desired condition and management approach descriptions 

in several areas of in the revised Forest Plan (pages 38, 69, 184 through 209). revised Forest Plan 

management prescriptions in these areas are aligned with locations identified as priority areas for fuels 

treatment in the CWPPs. 

The Revised Forest Plan hazardous fuel treatment objective of 100,000 to 250,000 acres is consistent with 

what occurred on the Forest during the 10-year period from 2002 through 2011. During this period 

approximately 57,000 acres of fuels reduction was accomplished using mechanical and prescribed fire 

treatments in the front country. Wildfires accounted for an additional 183,000 acres of hazardous fuels 

reduction. Most of these acres involved back country locations such as wilderness and roadless areas. The 

estimated acres to be treated and treatment methods relative to the different management areas for the 

next planning period are noted in various locations throughout the revised Forest Plan and EIS. 

Mechanical treatments such as timber harvesting in combination with prescribed fire are emphasized in 

Management Areas (MAs) 4, 5, and 8. These are the same management areas that include or are adjacent 

to priority areas for fuels projects identified in the CWPPs. Prescribed fire and naturally ignited wildfire 

will be the primary tools to accomplish fuels reduction and other resource benefit objectives in the back 

country and wilderness management areas (MAs 1, 2, and 3). The potential changes to vegetation and 

effects on other resources are documented in the various resource sections of the chapter 3 of the EIS. 

Standards and guidelines to avoid or minimize the impacts from fire management activities are described 

for multiple resources in chapter 1 of the revised Forest Plan. In the context of forest vegetation 

communities, the relationship of fuels to fire behavior attributes such as fire intensity is a matter of basic 

fire physics. The more fuel (trees, grass, and down dead and woody material) available to burn under the 

range of typical fire season conditions, the greater the potential for more intense and longer-duration 

burning wildfires when ignition occurs. Fires that burn in more dense forest types burn longer and hotter 

and are consequently more difficult to control. An example on the Shoshone National Forest that 

illustrates the benefits from a thinned forest can be found in the North Fork corridor west of Wapiti, 

Wyoming, where the Gunbarrel Fire burned in 2008. Numerous structures were threatened by intense 

surface and crown fire burning in heavy timber. Timber harvesting to thin the forest along with other fuels 

reduction work had been completed in areas around and adjacent to the structures. When the fire front 

reached these treated areas, the fire behavior was significantly reduced and firefighters were able to 

quickly extinguish fires before they reached the structures. This event was documented in a report titled 

“Fuel Treatment Effectiveness Report” (Weldon 2008).

Public Concern #569

The Forest Service should rethink its management philosophy. Fire has been burning ecosystems for 

hundreds of millions of years, helping to shape global biome distribution and to maintain the structure 

and function of fire-prone communities. Wildfire is widely acknowledged to be the primary architect of 

patch dynamics in coniferous forest ecosystems. The Forest Service should not try to exclude wildfire as 

part of its management options; it should embrace it and look for avenues of using it for desired results.

Fire is key to aspen “seedling” recruitment, and following the 1988 fires in Yellowstone, aspen 

recruitment was heavily correlated with burned areas (Turner et al. 2003). Fire is crucial because it 

exposes mineral soil the best seedbed for successful germination.

Interior forest birds and elk favor burned areas as foraging areas. Animals seek out burned sites for the 

newly available minerals and for the flush of plant growth.
Shoshone National Forest Land Management Plan Revision

860

Effective fire suppression has promoted dwarf mistletoe expansion and intensified pine beetle outbreaks. 

Periodic fire promotes forest health by killing trees infected with mistletoe and it removes trees that would 

sustain or further a buildup of beetle populations.

The effectiveness of fire suppression is also highly dubious. The result has been counterproductive: larger, 

more intense forest fires in recent years.

There is little evidence to suggest that pursuing a let-burn policy on the Shoshone would lead to 

catastrophic wildfires. Despain and Sellers (1977) pointed out that during the early years of the let-burn 

policy in Yellowstone, most wildfires were small. This would likely be the case on the SNF as well.

Response

Managing naturally ignited wildfires to accomplish resource benefits on a landscape scale is authorized 

under the current forest plan and is proposed to continue in the revised Forest Plan (page 68). The Forest 

has managed several large wildfires during the last 10 years that had responses based on protection and 

resource benefit objectives. For large fires that have occurred on the Forest, aggressive suppression 

actions have generally been limited to those portions of the fire that were threatening WUI, forest 

developments and infrastructure, and other resources that we did not want to burn. The revised Forest 

Plan continues with a similarapproach. All wildfires will be evaluated relative to land management goals 

and objectives which include protection objectives and opportunities to accomplish resource benefits. All 

wildfires receive a management response based on the values at risk, costs, potential for success and 

threats to public and fire fighter safety. These items are addressed in more detail in the fire and fuels 

section of the revised Forest Plan (Goals 1, 2 and 3 on page 67; Standards 1 through 6 on page 67; and 

management approach on page 69).

Public Concern #570

Today’s fires are a by-product of successful fire suppression strategy during the last century. Now if a fire 

becomes large it is hard to contain the fire irrespective of the amount of resources being used to control it, 

thus making recent large fire very costly to fight. Steps need to be taken to return the Shoshone NF into a 

healthy forest and not one prone to large fires due to the excess fuels.

Response

Some of the revised Forest Plan goals and objectives for vegetation and fire and fuels are intended to 

restore and maintain resilient ecosystems that are consistent with a healthy forest. This includes using 

wildfires on a landscape scale to accomplish resource benefits, where appropriate. Protection of resources 

that may be negatively impacted by wildfire is also indicated in various goals, objectives, and standards. 

Response to and use of wildfire will continue to be based on the values at risk, costs, potential for 

success, and threats to public and firefighter safety. These items are addressed in more detail in the fire 

and fuels section of the revised Forest Plan (Goals 1, 2 and 3 on page 67; Standards 1 through 6 on page 

67; and management approach on page 69).

Public Concern #571

The Forest Service should obtain and maintain adequate equipment and personnel to successfully fight 

fire at all times. Failure to have the proper equipment or trained personnel could lead to catastrophic 

results. Both in terms of acres burned or lives lost due to faulty or inadequate equipment.

Response

This comment is outside the scope of the revised Forest Plan analysis. 
Final Environmental Impact Statement -- Appendix A

861

Public Concern #572

The Forest Service should consider adding this statement on page 68 of the Forest Plan, Identify areas 

where commercial treatments are feasible and prioritize high risk areas for mechanical commercial fuels 

reduction. The Forest Service should delete a portion of Guideline #10, page 58 of the Forest Plan: 

“except when values would not be cost effective to protect”.

Response

Timber suitability is used to identify the areas appropriate for timber harvest. The fire section contains a 

goal indicating that risk should be reduced adjacent to communities. No standard was added.

Relative to Guideline #10, the direction is worded as it is based upon the realization that in some 

situations the cost of protecting the resource would exceed the value of the resource itself. Other direction 

in this section continues to point out that suitable timber lands are a valued resource that should be 

protected. Guideline #10 was not changed.

Subject: 1602 - Fire and Fuels Management - Methodology

Public Concern #573

The Forest Service needs to incorporate reductions in Forest Service budgets and wildfire suppression 

costs. This information is needed to reflect which programs will be impacted and how do these impacts 

affect local communities. It is important for this information to be included in both the NPV calculation 

and the net public benefits calculation.

Response

Annual budget fluctuations and the relationship to accomplishing forest plan goals and objectives are 

addressed on page 4 of the revised Forest Plan. Effects from fire and fuels management on other resources 

are discussed throughout chapter 3 of the FEIS. Information regarding suppression cost will be added to 

the fire and fuels analysis section in chapter 3 of the FEIS.

Public Concern #574

The Forest Service should utilize fall burning to meet air quality standards. Burning in the fall would 

broaden the window for prescribed burning allowing the burning of fewer acres at a time. This in turn 

would reduce the amount of particulates associated with prescribed burning in the air at one time.

Response

The Forest currently conducts prescribed burning in all seasons in accordance with established air quality 

standards and other prescription parameters identified in approved burn plans. The revised Forest Plan 

does not add or change any seasonal restrictions regarding the use of prescribed fire, but reiterates the 

need to adhere to current air quality standards (revised Forest Plan, page 28). Site-specific burn plans will 

be developed prior to prescribed burning to ensure adherence to air quality standards.

Public Concern #575

The Forest Service should reword Guideline #3; the forest plan should not preclude aggressive fire 

suppression strategies and tactics. These actions are needed to reduce the total number of acres burned or 

protect high value resources. Guideline #3 should reference the state of Wyoming BMPs, identify areas 

where equipment should not be used, and provide direction for mitigation rehabilitation.
Shoshone National Forest Land Management Plan Revision

862

Response

Water and soil Guideline #3 (Revised Forest Plan, page 28) does not exclude the use of aggressive 

suppression strategies and tactics. The suggestion to reword the guideline will be considered during the 

decision phase of the analysis.

Subject: 1604 - Fire and Fuels Management - Desired condition

Public Concern #576

It’s good the Forest Service is using prescribed burning as the preferred management choice instead of 

clear-cutting. Burning is a better choice and more natural looking for management than clear-cuts.

Response

The revised Forest Plan does not indicate that prescribed fire is the preferred management choice instead 

of clearcutting as indicated by the comment. Prescribed fire is just one of several tools that may be used 

including the full range of silvicultural treatments to remove trees and manipulate vegetation.

Public Concern #577

The Forest Service should consider addressing and clarifying the conflict with the discussion on page 429 

and the Alternative B paragraph on page 425 because it appears that achieving the desired condition is a 

more significant driver than the demand for timber products. 586

Response

We clarified the discussion on page 425 to better describe the intent of timber production on suitable 

lands.

Subject: 1605 - Fire and Fuels Management - Direct and indirect effects

Public Concern #578

The Forest Service should disclose in the DEIS the amount of anticipated wildfire and their associated 

direct and indirect costs. Disclosing this information may have an impact on the final alternative selected.

Response

Wildfire management costs will be included in the fire and fuels analysis section of chapter 3 of the FEIS.

Public Concern #579

The Forest Service should reconsider its selection of Alternative B as the preferred alternative. 

Alternative B proposes extreme disturbance in the lower elevation areas.

Response

We will consider the comment about not selecting alternative B as the preferred alternative because of the 

amount of disturbance in lower elevation areas in the decision phase of the analysis.

Subject: 1606 - Fire and Fuels Management - Cumulative effects

Public Concern #580

The Forest Service should analyze the use of resources for timber and wildlife and future uses in 

relationship to disturbance vulnerability. Disturbance from insects and fire are likely to increase with 

climate change and there is a clear risk to areas designated under Management Areas 5.1 and 5.4 in the 

Preferred Alternative.
Final Environmental Impact Statement -- Appendix A

863

Response

The wildlife and timber sections in chapter 3 of the EIS discuss the potential effects from wildfire, 

insects, and disease. The potential effects of climate change on disturbances such as fire, insects, and 

diseases are also discussed in chapter 3 of the EIS (pages 359 and 371).

Subject: 1607 - Fire and Fuels Management - Climate change

Public Concern #581

The Forest Service needs to re-evaluate the anticipated amount of unplanned ignitions. The Forest 

Service is estimating that there will be approximately the same amount in the next ten years as there has 

been in the previous ten years. This estimate seems low given the warming climate trends and anticipated 

shifts in fire regimes.

Response

The primary factors influencing the rationale to use the previous 10 years of acres burned by wildfire are 

the combination of fuel conditions in forested areas and climate trend. Insects have affected over 

1 million acres of forest community types causing a substantial increase in dead trees, and subsequently, 

more fuel that is readily available to burn when conditions are right. Climate trends during the past 10 

years were biased toward being warmer and drier, although there appears limited correlation between 

snowpack and spring precipitation with occurrence of large fires on the Shoshone in any given year. 

Similar vegetation and climate conditions are expected to be present during the next planning period and 

large fires are likely to continue; however, as more of the landscape burns, fewer acres become available 

to burn as well as recent burned areas become a barrier to spread for new large fires. Additionally, goals, 

objectives, and standards for fire and fuels management in the existing Forest are basically the same as 

what is being proposed in the revised Forest Plan.

Subject: 1608 - Fire and Fuels Management - Incomplete and unavailable 

information

Public Concern #582

Page 35 of the DEIS mentions increasing aspen cover type on 2,500 acres and restoring approximately 

750 acres of whitebark pine on suitable and generally accessible acres. Does “suitable” refer to suitable 

timber lands? The Forest Service should consider placing an emphasis on aspen restoration on aspen 

clones within conifer types wherever possible. Conifer cover types having decadent aspen with 

opportunities to remove conifers and expand declining aspen clones are significant in aspen restoration.

Response

It does refer to suitable timber lands. The actual goal in the plan states that 750 acres of whitebark pine 

will be restored. That restoration is not restricted to suitable lands. The EIS discussion reflects the reality 

that because of cost that restoration is more likely to occur on suitable lands and accessible areas. The 

actual location of restoration activities will be determined during project-level analysis. Aspen restoration 

will commonly occur in conifer types since natural succession patterns result in aspen being replaced by 

conifer types. Project-level plans will determine the location of restoration activities, but conifer removal 

from aspen clones will likely be a significant component of that activity.
Shoshone National Forest Land Management Plan Revision

864

Subject: 1626 - Fire and Fuels Management - Management Approach

Public Concern #583

The Forest Service should change the Preferred Alternative from a passive approach to a more active 

management of resources. The episodic and unpredictable nature of wildfires and a wildfire-based 

management approach will not create the jobs and sustainable economic activity that would most benefit 

local counties. By providing only minimal direction for active management opportunities for preemptive 

treatments to lessen direct and indirect wildfire costs and insect susceptibility, the preferred alternative 

will have substantial impacts to local economies.

Response

We will consider the comment to change alternative B to “more active management of resources” during 

the decision phase of the analysis.

Subject: 1650 - Insects and Disease - Resource General

Public Concern #584

The Forest Service should consider removing beetle killed trees from the forest by fire or other methods in 

order to make a healthier forest and help to minimize fuel for large wildfires, especially around Seven D 

Ranch.

Response

All alternatives allow the use of a variety of tools including prescribed fire and mechanical treatments to 

reduce fuels. Specific locations for where treatments will occur are addressed in site-specific project-level 

analyses, outside the scope of the revised Forest Plan analysis.

Public Concern #585

The Forest Service should clarify the following items in the DEIS: 1-more adequately account for the 

effects of the insect epidemics and fires of the last decade on age classes, snags, and species mix since the 

source used is based on inventory in 1999 and not more recent; 2- report the current and projected 

number of acres affected by the beetle kill and blister rust epidemic

Response

The Forest Inventory Analysis data are the most recent available for the Shoshone. The mapping of cover 

types and stand structure do reflect the changes that have occurred as a result fires and the insect 

epidemics. That mapping was first completed in 2004, and has been periodically updated to reflect 

changes from insect epidemics and fire. Over 60 percent of the vegetation mapping has been updated 

since 2004. In addition, the impacts of the insect epidemic were modeled in the projections of timber 

volumes.The EIS also uses recent data from insect aerial surveys and the EIS discussion projects the 

current trends. 

Subject: 1652 - Insects and Disease - Methodology 

Public Concern #586

The Forest Service should consider cleaning up the ground of dead wood, down fall, dead trees in order to 

protect the land from disease.
Final Environmental Impact Statement -- Appendix A

865

Response

The importance of leaving woody material on the ground after timber harvest for nutrient cycling is 

discussed in the EIS chapter 3 vegetation section – coarse-woody debris (EIS page 123). Revised Forest 

Plan soil and water Goal 4 addresses the need to maintain or improve long-term levels of organic matter 

and nutrients. Forest Service soil and water management activities are guided by FSH 2509.25, Region 2 

Watershed Conservation Practices Handbook, and Forest Service National Best Management Practice 

directives. These management practices are cited in the revised Forest Plan and FEIS.

Subject: 1654 - Insects and Disease - Desired condition

Public Concern #587

The Forest Service should consider taking into account recent and future potential changes in insect 

activity and fire risk in planning process since it seems the forest is using out of date information as basis 

for models and forest needs to keep trees alive for timber uses.

Response

The vegetation data used in the analysis have been updated to reflect the changes that have happened in 

the last 10 years from fire and insects. The timber yield tables were adjusted to simulate the effect from 

the ongoing insect epidemics. The effects analysis considers the current and future impacts from changes 

in fire regimes and insect epidemics.

Subject: 1656 - Insects and Disease - Cumulative effects

Public Concern #588

The Forest Service should consider discussing uses of resources for timber and wildlife and future uses in 

relation to disturbance vulnerability since disturbances from fire and insects is likely to increase with 

climate change in Management Areas 5.1 and 5.4.

Response

The revised Forest Plan includes direction on managing for a resilient forest in the face of changing 

climate in insect epidemics. The impacts of fire and insects in the last decade are used as a basis for 

predicting the impacts in the next 10 to 15 years. Though the pace of change may increase over time, the 

next 10 to 15 years is best predicted by the immediate past and not by estimates of what may happen 50

years in the future.

Subject: 1670 - Insects and Disease - Background

Public Concern #589

The Forest Service should have the Land Management Plan document clearly the amount of acres by 

species of mature and old growth forest that has been lost to recent, widespread insect and disease 

outbreaks and how this will affect future populations of wildlife species associated with older forests.

Response

In the vegetation section, the EIS documents the current acreage of older age classes and how they are 

affected by the alternatives, fires, and insect epidemics. Acres impacted by insects are presented in the 

EIS with a breakdown by timber species. The effects on wildlife populations that use older forests are also 

presented in the EIS. In many cases, insect epidemics do not eliminate a stand’s ability to meet the need 

of wildlife species that use older stands as habitat. Many components of older stands such as multiple 

stories, dead and down material, and older trees still exist in stands impacted by insects. There will be 
Shoshone National Forest Land Management Plan Revision

866

fewer older trees, but there still can be enough older and mid-age trees to dominate the stand conditions 

and structure.

Subject: 1677 - Insects and Disease - Management Approach

Public Concern #590

The Forest Service should identify in the Land Management Plan how they arrived at the management 

approach to reduce stands to a basal area of 70 square feet or less and identify where this practice been 

successful and the effects on wildlife species that are dependent on such forests for cover and food and 

also clarify how cutting trees prevents or controls marked beetle infestation expansion.

Response

The science regarding bark beetles and trees killed consistently indicates that stand conditions are the 

most important component in how large an epidemic will become. Spruce stands that are most susceptible 

to spruce beetle outbreaks generally have the following characteristics (Schmid and Frye 1976): 

(1) Are located in creek bottoms, 

(2) Have large diameter host trees, 

(3) Have high basal areas; and 

(4) Have a large proportion of spruce in the canopy. 

Stands that are most susceptible to Douglas-fir beetle outbreaks have the following characteristics 

(Furniss et al. 1981): 

(1) Stand density, stands stocked at 80 percent or more of normal are most susceptible, 

(2) Stand age, trees 120 years of age and older being the most susceptible; and 

(3) Proportion of Douglas-fir in the canopy. 

In lodgepole pine, susceptibility to mountain pine beetle is based on three factors (Amman et al. 1977): 

(1) Average tree diameter, 

(2) Average tree age, and

(3) Location by latitude and elevation.

The mountain pine beetle outbreak in the 1930s indicated that tree size (diameter) and stand density are 

likely important to beetle behavior and outbreaks in these pine systems (Perkins and Roberts 2003).)

In all cases, the indication is that stand conditions will be the deciding factor in whether a beetle epidemic 

occurs. Reducing stand density and stand diameter will lead to less susceptible stands. The practice is 

most successful if stands are treated before beetle epidemics, as it creates a landscape that is less 

susceptible to large-scale epidemics. Once a large epidemics has begun, it becomes more difficult to treat 

areas effectively; instead treatments are aimed at priority areas to maintain desired stand conditions.

Subject: 1700 - Invasive Species - Resource general

Public Concern #591

The Forest Service should note that Canada thistl is growing in abundance on the north side of the Clarks 

Fork of the Yellowstone Wild and Scenic River just downstream from the Wright Place and near the mouth 

of Canyon Creek.
Final Environmental Impact Statement -- Appendix A

867

Response

This is a site-specific issue and is beyond the scope of the revised Forest plan analysis. Thank you for 

informing the Forest of this noxious weed location.

Public Concern #592

The Forest Service should maintain wilderness to guard against weed infestation.

Response

These comments will be considered along with others by the decision maker. See response to PC #27

regarding recommended wilderness.

Public Concern #593

The Forest Service should follow the State of Wyoming Aquatic Invasive species law and Wyoming Game 

and Fish Commission regulations calling for mandatory inspection of all conveyances (i.e., watercraft 

and other water bearing equipment) that enter the state before using Wyoming waters.

Response

The Forest works closely with and follows State of Wyoming Aquatic Invasive Species (AIS) laws and 

direction. This also includes Forest Service AIS direction found in the Shoshone National Forest Aquatic 

Invasive Species Action Plan (2013) and Shoshone Forest Fire Resource Protection guidelines (2013). 

These documents were primarily based on Region 4 of the Forest Service Aquatic Invasive Species 

program and resource management direction and guidance. Currently, fire suppression equipment will not 

be stopped or inspected by Wyoming Game and Fish personnel. The Forest plans to have invasive species 

cleaning stations where both weeds and AIS would be treated and cleaned when equipment arrives and 

when it leaves the Forest.

Public Concern #594

The Forest Service should recognize that the spread of noxious weeds as a result of OHV recreation is 

inconsequential because of efforts to educate OHV users and routine maintenance performed by most 

OHV users. The map showing invasive plant location shows no noticeable infestations in the south 

Shoshone outside of Lander, an area that has an abundance of OHV use.

Response

It has been long recognized that road and trail corridors, livestock, wildlife, and recreationists are vectors 

for invasive plant spread. The revised Forest Plan and EIS include direction for early detection and rapid 

response for treating invasive species across the Forest regardless of source.

Your comments will be considered along with others by the decision maker. 

Subject: 1701 - Invasive Species - Legal and administrative framework 

Public Concern #595

The Forest Service should recognize that noxious weed detection and control are integral to management 

of other natural resources and should note our support for your record of controlling noxious weeds.

Response

Thank you for your support of the Forest’s invasive species program. This comment will be considered 

along with others by the decision maker.
Shoshone National Forest Land Management Plan Revision

868

Public Concern #596

The Forest Service should change Wyoming Game and Fish Department Aquatic Invasive Species 

Management Plan to Wyoming Game and Fish Commission Aquatic Invasive Species Management Plan 

(p. 380).

Response

We changed the name of the document.

Subject: 1706 - Invasive Species - Cumulative effects

Public Concern #597

The Forest Service should add language addressing hauling water and the potential of spreading aquatic 

invasive species to the cumulative effects discussion on p. 394.

Response

Discussion is now included.

Subject: 1709 - Invasive Species - Monitoring

Public Concern #598

The Forest Service should correct the inconsistency in the monitoring plan that requires annual 

monitoring Forest-wide and in the Greater Yellowstone area but monitoring of invasive plants in 

wilderness only every five years. Since Wilderness Rangers are in the backcountry throughout the 

summer, they should include invasive plant survey reports as part of their tours so that invasive plant 

surveys are easy to report annually.

Response

The annual Forest-wide treatment monitoring will include the acres treated in wilderness. The monitoring 

item for invasives in wilderness is tied to a wilderness stewardship goal that is reported every five years. 

Data used for both items are the same and are captured annually.

Subject: 1750 - Commercial Livestock Grazing - Resource – General

Public Concern #599

The Forest Service should consider closing any inactive or vacant lots permanently since livestock are 

biggest conflict with grizzly bears or even eliminating commercial grazing on the forest since the owners 

pay so little and the animals destroy the land.

Response

Based on issues and concerns relating to an individual allotment, site-specific analysis determines 

allotment closures and elimination of commercial livestock grazing. Adaptive livestock management 

strategies and forage utilization guidelines are implemented to reduce conflict with grizzly bears and 

protect rangeland resources. Commercial livestock grazing fees are established by law and not determined 

by the Forest Service.

Public Concern #600

The Forest Service should consider limiting or even closing commercial grazing including Clark’s Fork 

River since the cattle are getting out of their allotments and going into areas that local communities have 

water permits for drinking water and the cattle are overgrazing food areas that big game like elk use for 
Final Environmental Impact Statement -- Appendix A

869

winter food sources leading to them having poor nutrition and low pregnancy rates and it takes away 

from seeing true wildlife in the forest.

Response

Special use permits for domestic water sources that occur within livestock grazing allotments allow for 

the construction of fences to prevent livestock and wildlife from accessing the site. The permit holder is 

responsible for maintaining these exclosures. Allowable forage utilization levels on identified big game 

winter range are lower than other rangelands to account for and provide adequate forage for wildlife.

Public Concern #601

The Forest Service should consider no monetary compensation for livestock killed by cattle.

Response

The Forest Service does not compensate owners for livestock killed by cattle or any other animal.

Public Concern #602

The Forest Service should consider making the following changes : 1- Include in the plan: manage 

livestock in post-fire environments to avoid impacts to heritage resources; 2- Add this guideline: Avoid 

grazing and activities such as feeding, salting, herding, or placing water developments in areas where 

heritage resource have become exposed due to wildfire; 3- Add this guideline: Heritage personnel are 

consulted prior to making improvements or changes to historic grazing-related structures (e.g. cow camp 

structures, cabins); 4-Throughout the DEIS,the “Effects from Livestock Grazing" are characterized and 

most discussions include effects from big game. Some headings include “Big Game" and others do not. 

Please make headings consistent throughout the DEIS and add “and Big Game" after “Livestock."; 5- SNF 

and USFS as a national agency will work with ranchers to manage the non-forested and forested 

landscapes to provide forage for both wildlife and domestic livestock; 6- Grazing permits should remain 

at no less than 2012 levels; 7- Ranchers should not be penalized for other resource degradations which 

are not directly linked to livestock use; 8- Should clarify how much land on the forest is capable of 

commercial livestock grazing since the DEIS statement of 16% contradicts table 98; and 9- On page 40 

change wording to “Inside the Primary Conservation Area, the agency will always work with livestock 

grazing permittees to resolve conflicts and/or change management on cattle allotments or portions of 

cattle allotments with recurring grizzly bear conflicts. If conflicts cannot be resolved, livestock 

management will follow the Conservation Strategy.” “ 10-On page 73 of DLMP change the language 

changed to specify that when Forest Service and Wyoming Game and Fish wildlife biologists determine 

that available forage cannot support both wildlife and livestock, wildlife is given priority for available 

forage. 11- Page 20 fails to implement any changes to reduce conflicts between livestock and predator; 

12-ON page 16 the direction provided in nearly identical to or even more limited than the previous Forest 

Plan and not a new change in direction that is suggested. 13- Consider closing allotments and not just 

nonuse agreements" with “willing permittees” 14-On page 19, change should to may for the statement 

“Two aspects of commercial livestock grazing will be addressed in the revised forest plan. The first¬ what 

areas of the Shoshone should be available for commercial grazing...” 15-On Page 16, the “Need for 

change" section that includes the need to “improve critical wildlife habitat and to prevent negative impact 

on riparian areas” the forest should remove these items from the AMS as no change in current 

management is necessary to reach desired conditions in these areas.16- expand the discussion to address 

how range improvements will be protected from impacts associated with vegetation management, 

prescribed fire, recreation use and road construction. 17-support broad consideration of adaptive 

management techniques, such as exclusions and upland water developments; 18-protection of stream 

corridors through use of a minimum 100 foot buffer in areas of livestock grazing. 19-expanding the policy 

of prohibiting domestic sheep to occupied habitat outside the PCA.
Shoshone National Forest Land Management Plan Revision

870

Response

(1) This concern is addressed in Guideline 3 for commercial livestock grazing.

 This concern is addressed in Guideline 3 for commercial livestock grazing.

 This concern is addressed in the management approach for commercial livestock grazing.

 This is addressed in the FEIS.

 The revised Forest Plan provides direction and guidance for cooperative resource management with 

grazing permittees on the Shoshone National Forest; however, it cannot dictate national policy.

 This concern is addressed in Objective 1 and reflects the average level of commercial livestock 

grazing over the past 20 years.

 Permittees are held responsible for only the management of and impacts resulting from livestock 

grazing. However; changes in allowable use or planned grazing may occur as a result of varying 

resource conditions that are outside the control of the permittee.

 Table 98 displays the total acres in allotments and the capable acres within those allotments 

(approximately 32 percent). The narrative statement reflects the capable acres in allotments as a 

percent of the total acreage of the Forest (approximately 2.5 million acres) i.e., 16 percent.

 This input was considered along with other public input on the same item. In response to this and 

other comments, we edited the revised Forest Plan to clarify the intent of the direction. This issue 

would be more appropriately addressed in the commercial livestock grazing section.

 Most wildlife populations do not reside year around or rely solely on forage from the Forest. It 

takes cooperation between the Wyoming Game and Fish Department, Forest Service, and adjacent 

landowners to provide for complete wildlife habitat needs. Allowable forage utilization levels for 

livestock take into account the needs of wildlife as well.

 Potential resolutions noted on page 20 include: long-term non-use agreements and avoidance 

through the use of Forage Reserves and vacant allotments. This section is not intended to address 

all the possible management changes to reduce livestock/predator conflicts. More specific 

management direction is covered in chapter 1, livestock grazing and at the site-specific (allotment) 

analysis level.

 Page 16 is the Summary of the Analysis of the Management Situation. It is not intended to provide 

direction. Little change is suggested because desired conditions in relation to livestock grazing are 

generally being met or satisfactory progress is being made to meet them.

 This option is a part of the Grizzly Bear Conservation Strategy and is analyzed when and where 

appropriate.

 We changed the text to say: “...The first, what areas of the Shoshone are suitable and capable of 

supporting commercial livestock grazing....”

 A change in the focus of resource management is needed to better address the small percentage of 

critical wildlife habitat and riparian areas that are not meeting or moving toward desired conditions. 

Expanded use of adaptive management techniques, such as: forage reserves, intensive herding, offsite stock water, and livestock utilization monitoring are examples of potential techniques to 

address these issues.

 This issue would be addressed in a site-specific analysis for any proposed project or activity.

 See new language proposed for comment #15 above.

 Protection of streambanks and associated riparian areas is addressed through the allowable use 

standards and guidelines. Structural protection (fences) would not be a practical solution for all 

stream corridors and could have potential negative effects on wildlife.

 The Grizzly Bear Conservation Strategy addresses this issue.
Final Environmental Impact Statement -- Appendix A

871

Public Concern #603

The Forest Service should consider continued commercial grazing on the forest since it fulfills as part of 

our middle lands, working landscapes, production areas of essential commodities, quality rural 

ambiance, and the American cultural icons (ranches) of a living legacy.

Response

This concern is addressed under the goals and objectives for commercial livestock grazing.

Public Concern #604

The Forest Service should consider that the DEIS should identify all lands potentially capable of 

supporting grazing and determine whether grazing is suitable given the management objective for that 

area, minimize the areas the cattle can roam, and reduce the animal units per acre since economic 

impacts of grazing is not adequately captured in current document.

Response

The EIS identifies capable and suitable lands for livestock grazing. Standards and guidelines for livestock 

grazing account for the other resource needs and uses for all management areas, were applicable. It is 

neither necessary nor desirable to arbitrarily reduce allotments or stocking rates to achieve the overall 

goals and objectives of the revised Forest Plan. The economic analysis completed as a part of the EIS is 

adequate for determining the benefits and impacts of livestock grazing.

Subject: 1751 - Commercial Livestock Grazing - Legal and administrative 

framework

Public Concern #605

The Forest Service should continue to work with permittees to limit additional restrictions on working 

ranches due to predator expansion.

Response

The Forest will continue to work with permittees to avoid conflicts with predators and follow the 

management guidelines in the Grizzly Bear Conservation Strategy.

Subject: 1752 - Commercial Livestock Grazing - Methodology

Public Concern #606

The Forest Service should consider elaborating on the referenced changes to management practices and 

new strategies associated with livestock grazing and identify the features of an effective adaptive 

management plan that may be expected for future grazing allotment analyses.

Response

As each allotment and livestock operation is unique, so too are the potential management practices. The 

discussion of these specific alternatives is appropriately addressed at the allotment-level analysis.

Subject: 1753 - Commercial Livestock Grazing - Affected environment

Public Concern #607

The Forest Service should consider making the following changes: 1- Adding this information to the 

discussion on page 402 (Ch. 3,Commercial Livestock Grazing, Affected Environment) to clarify why 

sheep grazing permits are currently not issued on the Clarks Fork and Greybull Ranger Districts; 2- On 
Shoshone National Forest Land Management Plan Revision

872

Ch. 3, Commercial Livestock Grazing, Affected Environment. Pg. 405 add language from the Region 2 

Planning Desk Guide- Rocky Mountain Region Process Paper: A Process to Determine Rangeland 

Capability and Suitability and Standards for NEPA Display and must be evident in the several places, 

including the EIS, Land Management Plan and Appendix B. 3-include adaptive management strategies 

that could be implemented if monitoring indicates excessive livestock conflicts.

Response

(1) The decision document resulting from NEPA analysis at the allotment level concluded that the 

likelihood of conflicts with grizzly bears and wolves and the potential for disease transmission 

between domestic and Big Horn Sheep was too high to support the issuance of permits for domestic 

sheep grazing.

 The documentation of the process that was used for determining rangeland capability and suitability 

is in appendix B of the FEIS.

 See response to PC #615, PC #172 item 1.

Public Concern #608

The Forest Service should consider best science for current management of livestock on riparian areas 

since during winter months ungulates congregate to lower elevation and riparian areas.

Response

We use the best available science to manage all vegetation types including riparian areas.

Subject: 1754 - Commercial Livestock Grazing - Desired condition

Public Concern #609

The Forest Service should consider reducing livestock grazing in wildland urban interface areas such as 

Sink Canyon and Landor Front/Limestone Mountain and allow growing season rest from grazing.

Response

The existing livestock grazing management systems incorporate either deferred use or rotational rest, or 

both, to allow plants to complete their growing cycle prior to livestock use. Eliminating livestock grazing 

in the wildland-urban interface has the potential to increase the likelihood of occurrence and intensity of 

wildfires.

Public Concern #610

The Forest Service should consider changing pg. 73 “On big Game Winter ranges, livestock grazing can 

be utilized as a tool to improve forage conditions and maintain big game use on winter ranges” since this 

is not Best Science especially with drier conditions. Desired condition should focus more emphasis on elk 

and deer winter range and thus changes to commercial livestock grazing.

Response

The section referenced deals with commercial livestock grazing and desired conditions relevant to that 

topic. The beneficial use of livestock to improve forage conditions is documented in the literature cited.

Subject: 1755 - Commercial Livestock Grazing - Direct and indirect effects

Public Concern #611

The Forest Service should consider benefits of commercial livestock grazing such as it being a tool to 

improve Elk habitat by enhancing forage habitat.
Final Environmental Impact Statement -- Appendix A

873

Response

This is stated in the management approach section for commercial livestock grazing on page 73 of the 

revised Forest Plan.

Subject: 1756 - Commercial Livestock Grazing - Cumulative effects

Public Concern #612

The Forest Service should consider including a summary discussion of specific BMPs and adaptive 

management strategies to protect sensitive soils, wetlands, riparian areas, meadows, stream crossings, 

and critical habitat from grazing impacts and limiting grazing intensity, frequency or season of use where 

resource management objectives are not being met.

Response

Best management practices and adaptive management strategies are included in the appendice H.

Subject: 1757 - Commercial Livestock Grazing - Climate Change

Public Concern #613

The Forest Service should consider climate change may create need to modify grazing practices.

Response

Grazing management response to changes in resource conditions, for any reason, is applied by 

incorporating adaptive management strategies.

Subject: 1758 - Commercial Livestock Grazing - Incomplete and unavailable 

information

Public Concern #614

The Forest Service should utilize the higher value in the Present Net Value (PNV) calculations and other 

impact analyses so that the grazing contribution is accurately reflected relative to other resources. The 

Forest should realize that grazing is often in direct conflict with production of forage for big game and is 

only a limited application as a habitat modification tool for wildlife enhancement.

Response

Due to the numerous variables involved, it is generally not possible to determine an exact contribution or 

impact, so a conservative estimate or range of values is used for analysis. While livestock and wildlife 

may use the same rangeland resources, following the allowable use standards and guidelines assures that 

adequate forage remains for the established big game populations.

Subject: 1759 - Commercial Livestock Grazing - Monitoring

Public Concern #615

The Forest Service should monitor livestock grazing and require that fence maintenance be brought to the 

attention of operators. Better grazing monitoring is requested in the Warm Springs area north of Union 

Pass to assure over use does not occur.
Shoshone National Forest Land Management Plan Revision

874

Response

Adequate maintenance of structural range improvements is a condition of the Term Grazing Permit. 

Allotments are monitored for compliance with the permit terms and conditions and to assure livestock 

grazing does not exceed the specified allowable use level.

Public Concern #616

The Forest Service should only change livestock management if it is the reason desired conditions are not 

being met and change the guideline in the Draft Land Management Plan, Chapter 1- Forest-Wide 

Direction for Vegetation, Commercial Livestock Grazing #4, page 34 to: “Livestock management should 

be modified when conditions are not moving toward desired conditions due to current livestock grazing 

management and as determined through trend condition and monitoring,”

Response

While this would generally be the case, many times livestock management needs to be modified even if 

livestock use is not the primary reason resource conditions are not being met, i.e., impacts from fire, 

insects, or drought. Management of specific allotments will be addressed through the site-specific 

allotment management plans.

Public Concern #617

The Forest Service should consider adding a discussion on monitoring requirements, including the 

parameters to be monitored and the monitoring frequency, for water quality, wildlife impacts, general 

timing of adaptive management implementation and effectiveness, and soil quality parameters.

Response

Chapter 3 in the revised Forest Plan contains information on the monitoring strategy, including 

monitoring questions and potential monitoring items.

Subject: 1770 - Commercial Livestock Grazing - Background

Public Concern #618

The Forest Service should address impacts of removing Animal Unit Months (AUMs) on the Shoshone as 

their removal may have a significant impact on individual livestock grazing permittees, ranches, and 

communities.

Response

These impacts are addressed and considered in the economic analysis section.

Subject: 1771 - Commercial Livestock Grazing – Desired Condition

Public Concern #619

The Forest Service should add the following to the Land Management Plan: “As Endangered Species Act 

(ESA) listed predators become biologically recovered, as is the case with both grizzly bears and wolves, 

and as ESA restrictions become relaxed during and after the delisting process, the SNF will actively work 

with ranchers/permittees to make every effort to minimize adverse predator impacts to livestock in order 

to help keep working ranches working.”

Response

Regardless of the listing status of grizzly bears and wolves, the Forest Service will continue to work with 

permittees to minimize conflicts with livestock and the resulting impacts. Specific to the grizzly bear, the 
Final Environmental Impact Statement -- Appendix A

875

guidelines presently implemented through the Conservation Strategy are the management practices that

will make delisting possible and would continue to be required even after delisting. Currently, the State of 

Wyoming is responsible for managing the grey wolf.

Subject: 1774 - Commercial Livestock Grazing - Standards

Public Concern #620

The Forest Service should add “Existing range improvements can be maintained” to the Draft Land 

Management Plan, Chapter 2-Management Area Direction, Standards for Management Area 1.5A, 

Commercial Livestock Grazing #9, page 144.

Response

The revised Forest Plan allows commercial livestock grazing to occur in the area. See Guideline #8 in the 

FEIS. Maintaining structures needed for grazing is part of commercial livestock grazing and does not 

need to be stated separately.

Subject: 1776 - Commercial Livestock Grazing - Management Approach

Public Concern #621

The Forest Service should correct the grazing capability to reflect actual and documented distribution by 

livestock and ensure that strong management practices are continued including the protection of all 

wetlands from grazing.

Response

Because livestock will use or occupy areas that are not capable of supporting and sustaining grazing, 

actual livestock distribution would not be an accurate display of rangeland capability.

Subject: 1800 - Forest Products - Resource General

Public Concern #622

The Forest Service should take a conservative approach to logging to include replanting and cleanup. 

Selective harvesting may be allowed but not clearcutting. The Forest Service should use the old adage 

that ‘less is more’ should be used with the management of the Shoshone Forest. The less we try to change 

and control it the more the forest will give us. Clearcutting fragments the forest and has negative impacts 

on some of the residual flora and fauna.

The Forest Service should take a cautious approach to logging. Since climate change is apparently 

accelerating, the SNF should manage for the greatest conservation and the least environmental impact.

Response

Harvest levels in any of the alternatives represent a very small percentage of the Shoshone. All 

alternatives, except F, project harvest of well under 1,000 acres per year, and alternative F is about 1,200 

acres a year. Clear cutting is a small percentage of the harvest conducted. Though the alternatives don’t 

precisely predict the mix of harvest treatments, the acre projections are based upon continuing the harvest 

levels and treatments that have been used under the current plan. In the last 20 years, the forest has 

averaged 25 acres of clearcutting a year in timber sales.
Shoshone National Forest Land Management Plan Revision

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Public Concern #623

The Forest Service should consider hiring a professional forester from outside the Forest Service. This 

person or firm should have an unbiased opinion for creating a map and management plan for a 100 year 

cycle for logging saleable lumber. Techniques could be based on board feet per year and could be either 

clear cutting or select cutting. This will do many things like create jobs, eliminate forest fuels that have 

been built up for years, create fire breaks to protect private property, reduce bug and disease infestations, 

create healthier forests and create better habitat for our wild animals. Encourage logging it was viable 

here once before and it could be again if you could set it up to where a private company could make a 

living doing it.

Response

The current forest plan provides a long-range management plan for timber management. It projects timber 

harvest to continue in a manner similar to current levels. Though there have been fluctuations in the 

harvest levels historically, the trend has been relatively constant over the last 30 years and is projected to 

continue during the next 10 to 15 years.

Public Concern #624

The Forest Service should not log. Logging is bringing on extensive climate change resulting in adverse 

climatic conditions.

The Forest Service should stop clearcutting because it causes forest fragmentation. Fragmentation 

degrades habitat, splinters wildlife and plant populations, and contributes to species extinction on local 

and regional scales. These effects are greater than the loss of habitat alone, because as fragmentation 

progresses, remnant patches of habitat within disturbed areas become isolated from one another, thus 

preventing dispersal of animals and plants between them (Andren 1994, Bender et al. 1998). As the forest 

becomes progressively fragmented, the viability of native plants and wildlife is increasingly endangered, 

and the likelihood of extirpation increases.

The Forest Service should stop clearcutting because of the negative effects of the depth of edge influence. 

Clearcutting has a number of serious ecological consequences making it incompatible with the 

maintenance of healthy, functioning ecosystems. For instance, clearcutting increases the likelihood of 

insect irruptions by weakening trees along the edges and creating single-aged monocultures of insectintolerant early successional tree species (Berryman 1986). Compounding the problem, the efforts by 

Forest Service managers to eliminate beetle outbreaks are unwarranted and counterproductive. Samman 

et al. (2000) concluded that past timber harvest practices have actually made forests more susceptible to 

beetle outbreaks, and that forest mangers could render their forest less vulnerable to irruptions by 

allowing outbreaks to run their course. Clearcutting has significant long-term effects on soil communities 

leading to loss of forest productivity. Clearcutting creates forest edges of a type that have harmful 

ecological effects. Research has discovered that hard edges left behind by clearcuts make nesting birds 

more susceptible to predators than more gradual natural edges (Ratti and Reese 1988, Rufenacht and 

Knight 2000). Clearcutting creates favorable environments for invasions of non-native plant species, 

which are opportunistic and prefer open, disturbed habitats. Nonnative species can have disruptive effects 

on native ecosystems and invasions should be actively discouraged through forest management. Because 

of the destructive effects of clearcutting on ecosystem health and the Forest Service’s inability to mitigate 

its impacts, the inevitable conclusion must be that a moratorium on clearcutting is needed for the 

Shoshone National Forest. Even-aged harvest methods that create clearcuts over the long term, such as 

seed-tree cuts and two-stage selection cuts, should also be prohibited.

We propose a forest wide Natural Fire policy to drive the landscape-scale dynamics of forest succession. 

The obvious solution is to reintroduce stochastic forest disturbances into the forest landscape and to allow 
Final Environmental Impact Statement -- Appendix A

877

them to proceed along their natural courses. This policy will apply forest-wide, except in designated areas 

along the urban-forest interface, where special protection from wildfire would be granted.

The Forest Service should stop clearcutting because natural disturbance is better for the health of the 

ecosystem. Natural disturbances interact in complex ways which determine the natural patterns of forest 

succession-- patterns which are crucial to maintaining the viability of forest species, communities, and 

ecosystems. The inability of timber harvest programs to effectively imitate natural patterns of disturbance 

has been well-documented in the scientific literature (Mladenoff et al. 1993, DellaSala et al. 1995, Huff et 

al. 1995, Wallin et al. 1996, Franklin et al. 1997, Aplet 2000, Lowsky and Knight 2000, Dillon et al. 

2005).

Response

Providing timber products while protecting ecosystem integrity is part of the purpose and need for the 

Shoshone National Forest. We added to chapter 2 of the EIS a discussion on why an alternative that 

includes no timber harvest is not considered in the EIS. Harvest levels in any of the alternatives only 

represent a very small percentage of the Shoshone. All alternatives, except F, project harvest of well under 

1,000 acres a year, and alternative F is about 1,200 acres a year. Clear cutting is a small percentage of the 

harvest conducted. All alternatives provide habitat for wildlife species. The decision maker will consider 

these comments along with input from other commenters in making a final decision.

Public Concern #625

The Forest Service should continue logging. Commercial use or providing commercial products from 

National Forests is appropriate and it’s good for wildlife.

The Forest Service should provide enough trees killed by fire or insects, or that are senescent or 

overstocked, for logging to be profitable and to sustain new local and regional wood products industry. 

Logging is a necessary and reasonable approach for improving forest health and landscapes. Additional 

logging should occur in other areas accessible by existing roads. The Forest Service should also look at 

possibly seeking a temporary lifting of the Roadless Rule. By providing reliable local timber supplies, the 

SNF will support creation of new employment and industries in surrounding communities and 

constructively address wildfire fuel burdens before fire makes its own decisions.

The Forest Service should increase the amount of acres suitable for logging from 250,000 to 450,000 

acres. This would help timber sales have adequate terrain for logging access.

The Forest Service should consider raising the amount of acres suitable for timber production in 

Alternative A. There are more acres proposed for oil and gas development than suitable for timber 

production in Alternative A, yet timber is a more renewable resource.

Response

All of the alternatives provide some level of timber harvest for commercial purposes. The number of 

suitable timber acres varies across the alternatives, but they are all higher than the current situation. 

Changing the Roadless Rule is beyond the scope of the revised Forest Plan. With current rules and 

regulations, the maximum amount of acres available for suitable ground is near the amount included in 

alternative F. The decision maker will consider the public comments requesting more suitable timber 

acres in addition to other public comments in making the final decision.

Public Concern #626

The Forest Service should not log lesser known roadless areas but reclassify them as wilderness. This 

action would protect these areas from logging.
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Response

No scheduled timber production is allowed in roadless areas in alternative B, and any timber harvest 

would be consistent with the types of harvest allowed in the roadless rule. Alternatives C and D allow no 

timber harvest in roadless areas. The decision maker will consider the public comments requesting no 

timber harvest in roadless areas in addition to other public comments in making the final decision.

Public Concern #627

The Forest Service should not expand the suitable timber lands. This would be an extreme amount of 

disturbance in the lower-elevation areas.

The Forest Service should consider the extensive beetle-killed forest acreages and the resulting threats of 

more frequent fire regimes and blown-down timber will be more than the current funding and staffing 

levels of SNF will be able to handle. Concentrate on those without adding acreage for a non-existent 

timber market.

Response

All alternatives, but A, expand suitable timber lands, though acres of actual harvest will decrease in 

alternatives C and D, and will be slightly decreased in alternative B. Harvest levels in any of the 

alternatives only represent a very small percentage of the Shoshone. All alternatives, except F, project 

harvest of well under 1,000 acres a year, and alternative F is about 1,200 acres a year. Though it fluctuates 

year to year, a market for the timber sold from the Shoshone does exist. The decision maker will consider 

the public comments requesting no increase in suitable timber lands in addition to other public comments 

in making the final decision.

Public Concern #628

The Forest Service should select the least amount of acres designated as suitable for timber production. 

The current wild and relatively undeveloped condition of the Shoshone forest lands are the foundation for 

thriving outdoor-recreation based sustainable economies in Lander and Dubois. These economies are not 

derived from commodity production on forest lands; therefore, the Forest does not need to expand 

opportunities for timber production on these lands.

Response

The alternatives project various harvest levels with harvest acres lower than the current forest plan in 

alternatives C and D. Harvest levels in any of the alternatives represent only a very small percentage of 

the Shoshone. The decision maker will consider the public comments requesting a low number of suitable 

timber acres in addition to other public comments in making the final decision.

Public Concern #629

The Forest Service should maximize the conservation of old-growth and closed-canopy forest in order to 

counterbalance the depletion of these mature forest types as a result of beetles and climate change. The 

Forest Service should also maintain the 1986 level of harvesting. The Forest Service should create a 

standard in the Forest Plan that places a moratorium on clearcutting on the SNF. Uneven-aged 

management is preferable for interior forest species such as the boreal owl. Since there is only one 

commercial-scale lumber mill remaining in Wyoming and it does not get a large proportion of its timber 

from the SNF there isn’t a need to expand the suitable acres for timber harvest.

Response

Harvest levels in any of the alternatives represent only a very small percentage of the Shoshone. All 

alternatives, except F, project harvest of well under 1,000 acres a year, and alternative F is about 1,200 
Final Environmental Impact Statement -- Appendix A

879

acres a year. Harvest levels vary across the alternatives, but for most of the alternatives are similar to the 

current plan. Clear cutting is a small percentage of the harvest conducted. In the last 20 years, the forest 

has averaged 25 acres of clearcutting a year in timber sales. The Revised Forest Plan contains guidelines 

for maintaining a percentage of harvested watersheds as older stands. The vast majority of the forested 

acres on the Shoshone are not identified as suitable timber lands and will remain in a natural condition. 

The decision maker will consider the public comments requesting no increase in suitable timber lands in 

addition to other public comments in making the final decision.

Public Concern #630

The Forest Service should not conduct salvage logging as a result of insect outbreaks or fires. Snags and 

woody debris created by forest fires or insect outbreaks play an important role in maintaining the forest 

ecosystem health and function. The Forest Service should also consider stopping fuels treatment thinning 

prescriptions. Fuels treatment thinning at best are unproven and counterproductive at worst, prescribed 

fire should be the preferred method of fuels reduction. No fuels treatment of any sort should be allowed 

outside Residential-Forest Interface areas approximately 1⁄4 mile of currently existing structures.

The Forest Service should stop offering below cost timber sales. The Forest Service has no business 

spending tax dollars on programs that are clearly contrary to the public interest and are wholeheartedly 

opposed by an overwhelming majority the taxpayers. In cases where timber sales offer clear management 

benefits, below-cost sales are allowable only in cases where they are approved by the public in the form of 

a majority of public comments supporting the sale during the NEPA process.

Response

The revised Forest Plan contains guidelines for maintaining snags and woody debris in harvest areas. The 

alternatives contain differing levels of vegetation treatments, with the lowest amounts in alternatives C 

and D. Harvest levels in any of the alternatives represent only a small percentage of the Shoshone. The 

decision maker will consider the public comments requesting less vegetation treatment in addition to 

other public comments in making the final decision.

The issue of how budget dollars are allocated relative to what targets are produced is beyond the scope of 

the analysis. Congress determines dollar allocations and how associated products are to be produced with 

those dollars.

Public Concern #631

The Forest Service should preserve adequate amounts of old-growth during the present planning period 

and the Forest Service needs to plan for the creation of additional old-growth in the future through the 

natural processes of forest succession. The depletion of old-growth is one of the most important threats to 

its ecosystem health, and represents an issue that demands immediate redress. A number of species on the 

SNF are old-growth obligates, absolutely dependent on old-growth forests for their survival.

Response

The revised Forest Plan contains guidelines for maintaining a percentage of harvested watersheds as older 

stands. The vast majority of the forested acres on the Shoshone are not identified as suitable timber lands 

and will remain in a natural condition. Harvest levels in any of the alternatives only represent a very small 

percentage of the Shoshone. All alternatives, except F, project harvest of well under 1,000 acres a year, 

and alternative F is about 1,200 acres a year.
Shoshone National Forest Land Management Plan Revision

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Public Concern #632

The Forest Service should only do limited clearcutting. As a general rule clearcutting is not needed as a 

management tool on the forest. It is recognized that there are times when it is the best option after a stand 

replacement event.

Response

Harvest levels in any of the alternatives represent only a very small percentage of the Shoshone. All 

alternatives, except F, project harvest of well under 1,000 acres a year, and alternative F is about 

1,200 acres a year. Clear cutting is a small percentage of the harvest conducted. In the last 20 years, the 

forest has averaged 25 acres of clearcutting a year in timber sales. The plan contains a guideline that 

states “Clearcutting should be used only where it is the optimum method for meeting desired conditions 

and objectives.”

Public Concern #633

The Forest Service should revise Table 13 in the Forest Plan and Table 103 in the DEIS so they are 

consistent. The Forest Service should consistently discuss the ASQ as a decadal volume (per NFMA 

Section 13), or an annual average of that decadal volume. The Forest Service should go to a larger top 

diameter for dead lodgepole pine, other conifer sawtimber, aspen and POL. Consistency with ASQ will 

help the reader follow the flow of discussion. Increasing the top diameter from 6" to 6-8" would allow 

critical flexibility to deal with deteriorating dead sawtimber on the Shoshone NF

Response

The numbers in tables 13 and 103 are consistent, but they present that data in different ways for different 

purposes.

The documents will be reviewed to ensure that the ASQ is presented appropriately.

The timber utilization numbers are based upon a Regional Standard and will not be changed for the 

revised Forest Plan. Utilization standards can and have been modified to deal with specific project 

situations.

Public Concern #634

The Forest Service should delete “unless it was...effects” from the first sentence, third paragraph, page 

82 of the Forest Plan.

Response

The qualification in the sentence will remain. The sentence still identifies suitable timber lands as a high 

value assessment, but allows us to not protect it from fire when that fire would be beneficial or have no 

effect. One example is where we have a stand of dead trees on suitable ground that has no commercial 

value. In some cases, fire may accelerate the recovery of timber vegetation on that stand.

Public Concern #635

The Forest Service should display and discuss annual growth, mortality, and biologic potential for both 

suitable and non-suitable timberlands in the Forest Products section on page 420 of the DEIS. Providing 

a visual display and discussion will help compare suitable and non- suitable timberlands. The Forest 

Service should review paragraph 4, page 425 and the “Demand and Future Timber Products” paragraph 

on page 429. It appears that achieving DFC is a more significant driver than demand for timber products.
Final Environmental Impact Statement -- Appendix A

881

Response

We added a discussion on growth and mortality of timber resources into the affected environment from 

the FIA report for the forest. We reworked the effects discussion to clarify the purpose and need for 

timber harvest in alternative B.

Subject: 1802 - Forest Products - Methodology

Public Concern #636

The Forest Service should review the following tables, 103, 104, 105 and 106 because they are somewhat 

confusing, and need to be reviewed for accuracy and consistency. Specifically, are the acres in Table 104 

and the costs and revenues in Table 105 calculated on an annual or decadal basis? Is the volume in Table 

103 only from suited timberlands, or does it also include volume from OVM lands? Also, which volumes 

in Table 103 are in MCF and which are in CCF. Currently these tables do not make sense. Data in Tables 

103, 104 and 105 are not mathematically sound. There should be some explanation for Table 103 why 

some numbers are in Mcf and others are in Ccf.

Response

The information and display of the information in tables will be clarified.

Subject: 1804 - Forest Products - Desired Condition

Public Concern #637

The Forest Service should not let timber companies have carte blanche in tree cutting. Timber companies 

desire only to select trees that will make them money and would prefer to leave trees that aren’t as 

profitable for them.

Response

This is outside the scope of this decision. Timber contractors do not have a choice of what product to 

remove from a site. The Forest Service designates what should be removed in the contract.

Public Concern #638

The Forest Service should reclaim all acres associated with a timber sale to preexisting conditions. This 

will help preserve the aesthetic nature of the landscape.

Response

The revised Forest Plan contains standards and guidelines to protect the other resources and visuals that 

are also found on a harvest site. Sites valued high for their visual resources contain more direction on how 

they can be treated. Over time, as sites regenerate and vegetation grows, there is less and less evidence of 

harvesting activities.

Subject: 1820 - Forest Products - Background

Public Concern #639

The Forest Service should recalculate the average annual harvest of timber stated in the Forest Plan. 

Given the extensive conifer mortality that has occurred on the forest, was the volume of available timber 

recalculated for this plan? Is the 1994 estimate still valid?
Shoshone National Forest Land Management Plan Revision

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Response

Vegetation data used in the analysis has been updated to reflect the changes that have happened in the last 

10 years from fire and insects. The timber yield tables were adjusted to simulate the effect from the 

ongoing insect epidemics. The volume estimates are based upon these updates.

Subject: 1821 - Forest Products - Desired Condition

Public Concern #640

The Forest Service should consider revising the discussion under “Desired Conditions” to include, “A 

sustainable mix of timber products responsive to traditional, non-traditional, and new market demand, 

including that of local industry, is provided.” This is needed to acknowledge a changing market

Response

We will revise the wording to improve clarity.

Subject: 1822 - Forest Products - Goals

Public Concern #641

The Forest Service should delete “except when ... protect” in the Forest Plan, page 75, Goal #4.

Response

The goal is worded as it is based upon the realization that in some situations the cost of protecting the 

resource would exceed the value of the resource itself. Other direction in this section continues to point 

out that suitable timber lands are a valued resource that should be protected.

Public Concern #642

The Forest Service should consider changing on page 53 of the DEIS, “annual estimate” to “average 

annual” for TSPQ and ASQ. This will provide flexibility for management.

Response

The change was not made. The EIS numbers are providing an estimate of effects. They do not establish 

any direction. The revised Forest Plan is where the direction is established and it is written there to 

provide management flexibility.

Subject: 1824 - Forest Products - Standards

Public Concern #643

The Forest Service should revise Table 14 of the Forest Plan to include the following changes for 

lodgepole pine cover type: 1) add clearcut with reserve trees and seed tree under the even- aged column 

and, 2) add clearcut with reserve trees under the two-aged column. In the same table the Forest Service 

lists White-bark Pine and Limber Pine as trees that can be harvested using certain methods. Given the 

high mortality risk for both of these species, should they be targeted for commercial harvest? In mixed 

conifer stands that are harvested, how can saplings and seedlings of these 2 species be protected to 

ensure that they will persist in

Response

Clearcut with reserves and seed tree with reserves were added under the two-aged column. Seed tree is 

already listed and an approved even-aged management prescription. Limber pine and whitebark pine are 

generally not treated as commercial species, but that does not mean they cannot be harvested and used 
Final Environmental Impact Statement -- Appendix A

883

consistent with management direction in the plan. Stands are often managed for a mix of conifer species 

and could be done for limber pine and whitebark pine based upon the other plan direction for those 

species.

Subject: 1825 - Forest Products - Guidelines

Public Concern #644

The Forest Service should consider modifying and or adding the following guidelines (page 78): To 

Guideline 4 add: Meet vegetation desired conditions of stand size. Add new guideline: Uneven-aged 

systems are not appropriate for the stands with an historic fire regime II, IV, V (stand replacement burn 

severity.) Clearcutting with reserve trees is the most appropriate prescription. Modify Guideline 8: 

Harvest activities for the purposes of timber production should be used when there is reasonable 

assurance the harvested lands can be restocked within five years after final regeneration harvest. 

Otherwise, the expense of restocking should be considered as a cost to the greater vegetation objective. 

Add new guideline: Utilizing the Stewardship end results contracting is the preferred instrument for 

conducting forest product activities. Retained receipts can fund, above and beyond annual budgets, for 

additional stewardship treatments. Also very important, these instruments, because they allow for project 

proposals and are awarded on a ―best value criteria, provide the potential for innovative solutions. 

There is also the potential for cost savings through economy of scale by bundling multiple 

activities/treatments into a single contract. Finally, there are incentives, through agreements, for nonprofit organizations with mutual interest to assist with additional resources. Add new guideline: 

Inventoried Roadless Area acres that are―generally suitable for harvest can be accessed using 

temporary roads (if feasible) and logging systems, such as cut-to-length, forwarders, and/or excalines 

that afford treatment to meet vegetation desired conditions. Modify Guideline 10 to include: Overtime, 

however, the application of timber harvesting to obtain vegetation desired conditions should lessen the 

threat to suitable timber lands from unmanageable wildfire.

Response

Guideline 4 wasn’t changed. That guideline is a based upon NFMA requirements and is somewhat 

standardized across Region 2. It is complete as written. The suggested addition is not needed.

A guideline specifying the appropriateness of uneven-aged systems to certain fire regimes was not added. 

Those decisions are made on a site-specific basis, and we don’t want to limit the flexibility of choosing 

prescriptions at the project level.

Guideline 8 wasn’t changed. Like Guideline 4, it is based upon NFMA requirements and is standardized 

across Regions 2.

A guideline on the preference for stewardship contracting was not included. Specifying specific tools for 

implementing plan direction is not included as forest plan direction. The revised Forest Plan indicates 

what is to be accomplished and the method of accomplishing that direction is decided at the project level. 

Some of the proposed language was added to the management approach discussion on stewardship 

contracting.

A guideline on temporary roads in inventoried roadless areas was not added. Additional language on the 

use of temporary roads in inventoried roadless areas was added under the management approach for 

inventoried roadless areas in the suitable uses section.
Shoshone National Forest Land Management Plan Revision

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The suggested qualification to Guideline 10 is more a statement of the effects of implementing forest plan 

direction and not a statement of direction to apply during implementation of the revised Forest Plan. The 

change was not made.

Public Concern #645

The Forest Service should revise Forest Products Guideline #1 on page 78 is not appropriate. There is no 

reason for “timber harvest activities” to be singled out in the Draft Plan for review by an 

interdisciplinary team to ensure consistency with desired conditions and objectives. We expect all 

activities on the Shoshone NF, not just “timber harvest activities”, to conform to the forest plan. We 

recommend that you delete Forest Products Guideline #1.

Response

Guideline 1 wasn’t deleted. That guideline is based upon NFMA requirements and is standardized across 

Region 2.

Public Concern #646

The Forest Service should revise Guideline #6, regarding even-aged prescriptions, is confusing. Is the 

intent to favor uneven-aged prescriptions, or is the intent to favor clearcutting over seed tree or 

shelterwood prescriptions? Is it even necessary?

Response

The intent is not to favor a particular prescription in the plan. We agree that it is not necessary. Guideline 

6 is dropped.

Public Concern #647

The Forest Service should delete a portion of Fire and fuels Guideline, #10, page 58 – Delete “except 

when ... protect.”

Response

The direction is worded as it is based upon the realization that in some situations the cost of protecting the 

resource would exceed the value of the resource itself. Other direction in this section continues to point 

out that suitable timber lands are a valued resource that should be protected. The Guideline was not 

changed.

Subject: 1826 - Forest Products - Management Approach

Public Concern #648

The Forest Service should increase the use of temporary roads to allow for the use of mechanical 

treatments to improve forest health and restoration activities. This will provide temporary access that can 

be restored after the project is completed.

Response

Temporary roads are used routinely as needed for harvest operations. All the alternatives project the use 

of temporary roads. Harvest projections are not restricted by any temporary road limits.

Public Concern #649

The Forest Service should include more specific recommendations are needed in the LMP on how the 

SNF will manage and monitor white- bark pine and limber pine communities over the next planning 
Final Environmental Impact Statement -- Appendix A

885

period. These trees are being threatened by beetle attack and whitebark pine blister rust. The result of 

these two threats could have a severe impact on the whitebark pine and limber pine communities.

Response

Whitebark pine is a sensitive species and is already being extensively monitored on the Forest. See 

Whitebark Pine Strategy for the Greater Yellowstone Area referenced in the vegetation section of the 

revised Forest Plan. Limber pine is not followed as closely as whitebark pine, but it is benefiting from 

some of the same efforts.

Public Concern #650

The Forest Service should revise the lynx habitat guidelines referencing them in the Forest Products 

section of the LMP as harvest management projects will need to be evaluated at the level of the Lynx 

Analysis Unit during the planning phase. Management of lynx habitat has not been incorporated into the 

LMP in a meaningful way. The appendices provide what is required to be done for lynx but the plan itself 

does not incorporate management standards and guidelines for lynx habitat in a meaningful way.

Response

See response to PC #471 concerning changing the lynx direction. In the revised Forest Plan, the lynx 

direction is included in the appendix, but is also cross referenced into the main document. The FEIS 

includes an analysis that reflects the direction in the revised Forest Plan including the direction for lynx.

Public Concern #651

The Forest Service should consider limiting timber production to 100,000 acres. Without a current market 

for timber products and a dubious future, there isn’t any reason to create large timber sales if you are not 

going to be able to sell them.

Response

Though it fluctuates year to year, a market for the timber sold from the Shoshone does exist. Most of our 

timber sales are purchased.

Public Concern #652

The Forest Service should review and ensure that 2,130 acres of precommercial thinning in lynx habitat is 

adequate for timber management objectives. We also recommend that you allow those acres of 

precommercial thinning “per decade” instead of “for the next 10 to 15 years”. Further, we were unable 

to find the language in the Draft Plan to actually authorize the 2,130 acres of precommercial thinning in 

lynx habitat, and recommend that you ensure such language is included in the Revised Plan and Record 

of Decision. These actions are needed to authorize and promote lynx habitat improvement work.

Response

The acres are based on an estimate that was made when the lynx amendment was done and we believe it 

is still accurate. A discussion on the connection of precommercial thinning to producing timber is 

included, as well as a reference to the 2,130 acres.

Public Concern #653

The Forest Service should review the last paragraph of page 531 of the DEIS, 43,000 acres in the 

Shoshone NF inventory of roadless areas “no longer meet roadless characteristics”. The DEIS does not 

identify where those acres are located. However if they no longer have roadless characteristics and they 

are forested acres, then they should be available for timber production and should be considered for 

designation as lands suitable for timber production.
Shoshone National Forest Land Management Plan Revision

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Response

Alternatives E and F consider managing some of the inventoried roadless areas that no longer have 

roadless characteristics for timber production. Other alternatives manage those lands under the Roadless 

Rule direction. The decision maker while consider the public comments on how these altered lands should 

be managed in making the final decision.

Public Concern #654

The Forest Service should consider adding a Guideline under Forest Products stating an intent to salvage 

merchantable sawtimber from natural events such as wildfire, blowdown, insects, and disease on suited 

timberlands, plus lands not suited for timber harvest when consistent with MA direction. This would help 

move the salvage area toward the desired condition of the management area.

Response

We believe this intent to salvage timber is addressed in the revised Forest Plan. The back country 

management areas already have a reference to salvage in the guidelines for vegetation. The management 

approach for timber products talks about the emphasis on salvage activities during the life of the plan.

Public Concern #655

We agree with the separate calculation of ASQ and Predicted Annual Volume based on anticipated 

budgets.

Response

No response needed.

Public Concern #656

The Forest Service should maintain throughout the planning documents that ASQ is a decadal number. 

This will prevent confusion when comparing other planning documents.

Response

ASQ (annual sale quantity) is an average annual number. The documents will be reviewed for consistency 

and clarity. The definition is included in the glossary.

Public Concern #657

The Forest Service should on page 420 display and discuss annual growth, mortality, and biologic 

potential for both suitable and non-suitable timberlands in the Forest Products section. This will provide 

a comparison of the two types of management.

Response

See response to PC #635.

Public Concern #664

The Forest Service should consider adding offering stewardship end results contracts for up to 10 years 

since it will offer longer contracts and have a better value for forests.

Response

Specifying tools for implementing plan direction is outside the scope of the revised Forest Plan analysis. 

The plan indicates what is to be accomplished and the method of accomplishing that direction is decided 

at the project level. We added some of the language to the management approach discussion on 

stewardship contracting.
Final Environmental Impact Statement -- Appendix A

887

Subject: 1850 - Special Forest Products - Resource - General

Public Concern #658

The Forest Service should consider allow timber industry development as long as there is oversight and 

industry held accountable.

Response

All logging activities are done under contracts that include provisions designed to meet forest plan 

direction.

Public Concern #659

The Forest Service should consider discussing more how to use timber for local artisans and craftspeople 

since there does not seem to be much demand for timber.

Response

Though it fluctuates year to year, a market for the timber sold from the Shoshone does exist. Most of our 

timber sales are purchased. In addition, the revised Forest Plan does contain direction on the desire to 

provide for new and changing markets.

Subject: 1872 - Special Forest Products - Management Approach

Public Concern #660

The Forest Service should consider adding a discussion in the DEIS about goal to help maintain or create 

processing capacity and infrastructure in local communities since it is unknown how communities will be 

impacted amongst the various alternatives.

Response

The EIS includes a discussion on how volume changes across the alternatives and how timber-related 

labor income will change over the alternatives. The labor income analysis does provide information on 

how the alternatives affect the local economy. Whether any particular alternative can support the creation 

of a new mill involves too many variables to assess and goes beyond just what volume is available from 

the forest. It would include items like mill size and how well the mill could compete against other buyers. 

Such an analysis is beyond the scope of the EIS.

Subject: 1900 - Land (Special Uses) - Resource - General

Public Concern #662

The Forest Service should consider more opportunities for backcountry skiing, packrafting, and 

mountaineering and make it easier to do multiple year round activities without have to do multiple 

proposals, applications, and compete in multiple prospectus offerings since this would benefit both public, 

commercial entities, and the forest.

Response

Issuance of a prospectus or accepting an application for a special use permit for any type of recreational 

activity is a site-specific decision and analysis and is not at the forest plan level.
Shoshone National Forest Land Management Plan Revision

888

Subject: 1924 - Land (Special Uses) - Standards

Public Concern #663

The Forest Service should consider changing in the plan on page 173 so that the standards are 

established that support desired recreation settings and activities that are consistent with the nature and 

purposes of the CDNST and on page 50 switching guideline 10 to a standard.

Response

The standards on page 173 support the nature and purposes of the CDNST with standards for outfitting 

and guiding activities that only allow those types of authorized activities that do not interfere with the 

nature and purposes of the trail.

We feel Guideline #10 on page 50 is more appropriate as a guideline than a standard. A guideline is a 

course of action that should be followed to achieve a goal, while a standard is something that has to be 

followed and any deviation must be analyzed and documented in a forest plan amendment.

Subject: 1950 - Minerals - Resource – General

Public Concern #665

The Forest Service should consider prohibiting mineral exploration and leases in areas where they are 

already prohibited, winter game ranges, inventoried roadless areas and should be restrained by 

stipulations in the Land Management Plan since mining destroys wild lands.

Response

Alternatives B, C, and D provide differing restriction on oil and gas development on crucial winter range 

and inventoried roadless areas. The decision maker will consider the public comments requesting that 

winter range and roadless areas be allocated to no surface occupancy in addition to other public comments 

in making the final decision.

Subject: 1951 - Minerals - Legal and administrative framework

Public Concern #666

The Forest Service should consider the Energy Policy Act of 2005, the Energy Policy Conservation Act 

Amendments of 2000, the Resource Planning Act and 36 CFR 2822.03 and follow their requirements 

when making any changes to Minerals section of the Forest Plan.

Response

The alternatives analyzed in the EIS display a range of options for designating where oil and gas 

development is suitable. This range goes from alternative C, where no surface occupancy is allowed on a 

majority of the forest, to alternative F, where surface occupancy is allowed on a majority of the forest. 

The FEIS examines the effects of the alternatives to oil and gas development as well as to other forest 

resources. The decision maker will consider the trade-offs in making a final decision.

Public Concern #667

The Forest Service should make every effort possible to minimize any damage from mining.
Final Environmental Impact Statement -- Appendix A

889

Response

The revised Forest Plan identifies areas of the forest that are suitable for mining. It also contains direction 

on protecting water and wildlife resources. Site-specific mitigation for any mining operation would be 

developed during the project-level planning phase for any mining operation.

Subject: 1952 - Minerals - Methodology

Public Concern #668

The Forest Service should consider putting more detail into areas listed and stipulations for No Surface 

Occupancy since they are only vaguely referenced.

Response

Maps for no surface occupancy allocations are available at a scale that enables areas to be located on the 

ground. Those maps are too large to include in the documents.

Subject: 1954 - Minerals – Desired Condition 

Public Concern #669

The Forest Service should consider no surface development/occupancy on the forest especially for the 

Absaroka Front.

Response

The consideration of no oil and gas development on the forest was addressed in an alternative that was 

eliminated from detailed analysis in the EIS. The alternatives prohibit surface occupancy for oil and gas 

development on varying acres of the forest. Alternative C allows development on only 7 percent of the 

forest. The decision maker will consider the public comments requesting little or no oil and gas 

development on the forest, in addition to other public comments in making the final decision.

Subject: 1955 - Minerals - Direct and indirect effects

Public Concern #670

The Forest Service should consider making the following changes to the DEIS: 1-On page 457, 1st 

paragraph add “If the project proponent proposes alternative mitigation that the USFS and WGFD 

believes is better than the protection provided by the timing stipulations, then the timing stipulations 

maybe waived;” and address contaminations of groundwater and Line Creek from the 2006 Windsor 

Energy gas explosion since the forest had addressed the New World Mine water impairment but not the 

explosion impacts.

Response

On a project decision any standard or guideline could be modified with the proper documentation to 

accomplish the desired mitigation differently. This option is already covered generally in the plan 

direction.

The Line Creek Watershed is not classified as an impaired watershed. If that situation changes in the 

future, it will be managed as such.
Shoshone National Forest Land Management Plan Revision

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Subject: 1958 - Minerals - Incomplete and unavailable information

Public Concern #671

The Forest Service should consider adding a discussion on the benefits of additional no surface 

occupancy constraints and what is the lost opportunity cost.

Response

The EIS contains a discussion on the effects of no surface occupancy acres on land available for 

development. The projections under all alternatives for future development are low and very low. This is 

not related to land available, but rather it is related to the likelihood of development occurring. Given the 

low likelihood of development and the projections that any development would be small, any lost 

opportunity costs are low.

Subject: 1960 - Minerals - Monitoring

Public Concern #672

The Forest Service should consider the various impacts that oil and gas development does to sage grouse 

populations since it impacts their leks and nesting areas especially from the secondary roads built; also 

consider impacts to other birds and managing to minimize these impacts.

Response

The EIS projects a very low potential for any oil and gas development on the forest. As such, the potential 

for impacts are very low. Any project that did occur and is implemented under the revised Forest Plan 

would have to address any impacts and meet plan direction to protect sage grouse habitat.

Subject: 1961 - Minerals - Oil and Gas Leasing

Public Concern #673

The Forest Service should continue to allow Oil and Gas Leasing and Development on the Forest as long 

as it takes into account that it will mitigate measures to minimize impacts to recreation, fish, wildlife, and 

wilderness through strict protections and follows regulations for economic improvements such as jobs and 

tax money. No areas currently open to leases should be closed. After leasing has ceased the areas should 

be returned to its natural state.

Response

The revised Forest Plan contains direction to mitigate the effects of oil and gas development. The 

alternatives allocate varying acres open to oil and gas development. The decision maker will consider the 

public comments that request that oil and gas development acres not change in addition to other public 

comments in making the final decision.

Public Concern #674

The Forest Service should consider not allowing oil and gas leasing and development on the forest. But if 

that cannot be a feasible goal the forest should at least minimize it with no surface occupancy (NSO) on 

wilderness areas, crucial winter game ranges, highly erodible soil areas, riparian areas, Special 

Management Areas, areas were adjacent BLM is NSO, and roadless areas along with increasing buffers. 

This should be done to protect fish, wildlife, recreation activities, beauty of the forest, water, and clean air, 

and tourist economy for local communities. There are plenty of areas outside the forest that no to increase 

on forest especially with most of the forest having low potential.
Final Environmental Impact Statement -- Appendix A

891

Response

See PC #669.

Public Concern #675

The Forest Service should consider that management is the primary basis for the lack of development 

potential, since Maps 35 and 36 show the increase in NSO over areas that have high potential and with 

this design it will make it difficult to build support systems needed for development of a lease which 

makes a bad precedent for multi-use land.

Response

The land suitable for oil and gas development varies across the alternatives with alternatives C and D 

being lowest and alternatives A and F being highest. The decision maker will consider the public 

comments requesting more area be open for oil and gas development in addition to other public comments 

in making the final decision.

Public Concern #676

The Forest Service should consider some indication of possible future revisiting the Oil and Gas 

restrictions on drilling and the possible extension of exclusion areas and should be done with public 

commenting

Response

Once the revised Forest Plan is complete, in the future the leasing decision for the Shoshone will be 

updated to be more consistent with the plan direction. An EIS will be prepared as part of that decision. 

The leasing decision will be guided by the revised Forest Plan, but it is not restricted to what the plan 

states and it could amend the forest plan direction.

Public Concern #677

The Forest Service should consider developing management approaches for wildlife, recreation and 

energy development that are consistent with Bureau of Land Management neighboring lands and other 

public lands in the Greater Yellowstone Ecosystem. The forest should take into account the BLM's draft 

Resource Management Plans.

Response

See PC #1.

Public Concern #678

The Forest Service should consider adding the following tables: 1-on page 455 make a table similar to 

table 118 but showing oil and gas potential for development including the percent of high development 

potential, percent of moderate development potential, percent of low potential, percent of very low 

potential, and percent of no potential; 2-. an additional table should be included on page 455 detailing 

acres of high, low, very low, and non-existent development potential and how they are affected by various 

alternatives , 3- a discussion of anticipated effects from an increase in road development attributed from 

oil and gas activities.4- no estimate of the reasonably foreseeable development (RFD) is included in the 

DEIS and should be 5- a revision to the 1995 Shoshone ROD for oil and gas leasing is necessary.

Response

Additional analysis addressing the potential of oil and gas development is in the EIS. The EIS analysis 

projects that it is unlikely that there will be oil and gas development under any of the alternatives, given 

the past history and potential for development. The roads section of the EIS addresses the impacts from 
Shoshone National Forest Land Management Plan Revision

892

development of oil and gas. Any detailed analysis of impacts from roads related to oil and gas 

development is beyond the scope of this analysis.

A new Shoshone leasing decision will be done sometime after the revised Forest Plan is complete. The 

EIS references the reasonably foreseeable development done by the BLM, and uses that information in 

the analysis.

Public Concern #679

The Forest Service should establish a plan for the increase in future development of oil and gas, how the 

Forest will manage potential new exploration and development standards in the Shoshone, and the 

associated resource impact risks based on the DEIS assessment and establish a defined buffer for all 

forest resources. The Draft Land Management Plan should include a comprehensive list of measures and 

practices that address oil and gas impacts and an updated directional drilling reference, as the current 

reference is out of date.

Response

The revised Forest Plan contains direction to mitigate the effects of oil and gas development. The 

alternatives allocate varying acres open to oil and gas development. More detailed direction on how oil 

and gas will be developed will be addressed in future NEPA analysis such as the Leasing decision and 

specific development proposals.

Public Concern #680

The Forest Service should increase monitoring for all oil and gas activities to ensure that resource 

impacts are kept to a minimum.

Response

Monitoring of oil and gas development will be identified during project-level analysis of any proposals. 

There is currently no oil and gas development on the forest.

Public Concern #681

The Forest Service should consider the potential harm and impacts to water resources and how water 

resources may become depleted in the Forest Plan since a great deal of water would be utilized every 

stage of oil and gas development. A complete analysis of oil and gas development techniques and how 

they affect and are affected by the geology and hydrology of the proposed area should be completed prior 

to use.

Response

The revised Forest Plan contains direction to mitigate the effects of oil and gas development. Additional 

specific mitigation would be developed in association with any project proposal. Any future proposal 

would include NEPA analysis that would disclose the effects of any proposed development.

Public Concern #682

The Forest Service should make the following changes to the Draft Plan: (1) Discuss the impact of roads, 

pipelines, and transmission corridors associated with oil and gas activities which include soil disruption, 

habitat fragmentation, sediment erosion, and providing areas for noxious weed infestations. (2) Under 

Guidelines for threatened, endangered, proposed, and candidate species, re-write “Adverse effects from 

locatable mineral operations to threatened, endangered, proposed, and candidate animal species or their 

habitats should be avoided or minimized” so that the statement is less vague, which could allow for 

unregulated mineral development depending on perspective. (3) A goal should be added to Chapter 1, 
Final Environmental Impact Statement -- Appendix A

893

Forest-wide direction, Minerals, Goals, Objectives and Standards that address the analysis of impacts to 

other uses (i.e. wildlife, recreation) and address the spectrum of mitigation from no development to on site 

mitigation.

Response

The EIS analysis projects that it is unlikely that there will be oil and gas development under any of the 

alternatives, given the past history and potential for development. There is also no current or anticipated 

locatable mineral development on the Shoshone. In the EIS, the various resources talk in a general way to 

the types of impacts that can occur from mineral development. Any specific analysis effects will occur in 

association with future NEPA analysis if and when mineral development is proposed. There is no 

requirement to analyze impacts from activities that are not anticipated. The no-action alternative 

management activites would occur. The plan contains standards and guidelines for soil, water, wildlife, 

and invasive weeds that provide direction on how all management actions should be implemented to 

protect those resources. That direction also applies to mineral development and will provide for protecting 

resources during mineral development.

Public Concern #683

The Forest Service should make the following change to the DEIS, a map should be added for clarity to 

represent the 8,750 acres of land currently leased on the forest.

Response

A map will be added.

Public Concern #684

The Forest Service should determine adequate funding for sustainable fish and wildlife management, 

including monitoring, in areas proposed for energy development and establish a long term “mitigation 

trust” to benefit fish and wildlife.

Response

These types of proposals are beyond the scope of the revised Forest Plan analysis and would be developed 

and addressed during the NEPA analysis phase of a proposed project.

Public Concern #685

The Forest Service should identify, map, and add to management plans “special places” with exceptional 

resource concerns or values where energy development should not be allowed.

Response

These types of areas are identified in the revised Forest Plan. The management areas for special area 

designation generally do not allow oil and gas development. Public comment identified some additional 

areas for consideration, and the decision maker will consider those comments and others in making the 

final decision.

Subject: 1982 - Minerals - Goals

Public Concern #686

The Forest Service should consider modifying the goals section to allow for responsible mineral 

development and additionally modify Goal 2 (page 85) to include: provide for mineral resource 

development, especially in high oil and gas occurrence potential areas.
Shoshone National Forest Land Management Plan Revision

894

Response

The mineral development goal applies to all areas of the Forest were the revised Forest Plan identifies that 

the area is suitable for development, regardless of the underlying potential. To emphasize high occurrence 

areas would imply that there is a lesser desire for development in other suitable areas. A change in the 

goal for mineral development was not made.

Subject: 1983 - Minerals - Objectives

Public Concern #687

The Forest Service should consider developing quantifiable Objectives with associated Standards 

enumerating thresholds and types/levels of development since are needed for public to accept this plan 

and should coordinate with other agencies on this plan since it appears that this plan does not align with 

the management objectives for oil and gas suitability set forth in the Bureau of Land Management 

Bighorn Basin Resource Management Plan and Lander Resource Management Plan (RMP).

Response

See PC #1 and PC #682.

Subject: 1986 - Minerals - Management Approach

Public Concern #688

The Forest Service should consider the following: (1) stating where surface occupancy associated with 

mineral development is suitable on the Forest or where there is a NSO restriction. (2) Areas designated as 

NSO geophysical exploration activities should be evaluated on a case-by-case basis and this modification 

be included under Management Approach. (3) Coordinate with BLM on the Forest Plan and disclose the 

effects its decisions could have on adjacent BLM lands and how they were reached

Response

For oil and gas, a map is provided for each alternative that indicates where surface development is 

suitable. For locatable minerals, development is generally suitable outside of withdrawn areas as noted in 

the suitable uses section of the plan. Additional direction is provided in the revised Forest Plan to address 

the suitability for geophysical exploration activities. Further work was done to coordinate oil and gas 

suitability direction between Forest Service and BLM lands (see PC #1).

Subject: 2000 - Roads and Trails - Resource – General

Public Concern #689

The Forest Service should reduce motorized traffic within the forest and all existing inventoried roadless 

areas should remain so, with no new motorized road or trail development. There are enough roads on the 

forest and no more additional roads should be added as the focus of the forest should be wild and 

backcountry-based recreation. The Forest also needs to enforce the regulations of inappropriate use of 

off road vehicles on non-designated routes.

Response

We analyzed various alternatives concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C. The deciding officer will consider the various options along with other comments during 

the decision process.
Final Environmental Impact Statement -- Appendix A

895

Table 146 identifies inventoried roadless areas and what management area they are allocated to by 

alternative. The deciding officer will consider the various options along with other comments during the 

decision process.

The Forest Service will continue to manage inventoried roadless areas according to the most recent 

direction resulting from court rulings related to 2001 Roadless Area Conservation Rule.

We analyzed various alternatives for both existing and projected additional road miles by alternative in 

table 131. The deciding officer will consider the various options along with other comments during the 

decision process.

The Forest Service continually strives to curb illegal ORV or OHV use through education, signage, and 

enforcement and by providing quality ORV and OHV use where management area direction allows for 

such use.

Public Concern #690

The Forest Service should make an effort to remove washboards from road surfaces and consider closing 

roads that have not been used in many years. Reduce edge effects from new road construction by 

establishing harvest units along existing roads.

Response

Removing washboards from specific road surfaces is a site-specific road maintenance issue outside the 

scope of the Revised Forest Plan analysis. However, the Revised Forest Plan provides general Forestwide direction for roads and trails, and in chapter 1 and management areas specific direction in chapter 3, 

all existing roads would remain open under alternatives A, B, D, E, and F. Alternative C would 

decommission approximately 100 miles of roads currently open to the public under the most recent motor 

vehicle use map. The deciding officer will consider the various options along with other comments during 

the decision process.

New road construction is projected at 2 to 4 miles depending on the alternative. The edge effect from new 

road construction will be minor under any alternative.

Public Concern #691

The use of any ATVs should be restricted from use on forest lands as banning their use is an effective way 

to maintain the ecological integrity of the entire ecosystem.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C. The deciding officer will consider the various options along with other comments during 

the decision process.

Public Concern #692

The Forest Service should allow the use of the Pinnacle Butte trail and associated old trail by fourwheeler, hiking, bicycling, etc. to connect two areas that would be a benefit for recreationalists and 

commercial business properties.

Response

The Pinnacle Butte trail will not be open to motorized uses, as that type of use does not conform to the 

enabling legislation that set aside the Dunoir for “non-vehicular” recreation. Most non-motorized forms of 
Shoshone National Forest Land Management Plan Revision

896

recreation are allowed, such as hiking. Bicycle use was analyzed and the deciding officer will consider the 

various options along with other comments during the decision process.

Public Concern #693

The Forest Service should 1-provide an analysis of roads that are open for use in the winter for over-snow 

vehicles; 2 clarify a discrepancy in the total amount of acres that are available for summer motorized 

vehicle use; 3- correct a conflict in roads and trails suitable uses between the 2009 Continental Divide 

National Scenic Trail (CDNST) Comprehensive Plan and Forest Service Manual (FSM 2353.4). Modify 

the direction to be identical to the guidance found in FSM 2353.44b parts 10 and 11; 4- needs to edit the 

wording in the Forest Plan to stat that temporary road construction is not allowed in Inventoried 

Roadless Areas (IRAs) except outside of the IRAs and only when absolutely necessary. The wording used 

in the plan should better reflect the construction and management of new temporary roads as these 

temporary roads will open areas to the potential of increased OHV traffic, which in turn will have an 

impact to wildlife. Temporary roads may also impact the environment from increased erosion and 

sedimentation if the road is not reclaimed quickly. 5- Change the designation to MA 4.3 or 3.5 with a 100 

ft. boundary for all 1981 motorized trails around Kirwin/Franks Peak and Sunlight areas so that they can 

be part of the Travel Management process. 6- Change the designation of the Morrison Jeep trail to MA 

4.3 on its entire route to ensure that its historical usage is kept intact. 7- Add a definition for “Trail: A 

linear route managed for human-powered, stock, or OHV forms of transportation or for historical 

heritage values. Trails are not generally managed for use by four-wheel drive or high clearance vehicles. 

8- On page 105, Roads and Trails – in the first sentence, replace “over 1,127” mile of road with 

“approximately 1,130 miles” of NFS roads on the Shoshone NF as stated on page 461 of the DEIS; 9-

Include a summary discussion and map of foreseeable road construction and reconstruction, by 

alternative, based on revised management area allocations. 10- Design criteria and BMPs should be 

summarized in the FEIS; 11-address the effects of and the cost of subsidized road building.

Response

(1) In all areas across the Shoshone National Forest, over-snow vehicle use is not restricted to designated 

roads and trails, therefore, the effects analysis for this type of use is analyzed by the percentage of the 

Shoshone and location on areas where over-snow vehicle use is allowed. 

(2) There is no discrepancy in the EIS presentation. It identifies the total miles of roads and trails 

available. It indicates the use is only allowed on designated routes. It also identifies the acres of the 

forest that are suitable for establishing motorized routes. It does not say that there will be routes 

established to each acre of the suitable ground. There are also map displays that show what areas that 

are suitable for motorized routes, actually have existing routes. 

(3) The Revised Forest Plan is consistent with both the Comprehensive Management Plan and FSM 

2353.44b parts 10 and 11. Motorized use by the general public is generally prohibited unless that use 

is consistent with the applicable land management plan and is designated in accordance with 36 CFR 

part 212, Subpart B and the vehicle class and use we allowed on that segment of the CDNST was 

constructed as a road prior to November 10, 1978. 

(4) The revised Forest Plan states that road construction in inventoried roadless follows the Roadless 

Area Conservation Rule. Road construction and reconstruction is prohibited except in some very 

limited exceptions. 

(5) Management area boundaries are being looked at between draft and final and are being adjusted 

where appropriate. The deciding officer will consider the various options along with other comments 

during the decision process. 
Final Environmental Impact Statement -- Appendix A

897

(6) In the FEIS, the boundary of MA 3.1C the Sawtooth Peatbed Special Interest Area was adjusted to 

conform to the Morrison Jeep Trail on the northeast. The area adjusted out of MA 3.1C was 

designated 3.3B. 

(7) The revised Forest Plan glossary already has a definition of a trail that meets our needs. A trails is 

defined as “A route 50 inches or less in width or a route over 50 inches wide that is identified and 

managed as a trail.” 

(8) Road mileages will be corrected so that the mileages in the revised Forest Plan and FEIS match. 

(9) Table 117 shows the miles of different roads projected by functional class and by alternative. 

Locations and specifics of new road construction are a site-specific analysis and not part of a broader 

Forest Plan analysis. At the forest plan level, the management area allocations show where future 

construction may or may not be looked at. 

(10) Forest Service regional and national best management practice directives are incorporated by 

reference in the document, and as such, do not need to be summarized. 

(11) We are not aware of any subsidized road building that occurs on the forest.

Public Concern #694

The Forest Service should place signage and pedestrian gates along the north boundary of the Swamp 

Lake Special Interest Area, Chief Joseph Scenic Byway and Beartooth All-American Road to provide 

public access and inform the public of Swamp Lake’s ecological importance

Response

These are site-specific comments and requests appropriate to be considered for future site- specific 

interpretation efforts, and outside the scope of the revised Forest Plan.

Public Concern #695

The Forest Service should ensure that adequate road access is created and allowed for area access when 

issuing mineral leases for subsurface occupancy.

Response

In most cases, management areas allow road construction to the extent allowed by existing laws to honor 

existing rights.

Public Concern #696

The Forest Service should 1- Make all of Rattlesnake Mountain MA 3.5 from the BLM on the east to the 

Wilderness boundary on the north to the private land on the west so that the area can be managed for 

motorized summer and winter use as needed based on snow levers and elk herds. 2- Make all of Carter 

Mountain MA 3.5 from the BLM to the Carter Mountain Summit so that the area can be managed for 

motorized summer and winter use as needed based on snow levers and elk herds. 3- Add to the MA 3.5

description that motorized trail construction, maintenance, and use is allowed even in roadless areas.

Response

(1) and (2) Management area boundaries are being looked at between draft and final and are being 

adjusted where there are no resource concerns. The deciding officer will consider the various options 

along with other comments during the decision process. 

(3) A statement will be added to the roadless section of the revised Forest Plan clarifying that motorized 

trails are allowed in roadless areas per the Roadless Area Conservation Rule.
Shoshone National Forest Land Management Plan Revision

898

Public Concern #697

The Forest Service should maintain all trails and roads in the new plan and an emphasis should be placed 

on creating loops and trail extensions that will accommodate a variety of OHV users. Easily accessible 

and well-maintained trailheads for motorized users and expansion of existing motorized trail systems 

should be specifically mentioned as a goal for the plan. Creation of new roads and trails will help reduce 

the number of illegal roads and trails on the forest. The Forest Service should also re-open some of the 

roads that have been closed in the last 30 years, specifically in the Meeteetse area. Designated 

snowmobile trails should continue to be provided through all existing wildlife existing range areas and 

designated trails should be provided through new areas whenever a new winter range would cut off 

access to open snowmobile areas beyond the newly created winter range. Plans for future summer 

motorized planning should take into account the information provided by the Forest’s summer trail 

rangers. The Forest Service should evaluate and ensure that motorized trail loops are provided and 

available for riders of different abilities.

Response

Site-specific decisions on which roads or trails allow motorized and non-motorized uses is a travel 

management decision and is oustside the scope the revised Forest Plan process. The Plan includes broad 

goals including one to provide a variety of motorized loops for riders of different abilities.

Snowmobiling in winter range was worked out in partnership with the Wyoming Game and Fish 

Department based on crucial winter range coverages. Designated snowmobile trails within crucial winter 

range were kept open.

Public Concern #698

The Forest should examine roads and trails to close any that may threaten the wilderness character of the 

adjoining lands or have impacts on wildlife or have not been in use for many years. The Forest should 

make an effort to close all user-created roads and trails as they impact the natural environment. The 

Forest Service should consider not increasing the number of trails and roads on the forest because of the 

displacement of animal populations away from roads and, increase in human accidents and recreation 

type harassments, and increase in illegal trail offshoots from legal roads. The Forest Service should not 

consider adding new routes when the 1400 miles of roads and trails are not get adequately monitored and 

maintained. The Forest Service should consider not expanding motorized trails until the current system 

can be managed adequately. The Forest should protect aquatic resources from road impacts.

Response

1. The effects analysis under the wilderness section in chapter 3 of the EIS analyzes effects to 

designated wilderness resulting from the various alternatives. This included effects to the recreation 

opportunity spectrum (ROS) of Shoshone National Forest lands from motorized allocations.

2. Various alternatives were analyzed concerning motorized use allocations. These ranged from a high 

of 823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available 

in alternative C and a high of 887,600 acres available for winter motorized in alternative A to a low of 

103,000 acres in alternative C. The deciding officer will consider the various options along with other 

comments during the decision process.

Public Concern #699

The Forest Service should consider encouraging human and animal powered transportation to help 

maintain fields, streams and rivers.
Final Environmental Impact Statement -- Appendix A

899

Response

The Forest Service provides for a multitude of recreational uses, including human- and animal-powered 

types of transportation.

Subject: 2001 - Roads and Trails - Legal and administrative framework

Public Concern #700

The Forest Service should add language to the Roads and Trails section specifying how non- motorized 

trails are to be managed in accordance to the amended 2006 Classification System and the goals for 

Roads and Trails (page 107) should be split into two sections, “roads and motorized trails” and “nonmotorized trails” since there are more trail miles than road miles, but the goals are mostly for motorized 

roads; non-motorized trails need their own goals and objective section so that they are properly address

in the land management plan.

Response

The Forest Service Handbook 2309.18 Trails Management will be added to the other guidance section of 

the revised Forest plan.

We feel trails are properly addressed in the revised Forest Plan with Objectives #2 and #3 and Guidelines 

#1 and #2. In addition, roads and trails management area specific direction is included where needed in 

each specific management area.

Public Concern #904

The Forest Service should provide information on the requirements in the Directive Memorandum and the 

regulations in the Background section of the Plan. This should include explaining that the Forest Service 

is required to complete a science-based analysis to identify unneeded roads for decommissioning or 

conversion to other uses, and future projects and plans with road-related elements will be informed by its 

findings

Response

The direction for those tasks is referenced in the other guidance section under roads and trails. The travel 

management process is also addressed in the management approach section under roads and trails.

Subject: 2004 - Roads and Trails - Desired condition

Public Concern #701

The Forest Service should consider closing 110 miles of open roads.

Response

All existing roads would remain open under alternatives A, B, D, E, F and G. Alternative C would 

decommission approximately 100 miles of roads currently open to the public under the most recent motor 

vehicle use map. The deciding officer will consider the various options along with other comments during 

the decision process.

Overall, our objective is that there are fewer than 1,400 miles of roads with a goal that roads and trails not 

needed for long-term objectives are decommissioned, stabilized, and restored to a more natural state.
Shoshone National Forest Land Management Plan Revision

900

Public Concern #702

The Forest Service should consider making the following changes to the Draft Plan: 1-add “no net loss of 

transportation system infrastructure” as a desired condition; 2-should give direction for future road 

design and maintenance for varying economic conditions; 3-on page 106 should provide direction for 

non-Shoshone National Forest entities to provide physical and financial maintenance of roads to keep 

roads from getting closed; 4-add Mineral discussions in management area sections.

Response

Our objective is that there are fewer than 1,400 miles of roads with a goal that National Forest System 

roads and trails needed for long-term objectives and to meet desired conditions are constructed and 

maintained in a manner that provides for user safety and minimizes impacts to natural resources. How 

that is accomplished, for example with partnerships, is not a forest plan-level decision or discussion. 

Minerals and access and roads needs for that activity are covered under the specific minerals section in 

the revised Forest Plan.

Public Concern #703

The Forest Service should consider adding more roads for people to see the beauty of the forest. The 

Forest Service should not close areas to OHV use without sound determinations since many trails have 

been closed in the northern section of the forest.

Response

See PC #702 and PC #697.

Subject: 2005 - Roads and Trails - Direct and indirect effects include 

general effects

Public Concern #903

The Forest Service should disclose spatial information related to the transportation system, including 

road density data and use the enhanced analysis to inform the final decision and plan components to 

ensure that water, wildlife, and habitats are adequately protected. Information should include where roads 

and trails are distributed within the forest and where and what route densities exist, e.g., do high road 

densities overlapping with important resources such as crucial big game habitat, municipal watersheds, 

etc.?

Response

Secure habitat is used as a surrogate for road density in the EIS analysis. Secure habitat is represented by 

areas that are not near roads. See the discussion under elk in the EIS. Maps are included in the EIS that 

display the location of all existing motorized routes. The EIS analysis for each resource considered the 

impacts from roads as appropriate for that resource.

Subject: 2006 - Roads and Trails - Cumulative effects

Public Concern #704

The Forest Service should consider adding to the DEIS pg. 428 a statement about the effects from the 

appropriate management of National Scenic and Historic Trails and FEIS include a commitment to 

require dust management measures for future projects where such application is deemed necessary to 

reduce impacts, and to add design criteria and Best Management Practices be summarized in the FEIS.
Final Environmental Impact Statement -- Appendix A

901

Response

As outlined in FSM 2353.44b, all projects need to consider impacts to the Continental Divide National 

Scenic Trail (CDNST). Management direction used for establishing measurement indicators revolved 

around direction related to the scenery management system and recreational opportunity spectrum. 

Effects to scenic trails, such as the CDNST, are calculated by identified management objectives related to 

recreational opportunity spectrum and scenic integrity objectives with a 1-mile-wide corridor. Therefore, 

alternatives were analyzed by scenic integrity objectives and recreation opportunity spectrum proposed by 

each alternative, as they relate to the existing CDNST corridor.

Subject: 2021 - Roads and Trails - Desired Condition

Public Concern #705

The Forest Service should consider adding to the Desired Conditions section of the Forest Plan a 

statement the intention is to make the Forest road system as sustainable as possible by maintaining 

needed roads adequately, and reclaiming unneeded roads, including unauthorized roads, especially in 

IRAs and other ecologically important areas. Also state that the minimum road system should reflect long 

term funding expectations, and minimize adverse environmental impacts associated with road 

construction, reconstruction, decommissioning, and maintenance, and not economical and 

environmentally friendliness of temporary roads for work in roadless areas.

Response

We received numerous comments, both positive and negative, on the impacts of roads within roadless 

areas. Our current desired conditions adequately address roads within roadless areas and the revised 

Forest Plan direction follows the Roadless Conservation Rule. See also response to PC #898 regarding 

identifying minimum road system.

Subject: 2022 - Roads and Trails - Goals

Public Concern #706

The Forest Service should consider making the following changes in Goals of the Forest Plan:

1- add a goal that states temporary roads, properly designed and constructed, will afford economically 

and environmentally efficient access to Inventoried Roadless Areas and non- Inventoried Roadless Areas 

suitable timber acres; and 2- Goal 9 should include a statement of how resource impacts will be reduced 

or eliminated.

Response

1. Road construction and reconstruction is prohibited except in some very limited circumstances, so 

adding the suggested goal would not be appropriate. 

2. Goals are broad statements that describe conditions that will contribute to the attainment of desired 

conditions. Goals describe the ends to be achieved rather than the means of doing so.

Subject: 2023 - Roads and Trails - Objectives

Public Concern #83

The Forest Service should consider adding 1-2 new ATV trail loops each year rather than just three over 

the life of the plan to increase summer motorized opportunities and prematurely limit summer motorized 

use.
Shoshone National Forest Land Management Plan Revision

902

Response

An objective in the roads and trails section of the revised Forest Plan states “At least three new wheeled 

motorized trail loop opportunities are available.” This objective is realistic and could occur over the life 

of the plan. The objective does not limit the opportunity to develop additional trails if the opportunity is 

available.

Public Concern #707

The Forest Service should consider making the following changes in Objectives of the Forest Plan: 1-

create a separate section for non-motorized trails; 2-For Item 1 “Maintenance occurs on at least 60%” 

clarify if the objective is to maintain this or change; 3-For Item 2 “Maintenance occurs on at least 15%” 

clarify if the objective is to maintain this or change;4-For Item 3 begin the statement with the number of 

motorized trails in deferred status and then have object suggest that they will lower it so much each year 

and give a time frame; 5- in the trails section make a statement about clearing beetle killed trails both 

down and adjacent but still standing trees; and 6- revise objective 4 to read “All unauthorized routes will 

be closed and rehabilitated as soon as possible.”

Remove the objective that says, “There are fewer than 1,400 miles of National Forest System roads on the 

SNF” and replace it with an objective that says, “The road system on the SNF can be maintained to 

standard under projected revenues.”

Add the following objectives:

* Designate a system of roads and trails for biking, and, once done, disallow off route mechanized travel.

* Routes identified for decommissioning through the Travel Analysis Process or another process will be 

closed, decommissioned and reclaimed to a stable condition as soon as practicable.

Modify objective 5 to say, “Consider adding additional recreational opportunities if sufficient need is 

demonstrated and funding for construction and maintenance is projected.”

Response

(1) The discussion of desired conditions is already broken down between desired conditions for motorized 

trails versus non-motorized trails. Where a distinction is needed in the objectives, goals, standards, 

and guideline, the type of trail has also been identified. 

(2 and 3) The objectives are based upon the total miles at any time. So whether total miles go up or down, 

the indicated percentage of those miles will be maintained. 

(4) The miles of trails needing deferred maintenance changes frequently, thus it is not listed in a forest 

plan as it would even vary between the draft and final documents. That is also why instead of a 

percentage, a specific mileage figure of 10 miles is used. The timeframe is within the life of the 

revised Forest Plan.

The decision maker will consider the public comments regarding additional edits to the objectives in 

making the final decision.

Subject: 2024 - Roads and Trails - Standards

Public Concern #905

The Forest Service should add the following standards to the Roads and Trails section of the Plan:

*Every road and trail has an approved Management Objective.

*Close and rehabilitate temporary roads as soon as they are no longer needed for project purposes;
Final Environmental Impact Statement -- Appendix A

903

*Motorized activity will not occur off a designated system of roads, trails, and areas.

Response

We added a guideline to address unauthorized routes. The decision maker will consider the public 

comments in making the final decision.

See also response to PC #898 regarding travel management analysis.

Subject: 2025 - Roads and Trails - Guidelines

Public Concern #708

The Forest Service should consider making the following changes in Guidelines of the Forest Plan: 1-

Guideline 4 pg. 108 “4. All unauthorized routes will be closed and rehabilitated as soon as possible;” 2-

In the Special Management Areas 1.6A and 1.6B discuss Minerals and Roads and Trails under Standards 

and Guidelines. 3-Reword the guideline under Minerals to say “Any new road constructed under a 

special use permit or for mineral activity must be closed and obliterated at the conclusion of permitted 

activities, unless the road is determined to be needed and and availability for public use is evaluated 

pursuant to NEPA.”; 4-Retitle the subsection “Minerals and Special Uses.”

Response

3. We deleted the word “new.” 

4. Road and trail construction for any purpose is displayed in table 23. Both MA 1.6A and 1.6B do not 

allow road construction. The decision maker will consider the public comments regarding additional 

edits to the guidelines in making the final decision.

Public Concern #906

Add the following guidelines:

*When designating motorized trails and areas, minimize impacts to forest resources and other users.

*Annual progress is made toward achieving a sustainable road system through maintenance, 

decommissioning, and reclamation.

Response

Direction on having a road system that has limited impacts on other resources and is sustainable is 

included in the desired conditions and goals. See also response to PC #898 regarding travel management 

analysis.

Subject: 2050 - Recreation - Resource – General

Public Concern #709

The Forest Service should consider providing more opportunities for commercial guiding of backcountry 

skiing, pack rafting, and mountaineering in more locations and make the process simpler for getting 

permits to help local businesses but should not lead to oversaturation of outfitters, limit size of groups to 

keep experiences enjoyable but not severely impact the land, make changes to the language in guidelines 

for recreation concerning group size, and where recreation demand exceeds capacity or significantly 

changes the recreation experience, alternative management strategies are evaluated and management 

adjusted.

Response

See PC #662.
Shoshone National Forest Land Management Plan Revision

904

Public Concern #710

The Forest Service should consider prioritizing and even expanding recreation since many enjoy the 

forest for a variety of recreational experiences including motorized and backcountry for current and 

future generations and forest should not just be set aside for wildlife and industry and should do so in 

manner that prevents damage to the forest, helps local economies, takes into account future changes in 

amounts of people recreating in forest, and does so in consistency with neighboring lands.

Response

Our desired condition for recreation is to provide a diversity of year-round recreation opportunities that 

attracts increasing numbers of visitors to the Shoshone, thereby providing economic and social benefits to 

local communities.

Public Concern #711

The Forest Service should consider not closing any land to any type of motorized recreation in both 

winter and summer along with closing any types of access including motorized, non- motorized, and 

dispersed camping to allow people to get to see things they otherwise would not be able to.

Response

See PC #693 items 1 and 2.

Public Concern #712

The Forest Service should consider adding more parking by climbing walls, to maintain current bolting 

regulations, not have any restrictions, and not think about liability since climbers know what they are 

getting into.

Response

Addition of infrastructure such as a climbing wall at specific locations is a site-specific decision not 

handled at the forest plan level.

We changed bolting regulations in the revised Forest Plan with the addition of Standard #12 in MA 1.6 

Designated Wilderness. This standard restricts the use of power drills for installing fixed protection, 

including webbing, bolts, or pitons, and practices such as chipping, glue, and epoxy for hand and 

footholds, or use of other fixatives for climbing. We also added Guideline #9, which says that fixed 

anchors are appropriate and allowed where necessary to enable a rappel when no other safe means of 

descent are available, in areas impassable by the use of removable anchors, and in areas where resource 

conflicts do not exist.

Public Concern #713

The Forest Service should discuss the impact of banning pack goat recreation and should be done under 

NEPA requirements.

Response

The impacts of not allowing pack goat recreation are discussed in the species diversity and terrestrial 

wildlife section of chapter 3 in the FEIS.

Public Concern #714

The Forest Service should consider making the following changes to the forest: 1- separate lanes on 

roads for motorized and non-motorized for safety; 2-create some visitor centers for education assets; 3-

make education with recreation a desired condition especially concerning wilderness; 4-inceasing the 
Final Environmental Impact Statement -- Appendix A

905

buffer between camping and water bodies; 5- in the LMP section on recreation replace the word provide 

with evaluate since opportunities needs to be evaluated before provided; 6- add to the alternatives better 

big game habitat information that includes specific protection measures aimed at maintaining function 

and population parameters, reclamation guidelines defined and updated, recreation be considered as 

strong a use, both in terms of economic and social impacts, as other diverse uses on the SNF; 7- create a 

designated ski areas in the Wind River District at the Pinnacles, Deception Creek, Falls Campground and 

Sublette Pass, and the Two Ocean Mountain areas. 8- banning open fires.

Response

(1) Designating the class and mode of travel on a route is a travel management decision outside the scope 

of the revised Forest Plan and will be addressed during a future travel management planning effort. 

 Construction of specific developed recreation sites such as a visitor center is a site-specific analysis 

and not part of a forest plan-level decision. 

 Major issues and educational needs facing designated wilderness areas are addressed in site-specific 

education plans and Information Needs Assessments that are produced for each wilderness area and 

are not a forest plan-level document. Educational and recreational activities are covered in the desired 

conditions through the statement “Forest management strategies support recreational and educational 

activities when in alignment with the preservation of wilderness character.” 

 Guideline #2 sets the distance a campsite should be from lakes or wet meadows to at least 200 feet, 

and 100 feet from streams or creeks. 

 We considered a wording edit. Part of providing opportunities is the initial evaluation of recreation 

opportunity spectrum present. 

 Big game habitat information and protection measures are included in the species of local concern 

section of the revised Forest Plan. 

 The Forest already provides numerous ski areas including one in this general area and at this time is 

not looking to develop additional designated areas. 

 Campfires are a valid part of the camping experience and as such are not planned to be banned under 

normal conditions. Site-specific bans would be looked at based on an identified resource impact or 

severe burning conditions.

Public Concern #715

The Forest Service should consider emphasizing non-motorized recreation to keep the forest wild, have 

solitude, and curb illegal activity.

Response

See PC #691.

Public Concern #716

The Forest Service should view Timber Harvesting as a benefit to recreation.

Response

Timber harvesting can have a beneficial or a negative impact, or both, on recreation depending on the 

timing and type of recreational activity of concern. Impacts of timber management on recreation uses are

discussed in chapter 3 of the EIS.

Public Concern #717

The Forest Service should consider limiting hunting, fishing, and other recreational activities on the 

Forest.
Shoshone National Forest Land Management Plan Revision

906

Response

Recreation is a valid use of National Forest System lands. Any limits of use set would be in a site-specific 

analysis and based on some resource concern not set at a forest plan level. Hunting and fishing are 

administered by the State of Wyoming and are outside the authority of the Forest Service.

Public Concern #718

The Forest Service should consider the following revisions to the Shoshone National Forest plan: 

1) clarifying and describing in detail the outstanding remarkable values (ORV) in order to protect the 

unique values in the LMP. 2) clarifying the description, definition, and design a clear method of use for 

summer use management verses winter use management to decrease the likelihood of resource damage, 

disturbance of wildlife, and conflicts with non-motorized users. 3) The Forest Service should consider 

adding and incorporating the Wyoming Wilderness Act of 1984 into the Shoshone National Forest Plan. 

4) clarifying which areas in the forest should have roaded access with the objectives for multiple use . 

5) analyze the effects of Special Interest areas on recreation and conduct an effects analysis (CEQ 

1502.16 Environmental Consequences).

Response

(1) The Forest’s remarkable values are described in the desired condition for the Forest which indicates 

that “The Shoshone is rugged, remote, and wild. It plays a key role in providing locals and travelers 

an opportunity to connect with nature and experience wildlife. The rich western heritage provides a 

trail based infrastructure into and through the back country and continues to instill a sense of 

adventure and freedom.”

(2) Summer versus winter recreation dates are a site-specific decision made in travel management and 

may change from area to area based on resource concerns. 

(3) The 1984 Wyoming Wilderness Act is listed in the EIS under the Legal and Administrative 

Framework. 

(4) Table 23 in the revised Forest Plan displays which management areas allow motorized vehicles and 

road or motorized trail construction. In addition, the desired condition section for each management 

area discusses motorized access. 

(5) The effects of special interest areas on recreation will be analyzed and added to the FEIS.

Subject: 2051 - Recreation - Legal and administrative framework

Public Concern #719

The Forest Service should make best efforts to keep forest lands fee free.

Response

The question of fees on National Forest System lands is outside of the scope of a forest plan revision.

Public Concern #720

The Forest Service should add Executive Order 13195 to page 475 of the DEIS.

Response

Thank you for your comment. The referenced Executive Order 13195 will be added to the FEIS:

“Executive Order 13195 Transportation Equity Act for the 21st Century (Public Law 105-178) which 

aims to achieve the common goal of better establishing and operating America's national system of trails.”
Final Environmental Impact Statement -- Appendix A

907

Subject: 2052 - Recreation - Methodology

Public Concern #899

The Forest Service should manage for quality recreation. To do this the final LRMP and FEIS must 

accomplish the following:

Identify recreational preferences of user groups in terms of experiences and settings;

Identify physical and biological characteristics that make land suitable for different kinds of 

recreation;

Identify places and settings where visitors can achieve specific experiences, while ensuring protection 

of resources and, in the case of motorized designations, minimizing impacts to forest resources 

and other users18;

Explain how decisions result in quality opportunities for different types of activities;

Use the Recreation Opportunity Spectrum (ROS) to proactively plan for recreation opportunities that 

will maximize social and ecological sustainability as required by the ROS handbook; and

Ensure that management activities do not shift ROS settings.

Response

Chapter 3 of the EIS discusses analysis of recreation resources per current planning direction found at 36 

CFR 219.8 (b)(2) Sustainable recreation; including recreation settings, opportunities, and access; and 

scenic character; and at 36 CFR 219.10(a)(1),10 (b) Requirements for plan components for a new plan or 

plan revision. (1) The plan must include plan components, including standards or guidelines, to provide 

for: (i) Sustainable recreation, including recreation settings, opportunities, and access, and scenic 

character. Recreation opportunities may include non-motorized, motorized, developed, and dispersed 

recreation on land, water, and in the air.

Subject: 2053 - Recreation - Affected environment

Public Concern #721

The Forest Service should add a paragraph to Affected Environment, Transportation System, page 477 of 

the DEIS detailing the significant increase of illegal ORV that have been created since the last Forest 

Plan and how the Forest Service will address these illegal ORV trails and ensure that the area from 

Wiggins Fork through Bear Creek and east to the Wind River Indian Reservation boundary to maintain 

the largest area where no further motorized use should be permitted.

Response

The DEIS addressed the increased use and popularity of off-road vehicle (ORV) use on the Shoshone 

National Forest (motorized use trends page 482). Regarding “illegal ORV use,” the Forest does not have a 

means by which to accurately predict such behavior. Regardless, the Shoshone National Forest plans to 

curb such illegal use through education, signage, and enforcement and by providing quality ORV use 

where management area direction allows for such use.
Shoshone National Forest Land Management Plan Revision

908

Subject: 2054 - Recreation - Desired condition

Public Concern #722

The Forest Service should consider increasing access to the forest as deemed necessary especially access 

to the Beaver Creek Ski area as use has increased and current parking is dangerous and create a Middle 

Fork trail bypass for safer equestrian use.

Response

Access to a specific ski area or construction of a specific trail, or both, are project-level analysis and 

decisions are not within the scope of the revised Forest Plan analysis.

Public Concern #723

The Forest Service should not mark any trails, restrict motorized recreation and travel to preserve the 

wilderness state by providing non-motorized recreational uses.

Response

See response to PC #698 (item 2).

Public Concern #724

The Forest Service should clarify the desired conditions for recreation that state,“...―partnerships are a 

significant tool to help provide public use and year round recreation alternatives” as it currently appears 

to be a statement and should ask, “Would the forest service like to increase partnerships? Would they just 

like to maintain current partnerships? Where partnerships analyzed in the DEIS? How are the different in 

preferred alternative?” For the Land Management Plan, under Recreation uses and opportunities, 

Resource condition and trend on page 10, “wildlife viewing” should be added to the list of most popular 

activities and under Need for change on page 10, “Management practices should anticipate the impacts 

of continued increases in recreational use, recognizing that there is a point at which increased use begins 

to have significant, negative impacts on the total Forest resources.” should be added and under 

Projection of demand and need, page 10, “The intent of this plan is to achieve a balance with current 

uses and currently demanded uses, without future detriment to the resources of the Forest.”

Response

The use of partnerships to provide recreational opportunities is a desired condition whether it is 

maintaining existing partnerships or developing new ones. A forest plan does not get into that level of 

detail. Partnerships are not analyzed across the alternatives because they are a way we could possibly get 

work done not what we plan to do for work like new motorized trails opportunities.

The list referenced is not a list of every popular activity on the Forest but just a selected list of “some” of 

the popular activities.

Generally, we don’t anticipate a significant jump in recreation demand such that wide-scale negative 

impacts on the total Forest resources is foreseeable, thus, the current wording in the recreation need for 

change and projection of demand are acceptable.

Public Concern #725

The Forest Service should designate Two Ocean Mountain and Sublette Pass area as winter nonmotorized as the area is easily accessible for winter non-motorized recreation and the presence of 

snowmobiles poses a safety risk and that Beartooth Pass have snowmobile use restricted after the 

Beartooth Highway is open for motorized wheeled vehicle traffic for safety reasons between motorized 
Final Environmental Impact Statement -- Appendix A

909

and non-motorized winter use. The forest should also consider providing non-motorized recreation 

opportunities near Lander as it will provide easy access to the wilderness.

Response

In the various alternatives, two options for the Two Ocean area were analyzed. Alternatives A, B, E, F and 

G would kept this area open to all uses, and alternatives, C and D would close the area to winter 

motorized use. The deciding officer will consider the various options along with other comments during 

the decision process.

Closure of the Beartooth Plateau to snowmobiles once the road is open for wheeled traffic is a sitespecific travel management decision and not a forest plan decision.

Various alternatives for winter non-motorized use (MA 3.3C) were analyzed from a low of 4,563 acres in 

alternative F to a maximum of 98,030 acres in alternative E. The deciding officer will consider the various 

options along with other comments during the decision process. 

Subject: 2055 - Recreation - Direct and indirect effects

Public Concern #726

The Forest Service should consider that snowmobiles have less impact on the forest compared to other 

non-motorized means of travel.

Response

All types of recreation uses may have impacts other resources (i.e., cultural, terrestrial wildlife, botanical, 

economic, or recreational) and the effects analysis for recreational uses, including snowmobiling are 

identified in chapter 3 of the EIS.

Public Concern #727

The Forest Service should recognize the effects of pay avoidance and how RV and ATV campers have 

created a level of resource damage, primarily to soils and vegetation.

Response

Both developed (fee sites) and dispersed recreation (no-fee sites) are valid uses of the Shoshone National 

Forest. Effects to vegetation and soils from dispersed recreation are covered in the botanical and soils 

sections of chapter 3 of the EIS.

Public Concern #728

The Forest Service should consider making the following changes to the DEIS: (1) On page 412, Effects 

from Recreation, 3rd paragraph: add language to address potential impacts of adding fencing to manage 

livestock on wildlife. (2) On page 489-Recreation-Environmental Consequences, General Effects the 

forest should change the language in the statement, '“In general, alternatives that increase levels of nonmotorized recreational opportunities will generally increase the quality and quantity of non-motorized, 

recreation” since an increase in quantity does not automatically mean the quality of non-motorized 

recreation will also increase.

Response

(1) The section referenced addresses the effects of recreation on grazing activities and does not pertain to 

effects on wildlife from grazing activities such as fencing, see wildlife analysis section.
Shoshone National Forest Land Management Plan Revision

910

(2) The term “In general” is used so that the reader does not get the impression that this will always be 

the case, therefore the language will not change in the FEIS. The general discussion is to convey 

when more opportunities are present, use may be spread over different areas allowing individuals 

seeking non-motorized recreation opportunities in more areas with reduced use.

Subject: 2058 - Recreation - Incomplete and unavailable information

Public Concern #729

The Forest Service should consider the following changes in over-snow vehicle use in the Land 

Management Plan: (1) Page 492-Travel Management- Over-snow Vehicle Use, correct the general 

conclusion to include that that dispersed snowmobiling occurs across the forest wherever there is 

sufficient snowfall and is not just where authorized. (2) The Land Management Plan should be revised 

and the DEIS should show justification as to why there is such a drastic policy shift in acres between 

Alternatives A and B of motorized use areas and how they are effected by no longer allowing over-snow 

travel in backcountry motorized areas.

Response

(1) We will clarify the wording in the revised Forest Plan to state where snowmobiling is allowed.

(2) The 1986 Forest Plan generally allowed over-snow motorized vehicle use in management areas 

allocated to non-motorized recreation, including the Dunoir Special Management Unit (MA 1.6B). 

Only summer motorized use was specifically restricted in these areas. Though current plan allocation 

permits the use, over-snow motorized vehicle use is not occurring in all acres that are open to that use 

under the 1986 Forest Plan.

Subject: 2059 - Recreation - Monitoring

Public Concern #730

The Forest Service should monitor ATV usage by whatever means to determine what is actually needed 

and build a plan from the data, not through public opinion and make the best effort to reduce illegal offroad and off-trail usage.

Response

All-terrain vehicle (ATV) use is monitored through both trends in ORV registrations and what field-going 

ORV rangers observe during their patrols. The Shoshone National Forest plans to curb illegal use through 

education, signage, and enforcement and by providing quality ORV use where management area direction 

allows for such use.

Subject: 2060 - Recreation - OHV 

Public Concern #731

The Forest Service should consider not adding any more motorized trails or expanding OHV use on the 

forest in roadless areas (23 miles of new ORV trails and 3 loop trails) because of violations of the off road 

policy, riding in closed areas, and the damage to fragile alpine areas. The Forest Service should consider

the impact of OHV’s on the river drainages such as Sunlight, Dead Indian, Elk Creek, Beem Gulch, Huff 

Gulch, Gravel bar, Company Creek, Trail Creek, Lodgepole Creek, Crandall because of the uniqueness of 

the areas and damage to critical wildlife habitat. The Forest Service should consider the impact of OHV’s 

on Grizzly bear habitat and human/bear conflicts. The Forest Service should consider habitat 

effectiveness (HE) and habitat security (HS) analyses prior to the addition of loop trails or additional 

motorized access because loop trails and increased motorized use will negatively impact wildlife.
Final Environmental Impact Statement -- Appendix A

911

Response

(1) See response to PC #698 (item 2).

(2 and 3) Chapter 3 of the DEIS discloses the effects of each alternative by resource area. This includes 

recreational impacts to the following resources on the Shoshone National Forest; wildlife, riparian 

areas, aquatic species and water resources.

Public Concern #732

The Forest Service should consider reopening cultural and historic OHV trails and roads that have been 

closed in past years because no funding or forest service labor will be required to reopen the trails to 

motorized use. The Forest Service should consider keeping current OHV areas open in the Beartooth 

areas because so many areas are being closed to OHVs. The Forest Service should not remove any 

motorized access from the Shoshone National Forest because of the economic benefits and boosts to local 

communities hunting access, and 80% of the forest is currently closed to OHV’s. The Forest Service 

should consider keeping and expanding motorized access to the forest open because it would limit use by 

elderly and handicapped. The Forest Service should consider designating many of the existing jeep roads 

as Jeep-OHV-Motorcycle trails to concentrate the motorized use on the forest. The Forest Service should 

consider adding additional connecting trails and loop trails to the ATV trails system in the Dubois area.

Response

See response to PC #698 (item 2).

Public Concern #733

The Forest Service should consider reducing and limiting the use of motorized vehicles in the Shoshone 

National Forest because of noise and pollution and to preserve the wilderness quality. The Forest Service 

should consider the impact of OHV’s on the environment in their analysis because of increased 

technology; distance covered and speed of OHV’s and the increased damage to roadless areas. The Forest 

Service should consider the safety and user conflict between motorized and non-motorized users. The 

Forest Service should consider increased signage and regulation of OHV’s and OHV riders riding 

illegally to increase safety of the trails, limit resource damage, to prevent trespass on private property, 

and from encroaching on hiking only trails. The Forest Service should consider no OHV use in areas

adjacent to Yellow Stone Park to maintain the integrity of the Yellowstone Ecosystem. The Forest Service 

should consider no 4-wheeler use by hunters. The Forest Service should consider increased protection of 

inventories roadless areas (Fitzpatrick Wilderness Area and Popo Agie Wilderness Area) from 

encroaching motorized use.

Response

The Forest Service is tasked with providing quality recreational opportunities for the growing diversity of 

activities managed on National Forest System lands. As mentioned in the recreation section of chapter 3 

of the EIS, “Recreational use trends on the Shoshone have been affected by the increasing population in 

adjacent communities and changes in technology related to recreational activities.” Regardless, the 

Shoshone National Forest strives to provide safe, legal recreational opportunities through education, 

signage, and enforcement, and therefore, providing quality OHV opportunities where management area 

direction allows for such use.

Public Concern #734

The Forest Service should consider and apply the travel management plan and the roadless rule to define 

if areas are suitable for motorized use and motorized trail construction by monitoring current use and 

level of use on trails. The Forest Service should consider utilizing existing motorized trails and creating 
Shoshone National Forest Land Management Plan Revision

912

connections with existing roads to of the improve backcountry experience for OHV users. The Forest 

Service should consider the historical use of trails designated for motorized vehicles which were closed in 

1981 and referenced in the Shoshone National Forest Travel Maps (Map H: area 1, Map K: area 2, Map 

M: Sunlight Basin). The Forest Service should consider and identify the activities that are popular with 

OHV enthusiast in the development of the travel plan. The Forest Service should consider a proactive and 

balanced approach in creating an objective in the plan of a baseline inventory of user-created trails and 

monitoring the progress toward elimination of the those trails. The Forest Service should consider using

tools and resources available to forest planners such as Blue Ribbon Coalition, National Off-Highway 

Conservation Council and Americans for Responsible Recreation Access to in the trail system planning 

effort to provide quantity, quality, maintainable, and enough diversity and challenge to satisfy the OHV 

user.

Response

We considered roadless areas designation during the allocation process to different management areas. 

The conversion of existing trails from non-motorized to motorized or completing an inventory of nonsystem routes, or both, are travel management decisions or a project, and as such, beyond the scope of the 

revised Forest Plan analysis.

Use of different resources and tools during trail construction will be addressed in a site-specific analyses 

and implementation.

Public Concern #735

The Forest Service should consider the unsubstantiated impacts and the conflicts in science on OHV use 

because of the misconceptions associated with OHV recreation and resource damage to wildlife, soil 

erosion and sedimentation in streams, vegetation, invasive plants, and noxious weeds.

Response

The Forest Service strives to use the best available science in determining impacts and conflicts 

associated with OHV use. Chapter 3 of the EIS discloses these impacts and conflicts associated with OHV 

use.

Subject: 2061 - Recreation - Snowmobile

Public Concern #736

The Forest Service should consider not adding any more wilderness areas and keeping the High Lakes 

Wilderness Study area in the Beartoooths, the area just above Lava Mountain Lodge or the adjoining 

subdivision in the Wind River Valley, the Two Oceans Peak and the Togwotee Pass area open for winter 

motorized recreation, and multiple uses as outlined in Alternative B, with possibly setting an area aside as 

non-motorized for skiers and snowmobilers. Snowmobilers provide economic benefits to the area and are 

already prevented from using 80% of the Shoshone National Forest. The Forest Service should consider 

continuing snowmobile use in all Inventoried Roadless Areas, and multiple use areas. The Forest Service 

should consider continuing snowmobile use in all existing wildlife winter range and in new winter range 

areas if it would cut off access to open snowmobiling areas.

The Forest Service should consider continuing off-trail cross country snowmobiling where it is currently 

permitted.

Response

Thirty-four areas on the Shoshone were evaluated for potential wilderness. Various alternatives were 

analyzed including recommended wilderness ranging from 628,800 acres in alternative C to 194,500
Final Environmental Impact Statement -- Appendix A

913

acres in alternative D to 0 acres in alternative B. The deciding officer will consider the various options 

along with other comments during the decision process.

Various alternatives where analyzed concerning motorized winter use allocations. These ranged from a 

high of 887,600 acres available for winter motorized in alternative A to a low of 103,000 acres in 

alternative C. The deciding officer will consider the various options along with other comments during 

the decision process.

Just because an area is an inventoried roadless area does not mean snowmobile use is restricted. Typically, 

the only reason snowmobile use is restricted is because of critical winter range or some other resource 

issue.

Existing snowmobile trails through winter range remain in all alternatives.

Different off-trail snowmobiling opportunities were analyzed under the winter motorized

Public Concern #737

The Forest Service should consider the environmental impacts of winter motorized use to air quality and 

watershed that provides drinking water from the snowpack. The Forest Service should consider 

prohibiting snowmobile use in winter ranges, big game migration corridors, lynx habitat and potential 

wolverine habitat because of the increased motorized vehicles in wilderness study areas causing 

mortality, habitat loss and harassment of wildlife. The Forest Service should consider prohibiting 

snowmobile use in areas abutting Yellowstone National Park.

Response

Chapter 3 of the EIS discloses the effects of each alternative by resource area. This includes recreational 

impacts to wildlife, watersheds, and air, as well as other resources on the Shoshone National Forest. The 

soil and water analyses considered the overall effects of activities on soil and water. The air quality 

analysis considered the overall carbon emissions from activities on the forest. The deciding officer will 

consider the various options along with other comments during the decision process

Public Concern #738

The Forest Service should consider increasing areas devoted to human powered snow sports and 

decreasing motorized use in the forest. The Forest Service should consider closing the Togwotee Pass and 

Two Oceans Peak to snowmobiles because of the safety hazard, the conflict of multiple uses, and the 

destruction of the terrain and solitude for skiing and snowboarding. There are very few back country 

areas unimpeded by snowmobile traffic.

Response

See PC #736 second paragraph and PC #725 first paragraph.

Public Concern #739

The Forest Service should consider reducing the impact of wilderness trespass by over snow vehicles by 

providing winter trail maps that display the location of winter trails and trailheads in relation to 

wilderness boundaries and increasing signage along highways adjacent to designated wilderness. The 

Forest Service should consider increasing law enforcement patrols in wilderness trespass areas. The 

Forest Service should consider confining motorized use to current designated trails and areas. The Forest 

Service should consider having Game and Fish authorize snowmobile use.
Shoshone National Forest Land Management Plan Revision

914

Response

The discussion of providing trail maps, signing, and increasing law enforcement patrols are not forest 

plan issues. Trail maps are available that show the requested information and signing is provided at choke 

points.

Different alternatives to motorized use for both summer and winter were analyzed and considered. See 

PC # 698 item 2.

Public Concern #740

The Forest Service should consider and clarify in their analysis that conflicting science has shown the 

effects on wildlife from snowmobiles are minor. The Forest Service should consider clarifying and 

providing scientific support for winter motorized activities that compaction from snowmobiles harden the 

snow that may alter spring runoff patterns resulting in soil erosion and gullies.

Response

The effect of winter motorized activity on wildlife varies depending upon the particular wildlife species 

being addressed. The effects of winter motorized use are addressed by species throughout the species 

diversity section in the EIS page 140.

Winter motorized activities have relatively low potential to adversely affect water and soil resources. 

Damage to vegetation and soil erosion can occur if there is inadequate snowpack to protect these 

resources. The Forest Service Handbook 2509.25, Watershed Conservation Practices Handbook (Region 

2) specifies management measures for protecting soil and water resources.

Public Concern #741

The Forest Service should consider clarifying the capability assessment and its use in the analysis 

because motorized use in the wilderness areas is prohibited and whatever opportunity a given area offers 

for snowmobiling is irrelevant to its wilderness qualities and potential.

Response

In 2008 (edited 2012), 34 areas on the Shoshone were evaluated for potential wilderness. This process 

included three tests—capability, availability, and need. Capability is defined as the degree to which the 

area contains the basic characteristics that make it suitable for wilderness designation without regard to its 

availability for or need as wilderness. This evaluation was completed for areas that are currently not 

designated wilderness and may allow snowmobiling.

Public Concern #742

(1) The Forest Service should consider revising the statement on Page 7 under the “Recreation Uses and 

Opportunities” section of the DEIS from “Existing opportunities for motorized use on snowmobile trails, 

motorized trails, and roads will continue.” to document and clarify that off- trail snowmobiling will also 

be allowed to continue on the Shoshone National Forest.

(2) The Forest Service should consider revising the statement on Page 8 under the “Recreation Uses and 

Opportunities” section of the DEIS from “Proposed research natural areas and special interest areas 

preclude future expansion of motorized use in those areas. All existing uses in those areas can remain, 

including continued use of the Morrison Jeep Trail that passes through the Sawtooth Peatbed Geologic 

Area.” to add an additional statement clarifying that “off-trail snowmobiling would not be eliminated by 

creation of the proposed Beartooth Butte RNA”.
Final Environmental Impact Statement -- Appendix A

915

(3) The Forest Service should consider revising the DEIS on page 33 and 34 to update the management 

areas in roadless areas to management areas that allow winter motorized use and maintain historic areas 

used by snowmobiles because the statement “New summer motorized trails allowed in some inventoried 

roadless areas with existing winter motorized use are retained.” conflicts with inventoried roadless areas 

having management areas that do not allow winter motorized use.

(4) The Forest Service should revise and clarify the discrepancy in the number of snowmobile trails 

between the various section s of the EIS and plan (page 478 and 492). 5) The Forest Service should 

consider the amount of dispersed snowmobiling in its analysis of projected and existing snowmobile trails 

(Table 137).

Response

(1-3) The changes were not made. The EIS includes alternatives that analyze different allocations that 

vary in what areas are open or closed to motorized activity. Some of the alternatives are consistent 

with these comments and some are consistent with comments made by others. The decision maker 

will consider these comments along with those of others in selecting a final allocation on where 

motorized activity is suitable.

(4) The difference between tables on pages 478 and 492 in chapter 3 of the EIS is due to table 123 on 

page 478 summarizing miles of system trails whereas table 136 summarizes miles of system roads.

(5) Table 137 shows the total miles of existing and projected trails open to over-snow vehicle use. This 

table and the discussion to follow on pages 492 and 493 of the EIS are used for a comparative 

analysis for snowmobile recreational opportunities across all alternatives.

Subject: 2062 - Recreation - Bicycle

Public Concern #743

The Forest Service should consider keeping the Dunoir and Togwotee Pass area open to mountain bikers 

for summer recreation opportunities on the Pinnacle Butte Trail because it is one of the few wilderness 

settings open to mountain bikes to enjoy the scenic beauty and wildness, mountain bikes do not leave a 

permanent trace on the forest, and because of the significant economic benefits to the local community. 

The Forest Service should consider hosting some volunteer trail maintenance days on the Pinnacle Butte 

Trail.

Response

See PC #692.

Public Concern #744

The Forest Service should consider closing the Pinnacles and Buffalo Plateau region to mountain bikers 

because of the damage to the fragile alpine region and safety issues with other users. Mountain bikers 

should not be an exception to the wilderness rule. The Forest Service should consider prohibiting 

mountain bikes in the Line Creek Plateau Research Natural area, on trails 628 and 761 within the Wild 

and Scenic River corridor, and in the lesser known roadless areas.

Response

See PC #692.

Mountain bikes are allowed in the Line Creek Research Natural Area (RNA) on existing trails and as 

restricted, do not pose a threat to the RNA resources.
Shoshone National Forest Land Management Plan Revision

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Mountain bikes are a valid and acceptable use in both the Clarks Fork Wild and Scenic River corridor and 

roadless areas and that use will continue to be allowed in the revised Forest Plan.

Public Concern #745

The Forest Service should consider maintaining and expanding all back country recreational 

opportunities for mountain bikers. The Forest Service should consider engaging in a forest- wide trail 

system planning effort to expand recreational opportunities for mountain biking. The Forest Service 

should consider the following areas for mountain bike trails: south and west of the Chief Joseph Highway 

summit, Sunlight Basin, Beartooth Mountain, Rattlesnake Mountain, Backwater, Elk Fork, Sweetwater 

Drainage, North Fork of Shoshone River, Pahaska Tepee – Sleeping Giant Area, Carter Mountain Area, 

and the Bobcat and Houlihan Trails in the Aldrich Creek Area.

Response

Mountain bike use is allowed in most areas of the Forest outside of designated wilderness and the Dunoir 

(table 23 of the revised Forest Plan). Considering specific areas for mountain bike trails is a site-specific 

analysis that is not at a forest plan level and was not analyzed in the revised Forest Plan.

Public Concern #746

The Forest Service should consider not adding mountain bike use on current hiking only trails, and 

require that mountain bikes stay on a designated system road, trail, or area.

Response

The decision to change allowed uses on specific trails is a site-specific analysis, more appropriately 

addressed under the future travel management analysis, and outside the scope of the revised Forest Plan 

analysis.

Public Concern #747

The Forest Service should consider clarifying and not applying the definition of bicycles from within 36 

CFR 261.2 to the legislative command of the 1972 Act for the Dunoir Special Management Area, or other 

areas recommended for wilderness designation. “Vehicle” and the application of that definition to 

exclude bicycles do not support the Congressional intent.

Response

The term vehicle is adequately defined in 36 CFR 261.2. How this definition pertains to the Dunoir and 

the legislative intent in the enabling legislation is still open to some interpretation. Various options for 

bicycle or vehicle use within the Dunoir were considered and analyzed. Alternatives C and D include 

recommending areas for wilderness designation. Alternative A, B, E, F, and G do not include 

recommendations for wilderness designation. The deciding officer will consider the various options along 

with other comments during the decision process.

Subject: 2063 - Recreation - Noise Pollution

Public Concern #748

The Forest Service should consider increasing the analysis in the plan Alternatives and to address the 

impacts and levels of noise pollution on wilderness and front country because well- established 

techniques exist to quantify and map sound impacts. The Forest Service should consider the impact that 

motorized vehicles, mineral development, and engine noises have on the ecosystem, wildlife, winter 

range, local breeding bird populations, and the virtues of the remote recreation experience.
Final Environmental Impact Statement -- Appendix A

917

Response

When considering effects to existing wilderness management of recreation opportunity spectrum 

objectives play a role. Analysis of these objectives across the alternatives allows for identifying varying 

degrees of recreation development that correspond with varying degrees of noise pollution. The more 

acres devoted to more developed recreation opportunity spectrum settings, the higher likelihood of 

negative effects to existing wilderness. Conversely, the fewer acres devoted to more developed recreation 

opportunity spectrum settings, the lower the likelihood of negative effects to existing wilderness. 

Comparative analysis of the differences in the total acres of the recreation opportunity spectrum settings 

immediately adjacent to the wilderness boundary is used to compare alternatives. Finally, chapter 3 of the 

EIS discloses the effects of each alternative by resource area. This includes recreational impacts to the 

following resources on the Shoshone National Forest; recreation, wildlife, riparian areas, aquatic species, 

and water resources.

Subject: 2064 - Recreation - Trails

Public Concern #749

The Forest Service should consider not adding any new trails in areas already off-limits to motorized 

vehicles. The Forest Service should consider adding no new trails for motorized vehicles because of the 

financial burden of building and maintaining new motorized trails.

Response

See PC #691.

Public Concern #750

The Forest Service should consider increasing maintenance of non-motorized trails to protect water 

quality and resource damage. The Forest Service should consider recruiting volunteers to assist with trail 

maintenance and use monitoring.

Response

Our goal is to do maintenance on at least 15 percent of our trails annually. We feel this is an achievable 

goal based on past and projected budgets. We welcome volunteer partnerships. Currently, we have 

volunteers such as the Shoshone Backcountry Horsemen helping with trail maintenance.

Public Concern #751

The Forest Service should consider adapting a policy that considers each user-created trail as a 

candidate for inclusion in the trail system. User developed trails provide access to many popular 

climbing, and paddling destinations. They are the result of an unmet need. The Forest Service should 

consider adapting a “Hub and Spoke” network to include user developed trails. The Forest Service 

should consider creating a proactive plan to eliminate user created, unauthorized routes because of the 

resource damage to watersheds, wildlife habitat, soil erosion and the diminished trail maintenance 

funding. The Forest Service should consider adding a trail goal that creates multiple use non-motorized 

day use loop trails designed for hikers because the Shoshone National Forest has a very limited number 

of day use trails. Creation of more day use trails would increase the use of the forest by local users.

Response

Inclusion of any user-created routes into the system is considered on a case-by-case basis and a sitespecific travel management decision, and is outside the scope of the revised Forest Plan process.
Shoshone National Forest Land Management Plan Revision

918

Guideline #4 under the roads and trails section provides that “New unauthorized routes should be closed 

and rehabilitated as soon as practicable.”

Our intent for loop trails is covered under the trails desired condition which states “High quality loop 

trails exist for both motorized and nonmotorized recreation.”

Public Concern #752

The Forest Service should consider providing cross country skiing not adjacent to snow mobile areas and 

designated ski trail maintenance, to include widened track by tree removal and protection from wayward 

snowmobile use.

Response

Various alternatives were analyzed concerning motorized use allocations. These ranged from a high of 

823,900 acres available for summer motorized in alternative F to a low of 322,400 acres available in 

alternative C. The deciding officer will consider the various options along with other comments during 

the decision process.

Currently, not all ski areas are closed to snowmobile use. The issue of closing cross-country ski areas to 

snowmobiles is a travel management decision and is outside the scope of the revised Forest Plan. The 

issues of tree removal, maintenance, and law enforcement at existing ski areas are not forest plan issues 

and are not addressed in the revised Forest Plan.

Public Concern #753

The Forest Service should consider prohibiting access to areas currently 0ff-limits to motorized vehicles 

and closing motorized trails in sensitive wildlife areas.

Response

See PC #698 item 2 and PC #697 second paragraph.

Public Concern #754

The Forest Service should consider clarifying and correcting the inconsistencies in the trail mileages on 

page 478. The numbers in the EIS are inconsistent with the total trail miles presented in the draft LMP. 

The miles in the LMP does not include the summer motorized trail miles and the EIS dos not include the 

single track motorized (motorcycle) miles.

Response

There was an inconsistency between trail mileages in the draft forest plan and those identified in the 

DEIS. This inconsistency has been corrected in the revised Forest Plan and the FEIS.

Public Concern #818

The Forest Service should consider leaving historically used trails and roads open for ATV use since 

many have closed recently.

Response

Alternative F in the EIS allocates large portions of the forest to management areas that allow motorized 

access including areas that allowed such access prior to the existing forest plan. The decision maker will 

consider those public comments for keeping these areas open along with comments of others who would 

like the areas closed in making the final decision.
Final Environmental Impact Statement -- Appendix A

919

Subject: 2081 - Recreation - Desired Condition

Public Concern #755

The Forest Service should consider addressing and clarifying the proposed language for Management 

Area 3.3A – Back country recreation year-round motorized because there are several contradictions and 

misstatements: under desired conditions revise the language to promoting motorized recreation and given 

a clear and distinct preference across the board over non-motorized uses in all 3.3A managed areas.

Response

The order of motorized or non-motorized will be changed to highlight our preference. The preference for 

motorized is also highlighted in Goal #1 which is to “Provide year round motorized recreation 

opportunities” and Goal #2 which states “Increase diversity of motorized experiences.”

Public Concern #756

The Forest Service should consider addressing and clarifying “Recreation Uses and Opportunities” on 

page 7 and 8 to add that off-trail snowmobiling will also be allowed to continue in the Beartooth Butte 

RNA including use of the Morrison Jeep trail and through the Sawtooth Peatbed Geologic Area.

Response

Both of these are addressed in table 23, which lists the management areas and what motorized and 

mechanized use is allowed.

Subject: 2082 - Recreation - Goals

Public Concern #757

The Forest Service should consider addressing and clarifying the recreation goals to include:

1) how and why the preferred alternative supports the recreation goal of increasing tourism, complete an 

analysis on public benefit effects of increased and decreased motorized recreation across all alternatives, 

and add “while not compromising the integrity of important wildlife habitats to Goal 1 on page 90; 2) 

adding an additional goal to those stated on page 90 to retain all existing dispersed camping sites unless 

environmental degradation is occurring; 3) revise recreation goal 2 on page 174 to include implementing 

the direction in the 2009 CDNST Comprehensive Plan Chapter III €, and FSM 2353.42 and 2353.44(b) 

part 1 following the supportive direction that is found in parts 7 through 11and to identify the CDNST 

Comprehensive Plan as an Other Authority (FSM 2353.01d); 4) revising the goals stated for Management 

area 3.3A to focus solely on motorized preference to enhance attainability of the goal and to address 

safety concerns by removing non-motorized use.

Response

(1) How a selected alternative supports the goals in a forest plan is unknown until specific projects are 

implemented associated with the plan. The environmental effects of the different motorized 

alternatives were identified in the EIS effects analysis for recreation. The economic effects were 

analyzed and are disclosed starting on page 576 of the EIS.

(2) Decisions to close or keep a dispersed campsite locations open are site-specific decisions, and as 

such, a goal to keep all of them open is not included in a forest plan-type document.

(3) Page 174 included guidelines for recreation. Guideline #2 is consistent with the CDNST 

Comprehensive Management Plan and FSM 2353.42 and 2353.44 as written.

(4) See PC #755. In addition, while motorized use is the primary driver of MA 3.3, non-motorized use is 

also allowed and there is no safety concern with mixing the uses in this management area.
Shoshone National Forest Land Management Plan Revision

920

Subject: 2083 - Recreation - Objectives

Public Concern #900

The Forest Service should carefully assess recreational use data and design a recreational strategy that is 

responsive to user trends and preferences to the degree possible within the capacity of the land, and is 

affordable under projected revenues, before committing to build three motorized loop trails.

Focus plan components more on providing quality recreation to visitors, maintaining to standard the 

associated infrastructure, and ensuring positive experiences. For instance, consider including a plan 

component that says that the SNF will complete a Recreation Strategy informed by best available data 

that will drive recreation program priorities including maintenance, enforcement, construction, and 

monitoring through the plan life.

Response

The objective for additional loop trails would apply to areas that are suitable for such trails. Any specific 

development would be consistent with other plan direction to protect forest resources and other recreation 

opportunities. Before any new loop trail is established, a project-level environmental analysis would be 

conducted to ensure consistency with plan direction.

Subject: 2084 - Recreation - Standards

Public Concern #758

The Forest Service should consider addressing and clarifying the recreation standards to include: 1) 

adding a definition of “party” (in the terms of recreation) to glossary table 18 on page 91 and to clarify 

how the group size decision would be made and if the decision is subject to NEPA; 2). clarifying the 

recreation standards on page 173 because it is inconsistent with the comprehensive plan and policy and 

does not address the direction in FSM 2352.44(b)(1); 3) revising the standards to include stronger 

management protection standards and reduce motorized recreation in some sensitive backcountry areas 

because they are not reflected in Alternative B. and 4) revising the standards on page 90 to include a 

second quantifiable standard addressing the maintenance of habitat integrity through the use of HE/HS 

analyses and thresholds.

Response

(1) A definition of party associated with these standards has been added to the glossary. Any decision to 

change group size limits is a site-specific decision that would be analyzed separately.

(2) The proposed standards and guidelines are consistent with the CDNST Comprehensive Management 

Plan (CRMP). For example the CRMP requires, where possible, that the CDNST is located in 

primitive or a semi-primitive non-motorized recreation opportunity spectrum setting, but allows 

others if it is not possible. Direction in FSM 2353.(b)(1) requires a forest in a land management plan 

to establish a management area for the CDNST broad enough to protect it (the plan established MA 

3.6A, which includes a corridor within 0.50 mile of centerline of the trail); prescribe desired 

conditions, objectives, standards, and guidelines (the revised Forest Plan establishes these); and 

establish a monitoring program (the plan discusses monitoring requirements).

(3) Without know what “sensitive backcountry areas” being referred to, this question is difficult to 

address. We believe that we addressed needed standards and guidelines for motorized use and 

analyzed a variety of options for the deciding officer to choose from.

(4) Habitat effectiveness (HE) and habitat suitability (HS) standards are addressed in table 11 and the 

associated HE/HS standards and guidelines under the wildlife section in the revised Forest Plan.
Final Environmental Impact Statement -- Appendix A

921

Subject: 2085 - Recreation - Guidelines

Public Concern #759

The Forest Service should consider making the following changes to Recreation Guidelines: 1- under 

Management Area 2.2A, correct Guideline 14 to ensure motorized recreation opportunities in the winter 

are specifically included in the final plan; 2-under Management Area

2.3 please clarify in Guideline 5 where it states “Over-snow motorized use is allowed in areas currently 

open to such use” since it is inconsistent with RNA language which states non- motorized and Beartooth 

Butte RNA is in alternatives B, C, D which is popular snowmobile

area; 3-under Management Area 3.3A Guideline 2 states ”Some trails may be restricted to nonmotorized use” we object to this since this goes against MA 3.3A direction that should be for true 

motorized use areas and thus should be removed.

Response

(1) Limited winter motorized opportunities are included and authorized in management area 2.2A per 

direction in the desired condition section, stating the area provides a non-motorized recreational 

opportunity in the summer and motorized and non-motorized recreation opportunities in the winter. In 

addition, table 23 clarifies where winter motorized is suitable and authorized. A variety of winter 

motorized opportunities were analyzed. See PC #698 (item 2).

(2) Table 23 clarifies where winter motorized use is suitable and authorized.

(3) Guideline #2 is consistent with MA 3.3A direction. Although a management area emphasis may be 

motorized like MA 3.3A is, there may be locations where incompatible uses need to be separated.

Subject: 2086 - Recreation - Management Approach

Public Concern #760

The Forest Service should consider the following management approaches: 1-not opening more roads for 

recreation since the forest cannot manage regulations on the currently open roads; 2- remediation and or 

enforcement are not viable alternatives; 3-concerning recreation pack goats, the now-temporary closure 

order be expanded to include all 4 ranger districts and be permanently embedded; 4-recreation 

management specifics should allowed to adapt as use patterns change.

Response

(1) The miles of existing and projected additional roads by alternative were identified in table 131. The 

deciding officer will consider the various options along with other comments during the decision 

process.

(2 and 3) Different alternatives were analyzed associated with recreational pack goat use and are 

identified in table 53. The deciding officer will consider the various options along with other 

comments during the decision process.

(4) Implementation of recreation management specifics are adaptable within the goals, objectives, 

standards, and guidelines of the revised Forest Plan.

Public Concern #761

The Forest Service should consider on page 91 add “...which do not compromise the integrity of wildlife 

habitat“ to “Forest recreation management focuses on community and visitor interests, new as well as 

traditional recreational activities, and year round enjoyment of outdoor recreation on the Shoshone.”
Shoshone National Forest Land Management Plan Revision

922

Response

Wildlife habitat and recreation conflicts are covered in the desired condition with the following statement 

“Established recreation opportunities are maintained where not in conflict with other resources.”

Subject: 2100 - Designated Wilderness and Recommended Wilderness -

Resource – General

Public Concern #762

The Forest Service should maintain all existing wilderness areas and create all of the proposed 

wilderness areas to protect wildlife and rich biodiversity and preserve wild and scenic beauty of the 

Shoshone for future generations

Response

The existing designated wilderness areas are maintained in all alternatives considered. See response to PC 

#257 (item 3) regarding additional wilderness recommendations.

The forest planning process requires that unless otherwise provided by law, all roadless, undeveloped 

areas that satisfy the definition of wilderness found in section 2(c) of the Wilderness Act of 1964 should 

be evaluated and considered for recommendation as potential wilderness areas during plan development. 

To satisfy this requirement, an evaluation of areas for potential wilderness was completed in 2008 (edited 

2013). Thirty-four areas were evaluated for capability and availability, using the process identified in 

Forest Service Handbook 1909.12, chapter 70. See appendix C of the FEIS.

Public Concern #763

The Forest Service should not add any additional designated wilderness areas since currently 80% of the 

forest is already designated as wilderness or open to non-motorized uses. Reduced motorized use on the 

forest will have a negative impact to the local economy; The Forest Plan should keep more options 

available for multiple uses.

Response

The forest planning process requires that unless otherwise provided by law, all roadless, undeveloped 

areas that satisfy the definition of wilderness found in section 2(c) of the Wilderness Act of 1964 should 

be evaluated and considered for recommendation as potential wilderness areas during plan development. 

To satisfy this requirement, an evaluation of areas for potential wilderness was completed in 2008. Thirtyfour areas were evaluated for capability and availability, using the process identified in Forest Service 

Handbook 1909.12, chapter 70.

Public Concern #764

The Forest Service should remove any considerations or perspective from all impacts analysis from the 

final EIS and Plan since the Wyoming Wilderness Act in Section 504 – Prohibition of Buffer Zone, states 

that “non-wilderness activities or uses can be seen or heard from within any wilderness area shall not, of 

itself, preclude such activities or uses up to the boundary of the wilderness area.”

Response

Public Law 98-550-Oct. 30, 1984 otherwise known as The Wyoming Wilderness Act of 1984, specifically 

states: PROHIBITION ON BUFFER ZONES

SEC. 504. Congress does not intend that the designation of wilderness areas in the State of Wyoming lead 

to the creation of protective perimeters or buffer zones around each wilderness area. The fact that 
Final Environmental Impact Statement -- Appendix A

923

nonwilderness activities or uses can be seen or heard from within any wilderness area shall not, of itself, 

preclude such activities or uses up to the boundary of the wilderness area.

The 1964 Wilderness Act defines wilderness as an area of undeveloped Federal land retaining its primeval 

character and influence without permanent improvements or human habitation. Currently, effects to 

wilderness are measured by how any particular project or planning effort modifies the wilderness 

character of a wilderness area. The forest planning process requires that unless otherwise provided by law, 

all roadless, undeveloped areas that satisfy the definition of wilderness found in section 2(c) of the 

Wilderness Act of 1964 should be evaluated and considered for recommendation as potential wilderness 

areas during plan development. New areas considered for recommendation for wilderness designation 

have the potential effect of protecting wilderness resources. In addition, these areas preserve wilderness 

character through management efforts to maintain the five wilderness qualities (Natural, Untrammeled, 

Solitude or a pristine and unconfined type of recreation, Undeveloped and Other Features) that define 

wilderness character.

Only Congress can pass legislation to create wilderness, therefore, management area (MA) allocation for 

recommended wilderness (MA1B) does not create designated wilderness. MA1B, recommended 

wilderness, protects the values that make the area suitable for wilderness designation. Management 

strategies for recommended wilderness may affect recreation opportunities and experiences within these 

areas. The revised Forest Plan and the FEIS do not create buffers or perimeters around existing 

wilderness. Nor do they suggest precluding nonwilderness activities in areas immediately adjacent to 

wilderness, simply because the area is immediately adjacent to wilderness. Management areas, which 

provide direction on what activities are allowed immediately adjacent to existing designated wilderness, 

are established without regard to whether these nonwilderness activities could be seen or heard from 

within any wilderness area. The purpose and requirement for disclosing environmental effects to 

designated wilderness is required under the National Environmental Policy Act (NEPA) of 1969. The 

essential purpose of NEPA is to ensure that environmental factors are weighted equally when compared to 

other factors in the decision-making process undertaken by Federal agencies such as the Forest Service. 

The act establishes the national environmental policy, including a multidisciplinary approach to 

considering environmental effects in Federal government agency decision-making processes such as 

Forest Plan Revision.

Public Concern #765

The Forest Service should not follow the conclusion on pages 105 and 106 of the Draft EIS, Volume 2 

which states that there is no clear consensus from the public of additional wildernesses are needed on the 

forest since that is not an adequate reason to include recommendations.

Response

The statement referenced is on page 107 of appendix C which is the potential wilderness evaluation 

document. This statement is in the section summarizing public input associated with additional 

wilderness. Appendix C has been updated. The deciding officer will consider the various options along 

with other comments during the decision-making process.

Public Concern #766

The Forest Service should address and clarify motorized use in the wilderness for administrative purposes 

as it is a discrepancy in management of wilderness areas.

Response

Administrative motorized use in wilderness is governed by both the Wilderness Act and Forest Service 

directives which are listed under the legal and administrative framework sections of the EIS.
Shoshone National Forest Land Management Plan Revision

924

Subject: 2105 - Designated Wilderness and Recommended Wilderness -

Direct and indirect

Public Concern #767

The Forest Service should include the wilderness evaluation acres for MA 3.6A on page 514 of the DEIS.

Response

Thanks for your comment. We will add MA3.6A to table 147 in the FEIS.

Public Concern #879

The Forest Service should examine how the various alternatives will impact wilderness character on the 

nationals forest – that is how the alternatives will also impact the areas found in the Wilderness 

Evaluation report to have Wilderness character.

Response

The wilderness section in the FEIS includes a table that displays how the wilderness evaluation areas are 

allocated in each of the alternatives. The effects discussion also identifies the impacts of various activities 

associated with different allocations. Other maps in the FEIS can be used to determine how individual 

areas are allocated.

Subject: 2107 - Designated Wilderness and Recommended Wilderness -

Climate Change

Public Concern #768

The Forest Service should make the preservation of the wild, intact habitats the highest priorities as the 

Shoshone National Forest is a national recognized climate indicator forest; protection from fragmenting 

development and motorized use will not only sustain a healthier ecosystem but would also serve to buffer 

the effects of present climate change and slow local contributions to ongoing climate change.

Response

The alternatives in the EIS display a range of options for how to manage the forest. Alternative C 

allocates the most land to wilderness and non-motorized uses. The decision maker will consider those 

public comments that prefer that type of management along with other public comments in making the 

final decision.

Subject: 2125 - Designated Wilderness and Recommended Wilderness -

Guidelines

Public Concern #769

The Forest Service should elevate Guideline 13 under Guidelines for Management Area 1.1 – Wilderness 

to a Standard so that posting boundaries is mandatory versus being an option at the local forest District 

since good on the ground signing is critical to proper motorized management.

Response

Posting of wilderness boundaries in this guideline is associated with motorized incursions, thus, this 

guideline focuses on those areas with the highest potential for incursions, These areas include known 

areas of trespass for winter motorized use and where motorized routes are adjacent for summer motorized 

since there is a requirement to stay within 300 feet of a motorized road and trail.
Final Environmental Impact Statement -- Appendix A

925

Subject: 2126 - Designated Wilderness and Recommended Wilderness -

Management Approach

Public Concern #770

The Forest Service should maintain the responsible and sustainable stewardship of land through 

traditional grazing rights in recommended and designated wilderness areas and provide any requirements 

regarding reduction in livestock grazing where impacts to wilderness values are occurring.

Response

Grazing and grazing rights within designated and recommended wilderness would follow Forest Service 

directives.

Public Concern #771

The Forest Service should not allow construction of new range improvements within wilderness areas as 

this is a violation of the Wilderness Act.

Response

The Wilderness Act and Forest Service directives allow new range improvements within wilderness if 

they are needed to protect wilderness values. The revised Forest Plan complies with the Wilderness Act.

Subject: 2150 - Designated and Eligible Wild and Scenic Rivers - Resource 

– General

Public Concern #60

The Forest Service should clarify the segment descriptions for the Middle Popo Agie River and Wiggins 

Fork on the page 56 map to be, “Headwaters to Shoshone boundary.”

Response

We made the change.

Public Concern #772

The Forest Service should consider giving the 13 identified river segments as Wild and Scenic River 

Designation, including Lower Sunlight Creek.

Response

Only Congress can designate or add a river segment into the Wild and Scenic River system. During the 

forest plan revision effort, the Shoshone is required to make eligibility and classification determinations 

but not suitability or designation recommendations.

Public Concern #773

The Forest Service should consider clarifying the following items: 1-what does the Wild and Scenic River 

designation mean for where river’s cross private land especially concerning restrictions; 2- include a 

stream- by-stream description of the analysis for all streams eligible and not, why 13 of 26 made the list; 

3-explain why Crandall Creek, North Fork Popo Agie, and Grinnell Creek were not found eligible; 4-

explain the rational for Outstanding Remarkable Values Paddling on streams or not; 5-why are there 

Outstanding Remarkable Values differences between DEIS and Draft LMP for same waterways.
Shoshone National Forest Land Management Plan Revision

926

Response

(1) There is only one designated wild and scenic river on the forest—the Clarks Fork of the Yellowstone. 

Private properties along this designated river are not restricted as we only have authority to manage 

the Federal lands associated with a designation.

(2 –5) The Wild and Scenic eligibility document will be revised to address public comments received on 

the draft.

Public Concern #774

The Forest Service should consider delaying suitability determinations for eligible Wild and Scenic Rivers 

until these actions are triggered by proposed impacts or conservation actions and regularly update the 

public on eligibility inventory.

Response

The introduction to the wild and scenic river section indicates that suitability is not being conducted at 

this time and describes when a suitability determination might kick in. See FEIS appendix D.

Public Concern #775

The Forest Service should consider Dead Indian Creek downstream from the Dead Indian Creek 

Campground and the segment of Sunlight Creek downstream from Wyoming Highway 296 should be 

proposed as additions to the Clarks Fork of the Yellowstone Wild and Scenic River.

Response

See PC #773 items 2 through 5.

Public Concern #776

The Forest Service should consider closing roads and prohibiting bicycles within wild and scenic river 

corridors.

Response

Bicycle use is a valid use of wild and scenic river corridors. Roads within the one designated wild and 

scenic river are grandfathered in by the enabling legislation.

Public Concern #777

The Forest Service should consider that following stream routes for wild and scenic designation in 

addition to those already mentioned: North Fork of Shoshone River, South Fork of Shoshone River, Dead 

Indian Creek, Beartooth Creek, Wood River, North Fork of Popo- Agie River, Little Popo-Agie River, East 

Dunoir Creek, West Dunoir Creek, Clark’s Fork, Wiggins Fork, Frontier Creek, Wind River, and East 

Fork of Wind River. These rivers should be considered due to their scenic, wildlife, geologic, and 

recreational qualities.

Response

See PC #773 items 2 through 5.

Subject: 2152 - Designated and Eligible Wild and Scenic Rivers -

Methodology

Public Concern #778

The Forest Service should consider in order to be assessed as outstandingly remarkable for Wild and 

Scenic River Designation; a river-related value must be a unique, rare, or exemplary feature that is 
Final Environmental Impact Statement -- Appendix A

927

significant at a comparative regional or national scale and not just both and to identify and document all 

potential Outstanding Remarkable Values that reflect the iconic character of the Forest’s rivers and 

streams.

Response

See PC #773 items 2 through 5.

Public Concern #779

The Forest Service should consider any of the free-flowing streams on the Shoshone National Forest that 

contain healthy populations of Yellowstone Cutthroat Trout should be found eligible for Wild and Scenic 

designation based upon a “fish” Outstanding Remarkable Value since Wood River was.

Response

Not all streams with Yellowstone cutthroat trout populations are considered as an outstandingly 

remarkable value. The wild and scenic river eligibility document will be revised to reflect public 

comments and will address each stream evaluated by the interdisciplinary team.

Subject: 2175 - Designated and Eligible Wild and Scenic Rivers - Guidelines

Public Concern #780

The Forest Service should consider No Surface Occupancy stipulations that include a defined buffer for 

Wild and Scenic River segments and corridors.

Response

No surface occupancy is applied to the designated wild and scenic river corridor. All action alternatives 

protect the eligibility of the potentially suitable river segments until a suitability determination is made.

Subject: 2200 - Inventoried roadless areas - Resource – general

Public Concern #13

The Forest Service should consider following Roadless Area Conservation Rule since it will allow 

motorized activities without the new for roads in roadless areas and should do a detailed plan for M.A. 

3.6A to include scenery management.

Response

Alternatives A, B, and C are consistent with the Roadless Area Conservation Rule. The revised Forest 

Plan contains direction for scenery management in management area 3.6A.

Public Concern #781

The Forest Service should consider maintaining, not reclassifying, and perhaps increasing Inventoried 

Roadless Ares and not allowing any new roads/trails including in winter months and No Surface 

Occupancy including the following areas. Wood River, Franc's Peak, the DuNoir Special Management 

Unit, Beem Gulch, Huff Gulch, Wiggins Fork/Double Cabin , Little Popo Agie Canyon, Pat O’Hara 

Mountain, Gravelbar and Trout Creek and perhaps increase roadless areas since these areas purify air 

and water, provide wildlife habitat, protect area for future generations, the Supreme Court allowed 

Roadless Rule to stand, prevent ORV damage, cut costs for maintenance, noise ruins nature experience, 

and prevent soil erosion.
Shoshone National Forest Land Management Plan Revision

928

Response

The Forest Service will continue to manage Inventoried Roadless Areas according to the most recent 

direction resulting from court rulings related to 2001 Roadless Area Conservation Rule. 

Public Concern #782

The Forest Service should consider allowing snowmobiling in inventoried roadless areas.

Response

The Forest Service does allow snowmobiling in inventoried roadless areas. In other words, snowmobiling 

is not prohibited simply because the area is managed as an inventoried roadless area.

Public Concern #783

The Forest Service should consider designating all roadless areas as wilderness since they could be lost

due to Wilderness and Roadless Area Release Act (H.R. 1581).

Response

In 2008 (edited 2012), 34 areas on the Shoshone were evaluated for potential wilderness. This process 

included three tests—capability, availability, and need. Alternatives C and D include some of the 

evaluated areas as recommendations for wilderness designations. Some of the areas considered for 

potential wilderness were also roadless areas. An alternative that would recommend all roadless areas for 

wilderness designation was considered but eliminated.

Public Concern #784

The Forest Service should consider controlling illegal ORV use in roadless areas including South Fork 

and Wiggins Fork roadless areas which has had a lot of illegal use noticed by hunters and is hurting 

wildlife habitat.

Response

The Forest Service continually strives to curb illegal ORV use through education, signage, and 

enforcement and by providing quality ORV use where management area direction allows for such use.

Public Concern #785

The Forest Service should consider closing timber roads and unauthorized routes when harvest is 

completed and to protect soils.

Response

The Forest Service frequently closes temporary roads after they are no longer needed for administrative 

purposes such as fuels reduction and timber harvesting. Site-specific road management is analyzed in 

project-specific analyses and is outside the scope of the forest plan revision analysis.

Public Concern #786

The Forest Service should consider changing the following: (1) deleting ‘as required by law’ from the first 

sentence on page22. (2) Include specific management area direction that is less restrictive than the RACR 

in the Revised Plan.

Response

The Forest Service does not have the authority to change congressional legislation or presidential 

proclamations. This includes changing the wording of the 2001 Roadless Area Conservation Rule 

(RACR).
Final Environmental Impact Statement -- Appendix A

929

Public Concern #787

The Forest Service should consider creating a roadless management area that is outside wilderness 

designation to protect roadless areas that won’t get wilderness designation.

Response

The Forest Service will continue to manage inventoried roadless areas according to the most recent 

direction resulting from court rulings related to the 2001 Roadless Area Conservation Rule. This will 

include areas outside of wilderness that continue to be managed as inventoried roadless areas.

Public Concern #788

The Forest Service should consider not have roadless areas since OHV won’t stay on the trail if there is 

no trail.

Response

The Forest Service continually strives to curb illegal ORV or OHV use through education, signage, and 

enforcement and by providing quality ORV and OHV use where management area direction allows for 

such use.

Public Concern #789

The Forest Service should consider if inventoried roadless areas have been altered to no longer have 

altered characteristics it should be opened up for timber harvest under 36 CFR 294.13(b) and 36 CPR 

294.13(b)(4) “timber may be cut, sold, or removed in inventoried roadless areas.”

Response

The Forest Service does not have the authority to change congressional legislation or presidential 

proclamations. This includes changing the wording of the 2001 Roadless Area Conservation Rule.

Public Concern #892

The Forest Service should establish desired and management prescriptions for non-IRA lands that 

maintain roadless value and characteristics.

Response

The plan allocates all lands with a management prescription including lands outside inventoried roadless 

areas (IRAs). The alternatives contain a mix of allocations for these lands. Some that emphasize nonmotorized, non-commodity uses such as alternative C, and others that emphasize motorized and 

commodity uses such as alternative F. The decision maker will consider the range of public comments on 

how these lands should be managed in making a final decision.

Subject: 2202 - Inventoried roadless areas - Resource – Methodology

Public Concern #891

The Forest Service should take a hard look and disclose the impacts to roadless values and 

characteristics for each alternative and delineate IRA boundaries in the final LRMP management area 

maps. As part of this analysis provide information about adjacent roadless areas on lands administered 

by other federal agencies such as the Bureau of Land Management (BLM) and the National Park Service, 

as part of the cumulative effects analysis to help reviewers to evaluate the alternatives.
Shoshone National Forest Land Management Plan Revision

930

Response

The EIS includes a discussion on the effects of the alternatives on inventoried roadless areas. Maps of 

inventoried roadless areas are included in appendix C of the FEIS. Inventoried roadless areas only occur 

on National Forest System lands, so there is no comparison with adjacent BLM lands. The BLM does 

have ACEC (Areas of Critical Environmental Concern) areas adjacent to the Shoshone. Those are 

addressed in cumulative effects under research natural areas. Most of the other National Forest System 

land adjacent to the Shoshone is wilderness. Appendix C on wilderness evaluation does include 

discussion on lands with wilderness characteristics in the Greater Yellowstone Area.

Public Concern #790

The Forest Service should ensure No Surface Occupancy for oil and gas development in all Inventoried 

Roadless Areas.

Response

The areas associated with no surface occupancy are being looked at between draft and final and are being 

revised. The deciding officer will consider the various options along with other comments during the 

decision process.

Public Concern #791

The Forest Service should not allow the creation of any new motorized roads or trails all Inventoried 

Roadless Areas and manage these areas as non-motorized back country recreational areas. Any 

Inventoried Roadless Areas that have already been impacted by motorized use should be rehabilitated 

instead of excluded.

Response

See PC #781. Table 146 identifies inventoried roadless areas and the management areas to which they are 

allocated by alternative. The deciding officer will consider the various options along with other comments 

during the decision process.

Public Concern #792

The Forest Service should continue to allow snowmobiling in Inventoried Roadless Areas.

Response

Being in an inventoried roadless area has no bearing on whether snowmobiling is allowed. Winter 

motorized use is based on what the management area designation allows or does not allow. A variety of 

alternatives were analyzed for winter motorized and are displayed in table 129. The deciding officer will 

consider the various options along with other comments during the decision process.

Subject: 2209 - Inventoried roadless areas - Monitoring

Public Concern #793

The Forest Service should seek increased funding to maintain and monitor established trails to increase 

the amount of accessible land to motorized travel, but continue to manage and monitor the areas to 

ensure that there are no negative impacts to wildlife and use by recreationalists.

Response

Increased funding is an issue outside of the scope of the forest plan analysis. Monitoring will follow the 

monitoring strategy identified in chapter 3 of the revised Forest Plan. 
Final Environmental Impact Statement -- Appendix A

931

Subject: 2250 - Research Natural Areas – General

Public Concern #794

The Forest Service should consider adding 8 new Research Natural Areas including Bald Ridge and Pat 

O’Hara Mountain for studying climate change, ecology, and protecting wildlife and rare plants.

Response

Both alternatives C and D in the EIS include all eight research natural areas. The decision maker will 

consider the input from those who want all eight areas along with other public comment in making the 

final decision. Alternative G, developed to respond to comments on the draft plan, includes adding eight 

research natural areas totaling approximately 68,000 acres.

Public Concern #795

The Forest Service should consider leaving Research Natural Areas especially Beartooth Butte and Line 

Creek Plateau open to over snow motorized use as it currently is.

Response

Some alternatives in the EIS leave these areas open to snowmobiling, while other close them. The 

decision maker will consider the input from those who want snowmobiling access maintained along with 

other public comment in making the final decision.

Public Concern #796

The Forest Service should conduct the necessary research to apply best science.

Response

Best available science is used in the EIS analysis. Conducting research is beyond the scope of the revised 

Forest Plan analysis. The Forest Service Research Stations conduct research activities, and various 

research articles where considered during this analysis.

Public Concern #797

The Forest Service should consider making the following changes: 1-add a map that shows all watersheds 

with important streams labeled and Research Natural Areas to determine if streams will be protected in 

those areas especially Upper Pat O’Hara Creek; 2- describe specific management protocols for RNAs 

when not within wilderness.

Response

The management area maps supplied with the EIS displayed the location of the research natural areas and 

streams that occur in those areas. Research natural areas appear on map 58, which includes the wilderness 

boundaries for reference.

The direction for managing recreation in proposed research natural areas, including recreational uses, is 

found in direction associated with Management Area 2.3 in the revised Forest Plan.

Subject: 2255 - Research Natural Areas – Direct and indirect effects include 

general effects

Public Concern #893

The Forest Service should explain which RNAs are allocated to alternatives A, B, E and F, which plant 

communities would not be represented in the RNA system, state which RNAs are included in existing or 
Shoshone National Forest Land Management Plan Revision

932

[proposed] Wilderness and explain the rationale for recommending only some of the identified potential 

RNAs in the preferred alternative.

Response

The applicable proposed research natural areas (RNA) and special interest areas (SIA) are included in the 

alternative description in chapter 2 of the EIS.

Map 58 displayed the locations of the potential RNAs and potential SIAs with the wilderness boundary. 

Many of the potential RNAs are located within wilderness areas

The Potential Research Natural Areas report (USDA Forest Service 2008) included a summary of species 

represented in attachment B. This report is referenced in the revised Forest Plan and the FEIS.

The decision maker will consider the whole range of input provided by the public on what RNAs and 

SIAs to include in the final decision.

Public Concern #894

The Forest Service should conduct an assessment to better understand the potential for harm to 

recommended RNAs and SIAs by analyzing the effects of prescribed management within one mile of 

potential RNA and SIA boundaries and identify possible changes to the management of buffer lands

Response

RNA analyses were completed following the Guidelines for Research Natural Area Analysis by National 

Forests within the Rocky Mountain Region (USDA Forest Service 1997). Initial analyses were completed 

in 1999, and updated in August 2008 (USDA Forest Service 2008).

Subject: 2271 - Research Natural Areas – Desired Condition

Public Concern #798

The Forest Service will ensure the following for additional Research Natural Areas (RNA) and other 

special use designations: (1) Continuation of historical grazing areas. (2) No change in grazing 

capability and suitability of proposed RNA. (3) Any fence building to preclude grazing mandated by the 

Forest Service will be constructed by the USFS. (4) Ranchers shall not be penalized for other resource 

degradation not directly linked to livestock use.

Response

Proposed research natural areas are located in areas that have little conflict with livestock grazing. Any 

grazing that occurs is incidental and is addressed through allotment management. The EIS contains a 

discussion of effects of livestock grazing on RNAs in the RNA section.

Subject: 2277 - Research Natural Areas - Management Approach

Public Concern #799

The Forest Service needs to provide direction or requirements to address livestock grazing currently 

located within Research Natural Areas (RNA) and should add a statement clarifying that off-trail 

snowmobiling would not be eliminated by the creation of the proposed Beartooth RNA since the

Recreation Uses and Opportunities’ section allows for existing trail use to continue in other RNAs.

Response

See PC #798 for livestock grazing. See PC #795 for snowmobiling.
Final Environmental Impact Statement -- Appendix A

933

Subject: 2300 - Special Interest Areas – Resource - General

Public Concern #800

The Forest Service should clarify if there would be any impacts to private land holders that have lands 

adjacent or near to proposed Special Interest Areas.

Response

There are no private lands near any of the proposed special interest areas.

Public Concern #801

The Forest Service should create the three proposed Special Interest Areas to highlight geological and 

historical aspects of the forest and their support for plant and wildlife communities and preserve the 

existing Special Interest Area at Sawtooth Peatbed. Bald Ridge and Pat O’Hara Mountain should be 

added to Special Interest Areas.

Response

Both alternatives C and D in the EIS include all special interest areas. The decision maker will consider 

the input from those who want all special interest areas along with other public comment in making the 

final decision.

Subject: 2350 - Scenery Resources – General

Public Concern #802

The Forest Service should not allow drilling along Chief Joseph Highway because the area between the 

Sunlight Valley and Beartooths is a preferred scenic touring route and drilling would diminish its 

ecological value.

Response

Drilling, mineral exploration, and all forest management activities must comply with the Scenery 

Management System (SMS). Within SMS, specific scenery objectives are allocated to every portion of the 

Shoshone National Forest. If drilling were allowed to occur along Chief Joseph Highway, the operation 

and physical activity would have to meet the allocated scenery objective for that area, thus maintaining 

the desired future scenic characteristic.

Public Concern #803

The Forest Service should adopt lower short-term scenery objectives in order to achieve long- term scenic 

diversity that is consistent with historic fire patterns on the landscape and to promote restoration 

treatments that increase ecosystem resiliency and forest health.

Response

Scenery Guideline 6 allows for lower short-term scenery objectives. Temporary drops of more than one 

scenic integrity objective may be made during and following project implementation with deciding officer 

approval, provided the original scenic integrity objective is met within three years of project completion

Public Concern #804

CDNST is not discussed under scenery resources. Add a CDNST discussion to this section. DEIS, Page 

558.
Shoshone National Forest Land Management Plan Revision

934

Response

Scenery and the Continental Divide National Scenic Trail are discussed in the recreation section of the 

FEIS.

Public Concern #805

The Forest Service should maintain the natural beauty of the Shoshone National Forest because the local 

economy depends on scenic, recreation and wildlife values.

Response

The Forest Service has adopted and implemented the Scenery Management System to maintain and 

protect scenery resources on the Shoshone National Forest.

Subject: 2373 - Scenery Resources - Objectives

Public Concern #806

The Forest Service should change the wording of the second issue/indicator on page 555 to the following 

because the way it is currently written implies Scenic Integrity Objectives are allocations as in 

management area allocations: “...proposed scenic integrity guidelines....”

Response

Scenic integrity objective is a standard term and is an integral component of the Scenery Management 

System.

Subject: 2374 - Scenery Resources - Standards

Public Concern #807

The Forest Service should retain Scenery Standard 1 in the draft plan because it is appropriate.

Response

The Forest Service will retain Scenery Standard 1 as recommended.

Subject: 2375 - Scenery Resources- Guidelines

Public Concern #808

The Forest Service should limit Scenery Guideline 4 to the Travel Corridor Management Area rather than 

a generic travel corridor where it could overemphasize middle-ground and background views from travel 

routes.

Response

Guideline 4 is consistent with the desired condition for scenery on the Shoshone. It is intended to mitigate 

the scenic impact of large facilities by blending them into the landscape in terms of scale, color, texture, 

form, etc.

Public Concern #809

The Forest Service should follow Forest Service Manual 2380 scenery management direction instead of 

Scenery Guideline 5 in the draft plan because it is not in compliance with the Scenery Management 

System and is not supportive of the desired condition.
Final Environmental Impact Statement -- Appendix A

935

Response

We agree, Guideline 5 “Scenic Integrity Objectives for management areas apply only to the area within 

the management area boundary” is redundant and is implied in all Forest-wide SIO allocations. Guideline 

5 will be removed.

Public Concern #810

The Forest Service should reconsider Scenery Guideline 6 in the draft plan because it may not fulfill all 

the requirements of the National Trails System Act that requires a reduction of Scenic Integrity along a 

National Scenic and Historic Trail corridor to be addressed through a substantial interference 

determination before another use can be allowed.

Response

Scenery Guideline 6 will allow for reduction of SIOs from minor adjustments, to temporary drops of 

more than one SIO during and following project implementation. Each project and potential change of 

SIO allocation will be considered on a case-by-case basis and will be allowed only by a deciding officer’s 

approval.

Public Concern #811

The Forest Service should make the Scenery direction in Guideline 4 on page 174 of the draft plan 

consistent with the 2009 Continental Divide National Scenic Trail Comprehensive Plan Chapter III €, and 

Forest Service Manual 2353.42 and 2353.44(b), and address it as a standard instead of a guideline

Response

Guideline 4 in conjunction with Standard 5 reflects direction in the Comprehensive Plan and Policy.

Subject: 2400 - Heritage Resources – General

Public Concern #812

The Forest Service should update the Infrastructure (INFRA) Database with heritage data for better 

project and resource management.

Response

The heritage program for the Shoshone National Forest is recorded, maintained, and tracked via the 

INFRA Database. Every project, event, or historic property is placed into the INFRA database.

Yearly heritage reports to the Washington Office are pulled from INFRA databases for all forests. The 

maintenance of the INFRA database is a normal part of operations for the Shoshone heritage program and 

every heritage program in the Forest Service. This is mentioned in the management approach section on 

page 99, top paragraph, second sentence.

Public Concern #813

The Forest Service should increase the number of historic properties available for public rental use.

Response

The Shoshone National Forest does and will consider the use of historic properties for rental use. The 

Forest’s first and foremost priority is to protect and preserve these resources, while assuring that a reclassification of use will not cause an adverse effect to a historic property eligible for or potentially 

eligible for listing in the National Register of Historic Places.
Shoshone National Forest Land Management Plan Revision

936

Other issues that arise when considering a switched use of historic structures is updating facilities to 

conform with current building codes, safety standards, and accessibility requirements. These can be costprohibitive activities given the current budget shortfalls. Partnerships with local historic interest groups, 

in the form of Challenge Cost Share Agreements, are a viable route for the maintenance and management 

of a property.

Public Concern #814

The Forest Service should better define the Heritage Program plan on the Shoshone National Forest by 

updating the heritage resource overview of heritage resources on the forest, consistently update historic 

property plans, address in plan long term goal of monitoring and maintaining structures such as 

Anderson Lodge and Clay Butte Tower, change funding to add more staff to the forest, make sure all forest 

personal and permittees have Archaeological Resources Protection Act of 1979 (ARPA) training with 

refreshers to know consequences of damage to heritage sites, and make an emphasis in plan for Priority 

Heritage Assets., and specify how it will meet its desired conditions and goals especially concerning 

livestock grazing.

Response

Forest Service objectives related to planning for heritage programs are defined in FSM 2362-Planning. 

The Shoshone National Forest does not yet have a comprehensive Heritage Program Plan (HPP). The 

Forest’s HPP is in development as a result of Heritage Program Managed to Standard Program 

implemented in 2012.

The seven elements of a National Forest HPP are delineated in FSM 2362.3-Heritage Program Planning. 

Development of the specific elements of the Forest’s HPP will be in consultation with tribal, state historic 

preservation office, local governments, and interested parties per direction from FSM2361.03-Policy.

The development of an HPP for the Shoshone is a part of the heritage program, in general, and will be 

conducted in accordance with Federal legislation and agency policy in collaborative partnerships with 

appropriate State, tribal, and local organizations. The development of an HPP is a program-level project, 

and is outside and beyond the scope of the revised Forest Plan analysis. ||

Public Concern #815

The Forest Service should clarify how it produces the Priority Heritage Asset list and increase that list in 

order to know criteria is used, determine timeframes from completing plans, make the list more available, 

include more non-listed but eligible to National Register of Historic Places (NRHP) sites, include forest 

administrative facilities to plan, include State Historic Preservation Office (SHPO) and Native American 

Tribes, local preservation organizations, and other interested parties in producing the list, and include 

more associated cabins and mines within the Kirwin potential district.

Response

The USDA Forest Service is steward to over 300,000 heritage assets. To aid in managing these assets, the 

Forest Service has further defined priority heritage assets (PHAs) using criteria outlined in Forest Service 

Manual 2360 and using guidance for identifying heritage asset major categories as described in the 

Technical Release 9: Implementation Guide for Statement of Federal Financial Accounting Standards 29: 

Heritage Assets and Stewardship Land.

PHAs are those heritage assets of distinct public value, recognized for research potential to yield scientific 

information or management decisions, interpretation, education, or economic benefits, and are thus 

actively maintained within the program for maintenance and other assessment activities. There is no limit 
Final Environmental Impact Statement -- Appendix A

937

to the number of priority assets a forest may have and the list of priority heritage assets can change over 

time; however, PHAs must meet one or more of the following criteria:

• The significance and management priority of the historic property is recognized through official 

designation, such as the Listing on the National Register of Historic Places (NRHP) or State Register;

• The significance and management priority of the property is recognized through prior financial 

investment in preservation, protection, interpretation, or use;

• The significance and management priority of the property is recognized in an agency approved 

management plan; or

• The property exhibits critical maintenance or protection needs that have been clearly documented.

While no heritage asset has more intrinsic value than another, some offer greater potential for use as 

interpretive sites, while others may meet additional management purposes, such as cabin rentals, while 

others hold great research potential, and some must be recognized for their value to specific communities. 

With a limited funding base, PHAs help the unit identify where to direct planning efforts and resources.

All historic properties, cultural materials, and features within the Shoshone National Forest are protected 

and managed under Federal laws, regulations and agency policies listed in the Other Guidance section of 

the revised Forest Plan pages 99 through 100. The Shoshone will share the list of PHAs with the 

appropriate Federal, State, and Native American tribes upon request and readily consider suggestions to 

the PHA list.

Public Concern #816

The Forest Service should create Heritage Interest and Research areas to protect archaeological assets 

such as those on Wood River and Bear Creek, amongst other locations

Response

All historic properties, cultural materials and features within the Shoshone National Forest are protected 

and managed under the Federal laws, regulations, and agency policies listed in the “Other Guidance” 

section of the revised Forest Plan on pages 99 through 100. The Forest will consider the designation of 

areas of importance

The Kirwin Special Interest Area (SIA) has been expanded and the Double D Ranch has become an SIA 

in response to comments received concerning these resources.

Public Concern #817

The Forest Service should note the designation of the Beartooth Highway to the National Register of 

Historic Places since it is being processed by the State Historic Preservation Office.

Response

When the Beartooth Highway is listed in the National Register of Historic Places, the new designation 

will be noted in the forest plan with an amendment.

Public Concern #819

The Forest Service should revise The Land Management Plan to include management of non-PHA sites. 

There is a concern that the current plan focuses on only a small number of Priority Heritage Asset (PHA) 

sites, neglecting hundreds of other significant historic and prehistoric resources.
Shoshone National Forest Land Management Plan Revision

938

Response

All historic properties, cultural materials and features within the Shoshone National Forest are protected 

and managed under the Federal laws, regulations and agency policies listed in the Other Guidance section 

of the revised Forest Plan on pages 99 through 100. These laws and regulations direct how the Forest 

protects and preserves archaeological materials and sites, not the forest plan.

Subject: 2421 - Heritage Resources - Desired Condition

Public Concern #820

The Forest Service should document the archeological sites on Bald Ridge and should be documented in 

cooperation with BLM.

Response

Any information concerning unrecorded archaeological sites will be investigated. This is not information 

or direction to be placed in the forest plan.

Subject: 2423 - Heritage Resources - Objectives

Public Concern #821

The Forest Service should consider the following changes to the objectives in this section: (1) Revising 

Objective 4 so that it identifies priority historic properties and completes a historic property plan for at 

least one National Register eligible or listed property every three years; (2) Add an additional objective

that a Heritage Resource Overview will be written within 5 years of the Forest Plan implementation; and 

(3) Delete Objective 5 as the requirement lacks sufficient reason to keep.

Response

(1) It was determined, based on current staffing and budget projections that three Historic Property Plans 

(HPPs) was an achievable goal. As time and budget allow, as a part of the Shoshone National Forest 

Heritage Program, more historic property plans will be developed. Three HPPs over the life of the 

forest plan is the achievable goal determined by the interdisciplinary team.

(2) While this is a desirable objective for the Shoshone National Forest Heritage Program, we are not 

certain if we will have funding to implement within the timeframe suggested. 

(3) The development of an historic overview is within the Heritage Program Managed to Standard 

Program implemented in 2012, as a part of the performance standards established by the agency. 

The Forest will be looking for ways to develop and fund an historic overview, but timing is uncertain 

at this point.

(4) As a part of the Forest’s responsibilities as a steward of historic properties and resources, after a 

natural catastrophic event such as a forest fire an inventory of the effects on cultural resources is 

mandated by the Federal laws and regulations that direct agencies on the stewardship of these 

resources. Objective #5 will not be deleted.

Subject: 2424 - Heritage Resources - Standards

Public Concern #822

The Forest Service should consider revising Standard 3 to include potential effects on unevaluated sites in 

this area and incorporate guideline 8 into this standard so that potential sites that are unevaluated must 

be evaluated for eligibility in the National Register of Historic Places, and if eligible, prohibit outfitter 

and guide camps from the areas.
Final Environmental Impact Statement -- Appendix A

939

Response

Guideline 8 was dropped and a new standard was added to address this comment.

Subject: 2425 - Heritage Resources - Guidelines

Public Concern #823

The Forest Service should consider adding the following guidelines for heritage resources in regards to 

livestock grazing: (1) Managing livestock post-fire environments to avoid impacts to heritage resources; 

(2) Avoiding grazing and activities such as feeding, salting, herding, or placing water developments in 

areas where heritage resources have become exposed to wildfire; (3) Not allowing water, mineral, 

supplement/salting stations to overlap or occur within the boundaries of resources eligible for or listed on 

the National Register of Historic Places; (4) Ensuring that when cultural resources are identified, they 

are recorded, evaluated, and consultation of their eligibility with the SHPO will occur; and (5) Heritage 

personnel are consulted prior to making improvements or changes to historic grazing related structures.

Response

Standards and guidelines are typically located in the relevant activity section of the plan. Where the 

standards or guidelines pertain to multiple activities, they are usually located in the applicable resource 

section.

The IDT determined that

(1) This practice is mentioned in Range/Commercial Livestock Grazing – Guidelines 2 and 3, page 73.

(2) This practice is mentioned in Range/Commercial Livestock Grazing – Guidelines #2 and 3, page 73.

(3) This is a normal practice within the Range Management Plan and Section 106 review for Allotment 

Permit Renewals and part of the evaluation of and cultural resource survey work concerning Range 

Allotments for NEPA purposes.

(4) This suggestion is already required under Section 106 of the National Historic Preservation Act. 

(5) This practice is mentioned in Range/Commercial Livestock Grazing – Guideline 2, page 73, a part of 

the Shoshone National Forest Range Management Plan and also required under Section 106 of the 

National Historic Preservation Act.

Public Concern #824

The Forest Service should consider adding a section on heritage resources to the guidelines in 

Management Area 4.2 as some of them are historic properties.

Response

The guidance is provided elsewhere in the heritage and facilities sections of the revised Forest Plan.

Subject: 2427 - Heritage Resources - Public Involvement - General

Public Concern #825

The Forest Service should consider if the Priority Heritage Asset List becomes a component of Forest 

heritage resource management, then the County Historic Preservation Commission, the Historic 

Preservation Commission in Fremont County, and other groups with strong interests, local expertise, and 

archival information are included in the process.

Response

See PC #815 response concerning the Shoshone National Forest PHA list.
Shoshone National Forest Land Management Plan Revision

940

Subject: 2450 - Social and Economic - Resource – general

Public Concern #826

The Forest Service should take into consideration tourism and how it will be impacted from Forest policy 

changes since tourism is major source of the local economy.

Response

The economic impacts of tourism were considered and analyzed in the EIS (pages 576 through 604).

Some comments highlight the role of the tourism sector within the study area as a stable economic force. 

The revised Forest Plan analysis shows the tourism sector within the study area to be very cyclical in 

nature, particularly on an annual basis. For example, the SFRED (Sportsmen for Responsible Energy 

Development) report for Park County indicates there were 40 lodging places open in Cody during the 

summer, but only 18 open during the off-season. The report also indicates the occupancy rate for lodging 

in Cody is 90 percent during the summer, but 33 percent during the off-season. Such statistics do no 

support a stable economic sector on an annual basis.

Others suggested in their comments that the tourism industry had grown faster than other resource 

industries and such information should be highlighted in the EIS. However, in recent years (2001 through 

2011) mining employment in Fremont County has increased by 157 percent and agricultural employment 

has increased by 23 percent, while accommodation and food service employment (associated with tourism 

activity) has decreased by 0.5 percent. In Park County, mining employment has increased by 99 percent, 

accommodation and food service employment has increased by 6 percent, and agricultural employment 

decreased by 2 percent. The comment of higher tourism growth cannot be supported by data, and thus, 

was not included in the EIS analysis.

Public Concern #827

The Forest Service should consider a plan that helps and not hinders the local economy with many rural 

communities main source of revenue dome with businesses that rely on the use of the forest like outfitters, 

motorsports sales and rentals, fishing, tour, and fishing. Additionally the Forest should look for ways to 

work together with businesses to better address needs of both.

Response

Desired conditions in the revised Forest Plan recreation section include benefits to local communities 

from recreation opportunities: “A diversity of year round recreation opportunities attracts increasing 

numbers of visitors to the Shoshone, thereby providing economic and social benefits to local 

communities.” and “Partnerships are a significant tool to help provide public use and year round 

recreation opportunities.” (page 89, revised Forest Plan – Shoshone National Forest). Goals for recreation 

also address the benefits of recreation for local economies: “Goal 1. Seek increased tourism that will 

enhance local economies by providing information and a broad spectrum of high quality outdoor 

recreation opportunities for visitors.”

Many comments requested the analysis recognize the economic importance of public lands to local 

economies. The EIS does include a contribution analysis of forest outputs to the study area. Some 

comments refer to the benefits of “protected” public lands to local economies, but these studies are 

conflicting with other analyses. A more complete review is included in the literature review section. 

Many comments reflected the idea that people are moving into the study area only because of the quality 

of life provided by, in part, the Shoshone National Forest. While quality of life is certainly a factor, it is 

not a primary motivator factor that can be attributed to the Forest. For example, Wyoming Community 
Final Environmental Impact Statement -- Appendix A

941

Development Authority data on individuals obtaining new drivers licenses in Park County in 2012 

indicate that “better quality of life” was the reason for moving to Wyoming for 11.3 percent of 

individuals, less than “friends or relatives in Wyoming” (27.8 percent), “new job” (23.7 percent), or “job 

transfer for self or spouse” (16.5 percent). Quality of life, while an important value to people, it is likely 

more complicated than just access to natural resources.

Specific comments highlight the importance of the economic contribution of the National Outdoor 

Leadership School (NOLS). While NOLS operates in a number of jurisdictions in addition to the 

Shoshone National Forest, to the extent possible, the economic activity of NOLS within the Forest has 

been included in the EIS analysis.

Several comments refer to tourism income/employment data sources that are defined/used inconsistently. 

The EPS/HDT report highlights a ‘travel and tourism’ sector, however this estimate is based on the 

assumption that all activity within the Retail Trade, Passenger Transport, Arts/Entertainment/ Recreation, 

and Accommodation and Food Services employment is based on travel and tourism, no services are 

provided to local residents. Since most of these sectors provide at least some and, in many cases, most of 

their goods and services to the local population rather than visitors, this assumption in not appropriate and 

results in an overestimate of the relative importance of travel and tourism.

In contrast, Dean Runyan Associates estimated for the Wyoming Division of Travel and Tourism 1,560 

direct jobs for travel and tourism in Fremont County for 2011, about 6.3 percent of the total county 

employment. In comparison, the Bureau of Economic Analysis estimated 1,514 agricultural sector jobs 

and 1,246 mining sector jobs within Fremont County during the same 2011 period.

Public Concern #828

The Forest Service should consider protecting wilderness, roadless areas, and wildlife because these 

aspects of the forest help drive the local economies.

Response

The revised Forest Plan contains goals consistent with protecting wilderness, roadless areas and wildlife: 

wilderness: “Goal 2. Preserve and improve the characteristics of wilderness areas”; roadless: the revised 

Forest Plan is consistent with the protective measures of the 2001 Roadless Rule; and wildlife: “Goal 1. 

Provide well-distributed habitat capable of contributing to the survival and recovery of species listed 

under the Endangered Species Act.”

The contribution analysis in the EIS includes the contribution of employment and income from forest 

outputs from outfitters and guides and other activities in roadless and wilderness to the study area. With 

56 percent of the Shoshone National Forest currently designated as wilderness and another 28 percent is 

inventoried roadless areas, the magnitude of difference among alternatives will be small with minor 

acreage changes.

Public Concern #829

The Forest Service should consider maintaining the present level of timber industry or even expanding it 

to include niche products since the Counties and Conservation Districts believe that we owe it to their 

constituents to look for creative ways to expand the wood products industry.

Response

Alternative A, the current plan, considers 86,300 acres to be suitable for timber production, with an 

allowable sale quantity of 19,800 hundred cubic feet per year. Alternatives B and G consider 

127,000 acres to be suitable for timber production with an allowable sale quantity of 22,800 hundred 
Shoshone National Forest Land Management Plan Revision

942

cubic feet per year. Alternative F considers 251,200 acres to be suitable for timber production, with an 

allowable sale quantity of 30,500 hundred cubic feet per year. The revised Forest Plan does not restrict the 

type of forest products that are produced or sold. And no alternative creates guarantees for any 

commercial industry. Forest outputs are offered for commercial use and it is up to individuals within an 

industry to create a viable business.

Public Concern #830

The Forest Service should consider the economic impact of banning pack goats since it would cause the 

people in that business to leave the area and decreasing some of the economic dollars for the surrounding 

communities.

Response

Pack goats are being banned only from core native bighorn sheep ranges to protect bighorn sheep 

populations from diseases carried by domestic goats. Hunting of bighorn sheep and wildlife viewing of 

bighorn sheep have positive economic impacts for local communities. Currently, no permitted outfitters 

use pack goats on the Shoshone National Forest.

Public Concern #831

The Forest Service should consider taking into account the desires of the general public locals that were 

surveyed such as those from survey of “Study of Preferences and Values on the Shoshone National 

Forest” dated January 16, 2008 and the Cody 2020 survey that received replies from over 1,700 citizens.

Response

Information from the Study of Preferences and Values on the Shoshone National Forest (2008) was 

considered, included, and included in the social and economic section of the EIS. Individually funded 

community efforts such as Cody 2020 are very beneficial to the local communities they focus on and 

serve, but for a planning effort encompassing a larger landscape, it is important to use consistent data 

available throughout the study area.

Public Concern #832

The Forest Service should consider not closing any areas to snowmobiles as that would negatively impact 

the local communities and businesses that rely on snowmobile access for their economy.

Response

The intent of the revised Forest Plan is to leave open for winter motorized use all of the areas currently 

being used by snowmobilers. Generally, areas are closed to winter motorized use for reasons of 

compliance with wilderness regulations or the protection of crucial winter range for wildlife, or both. 

Specific closure information is included in the recreation section of the EIS. The contribution of 

snowmobile use on the Forest to the study area is included in the economic analysis.

Public Concern #833

The Forest Service should consider requiring businesses such as outfitters and lodges to serve different 

market segments and not just certain groups to better maintain sustainable regional economy.

Response

Special uses desired conditions direction provides that recreation authorizations should meet 

demonstrated public needs when consistent with the desired conditions for a specific area, and that 

authorizations should provide opportunities for those needing outfitting and guiding services to 

participate in the recreational opportunities provided on the Shoshone.
Final Environmental Impact Statement -- Appendix A

943

Public Concern #834

The Forest Service should consider better protecting mule deer since hunting is a big revenue source for 

the area.

Response

The management of mule deer on the Shoshone falls under the purview of the Wyoming Game and Fish 

Department. The Shoshone is responsible for managing the habitat for mule deer. The revised Forest Plan 

would put in place special considerations for mule deer by protecting big game crucial winter range. 

Human disturbance is minimized in big game crucial winter range. The contribution of hunting on the 

Forest to the study area is included in the economic analysis

Public Concern #835

The Forest Service should consider adding more oil and gas leasing on the forest because of its socioeconomic support it can bring to the local communities.

Response

The Shoshone has identified lands available for oil and gas leasing. Current industry demand for oil and 

gas leases on the Forest is minimal. A recent survey of industry indicated that demand for oil and gas 

leases on the Forest is expected to remain very low into the foreseeable future. Economic impact to the 

study area from oil and gas leases would only occur if a private company determined resources on the 

Shoshone were profitable to develop. Currently, there is no activity with no interest, so the economic 

analysis does not include any oil or gas impact under any of the alternatives.

Public Concern #836

The Forest Service should consider that 70% of Forest Service projects lose money.

Response

The Forest Service is not required to be profitable. Many of the projects completed on National Forest 

System lands are done to benefit elements of the ecosystem—improve habitat and forest health, reduce 

wildfire hazard, or to improve recreational opportunities for a variety of users or protect resources while 

allowing those uses to occur. These resource projects produce a variety of benefits for society, but those 

benefits are not valued in terms of dollars—but that does not make the benefits any less important

Public Concern #837

The Forest Service should consider expanding and clarifying the Socio-Economic Impact section as it 

does not give enough detail for forest managers to adequate information and to identify and quantify the 

impacts of the proposed Shoshone Forest Management Plan on all aspects of human society in nearby 

communities since DEIS, Plan and material by Dr. Taylor have not met that purpose.

Response

Community-level analysis is not completed for forest plan-level analysis because of the data available for 

outputs. It would also require a great deal of speculation to predict which communities would likely 

receive resource outputs over another community. For a variety of reasons, Forest Service analysis is not 

prepared for selecting “winners or losers” but to show the relative difference among alternatives for forest 

plan analysis. When implementing the revised Forest Plan, project-level NEPA analysis will continue to 

include social and economic analysis to address these issues if they are raised and are more likely to be 

addressed at a more local scale.
Shoshone National Forest Land Management Plan Revision

944

Public Concern #838

The Forest Service should consider how do changes in the structure and function of protected ecosystems 

and the surrounding landscape feedback to change human attitudes and trajectories of development?

Response

The Forest has considered the amenity values of protecting ecosystems and wildlands and their 

importance to local communities and as a national resource. The Forest has similarly considered the tradeoffs to resource extractive industries from special area designations within National Forest System lands.

Public Concern #839

The Forest Service should consider that if more wilderness is added that some local business will be hurt.

Response

The decision maker will consider this along with other input in making the decision.

Public Concern #840

The Forest Service should consider allowing its research to extend to northern Minnesota tourism by 

contacting business organizations sponsoring tourism in that State.

Response

The revised Forest Plan is a programmatic land management strategic document that does not prescribe 

actions at the level of contacting the tourism department of a particular state. Available visitor information 

and census information, along with other available data, were considered during the analysis as described 

under methodology in the recreation and social and economic sections of the EIS.

Public Concern #841

The Forest Service should consider incorporating aspects of the America’s Great Outdoors Initiative in 

having trans-agency and external partnerships with non-profits and local communities

Response

Partnerships are promoted in the recreation section of the revised Forest Plan: “Through recreation special 

use authorizations, commercial and non-commercial partners provide a variety of opportunities to the 

public.” And “Partnerships are a significant tool to help provide public use and year round recreation 

opportunities.”

Subject: 2452 - Social and Economic - Methodology

Public Concern #842

The Forest Service needs to reexamine the discussion of environmental justice in the DEIS in that by 

closing the Shoshone to pack goats, elderly or disabled individuals who rely on pack goats to carry gear 

will effectively make access to the trails and the backcountry of the Shoshone for these individuals 

impossible.

Response

Please see response to PC #830 concerning the extent of pack goat use or limitation. While pack goats 

will not be available for anyone to use within core bighorn sheep areas, other types of pack animals are 

available for use throughout the Forest. The decision to limit domestic goats and sheep from specific 

bighorn sheep areas was done to protect the health of the bighorn. An unfortunate trade-off of this 
Final Environmental Impact Statement -- Appendix A

945

protection is the limited access within these specific areas. But, there are other areas on the Forest open to 

pack goats, and the bighorn core areas are accessible by other means (e.g., horse, llama).

Environmental Justice, as defined by E.O. 12898, relates specifically to minority and low- income 

populations. Limiting use of pack goats from a specific area that has concerns for elderly and disabled 

would not fall into the considered populations under Environmental Justice.

In this case, no one is allowed to enter the area with pack goats, so that specific access type has been 

equally closed off to all persons, and no individual class has been treated differently. 

Public Concern #843

The Forest Service should examine their mineral, recreation, grazing, timber, and forest management data 

in greater detail in order to better convey impacts to local comminutes or net public benefits across 

alternatives. The Forest Service needs to calculate the maximum Present Net Value (PNV) benchmark to 

develop a maximum PNV for those resources that have a market or non-market value and are relevant to 

the plan revision issues. The Forest should provide sound data from individual resource specialists to 

provide a viable analysis of PNV and net public benefits.

Response

Please see response to PC #837 – data in greater detail are not available for analysis at the forest plan 

level. Specific to the PNV analysis; the final analysis for the revised Forest Plan includes a maximum 

PNV analysis that was inadvertently not included in the draft. The FEIS and appendix B PNV analysis 

has been updated to better account for relevant PNV values.

Public Concern #844

The Forest Service should provide more detail in accurately estimation the economic value of outdoor 

recreation. Within the DEIS, the estimation states that there are no changes in recreation employment and 

labor income for recreation around all six alternatives. It is recommended that a stronger review of the 

viable economic contribution toward the sustainability of surrounding forest communities be made to 

ensure representation of the local economies.

Response

A comment expressed concern that there is no change in the economic impacts of recreation among 

alternatives. This occurs because the Forest has been unable to estimate the change in recreational use 

across the alternatives. Without changes in recreational outputs or use, the estimates of economic impact 

will remain the same among alternatives.

Public Concern #881

The Forest Service should not rely on the IMPLAN modeling software and the underlying economic base 

theory to provide a picture of what is the “total economic contribution [of the SNF] to the local economy 

(DEIS pp 577-8).” IMPLAN, while useful for appraising the total economic impacts of a forest plan, is 

insufficient for evaluating impacts on communities. IMPLAN has an additional shortcoming for assessing 

community impacts in that the economic data used to construct IMPLAN do not provide comparable 

details for all resource-based sectors of the economy.

Response

The standard terminology for input-output analysis refers to total economic contribution as the sum of 

direct and secondary effects. In this sense, total refers to the sum of direct and secondary impacts, not the 

sum of all conceivable economic contributions.
Shoshone National Forest Land Management Plan Revision

946

Perhaps total economic contributions in terms of jobs and income would be more definitive. However, 

this seems to primarily be a matter of semantics.

Public Concern #883

The Forest Service should not use input-output models like IMPLAN since they do not estimate the total 

economic contribution to the economy. The main way input-output models specifically and economic base 

models generally adjust to a decrease in supply or demand, for example, is through unemployment and 

the idling of production plants. As a result, input-output analysis is well known to predict higher 

multiplier effects than are actually experienced

Response

The contribution analysis completed for the EIS describes those resource outputs provided by Forest 

Service programs and budgets that individuals within the study area used to produce jobs and income. 

The IMPLAN model was the tool used to complete this analysis.

Subject: 2453 - Social and Economic - Affected environment

Public Concern #845

The Forest Service needs to re-examine the grazing scenario employment numbers as they are 

considerably lower than the number on Table 3, page 20 of the Shoshone Cooperating Agency Coalition 

(SCAC) comment letter, which minimizes the impacts of grazing across alternatives and in relation to 

other resources uses. The current impact analysis does not provide enough information on the differences 

among alternatives to conclude that Alternative B provides the highest net public benefits (Table 4, page 

24, of the SCAC comment letter), the

Forest should clarify these differences as well as discuss the impacts to the communities of the impact 

area instead of just the impacts to the Forest or Forest resources. The DEIS economic analyses should 

include some of the impacts of the Shoshone on nearby communities as income is generated from the use 

of backcountry and snowmobile use as well as nearby residences that were established to take advantage 

of living in a wild and scenic environment and the local businesses that support recreation and the local 

community .

Response

The livestock grazing analysis completed for the FEIS used the more robust level of grazing impact from 

the University of Wyoming study. In addition, some general information concerning the ranching industry 

has been included in the analysis.

Public Concern #846

The Forest Service should ensure the sustainability of the economic diversity through conservation of the 

region’s natural resources. Fishing, hunting, and wildlife related activities are a sustainable part of the 

economy and must be considered in the process of the Shoshone National Forest planning process.

Response

Fishing, hunting, and wildlife-related activities were included and considered in the social and economic 

analysis of the FEIS for the Shoshone National Forest Land Management Plan. The comment suggested 

that “sustaining the economic diversity will depend on the conservation of the regions natural resources.” 

But conservation of the region’s natural resources represents economic specialization rather than 

economic diversity. A balance between conservation and development represents economic diversity, 

which is what the different alternatives attempt to do in the revised Forest Plan.
Final Environmental Impact Statement -- Appendix A

947

Subject: 2454 - Social and Economic - Desired condition

Public Concern #847

The Forest Service should proceed with active logging since it will contribute to forest health and 

positively affect local businesses including the construction industry and create additional employment 

opportunities. The Forest should ensure that there is no loss of wildlife in that it negatively impact local 

businesses.

Response

The revised Forest Plan directs the continuation of the Forest’s timber management program at a level 

similar to that of the 1986 Plan. The revised Forest Plan provides direction for protecting habitat for listed 

species, sensitive species, management indicator species, and species of local concern. The contribution 

of commercial timber use from the Forest to the study area is included in the economic analysis.

Subject: 2455 - Social and Economic - Direct and indirect effects include 

general effects

Public Concern #848

The Forest Service should promote snowmobiling on the Shoshone, not close any additional lands to 

snowmobiling since 80% of the forest is already closed. Areas of the Shoshone up for closure to 

snowmobiling such as Togwotee Pass are world famous in the snowmobile community, if closed tourism 

to the region would decline, greatly impacting many of the lodging and other businesses in the area which 

provide substantial revenue for the state of Wyoming. The Forest Service should focus more on the 

tourism and recreation of the Shoshone rather than the mineral development in that the tourism industry 

provides stability and employment for the people of Dubois and other parts of the state. The Forest should 

not close any areas to mountain cycling, as this too provides a positive economic benefit to local business.

Response

“A diversity of year round recreation opportunities attracts increasing numbers of visitors to the 

Shoshone, thereby providing economic and social benefits to local communities.”

The intent of the revised Forest Plan is to leave open for winter motorized use all of the areas currently 

being used by snowmobilers. Areas closed to winter motorized use are generally for reasons of 

compliance with wilderness regulations or the protection of crucial winter range for wildlife, or both. 

Specific closure information is included in the recreation section of the EIS. The contribution of 

snowmobile use on the Forest to the study area is included in the economic analysis.

See also, PCs #826 and #827 concerning tourism as a stable industry.

Public Concern #849

The Forest Service should not allow any drilling rigs and associated roads and increased vehicle traffic 

as it will be detrimental to businesses that depend on the unspoiled beauty for tourism.

Response

Please see response to PC #835. Oil and gas drilling on National Forest System lands is an appropriate 

use where an oil and gas leasing decision has been made. All management decisions of the Shoshone 

National Forest are a balance between different types of users and different types of industries, all with 

different needs and values of public resources.

For study area social and economic impacts, the EIS includes the potential impacts of tourism.
Shoshone National Forest Land Management Plan Revision

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Public Concern #880

The Forest Service should consider the full range of economic values of the SNF. Inclusion of the nonlabor income of amenity residents (measured in the DEIS as the excess of non-labor income of SNF 

region residents over the state average) is incomplete. People migrate to areas during their working years 

and in a wide range of occupations and industries. To provide a complete picture of the contribution of 

the SNF to the regional economy, the EIS should include a portion of the jobs and incomes of all residents 

as dependent on or related to the attractive amenities of the SNF. There is likely to be significant labor 

income of amenity residents that depends on the SNF’s scenic, recreational and other amenities.

Response

While some portion of labor income within the study area may be due to amenities of the Shoshone 

National Forest, the actual amount is difficult to quantify and is beyond the scope of the EIS. First, this 

may not apply to all residents; some residents may have little or no appreciation for the Forest’s 

amenities. Second, there are a number of natural resource amenities in the region, so it would be difficult 

to determine the specific contribution of the Shoshone National Forest versus the others (Yellowstone 

National Park, Teton National Park, etc.). Lastly, the Shoshone and other amenities in the region may 

actually reduce labor income in the region because individuals may be willing to forego higher wages 

somewhere else to live near the amenities.

See also responses related to oil and gas PC #681 regarding potential harm and impacts to water resources 

and PC #682 regarding potential for development.

Public Concern #882

The Forest Service mis-states that “the economic and social impacts [of SNF management] are 

considered indirect as they are the result of a direct resource action taking place on NFS lands (timber 

sale, outfitter/guide permit, grazing permit, etc.) (p. 578).” But these actions do produce direct effects, 

such as the processing of timber, the sale of guiding services or the production of livestock. Indirect 

effects, by contrast, would include the purchase of goods and services by timber processors, guides and 

livestock producers from other firms. (Input-output analysis also estimates induced effects, which is the 

economic activity that results when the employees of the firms responsible for the direct and indirect 

effects spend their wages on goods and services locally.)

Response

The commenters are confusing direct and indirect in an economic base sense with direct and indirect in 

the sense of cause and effect. Again, this seems mostly a matter of semantics.

Public Concern #884

The Forest Service should present a full picture of the importance of the economic contributions of the 

wild, backcountry forest of the Shoshone National Forest to the economy of local area economic health 

and vitality of the three county region. The natural assets support the following the economic 

contributions:

- A strong travel and tourism based sector, bolstered by world-class hunting, fishing and outdoor 

recreation opportunities;

- A diverse recreational sector, including small businesses, guiding and commercial outfitting businesses;

- A world-recognized educational institution and a growing outdoor education sector;

- A local small business and retiree investment sector attracted by high quality of life;
Final Environmental Impact Statement -- Appendix A

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- A thriving farm and ranch sector; and

- World class opportunities for hunting, fishing and outdoor recreation for residents and visitors.

Response

The DEIS does include a contribution analysis of current activity by forest sector (recreation/tourism, 

livestock grazing, wood products, and mineral/oil/gas) for the study area. There is also an analysis by 

sector for each alternative for the study area. Local-level analysis is not completed for forest plan-level 

analysis due to the data available for outputs. It would also require a great deal of speculation to predict 

which communities would likely receive resource outputs over another community. For a variety of 

reasons, Forest Service analysis is not prepared for selectiing “winners or losers” but to show the relative 

difference among alternatives for forest plan analysis. When implementing the revised Forest Plan, 

project-level NEPA analysis will continue to include social and economic analysis to address these issues 

if they are raised, and are more likely to be addressed at a local scale.

Public Concern #885

The Forest Service should evaluate the economic impacts of harmful effects to wildlife, undeveloped 

backcountry character, and other resources (e.g., air and water quality) from differing levels of oil and 

gas activity, particularly from surface development.

Response

The Shoshone has identified lands available for oil and gas leasing. Current industry demand for oil and 

gas leases on the Forest is minimal. A recent survey of industry indicated that demand for oil and gas 

leases on the Forest is expected to remain very low into the foreseeable future. Economic impact to the 

study area from oil and gas leases would only occur if a private company determined resources on the 

Shoshone were profitable to develop. Currently, there is no activity, with no interest, so the economic 

analysis does not include any oil or gas impact under any of the alternatives.

Public Concern #886

The Forest Service should to take into account the economic contributions of outdoor educational 

institutions, such as the National Outdoor Leadership School (NOLS), The Wyoming Catholic College, 

Central Wyoming Community College and others that are dependent on the recreational and backcountry 

classroom opportunities provided on the SNF.

Response

To the extent that NOLS activities occur on the Shoshone National Forest, its economic contribution is 

considered through the commercial recreation analysis. However, since NOLS uses a number of areas in 

the region in addition to the Forest, it is not appropriate to attribute the entire NOLS operation to the 

Shoshone NF.

Public Concern #887

The Forest Service should consider the contributions of other businesses that due to the growth of the 

information and technical global economy and the ability to work remotely, businesses and professional 

can increasingly locate where they choose to live for lifestyle, and bring their businesses and work with 

them

Response

Between 2001 and 2011, the percent of total employment from the private service sector declined from 

56.1 percent to 55.1 percent in Fremont County. The percent of total labor earnings from the private 

service sector declined from 48.6 percent to 43.9 percent in Fremont County and average earnings per job 
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declined from 86.7 percent of the Fremont County average to 79.6 percent of the county average. So, it 

does not appear that private service sector in Fremont County was the fastest growing sector in the county 

during the last 10 years, and that labor earnings in the private service sector in Fremont County were 

increasing relative to other sectors in the county during the last 10 years.

Public Concern #888

The Forest Service should use the job figures developed by the US Department of Commerce about actual 

timber jobs to correct the over-representation of the timber/wood products industry job information used 

in the DEIS since there are no active mills in the three county region.

Response

Although there are no active sawmills in the region, there are other timber-related jobs in the study area, 

such as logging or independent workers. The numbers referenced in this comment in the Bureau of 

Economic Analysis Regional Economic Information System were not available for consideration.

In recent years, neither the Bureau of Economic Analysis nor Bureau of Labor Statistics has reported 

timber employment or earnings for Wyoming. The EIS relied on the University of Montana survey data 

for the intermountain region to estimate the economic impact of timber harvest activity on the Shoshone 

National Forest study area.

Subject: 2456 - Social and Economic - Cumulative effects

Public Concern #850

The Forest Service should provide detailed information of where and to whom the considerable impacts 

will occur and not just an analysis of the negligible impacts across the planning area.

Response

Community-level analysis is not completed for forest plan-level analysis due to the data available for 

outputs. It would also require a great deal of speculation to predict which communities would likely 

receive resource outputs over another community. For a variety of reasons, Forest Service analysis is not 

prepared for selecting“winners or losers” but to show the relative difference among alternatives. When 

implementing the revised Forest Plan, project-level NEPA analysis will continue to include social and 

economic analysis to address these issues if they are raised, and are more likely to be addressed at a local 

scale.

Subject: 2458 - Social and Economic - Incomplete and unavailable 

information

Public Concern #851

The Forest Service should provide enough information on the differences among the alternatives to 

conclude that Alternative B provides the highest net public benefits and to provide detailed information of 

where and to whom the considerable impacts will occur and not just an analysis of the negligible impacts 

across the planning area. The Forest should provide a more detailed analysis of the economic 

contributions of the various components of outdoor recreation and incorporated into the final plan to 

break down the economic impact differences between motorized and non-motorized recreation.

Response

Community-level analysis is not completed for forest plan-level analysis due to the data available for 

outputs. It would also require a great deal of speculation to predict which communities would likely 
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receive resource outputs over another community. For a variety of reasons, Forest Service analysis is not 

prepared for selecting “winners or losers” but to show the relative difference among alternatives.

Specifically, accurate spending data (that meets Data Quality Act requirements) are not available to 

complete an analysis to compare differences between motorized and non-motorized use on the Shoshone 

National Forest. When implementing the revised Forest Plan, project-level NEPA analysis will continue to 

include social and economic analysis to address these issues if they are raised, and are more likely to be 

addressed at a local scale.

Subject: 2459 - Social and Economic - Monitoring

Public Concern #661

The Forest Service should consider incorporating social indicators into the plan and addressing 

indicators such as quantity of off road, Christmas tree and firewood permits issued to local residents as 

well as utilization of campgrounds within the forest.

Response

Though not gathered through the revised Forest Plan, many of these types of items are gathered in a form 

that does not differentiate between local residents and others. The social and economic analysis includes 

discussions of Fremont, Hot Springs, and Park counties using available data. Collecting information to 

differentiate the data would take additional resources that are already limited. We will review the data 

already collected to determine if it can differentiate between local and non-local residents and consider 

including those.

Subject: 2477 - Social and Economic - Public Involvement - General

Public Concern #852

The Forest Service should work cooperatively with various funding sources to leverage additional federal 

or state grants.

Response

The Forest will continue to pursue partnerships and cooperative agreements with the State and other 

Federal agencies under the direction of the revised Forest Plan.

Public Concern #853

The Forest Service should notify the public and allow public comment on energy development projects 

involving all public lands and resources along with all information regarding modifications to the current 

development plans and allow sufficient time for public comment and ensure that all meetings are part of 

the public record. Up to date information regarding energy development projects should be provided 

through a range of media and informational outlets to the public. The Forest Service should ensure that 

coordination is maintained between all stakeholders and experts that manage fish and wildlife at the 

local, state, and national levels to ensure that fish and wildlife are properly managed during energy 

project planning, implementation, and after development to ensure sustainability.

Response

The Forest Service follows all National Environmental Policy Act regulations including public 

involvement and notification when proposing, analyzing effects on affected resources, and implementing 

energy development projects. The Schedule of Proposed Actions (SOPA) contains a list of proposed 

actions that will begin or are currently undergoing environmental analysis and documentation. See 
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http://www.fs.usda.gov/projects/shoshone/landmanagement/projects. Interested individuals may direct 

questions and comments regarding projects listed in the SOPA to the project contact shown in the SOPA.

Public Concern #854

Direct and manage leasing and development using complete and up-to-date baseline information on fish 

and wildlife resources.

Response

The Forest Service follows all National Environmental Policy Act regulations and the Endangered 

Species Act when proposing, analyzing, and implementing energy development projects. The best 

available information is considered during environmental analyses.

Subject: 2501 - Other Required Disclosures - Environmental Justice

Public Concern #855

The Forest Service should consider the issue of restricting access to the elderly and disabled to the forest.

Response

While not all portions of the Forest are accessible, any developed sites are engineered or upgraded to 

proper Americans with Disabilities Act (ADA) standards to allow access where improvements to forest 

resources have been made. In undeveloped or dispersed areas of the Forest, access is varied by travel 

management decisions and by resource or terrain.

Pack animals that do not pose disease transference issues including llamas, horses, donkeys, and 

assistance dogs are not restricted for use by elderly forest visitors. See also PC #228 pertaining to use of 

pack goats and transmission of disease to native bighorn sheep.

Subject: 2503 - Other Required Disclosures -Potential Conflicts with Goals 

and Objectives of Other Agencies

Public Concern #856

The Forest Service needs to address the following potential conflicts with local agencies: (1) 

Inconsistencies between the Forest Plan and DEIS with the County and Conservation District Land Use 

Plans and the Forest is not in agreement with CEQ Section 1506.2 – Elimination of Duplication with 

State and Local Procedures. (2) In areas where the Forest Service’s preferred alternative is inconsistent 

with adjacent BLM, state, private, or tribal land management, which includes the Absaroka Front, Wood 

River, Franc’s Peak, Dunoir, and Dubois area, the Forest should take action to keep fish and wildlife and 

protections and land management practices consistent and contiguous, especially regarding oil and 

mineral leasing and no surface occupancy

Response

We reviewed adjacent land use plans and met with BLM and State agencies to address differences along 

boundaries. The revised Forest Plan has been edited to reflect changes for management approaches to be 

consistent across boundaries. We edited the other required disclosure section of the FEIS to clarify the 

potential conflicts with goals and objectives of other agencies.
Final Environmental Impact Statement -- Appendix A

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Subject: 2600 - Appendix A – Public Involvement

Public Concern #858

The Forest Service should address the following in the draft process: (1) Problems and obstacles in the 

planning process when measured against the requirements of the 1982 Planning Rue (219.12) and the 

CEQ regulation for implementing NEPA. (2) The DEIS and Draft plan are confusing and not consistent 

with many of the maps, tables, and narratives not in agreement and should be corrected.

Response

(1) The DEIS summary (p. viii) and chapter 1 (p.5), explained the use of some of the information from 

public involvement efforts conducted in 2005 through 2009, and the development of the revision 

topics. The notice of intent (NOI) to prepare an environmental impact statement was published in the 

Federal Register on September 24, 2010. The comments in response to the NOI were considered (see 

also DEIS appendix A). The revision topics were identified repeatedly in public meetings held across 

the Forest and by the Government Cooperators Work Group from 2005 through 2010, and validated 

during the scoping period in late 2010.

♦ CEQ regulations at 1501.6 note the purpose of that section is to emphasize agency cooperation 

early in the NEPA process. FSH 1909.15, 11.31a and 11.31b note the roles of Lead and 

Cooperating Agencies. Agencies are encouraged to document the cooperating agency agreements; 

however, this is not a requirement. The Forest involved the Government Cooperators Work Group 

from 2005 through 2010, in developing revision topics and has continued with cooperator 

meetings from February through December 2011, to clarify and refine the revision topics, and to 

refine the proposed draft of the revised Shoshone National Forest Land and Resource 

Management Plan (proposed draft revised Plan). On January 4, 2012, the proposed draft revised 

Plan was sent out for public comment. The Forest has continued to meet with the Government 

Cooperators Work Group to clarify comments received on the DEIS and adjustments in response 

to comments.

♦ The “proposed action” or preferred alternative, was developed in response to the purpose and 

need and incorporated public comments from 2005 through 2009 in preparing the proposed draft 

revised Plan, released for comment January 4, 2012.

♦ Available data were used in the analysis. Databases are continually refined and updated. For the 

analysis in support of the DEIS the Forest database was ”frozen” to have a point in time database 

for analysis of effects.

♦ The Analysis of the Management Situation was made available on the Forest website. Baseline 

and benchmark data are not completed until the PDEIS is released

(2) Lack of data prevents consideration of a full range of alternatives. The Forest database was made 

available to interested parties upon request.

 Maps and tables have been reviewed between the Draft Plan and the DEIS and will be corrected in 

the final documents.

Public Concern #859

The Forest Service should notify the public and allow public comment on energy development projects 

involving public lands or resources and provide the public with information regarding modifications to 

current development plans. The Forest should also establish partnerships with public groups and reach 

out to members to for assistance to any management challenges or opportunities.
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Response

The forest plan revision effort provides direction for the National Forest System lands. Each energy 

development proposal involving National Forest System lands would be analyzed when received in a sitespecific analysis, including public notice and comment periods.

As opportunities arise, the Forest encourages partnerships with public groups for various management 

challenges and opportunities. Site-specific project analyses and partnership opportunities are outside the 

scope of the forest plan revision effort, and will be considered when proposed.

Subject: 2800 - Appendix C Evaluated Areas for Potential Wilderness

Public Concern #860

The Forest Service should consider recommending to the United States Congress the creation of the 

following areas as new roadless and wilderness areas as outlined in Alternative D (and all of the priority 

one areas) for the scenic qualities, important wildlife habitat, winter range and migration corridors, the 

non-motorized recreation opportunities, and the proximity to Yellowstone National Park. The Forest 

Service should consider protection and preservation of the proposed wilderness areas for future 

generations. (North Absaroka Wilderness, Dead Indian Creek, Warm Springs Creek, Wiggins Fork, Rock 

Creek Area, Sunlight Basin, Blackwater Creek, Little Popo Agie Canyon, Sulphur Creek, Double Canyon, 

Jojo Mountain, Middle Fork, South Fork Shoshone, Wapiti Valley South, Elk Creek, Line Creek Research 

Natural Area, Deep Lake).

Response

See PC #27.

Public Concern #861

The Forest Service should consider broadening the assessment in the DEIS to include a perspective of the 

National distribution and availability of wilderness and clarifying pages 105-106 of Appendix C for no 

wilderness recommended. The Forest Service should clarify how the ratings for wilderness 

recommendation were used in the alternatives and raise the rating to High and change the management 

direction to adapt accordingly.

Response

The wilderness needs assessment in appendix C of the EIS follows Forest Service Handbook Direction 

(1909.12 Chap 72.3). The factor that is to be applied nationally is tied to landform types and ecosystems 

represented in the National Wilderness System. We will review the assessment between draft and final to 

improve the clarity of the presentation. Though some factors in the assessment come out as low others 

come out as high.

Three wilderness recommendation scenarios are represented in the alternatives. Alternatives B, E, F and 

G recommend no new wilderness. Alternative D recommends seven wilderness evaluation areas for 

wilderness designation. These seven areas represent the areas that based upon public input had the highest 

level of public support. Alternative C recommends 23 wilderness evaluation areas for wilderness 

designation. Two screens were used in combination to decide what areas to include in this alternative. The 

need criteria related to providing habitat for species that use primitive habitat and for providing 

representative landforms was one screen. The second was whether there was some public support stated 

for the specific area based upon public input. As a result of these two screens, 14 of the 15 wilderness 

evaluation areas that rated high for the two need criteria are included in alternative C.
Final Environmental Impact Statement -- Appendix A

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The decision maker will consider the public comments requesting more wilderness in addition to other 

public comments in making the final decision.

Subject: 2806 - Appendix C Evaluated Areas for Potential Wilderness Trout 

Creek 02044

Public Concern #862

The Forest Service should consider recommending to the United States Congress the creation of Trout 

Creek roadless area as a new wilderness area as outlined in Alternative D because of its value in 

backcountry non-motorized/non-mechanized recreation, wildlife conservation, watershed for production 

and delivery of clean water, native fisheries, and the crucial habitat for big game and winter range for 

bighorn sheep and elk, and Grizzly Bear primary conservation area. The areas historic, economic, 

cultural values as well as scenic landscapes should be preserved for future generations without an option 

for oil and gas exploration and removal.

Response

See PC #27.

Subject: 2813 - Appendix C Evaluated Areas for Potential Wilderness 

Franc’s Peak 02051

Public Concern #863

The Forest Service should consider recommending to the United States Congress the designation of 

Franc’s Peak roadless area as a new wilderness area as outlined in Alternative D because of its value in 

backcountry non-motorized/non-mechanized recreation, wildlife conservation, watershed, native fisheries 

and protection for the crucial habitat for grizzly bear, pronghorn, a lynx analysis unit big game and 

winter range for bighorn sheep and elk. The areas historic, economic, cultural values as well as scenic 

landscapes should be preserved for future generations without an option for oil and gas exploration and 

removal, and without the addition of new roads or trails.

Response

See PC #27.

Subject: 2814 - Appendix C Evaluated Areas for Potential Wilderness Wood 

River 02052

Public Concern #864

The Forest Service should consider recommending to the United States Congress the designation of 

Franc’s Peak roadless area as a new wilderness area as outlined in Alternative D because of its value in 

backcountry non-motorized/non-mechanized recreation, hunting, wildlife conservation, watershed, native 

fisheries and protection for all mammals, and for the crucial habitat for grizzly bear, pronghorn, a lynx 

analysis unit big game and winter range for bighorn sheep and elk. The areas historic, economic, cultural 

values as well as scenic landscapes, and unique geographic features should be preserved for future 

generations without an option for oil and gas exploration and removal, and without the addition of new 

roads or trails. The Forest Service should consider expanding the opportunities for commercial guiding 

and ecotourism in the backcountry.

Response

See PC #27.
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Subject: 2819 - Appendix C Evaluated Areas for Potential Wilderness 

Dunoir 02058

Public Concern #865

The Forest Service should consider recommending to the United States Congress the designation of 

Franc’s Peak roadless area as a new wilderness area as outlined in Alternative D because of its value in 

backcountry non-motorized/non-mechanized recreation, hunting, wildlife conservation, watersheds for 

production and delivery of clean water, native fisheries and protection for all mammals, and for the 

crucial habitat for grizzly bear, wolves, a lynx analysis unit big game and winter range for bighorn sheep 

and elk. The areas historic, economic, cultural values as well as scenic landscapes, and unique 

geographic features should be preserved for future generations without an option for oil and gas 

exploration and removal, and without the addition of new roads or trails. The Forest Service should 

consider expanding the opportunities for ecotourism in the backcountry.

Response

See PC #27.

Subject: 2829 - Appendix C Evaluated Areas for Potential Wilderness 

Togwotee Pass 02903

Public Concern #866

The Forest Service should consider recommending to the United States Congress the creation of Togwotee 

Pass as a new wilderness area as outlined in Alternative D because of its value in backcountry winter 

non-motorized/non-mechanized recreation. Motorized use is incompatible with the quiet and clean 

recreation experience of the high elevation and diverse mountain terrain.

Response

See PC #27.

Public Concern #867

The Forest Service should not consider adding any more wilderness areas in the Togwotee Pass area. 

Response 

See PC #27.

Public Concern #868

The Forest Service should keep Togwotee Pass, especially the Two Ocean area, as backcountry recreation 

summer motorized with winter non-motorized to create a peaceful, enjoyable, and safe recreation area for 

non-motorized winter use as outlined in Alternative D.

Response

See PC #399.

Subject: 2833 - Appendix C Evaluated Areas for Potential Wilderness High 

Lakes 02915

Public Concern #869

The Forest Service should consider recommending to Congress the designation of the High Lakes as a 

wilderness area because it deserves wilderness protection.
Final Environmental Impact Statement -- Appendix A

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Response

See PC #27.

Public Concern #870

The Forest Service should not consider recommending to Congress the designation of the High Lakes as a 

wilderness area because I am against any more wildernesses in the High Lakes area.

Response

See PC #27.

Subject: 2900 - Appendix D Wild and Scenic River Eligibility Evaluation –

General

Public Concern #871

The Forest Service should consider not recommending any rivers at this time for Wild and Scenic 

designation, until the recommendation is initiated by proposed impacts or conservation efforts.

Response

The revised Forest Plan does not designate or recommend wild and scenic rivers; only eligibility 

determinations are made in a forest plan.

Public Concern #872

The Forest Service should consider ensuring that the Wild and Scenic Eligibility Inventory is kept up to 

date at all times, in order to provide detailed clarification on how rivers and streams are, or are not, 

selected. Information on selection, or non-selection, for all rivers and streams that were analyzed should 

be included in the final Forest Plan.

Response

Wild and Scenic River eligibility determinations are done on an as-needed basis typically in association 

with forest plan revisions.

See PC #773 items 2 through 5.

Public Concern #873

The Forest Service should go forth with recommending the 13 river segments for Wild and Scenic River 

Eligibility, with some modification, and evaluate more areas for this designation. Please see comment 9

from contact number 879 for detailed table of suggested modifications.

Response

See PC #871.

Public Concern #874

The Forest Service should consider recommending the following rivers and/or streams to the Wild and 

Scenic category. (1) Sunlight Creek, for its scenic and recreational paddling ORVs; (2) Crandall Creek; 

(3) North Fork Popo Agie; (4) Grinnell Creek; (5) Warm Springs Creek (recreational paddling ORV); (6) 

Wiggins Fork (recreational paddling ORV); (7) Clark’s Fork (scenic, recreational ORV, moose and grizzly 

habitat); (8) North Fork Shoshone (grizzly habitat and large big-horn sheep population); (9) South Fork 

Shoshone (grizzly and big-horn sheep habitat, cutthroat trout fisheries, recreation); (10) West Fork 

Dunoir (grizzly and potential wilderness designation); (11) Wood River (wilderness, scenic, pure strain 
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Yellowstone cutthroat trout population). If these additional requests are not found suitable for 

recommendation, please provide detailed analysis for decision.

Response

See PC #871 and PC #773 items 2 through 5.

Subject: 3000 - Appendix E - Maps General

Public Concern #875

The Forest Service should consider adding a map for the Class 1, Class 2 and Class 3 watersheds on 

pages 65 and 71.

Response

A map of Class 1, 2, and 3 watersheds will be added to the FEIS.

Public Concern #876

The Forest Service should consider adding a map that shows land capable of supporting grazing, with 

attention to the areas found suitable for grazing for each alternative. The slope criteria that should be 

used is that slopes greater than 60% do not support grazing; slopes between 40-60% support sheep 

grazing, and slopes less than 40% support sheep and cattle grazing.

Response

Appendix E maps for grazing will be modified to show suitable areas for sheep grazing and livestock 

grazing.

Subject: 3100 - Commercial Livestock Allotment Capable and Suitable 

Acres and AUMS - General

Public Concern #877

The Forest Service should not recommend Alternative C as it reduces the Animal Unit Months (AUM) and 

this lowers the ability to manage livestock grazing. AUMs should be allowed to be increased when 

necessary and vacant grazing lots should be able to be utilized on a temporary or long term permit basis.

Response

The decision maker will consider public comments that oppose the livestock grazing in alternative C 

along with other public comments that are in favor of those reductions in making the final decision.

Public Concern #878

The Forest Service should consider reevaluating the capability and suitability analysis using the Rocky 

Mountain Region 2 Process Paper, because what was presented in the plan is inaccurate. Slopes greater 

than 40% should not have been removed from analysis, as these lands are potentially capable for grazing 

by sheep. All capable land should be included in the analysis, with the suitability analysis determining the 

variations by alternatives.

Response

See response to PC #876.
Final Environmental Impact Statement -- Appendix A

959

Prepared by

Interdisciplinary Team Members:

Name Position

Joseph Alexander Forest Supervisor

Bryan Armel Resource Staff Officer

Carrie Christman Planning Staff Officer

Mark Giacoletto Forest Fire Management Officer

Joe Harper Forest Wildlife Biologist

Joe Hicks Rangeland Management Specialist

Kent Houston Forest Soil Scientist/Botany/Weeds

Ben Lara Recreation Specialist

Karin Lovgren Engineering Staff Officer

Lois Pfeffer Environmental Coordinator

Kelsey Pike Editorial Assistant

Loren Poppert Recreation Staff Officer

Randy Spiering Timber Management Officer

Paul Valcarce Landscape Architect

Kyle Wright Archaeologist 

Ray Zubik Forest Fisheries Biologist 

Content Analysis Team

Name Position

Bill Overland Content Analysis Lead

Ann Braun Program Support

Nicole Dougherty Program Support

Seth Steadman Archaeological Technician

Chad Hovis Archaeological Technician

Katherine Malengo Wildlife Biologist

Katherine Carsey Botanist

Steve Overton Forester

Frank Yurczyk Forester

Final Environmental Impact Statement -- Appendix A

961

Comments from Federal, State and Local Agencies, and Elected 

Officials

We received letters from the following Federal, State and local agencies, and elected officials. Letters are 

reproduced on the following pages.

Department of Environmental Quality

Hot Springs County Planner

Meeteetse Conservation District

Office of The Governor

Park County Historic Preservation Commission

Shoshone Cooperating Agency Coalition

State Historic Preservation Office

United States Department of Interior

United States Environmental Protection Agency Region 8

Wyoming Department Of Agriculture

Wyoming Department of State Parks And Cultural ResourcesState Trails Program

Wyoming Game and Fish Department

Wyoming Legislative Service Office

Wyoming State Forestry Division

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Final Environmental Impact Statement -- Appendix A

1019
Shoshone National Forest Land Management Plan Revision

1020
Final Environmental Impact Statement -- Appendix A

1021
Shoshone National Forest Land Management Plan Revision

1022
Final Environmental Impact Statement -- Appendix A

1023
Shoshone National Forest Land Management Plan Revision

1024
Final Environmental Impact Statement -- Appendix A

1025
Shoshone National Forest Land Management Plan Revision

1026
Final Environmental Impact Statement -- Appendix A

1027
Shoshone National Forest Land Management Plan Revision

1028
Final Environmental Impact Statement -- Appendix A

1029
Shoshone National Forest Land Management Plan Revision

1030
Final Environmental Impact Statement -- Appendix A

1031
Shoshone National Forest Land Management Plan Revision

1032
Final Environmental Impact Statement -- Appendix A

1033
Shoshone National Forest Land Management Plan Revision

1034
Final Environmental Impact Statement -- Appendix A

1035
Shoshone National Forest Land Management Plan Revision

1036
Final Environmental Impact Statement -- Appendix A

1037
Shoshone National Forest Land Management Plan Revision

1038
Final Environmental Impact Statement -- Appendix A

1039
Shoshone National Forest Land Management Plan Revision

1040
Final Environmental Impact Statement -- Appendix A

1041
Shoshone National Forest Land Management Plan Revision

1042
Final Environmental Impact Statement -- Appendix A

1043
Shoshone National Forest Land Management Plan Revision

1044
Final Environmental Impact Statement -- Appendix A

1045
Shoshone National Forest Land Management Plan Revision

1046
Final Environmental Impact Statement -- Appendix A

1047
Shoshone National Forest Land Management Plan Revision

1048
Final Environmental Impact Statement -- Appendix A

1049
Shoshone National Forest Land Management Plan Revision

1050
Final Environmental Impact Statement -- Appendix A

1051
Shoshone National Forest Land Management Plan Revision

1052
Final Environmental Impact Statement -- Appendix A

1053
Shoshone National Forest Land Management Plan Revision

1054
Final Environmental Impact Statement -- Appendix A

1055
Shoshone National Forest Land Management Plan Revision

1056
Final Environmental Impact Statement -- Appendix A

1057
Shoshone National Forest Land Management Plan Revision

1058
Final Environmental Impact Statement -- Appendix A

1059
Shoshone National Forest Land Management Plan Revision

1060
Final Environmental Impact Statement -- Appendix A

1061
Shoshone National Forest Land Management Plan Revision

1062
Final Environmental Impact Statement -- Appendix A

1063
Shoshone National Forest Land Management Plan Revision

1064
Final Environmental Impact Statement -- Appendix A

1065
Shoshone National Forest Land Management Plan Revision

1066
Final Environmental Impact Statement -- Appendix A

1067
Shoshone National Forest Land Management Plan Revision

1068
Final Environmental Impact Statement -- Appendix A

1069
Shoshone National Forest Land Management Plan Revision

1070
Final Environmental Impact Statement -- Appendix A

1071
Shoshone National Forest Land Management Plan Revision

1072
Final Environmental Impact Statement -- Appendix A

1073
Shoshone National Forest Land Management Plan Revision

1074
Final Environmental Impact Statement -- Appendix A

1075
Shoshone National Forest Land Management Plan Revision

1076
Final Environmental Impact Statement -- Appendix A

1077
Shoshone National Forest Land Management Plan Revision

1078
Final Environmental Impact Statement -- Appendix A

1079
Shoshone National Forest Land Management Plan Revision

1080
Final Environmental Impact Statement -- Appendix A

1081
Shoshone National Forest Land Management Plan Revision

1082
Final Environmental Impact Statement -- Appendix A

1083
Shoshone National Forest Land Management Plan Revision

1084
Final Environmental Impact Statement -- Appendix A

1085
Shoshone National Forest Land Management Plan Revision

1086
Final Environmental Impact Statement -- Appendix A

1087
Shoshone National Forest Land Management Plan Revision

1088
Final Environmental Impact Statement -- Appendix A

1089
Shoshone National Forest Land Management Plan Revision

1090
Final Environmental Impact Statement -- Appendix A

1091
Shoshone National Forest Land Management Plan Revision

1092