Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-1 

Chapter 5: Response to Comments 

5.1 PUBLIC COMMENT ANALYSIS PROCESS 

Content analysis of comments received on the DEIS was conducted. Public comments were received 

in the form of letters or postcards, electronic mail (e-mail), phone calls, and facsimiles. A Content 

Analysis Team reviewed all the comments on the DEIS. Substantive comments from each letter, email, or form were identified. Each issue or topic was assigned to a subject area and a response 

number and the various comments dealing with that topic or issue were grouped under the response 

number heading. A response was written for each topic or issue that was identified. All of the 

responses are grouped by subject area and provided in this chapter. 

Respondent’s and agency names are listed below with response numbers to allow the reader to see 

how their comments were responded to or used. Persons wishing to find responses to their comments 

on the DEIS should locate their name and assigned codes below and the corresponding ID Team 

response. For example: 

Colstrip Sportsman Club MGMT-5, MISC-8, MISC-9, R-3 

White, Kathleen MISC-2, WL-3, R-14 

The only agency comment letters received on the project were from the Environmental Protection 

Agency and USDI-Office of Environmental Policy and Compliance. These letters are included in 

Appendix E. 

Agency Names DEIS Response Numbers 

U.S. Environmental Protection Agency, Region 8 

MT Office 

F-1, F-2, MGMT-1, MISC-1, MISC-2, S-1, V-1, WQ-1, 

WQ-1, WQ-2, WQ-3 

USDI Office of Environmental Policy & 

Compliance No Comment 

Organization Names DEIS Response Numbers

Capital Trail Vehicle Association E-2, MISC-1, MISC-14, MISC-5, S-2, R-7, R-8, R-9, R-10, 

R-11, R-4, R-6, R-12, R-13 

Colstrip Sportsman Club MGMT-4, MISC-8, MISC-9, R-3 

Treasure State ATV Association C-4, E-3, MISC-3, MISC-7, R-3, R-5 

Wildlands CPR 

C-1, F-3, F-4, F-5, MGMT-1, MGMT-2, MGMT-3, 

MISC-1, MISC-2, MISC-6, R-1, R-14, S-1, S-3, V-4, V-5, 

WL-10, WL-11, WQ-1, WQ-2, WQ-5, WQ-6, WQ-7, 

WQ-8, WQ-9, WQ-10, WQ-11, WQ-16, 

Individual Names DEIS Response Numbers

Alexander, Greg R-1 

Ankrum, Daniel MISC-7 

Bates, Larry R-1 

Blalack, Russell MISC-2, R-14, WL-3 

Borsheim, Seana L. 

No Substantive Comments identified during Content 

Analysis 

Brabec, Darrell MISC-9, R-5 

Cain, Gladys 

No Substantive Comments identified during Content 

Analysis 
Chapter 5: Response to Comments 

Page 5-2 Ashland Travel Management Final EIS 

Individual Names DEIS Response Numbers

Chappel, William E-1, R-5 

Dice, Brian & Mary MISC-12 

Donner, Robert M. 

No Substantive Comments identified during Content 

Analysis 

Dudley, Wayne 

No Substantive Comments identified during Content 

Analysis 

Ferrell, Doug R-14 

Fortner, Tim & Gaylene 

No Substantive Comments identified during Content 

Analysis 

Hanson, Harold 

No Substantive Comments identified during Content 

Analysis 

Hanson, Marian A. 

No Substantive Comments identified during Content 

Analysis 

Hanson, Norma MGMT-5 

Hanson, Tary L. MGMT-5, R-5 

Hemmer, Scott R-5, R-17, WL-4 

Huffmann, Brad R-15 

Hughes, Bob R-14, WL-3 

Hughes, Sally R-14, WL-2 

Jackson, Ron MISC-3, MISC-4, R-1 

Jaquith, Phillip H. 

MGMT-2, MGMT-5, MISC-10, MISC-11, MISC-2, R-2, 

R-16, S-1, WQ-12, WQ-13, WQ-14, WQ-15, WQ-16 

Kohn, Jon & Aurora 

No Substantive Comments identified during Content 

Analysis 

Madson, Pete 

No Substantive Comments identified during Content 

Analysis 

Mathieus, George MGMT-2 

Messner, Robert 

No Substantive Comments identified during Content 

Analysis 

Montagne, Joan MISC-2, R-14, WL-3 

Musgrove, Jackie 

C-1, C-2, C-3, MGMT-2, R-5, V-2, V-3, V-6, WL-8, WL-9, 

WQ-4 

Peterson, Ole MGMT-5, R-5 

Pilski, Chris 

No Substantive Comments identified during Content 

Analysis 

Smith, Gene 

No Substantive Comments identified during Content 

Analysis 

Thorn, John R-1, R-2, R-3, WL-1, WL-3, WL-5, WL-6, WL-7, 

Wagner, Dennis 

No Substantive Comments identified during Content 

Analysis 

Weirick, Greg 

No Substantive Comments identified during Content 

Analysis 

White , Kathleen MISC-2, R-14, WL-3 

Whitehead, Robert R-5 

The following comments were received after the closing date of the comment period. Comments were reviewed 

and are address in the FEIS; however, based on 36 CFR 215.13, commenter will have not have standing for 

appeal. 

Individual Names DEIS Response Numbers

Maier, M. MISC-13, R-1, R-18 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-3 

5.2 RESPONSE TO COMMENTS 

What follows are individual or summarized comments for each of the subject areas identified through 

the content analysis process, as well as the response to those comments. If numerous similar 

comments were received on a topic, they were summarized into a single comment. The response to 

comments may be a direct response to the comment, or will note whether the comment was addressed 

by adding analysis or discussion to the FEIS. 

CULTURAL RESOURCES 

Subject: Cultural Resources Response #: C-1, Area of Potential Effects

Letter-Comment #:

8-8 

Page 3-24 states that cultural resources will be inventoried for a distance of 150 feet from the 

center of each road. The FS currently allows camping within 300 feet of each road. Therefore, 

50% of the potentially impacted camping areas are not being inventoried. This failure to 

inventory cultural resources is inconsistent with current policy and should either be extended to 

300 feet or camping restricted to 150' or some other distance that allows for cultural examination 

of all camping areas. 

Letter-Comment #:

18-7 

Second, the CNF should have included an action alternative that protected cultural resources 

sites, specifically in Areas of potential Effects (APE). The preferred alternative allows 

motorized use in several problematic areas as the DEIS states: At least 39 recorded cultural 

resource sites are located within the APE corridor and could be adversely affected by these new 

motorized trail additions. (p. 3-29). For 74 roads proposed for conversion to motorized system 

trails, the maintenance standard may change. For the 30 historic roads proposed to be 

converted, this may alter their original integrity and historic function. Three CCC roads 

(Tenmile-Fifteen #4030, Horse Creek #4135, and Indian-Taylor Creek Divide #4434) are 

proposed to be converted to motorized system trails which may alter the original character and 

function of these NRHP eligible properties. (p. 3-28, 29). Over 190 sites located within the APE 

along the proposed converted roads may require evaluation to determine the effects of a 

potential change in maintenance and allowing additional motorized use (i.e. unlicensed vehicles 

in addition to licensed vehicles) as a result of designation of the routes as motorized trails (p. 3-

29). Five archaeological NRHP eligible sites and 19 culturally sensitive sites are also located 

within the APE along the proposed converted motorized system trails. (p. 3-29). The addition of 

26 user created motorized trails opens up new access to areas previously considered somewhat 

remote and, as studies have found, could increase the occurrence of vandalism and site theft. 

(p. 3-29). Access to one archaeological site that is eligible to the NRHP would be allowed by 

the additions of a user created route to the motorized trail system (p. 3-29). Designating 

dispersed camping within 300 feet of the added user created could affect 39 sites identified 

within the APE under Alternative B (p. 3-29). 

Response: The FEIS has been clarified to better explain the nature of the effects and mitigation that will be 

implemented to minimize impacts on cultural resources. For example, dispersed vehicle camping within 300 feet of 

motorized routes has been an authorized activity since 2001. Monitoring of NRHP eligible and culturally sensitive 

sites within these areas has not revealed any adverse effects to these resources. Concerns regarding reduced 

maintenance on historic roads converted to motorized trails have been addressed through the recent issuance of new 

Forest Service Trails Manual and Handbook guidance that facilitates development of Trail Maintenance Objectives that 

will protect the historic elements of these routes. Finally, mitigation will be incorporated in the form of monitoring of 

NRHP eligible and culturally sensitive sites for adverse and beneficial effects from this travel management decision.

Subject: Cultural Resources Response #: C-2, Clarification

Letter-Comment #:

8-9 

On another note, Page 3-21 359 cultural and 50 historic sites, Page 3-27 states 353 historic sites 

and 50 historic roads. The numbers do not appear to be consistent and clarification should be 

considered in the Final EIS. 

Response: These discrepancies have been corrected in the FEIS.
Chapter 5: Response to Comments 

Page 5-4 Ashland Travel Management Final EIS 

Subject: Cultural Resources Response #: C-3, Historic Uses

Letter-Comment #:

8-10 

Cultural resources eligible for the National Register of Historic Places included both historic and 

prehistoric. Logging and grazing are historic uses of the Ashland District and was being 

conducted by Americans of European descent prior to the establishment of the forest. There is no 

indication that these historic uses of the forest were included in the cultural resource survey. This 

is a significant omission and must be included to be a complete EIS. 

Response: These historical activities were identified in the DEIS, Chapter 3, Cultural Resources Affected 

Environment section, and will be expanded in the FEIS in response to this concern. 

Subject: Cultural Resources Response #: C-4, Vandalism

Letter-Comment #:

24-6 

Reading 3.2.2.2 Environmental Consequences - Archaeological and Tradition Cultural 

Properties in the DEIS, we found similar verbiage, as found in other plans, dealing with 

damage, vandalism, treasure hunting, etc. Motorized vehicles are again unfairly highlighted as 

potential "what if" contributors. Historically hikers, camels, elephants, mules, horses and many 

other means of transportation have been used by looters and "treasure hunters". We do not 

agree with many of the references or find them applicable to their use in the DEIS. 

24-7 Is it possible a looting or treasure hunting hiker would find his misdeeds easier with the closure 

of roads, trails and large areas of public land in general? 

Response: Yes, vandalism does occur in areas with little or no motor vehicle access. However, the literature cited in 

the DEIS and FEIS indicate a general trend of direct and indirect effects, including vandalism, on cultural resources in 

remote or rural settings when there is routine human activity in the area – human activity that is facilitated by motor 

vehicle access. 

ECONOMICS 

Subject: Economics Response #: E-1, Revenue

Letter-Comment #:

9-1 

Plan B would also reduce the revenue for the F.W.P. through licenses, also the local communities 

would loose revenue. 

Response: The Montana FWP has indicated that if some hunters are displaced by the proposed actions in the Preferred 

Alternative, they are likely to be replaced by other hunters looking for the opportunities created by the proposed 

actions (FWP 2008b). This is based on their observations in areas where block management changes have resulted in 

conversion of areas from primarily motorized access to primarily non-motorized access without a decline in hunter 

numbers. Recreation and hunter trend information for Montana (FWP, 2005) supports the assumption that the types of 

changes proposed would not be likely to affect the overall total hunter numbers given the strong demand for big-game 

hunting opportunities. 

Subject: Economics Response #: E-2, Economic Analyses

Letter-Comment #:

13-9 

Each route must include a socio-economic analysis that includes the impacts on the public 

owning OHV's and looking for opportunities to use them and landowners who purchased 

property with the intent of being able to access and recreate using motor vehicles. 

Response: The Forest Service does not conduct economic analyses that isolate portions of the population based on 

their choices about purchases. The analysis in the EIS Chapter 3 Recreation section evaluates the relative motorized 

and non-motorized opportunities provided under each of the alternatives. The results of this analysis are used in the 

economics section to suggest that if any economic impacts occur, they would be very small compared to the total 

economic activity in the economic impact area. 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-5 

Subject: Economics Response #: E-3, Accuracy of Analyses

Letter-Comment #:

24-8 

Dealing with other travel plans, we have found inaccurate and incomplete economic information 

which leads to bad conclusions. Section 2.4.4 Economic on page 2-5 downgrades economic 

motorized and non-motorized activities as being very small and difficult to estimate. We do not 

like misinformation in other travel plans, nor do we like the lack of information in this DEIS. 

The lack of economic impact analysis is a major deficiency in the overall national travel plan 

process and a problem with properly analyzing the human component of the environment. 

Response: The detailed economic analyses conducted to support travel planning rely on statistically valid estimates of 

recreation visitation, wildlife associated visitation, and party expenditure data collected by USFS National Visitor Use 

Monitoring Surveys, conducted every five years on each national forest. By combining expenditure estimates with 

visitation estimates the contribution of various activities to a selected group of counties (termed economic impact area) 

is estimated. Typically all USFS contributions to an economic impact area (including forest products, mining and 

minerals, range allotments, recreation opportunities and special use permits, USFS employment and expenditures) 

range from 1-5 percent of the part and full-time jobs and labor income, with recreation representing only a portion of 

this economic activity. Downhill skiing is the one notable exception where this is sometimes a large portion of seasonal 

economic activity in parts of the country with numerous large resorts. 

This methodology was used to estimate the economic contribution to the Beartooth Ranger District, where use is 

estimated as 75% of the total for the Custer National Forest, and was upheld in a recent and proximate travel planning 

effort on the Gallatin National Forest (USDA Forest Service 2006). In addition, the former USFS Northern Region, 

Regional Economist visited numerous retailers in central Montana that sell and repair off highway vehicles to validate 

that modeling accurately represents the motorized sporting goods industry in Montana (many National Forests in 

Montana are low expenditure forests compared to the national average). 

According to the recreation staff on the Custer National Forest, the Ashland and Sioux Districts of the Custer National 

Forest host roughly 25 percent of the recreation visits each year to the Forest. The Montana FWP has indicated that if 

some hunters are displaced by the proposed actions in the Preferred Alternative, they are likely to be replaced by other 

hunters looking for the opportunities created by the proposed actions (FWP 2008b). Given this information, there is no 

reason to expect detectable changes in economic activity associated related to hunting with travel management 

proposals. 

FISHERIES AND AQUATICS 

Subject: Fisheries and Aquatics Response #: F-1, Roads and Trails

Letter-Comment #:

3-8

We do not concur entirely with the statement that in most cases, the actual use, or mode of travel 

(motorized versus non-motorized) is inconsequential in terms of watershed effects (page 3-74). 

We believe motorized uses in general are more likely to accelerate erosional processes and 

worsen poor road conditions, and increase stream sedimentation and degradation of fisheries 

habitat when compared to non-motorized uses. Sediment yields are generally higher from roads 

than from trails, and from trails, and from motorized trails than from non-motorized use, creating 

a greater need for monitoring of road/trail conditions, and for road and trail maintenance for 

repair and erosion control. 

Response: The paragraph referred to was intended to imply that in most situations the scale of the infrastructure is 

directly related to the degree of impact. There is evidence to support both motorized and non-motorized routes 

impacting watersheds at varying scales. However, for the purpose of the Ashland Ranger District TMP, the designation 

or conversion of roads to trails is from motorized roads to motorized trails only. Therefore, in both the Draft EIS and 

Final EIS, motorized trails were considered equal to roads in the watershed and fisheries risk analysis and were 

referred to as routes. 
Chapter 5: Response to Comments 

Page 5-6 Ashland Travel Management Final EIS 

Subject: Fisheries and Aquatics Response #: F-2, Fish Passage

Letter-Comment #:

3-9 

Has the Custer NF and Ashland Ranger District evaluated or conducted a survey of fish passage 

on culverts on the District? 

Response: All Forest Highway stream crossings on the Ashland District have been inventoried and evaluated for 

fish/aquatic organism passage. The remaining culverts in the analysis area are evaluated on a case by case basis. Few 

culverts on the Ashland District are associated with perennial waters and hold potential to affect fish passage. 

However, Aquatic Organism Passage (AOP) is a key factor in all culvert replacements and is incorporated when 

applicable. The scope of the travel plan is limited to the designation of roads and trails. Construction, reconstruction, 

maintenance and decommissioning proposals will require future and separate NEPA decisions. 

Appendix D includes opportunities to reduce impacts to water quality and aquatic habitat where there are: 1) site 

specific impacts from existing routes not associated with the proposed action, and 2) proposed actions with potential to 

improve conditions but do not eliminate impacts. Implementing mitigation measures to address opportunities will 

require future and separate NEPA decisions. 

Subject: Fisheries and Aquatics Response #: F-3, Risk Analysis

Letter-Comment #:

18-9 

Additionally, the CNF should include an action alternative that better protects amphibian species 

in riparian areas. The DEIS states, "Removal of riparian vegetation in amphibian breeding, 

incubating and rearing habitats may reduce its suitability for those functions and may increase 

vulnerability of the amphibians to predation (Maxell 2000, Forman et al. 2003)." (p. 3-75). 

Therefore, it makes sense to measure the potential consequences for designating motorized 

routes within riparian areas based on the dispersed camping allowance of 300 ft from either side 

of the route. The new action alternative should not designate those areas found to have an 

increased potential to harm amphibians. Also, this alternative routes should not designate routes 

for motorized use that follow streams in high and moderate risk watersheds as listed in Table 3-

24 of the DEIS. 

18-32 

As explained previously, the CNF's analysis in relation to riparian areas is inadequate. 

Specifically the CNF needs to better measures impacts to amphibian species in riparian areas. 

The DEIS states, “Removal of riparian vegetation in amphibian breeding, incubating and rearing 

habitats may reduce its suitability for those functions and may increase vulnerability of the 

amphibians to predation (Maxell 2000, Forman et al. 2003).” (p. 3-75). Therefore, it makes sense 

to measure the potential consequences for designating motorized routes within riparian areas 

based on the dispersed camping allowance of 300ft from either side of the route. 

18-33 

The CNF explains, “Direct effects are those resulting in the direct mortality of fish or 

amphibians, or the destruction of fish or amphibian habitat." (p. 3-79). However, there was no 

evaluation of the mortality risk to amphibians from collisions, or the potential loss of habitat from 

dispersed camping. In relation to wildlife analysis, the DEIS states, Since small, slow moving 

animals are susceptible to mortality even on narrow roads, motorized trails were included in the 

above road mileages." (DEIS, p. 3-50). Unfortunately, amphibians were not included in the 

wildlife analysis and even if they were, miles of routes will not measure loss of habitat in acres 

based in the dispersed camping exemption. 

18-44 

Additionally, the CNF proposes route designations in high risk watersheds where the Great Plains 

Toad, Northern Leopard Frog and Plains Spade foot are found. (DEIS, Table 3-24, p. 3-77). The 

CNF must minimize impacts to these species by not designating routes where they occur. 

Response: The watershed and fisheries risk analysis was a broad-scale analysis used to provide a coarse level picture 

of relative risk across the District and a way to focus effects analysis. It is not appropriate to use this coarse assessment 

to fine-tune proposed actions of individual routes in order to adjust risks to specific species or habitats. However, in 

the Final EIS, alternative B-Modified provides greater protection for aquatic resources, including amphibians, than 

Alternative B (net decrease in risk of 108.4 miles versus a net decrease of 99.3 miles) and substantially greater 

protection than Alternative A and the No Action Alternative. 

Existing condition allows for dispersed camping 300 ft from either side of a route. There are no known impacts to 

amphibian species or habitats in relation to current dispersed camping practices on the Ashland District. This is likely 

because moist ground and wetland areas are not typically chosen for camping. Additionally, there are no known 

locations on the Ashland District where repetitive amphibian mortality has been documented in relation to vehicle 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-7 

Subject: Fisheries and Aquatics Response #: F-3, Risk Analysis

collisions. Under alternatives B and B-Modified, two routes previously identified with potential wetland/amphibian 

habitat concerns will have actions proposed to address these concerns. These are system routes that will be converted 

to administrative use only. The other routes are identified in Appendix D as future restoration opportunities. 

Subject: Fisheries and Aquatics Response #: F-4, Direct Effects

Letter-Comment #:

18-34 

Furthermore, this section makes the same error as in the water quality analysis by falsely stating, 

“...only the installation, reconstruction or removal of stream crossing structures..." result in 

direct impacts. (p. 3-79). This arbitrarily discounts the impacts from stream crossings without 

structures, where those structures are in need of maintenance, or a loss of amphibian habitat. 

Response: Direct effects are caused by the action and occur at the same time and place [as the action] (40 CFR 1508.8 

(a)). In this analysis, fords are considered a stream crossing structure as approaches and channel substrate generally 

require some level of excavation and therefore can result in direct effects if they are part of the proposed action as new 

construction or reconstruction. Direct effects, by this definition, cannot occur from existing stream crossings if no 

action is proposed for an individual crossing. Existing crossings with existing impacts and impacts from vehicles 

fording streams are a cumulative effect, not a direct effect from an action that is not proposed. 

All stream crossings are considered a high risk for the water quality/fisheries and aquatics analyses, regardless of the 

condition or type. This information was used to help identify existing risk levels for 6 HUC watersheds. 

Subject: Fisheries and Aquatics Response #: F-5, Sediment Production

Letter-Comment #:

18-35

The DEIS explains that sedimentation is a primary factor in assessing impacts to fisheries and 

aquatic species in general. (p.3-73-76). Yet the CNF bases its entire set of conclusions on the 

water quality analysis, which did not factor in soil conditions. This is especially troubling for 

those routes on high grades with highly erosive soils that are adjacent to or directly above 

streams. The DEIS explains, “Values obtained from the analysis provide an index of potential 

water quality impact, or route risk to water quality. The route value is not intended to predict an 

absolute value or level of impact to water quality, aquatic systems, or species, rather a 

hierarchical approach to prioritizing impact potential by category; Low, Moderate, and High 

Risk." (p. 3-76). Since the route value is generalized, it seems apparent that the CNF needs a 

more specific way to analyze water quality and potential impacts to aquatic species. The agency 

does not have to reach an absolute value, but it should include factors such as sedimentation in 

its analysis and support the modeling with site-specific evaluations. 

Response: Sediment production from travel routes was not quantified for this analysis due to numerous issues 

associated with existing sediment models as relayed in the DEIS. Erosion and sediment transport was discussed in both 

general terms, and in specific terms in relation to various activities. 

The water resource and fisheries/aquatics analyses are broad scale risk based assessments, not absolute quantified 

impact assessments. Increased erosion and sediment delivery to streams is accounted for indirectly through the risk 

assessment. From a travel route management standpoint, as roads and stream crossings increase, risk of erosion and 

sediment delivery to streams also increase. More variables and more spatial layers could be incorporated to refine the 

evaluation of watershed risk, but the main drivers of risk will still be road miles and stream crossings. Due to the 

extensive area involved (1, 008, 934 6 HUC watershed acres) and the high number of route miles across the District 

and adjacent lands (2, 470 miles), quantifying absolute impacts is not practical. 

MANAGEMENT 

Subject: Management Response #: MGMT-1, Enforcement

Letter-Comment #:

3-2 

The DEIS states that off-road vehicle use has increased by 40% in Montana during the last 

decade and is expected to continue to increase. We believe the ability of the Forest to enforce 

restrictions on motorized uses that damage the environment in light of the expanded use off-road 

vehicles (trail bikes, all terrain vehicles, 4x4 vehicles, etc.) is an important aspect of travel 

management and should be better addressed in the EIS. 

18-3 However, it is unclear how the change in enforcement authority or the MVUM will lease to 
Chapter 5: Response to Comments 

Page 5-8 Ashland Travel Management Final EIS 

Subject: Management Response #: MGMT-1, Enforcement

enforceable guidelines in the absence of adequate capacity to physically enforce the travel 

management decision. 

18-4 

However, in order to meet the purpose and need, the CNF should provide (in dollars) the funding 

it would take to actually accomplish the objectives, the number of additional FPOs needed and 

how the CNF will prioritize the staff work. 

18-5 

Therefore we reject the CNF's statement, “that law enforcement is an administrative rather than 

biophysical aspect of travel management planning, no further discussion of this issue is included 

in DEIS." (DEIS, p.2-7). The addition of more motorized routes increases the need for more 

enforcement capacity, and the CNF should demonstrate how it will meet this need. Additionally, 

the DEIS analysis relies on seasonal closures and non-use of undesignated routes for many of its 

conclusions that the preferred alternative will have beneficial outcomes; for example see 

Determination of Effects - Big Game Species (p. 3-44), and Table 3-22. Summary of Route 

Miles with Proposed Actions on the District (p.3-68). In both examples, the CNF expects 

motorized use not to occur on undesignated and administrative use routes, but the benefits can 

only be realized if there is adequate enforcement of seasonal closures and non-use on 

undesignated routes. Therefore, enforcement does become a biophysical aspect of travel 

management, and the capacity to enforce the guidelines has a direct impact not only on the 

resource, but also on the conclusions reached in the DEIS. 

Response: Enforcement of regulations is part of everyday operations on National Forests. Through the 

implementation of this travel plan decision, a clear system of designated roads and trails for motorized use will be 

employed. The 2005 Motorized Travel Rule clarified regulations under which we will implement this decision, and 

will make enforcement of illegal cross country travel much easier in the future. With a motor vehicle use map and 

standard route signs, along with an aggressive information and education campaign, users will have a better 

understanding of the designated routes available for use. 

All users, including enforcement officials, will be able to have a clearer understanding of the designated routes 

available for use. Violations of 36 CFR 261.13 are subject to a fine of up to $5, 000 or imprisonment for up to 6 

months or both (U.S.C. 3571(e)). This prohibition applies regardless of the presence or absence of signs. 

Although there is no additional funding for implementation of this decision, it is one of the Forest Service’s national 

priorities set by the Chief. 

Subject: Management Response #: MGMT-2, Maintenance

Letter-Comment #:

2-1

Finally, a decrease in available road travel will inevitably result in a concentration of use on roads 

where allowed. Therefore it is vital that the Forest Service utilize some level of maintenance to 

provide usable roads for the public and to help ensure protections of soil and water resources. 

8-2 

At the very least, the existing road system should be maintained and expanded to provide more 

non-highway vehicles and drivers as proposed with 'trails' for the use of hunters and growing 

OHV recreational population. 

8-7

The FS depends on logging companies and livestock permittees to provide substantial quantities 

of labor and money on the forest resources such as road maintenance. What do the hunters 

provide substantial quantities of labor and money on the forest resources such as road 

maintenance. What do the hunters provide besides traveling down those primitive, unsurfaced 

roads during wet weather causing rutting and widening of the trail as they avoid wet areas? 

Placing the labor and expense burden proportionately on the user is appropriate. A plan that 

enhances the hunting experience at the labor and expense of other users is poorly developed and 

poorly thought out. Additional analysis should be completed to calculate the adverse impact of 

'enhanced hunting' experiences on the cost impact to those charged with maintaining the roads in 

a useable condition. 

18-11 

Additionally, the CNF should provide an alternative based on what it can actually afford to 

maintain and administer. The 2005 Travel Management Rule requires the Forest Service to 

consider these variables in designating routes for motorized use, and it is clear that the CNF did 

not meet this requirement: "Based on past funding levels, the Forest is unlikely to have sufficient 

protections of the District for the foreseeable future." (DEIS, p. 1-10). While this disclosure is an 

honest assessment, it does not provide enough detail for an adequate comparison to other 

alternatives. 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-9 

Subject: Management Response #: MGMT-2, Maintenance

18-26 Additionally, the CNF failed to incorporate changes in maintenance costs and needs of the mass 

road to trail conversions when determining potential impacts. 

18-37 

Furthermore, the CNF places much emphasis on work to be completed sometime in the future 

through regular maintenance: "...as long as most impacts are limited to the immediate area of 

disturbance, the road or trail can be maintained at a reasonable cost, and permits use as long as 

it's needed." (DEIS, p. 3-84). This assertion is in direct conflict with earlier statements that the 

CNF cannot maintain its current transportation system, and has not used any trail funds. The 

DEIS should have specifically identified which routes need BMPs, the type of work involved 

(such as relocation), the funding necessary to implement the work and where those funds would 

come from. 

18-41 

Throughout the analysis, it is apparent that the CNF did not consider maintenance funding in 

designating routes (see above on Water Quality). At the same time, the CNF relies on 

maintenance funding to implement mitigation measures (see Soils section). In order to satisfy 

travel management regulations, the CNF should identify the necessary funding to maintain its 

transportation system in addition to mitigation costs. It then should demonstrate how this 

consideration affects decisions to designate routes for motorized use. Without such action, the 

CNF is in violation of the regulation. 

18-47 

The motorized trail maintenance backlog is not included in road maintenance backlog 

calculations, providing a sunnier picture of the state of the forest than may be the case on the 

ground and giving the CNF less complete information on which to base their management 

decisions. Maintenance of motorized trails should be tracked in the same manner as maintenance 

for roads. Keeping an inventory of motorized trail maintenance needs will help ensure that 

maintenance that would decrease the impacts of motorized trails on forest resources is 

appropriately scheduled and increase the likelihood of obtaining funding for these repairs. The 

CNF needs to fully account for how much it will cost to maintain and/or bring these motorized 

trails up to the appropriate standard, and what measures will be taken in the interim to ensure 

that environmental harm will not occur and/or will be minimized in compliance with the 

Executive Orders. 

28-1 

What Table 1-2 indicates to me, is that for these past six years, maintenance was deferred on 

from 697 to 754 miles of road in the respective years. This record of maintenance deferment is 

important to show the Public and the Motorized User Group, a serious situation. This 

information is not disclosed in the discussion of any alternative. 

28-2 

b. A fourth Alternative: One possible way to address this aspect of Travel Planning would be to 

add a fourth Alternative. This would be an alternative which predicts receipt of a level of 

maintenance funding expected each year for a ten year period. And, indicates specific routes 

which would be fully maintained, which roads would be closed, and which user created 

motorized routes would not be added to the system. 

28-3 Furthermore, the analysis must full disclose the adverse impacts of your action. i.e., the 

environmental costs of deferred maintenance. 

28-21 The Chart should show the number of system miles without maintenance. The analysis should 

reflect what is happening on non-maintained roads. 

28-22 

Your analysis should discuss the negative impacts to the System of years of deferred 

maintenance...you analysis should discuss the environmetnal costs in terms of lost driving 

surfaces, more erosion of the driving surface, and subsequent additional eroded soil moving into 

the water courses. 

Response: The Maintenance section in Chapter 2 has been expanded in response to comments. 

Funding for maintenance of roads and trails is not anticipated to change significantly in the next 10 years. Based on 

past funding levels, the Forest is unlikely to have sufficient funding to maintain to standard all of the routes necessary 

for the administration, utilization, and protection of the District for the foreseeable future. As a result, the Forest 

prioritizes maintenance work and routinely applies for additional/supplemental funding to increase the number of miles 

of roads and trails maintained. If issues arise, road closures will be considered to protect resources and/or user safety. 
Chapter 5: Response to Comments 

Page 5-10 Ashland Travel Management Final EIS 

Subject: Management Response #: MGMT-3, Actions Related to 

Maintenance Level 1 Roads

Letter-Comment #:

18-28 

The CNF needs to list the number of maintenance Level 1 roads it is converting to motorized 

trails and better analyze the impacts from this action. When converting roads previously 

classified as ML 1 roads, which are by definition closed to motorized use, the CNF did not 

evaluate the environmental effects of the increase and change of use in the analysis. The Revised 

DEIS should correct this error and recommend the appropriate mitigation measures to ensure that 

environmental degradation does not occur. 

Response: None of the action alternatives propose to change any ML 1 roads to routes designated for public 

motorized use. 

Subject: Management Response #: MGMT-4, Fire Suppression

Letter-Comment #:

27-7 The process of closing road may actually hinder the suppression of fires as many of the roads 

provide a fire break in the landscape that the roads provide for faster and safer response to fires. 

Response: To utilize a road as a "fuel break" is not very feasible. A fuel break is used to limit the spread of a wildfire. 

In order to assess how large fuel breaks should be, you need to determine the spotting distance of the prominent fuels. 

Across the District, the potential spotting distance may range from tens of feet to 0.3 miles based on the fuel types. 

(This is a conservative estimate and under extreme events, such as the 2000 fire season, this distance may be much 

higher.) The majority of the routes on the District are “two-tracks” that are approx. 6-8 feet wide, and as such do not 

provide effective fuel breaks. 

Fire suppression is an emergency activity, which is exempt from the 2005 Motorized Travel Rule, so firefighters can 

use motor vehicles where they need to for fire suppression activities. 

Upon detection, most wildfires are attacked using the "direct approach", which means that crews dig a bare soil line as 

close to the burning material as they can get (most of the time a road is not utilized for this). If direct attack is not 

possible, then indirect attack methods may be necessary. Most commonly, indirect methods on the Ashland Ranger 

District involve using routes as a point to begin to burn out the unburned fuels between the route and the main fire, thus 

creating a sufficient fuel break. To be successful these routes do not have to be maintained at the highest standard 

available, but rather be accessible by a four-wheel drive fire engine. 

None of the alternatives are expected to appreciably change fire fighting ability. Alternative A would designate nearly 

all existing routes for public motorized use, making them available for fire fighting activities. Alternatives B and B 

Modified would not be expected to have much effect because, the majority of routes that are not designated for public 

motorized use are either routes that are parallel to routes that would be designated or they are becoming administrative 

routes. Consequently, access for fire fighting activities is not expected to change appreciably. 

Subject: Management Response #: MGMT-5, Safety

Letter-Comment #:

15-1

I do want to go on record that if you close travel from Fly Creek, (4450) to Cabin Creek (4425) 

and force ATV's to use the highway with heavy truck traffic, and an accident results, I will be 

among those who hold you responsible. 

28-6 

To state or imply that the Agency has no responsibility to manage the open roads, as passable and 

safe is incorrect. At least one basic tenet in the FS regulations and the 2005 Rule is the 

development of safe passable routes for motorized travel. If they are impassable or unsafe for the 

vehicle classes for which they have been open, then the routes should be taken off the System. 

36-2 and 37-2 

If you look at the map, the main access south of highway 212 inside the forest administrative 

boundary is Road 4703 (Lemonade Road). Lemonade Road starts in (T3SR47E Sec 28) and runs 

south to intersect with Road 4092 (Ten Mile Road) in (T4SR47E Sec 31). My concern with 

your proposed travel plan is that slower off-road vehicles and ATV's using 4703 (Lemonade 

Road) and wanting to access the north side of highway 212 will be required to drive on highway 

212 for approximately 2 miles to gain access. Given that highway 212 has high-speed car and 

truck traffic, I believe this to be a major safety issue. 

Response: The Forest Service defers to State Law in regard to operation of vehicles on roads and trails. State laws 

related to roads fall under: Montana Code Annotated, Title 61. Motor Vehicles. State laws related to trails fall under: 

Montana Code Annotated, Title 23 Parks, Recreation, Sports, and Gambling, Chapter 2 Recreation. Any vehicles that 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-11 

Subject: Management Response #: MGMT-5, Safety

use Highway 212 would need to be highway legal vehicles in accordance with state law. 

Both the DEIS and FEIS state in the Maintenance section that, “The Forest is required to maintain National Forest 

System roads in a condition to safely accommodate intended use in accordance with the maintenance objective for that 

road. Trail maintenance is intended to preserve the trail and related facilities to meet established objectives for that 

trail.” 

MISCELLANEOUS 

Subject: Miscellaneous Response #: MISC-1, Monitoring

Letter-Comment #:

3-11 

We also recommend that mechanisms for public disclosure of the monitoring analysis and the 

decisions for the Travel Plan be provided. The roles of the Forest Service, other Agencies, 

independent science, and the public should be identified. The FEIS should discuss the future 

decision points in this adaptive process that may require additional NEPA analysis. The FEIS 

should also discuss the funding is available for monitoring and adaptive management. 

13-7 Site specific monitoring of motorized versus non-motorized use must be provided for each route. 

18-42 

At present, the DEIS is inconsistent with Executive Order 11644 as amended for three reasons. 

First, the CNF is not locating or designating roads and trails to minimize harm to watersheds, 

wildlife populations and habitat, or other resources. Second the USFS has not adequately 

demonstrated how they will effectively monitor travel plan implementation since they tier this 

activity to a programmatic Forest Plan monitoring system that does not provide for on-site 

evaluations. Third, the CNF did not analyze or account for changes in maintenance needs and 

related funding resulting in a failure to minimize impacts. 

18-46 

Without monitoring protocols specific to the travel management plan, the CNF cannot adequately 

assess how well mitigation efforts are working, or the formation of new user-created routes, or 

other illegal use. In other words, to comply with the Executive Orders and the TMR, the CNF 

needs to develop a more comprehensive monitoring plan. 

Response: The monitoring identified in the EIS is consistent with the 2005 Travel Management Rule and the Custer 

National Forest Land Management Plan. The nature of the monitoring is described in the Monitoring section of 

Chapter 2. 

Subject: Miscellaneous Response #: MISC-2, Dispersed Vehicle Camping

Letter-Comment #:

3-13 

EPA encourages locating campground facilities, and concentrated public recreational uses away 

from ecologically sensitive resources. We believe motorized access to camping sites in 

ecologically sensitive areas should be restricted even if they are within 300 feet of designated 

routes. It would be helpful and appropriate to identify and designate camping sites that avoid 

sensitive areas, and/or to encourage camping or concentrated public use in areas that are more 

resilient and can more easily recover from impacts an /or accommodate public use with less 

impacts. 

18-38 

the USFS has improperly authorized extensive dispersed motorized camping and failed to justify 

its exemption allowing cross-country motorized use for dispersed motorized camping on every 

motorized route in the District. The 2005 Travel Management Rule does provide for this 

exemption to the ban on cross country travel, but only for the "the limited use of motor vehicles 

within a specified distance of certain designated routes." 36 C.F.R. & 212.51(b) (emphasis 

added). Moreover, this exemption cannot be imposed, as it is in the preferred alternative, without 

the proper NEPA analysis and an evidentiary basis provided in the record. 
Chapter 5: Response to Comments 

Page 5-12 Ashland Travel Management Final EIS 

18-39 

This limited exemption was addressed in the Q & A which accompanied the Travel Management 

Rule: The Department expects the Forest Service to apply this provision sparingly, on a local or 

State-wide basis, to avoid undermining the purposes of the final rule and to promote consistency 

in implementation. In a letter dated June 8, 2006, the Chief of the Forest Service also released 

follow-up guidance regarding the use of the dispersed camping and game retrieval exceptions 

allowed by 36 CFR 212.51(b). The letter (emphasis added) states: Such designations represent 

site-specific decisions associated with specific roads and trails or road and trail segments, rather 

than a blanket exception to the rule. Designations under 36 CFR 212.51(b) will be applied 

sparingly to avoid undermining the purpose of the rule and to promote consistency in 

implementation. In a June 30, 2006 letter, the Region 1 Regional Forester provided Forest 

Supervisors with the following guidance: "Supervisors will follow national direction and apply 

this provision [referring to the dispersed motorized camping exemption] sparingly and on a route 

basis." Unfortunately, the CNF has failed to follow this direction to apply dispersed motorized 

camping "sparingly" and "on a route by route basis." 

18-40 

By not taking a hard look on a "route-by-route" basis, the Custer has violated NEPA by applying 

this buffer for dispersed motorized camping without site specific analysis, disclosed through the 

NEPA process, of the effects of continued motorized travel on water quality, wildlife, 

vegetation (including the spread of noxious weeds), and soils. Without site specific surveys it is 

impossible to know what the effects of continued motorized travel on water quality, wildlife, 

vegetation (including the spread of noxious weeds), and soils. Without site specific surveys it is 

impossible to know what the effects of allowing continued motorized cross country travel to this 

extent will really be throughout the Ashland District. 

26-5 Prevent user created routes and off-road damage by limiting travel off-road for dispersed 

camping to designated routes or the length of a vehicle, as in other national forest. 

28-10 

c.3-6 par 3; It appears that you are applying the 600 foot corridor on all motorized routes. This 

application is too broad. The Agency must analyze this application on a facility by facility basis 

and apply it sparingly as the 2005 Rule directs. 

39-4 Prevent user created routes and off-road damage by limiting travel off-road for dispersed 

camping to designated routes or the length of a vehicle, as in other national forests. 

40-4 4. Prevent user created routes and off-road damage by limiting travel off-road for dispersed 

camping to designated routes or the length of a vehicle, as in other national forests. 

Response: In general, these concerns were considered when developing Alternatives B and B Modified. This use has 

been authorized since 2001. No site-specific areas of concern have been identified by the Forest Service. The Forest 

Service identified the following considerations: 1) many sensitive areas are not desirable for dispersed vehicle camping 

(wetlands, grades greater than 6%, etc.); 2) the highest use on the District is during the fall, when areas tend to be 

dry; 3) there have not been any specific issues identified during the last 8 years of this activity that indicate the 300 

foot allowance has been an issue; 4) terrain tends to limit where folks tend to camp; 5) typically, heavy use occurs in 

same location every year and have not been in sensitive areas. 

Subject: Miscellaneous Response #: MISC-3, Administrative Use

Letter-Comment #:

12-1 

I would like you to publicly define what the administrative use is on each road. I believe you are 

not being very honest when you say that roads are needed for administrative use. What you 

really mean is a permittee will be the only ones driving the roads. 

12-2 

I ask that all administrative use only roads are closed during big game hunting seasons. The 

permit holders should not be able to drive the roads during big game season. If they need them 

for their cattle, they can do that outside of big game season. 

24-4 

Comparing the Ashland DEIS with other travel plans we have worked on, commented on and 

appealed, Alternative B of the DEIS has much higher than normal For Administrative Use only 

designations. From what we can gather, this designation is really a closure to all but special 

permit holders. This is capricious and not related to overall fairness. 

Response: The purpose of administrative routes is to provide access for necessary activities associated with 

administration of the National Forest. Administrative routes are identified when there is a need and no public right-ofway exists or there is a resource/facility concern that can reasonably be expected to be reduced if the route is identified 

for administrative use, i.e. to reduce potential vandalism of remote facilities. 

The criteria used for developing Alternative B included eliminating “parallel” routes. Some of these routes were 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-13 

Subject: Miscellaneous Response #: MISC-3, Administrative Use

however necessary for administrative access to powerlines, pipelines, improvements, and facilities, therefore these 

routes were identified for administrative use. 

The administrative uses or activities that occur on system administrative use only roads are unique to that route. Use of 

these routes is at the discretion of the Forest Service. Yes, in some cases, permittees may be the only ones operating a 

motor vehicle on an administrative route, but it can only be for the purpose of meeting the terms and conditions of their 

permit. 

Subject: Miscellaneous Response #: MISC-4, Legal Access

Letter-Comment #:

12-3 

Any road that originates on private land and does not have a legal easement, cannot be used by 

FS personnel. You would have to gain written permission by the land owner to cross the private 

land to use the FS road. This is a poor way to manage our forest. Please close all roads to all 

uses that originate on private. If the public doesn't have access, the special few landowners 

should not be given special access. You can always write a special motor vehicle use into their 

permit. If the permit holder wants the access, then require them to provide an easement, so the 

public will benefit. 

Response: Permittees are required to maintain facilities as a part of the terms and conditions of their permit. 

Maintenance of facilities may require the use of motorized vehicles, if approved by the Forest Service. Identifying a 

specific route for permittees to use to access facilities if preferable to authorizing permittees to travel cross-country with 

a motorized vehicle to access facilities.

Subject: Miscellaneous Response #: MISC-5, Cumulative Effect

Letter-Comment #:

13-3 

The cumulative effect of all motorized closures has been significant and is growing greater every 

day yet they have not been adequately addressed. Ignoring the facts are not on the table. CEQ 

guidance on cumulative effects was developed to prevent just this sort of blatant misuse of 

NEPA....[see table] 

Response: This additional information has been incorporated, as appropriate, in the Recreation section of Chapter 3.

Subject: Miscellaneous Response #: MISC-6, Revised Draft EIS

Letter-Comment #:

18-14 

In order for the public to adequately comment, we ask that the Custer NF produce a Revised 

Draft EIS with another 45 day comment period. We would expect that the new DEIS have more 

than three action alternatives to truly meet the intent of NEPA to explore informed and 

meaningful alternatives with the goal of producing a decision that best protects forest resources. 

Response: The DEIS was prepared in compliance with NEPA and the Council on Environmental Quality Regulations 

for Implementing NEPA.

Subject: Miscellaneous Response #: MISC-7, Previous Decisions

Letter-Comment #:

23-1 

The White Tail Decision needs to be voided because it was issued during the Travel Planning 

Process. At the beginning of the process in December 2007, all groups were informed that all 

roads and trails would be included in this process. After the DEIS was issued we were informed 

this was in fact not true. Why were all the groups not informed of this action? It seems that the 

only person that likely knew of this action was probably the district itself. If the White Tail 

Decision was indeed in planning before the December 2007 Travel Planning meeting it should 

have been put out at that time, instead of signing the decision and not informing the concerned 

groups. 

24-60 

The agency has provided information stating this route has been closed by a previous decision. 

Yet at the December 13, 2007 scoping meeting held in Billings the question was asked and 

answered by the agency stating all routes located on the ground as of the December meeting were 

to be open for discussion in forming the Ashland Travel Plan. 

Response: The Forest agrees that this travel management decision may supersede past decisions on roads. Forest staff, 

District staff, and the District Ranger reviewed decisions for the past several years that included actions related to roads, 

with particular attention paid to routes identified by the public as important for motorized recreation opportunities. This 

review included determining if the rationale for the previous route decision was still applicable and appropriate, and/or 

if it would be appropriate to propose changing the route designation. 
Chapter 5: Response to Comments 

Page 5-14 Ashland Travel Management Final EIS 

Subject: Miscellaneous Response #: MISC-8, Signing

Letter-Comment #:

27-1 

Due to the map accuracy the club would like to have all roads marked physically in forest to road 

number and whether the road is open or closed. 

Response: The Motor Vehicle Use Map (MVUM) will indicate those roads and trails designated for public motorized 

use. The Forest will be installing route signing that corresponds to the designated routes shown on the MVUM.

Subject: Miscellaneous Response #: MISC-9, Americans with Disabilities

Letter-Comment #:

27-6 

Closing roads will have adverse effect on those people with handicaps and that as a government 

agency there is a requirement by the Americans with Disability Law that the forest service must 

try and mitigate in the address in the travel plan. 

35-1 I would like to know how the travel management plan is to deal with the Americans with 

Disabilities act which is a requirement by law. 

Response: As indicated in Section 1.6.4.1 of the FEIS, special provisions aimed at providing people with disabilities 

motorized opportunities not available to all forest users have not been included in this proposal. In the comments and 

responses on the 2005 Motorized Travel Rule published on November 9, 2005 in the Federal Register, the agency 

states, “Under section 504 of the Rehabilitation Act of 1973, no person with a disability can be denied participation in a 

Federal program that is available to all other people solely because of his or her disability. In conformance with section 

504, wheelchairs are welcome on all National Forest System lands that are open to foot travel and are specifically 

exempt from the definition of motor vehicle in § 212.1 of the final rule, even if they are battery-powered. However, 

there is no legal requirement to allow people with disabilities to use OHVs or other motor vehicles on roads, trails, and 

areas closed to motor vehicle use because such an exemption could fundamentally alter the nature of the Forest 

Service’s travel management program (7 CFR 12e.103). Reasonable restrictions on motor vehicle use, applied 

consistently to everyone, are not discriminatory”. This concept also applies to providing special provisions for aging 

populations that may have limited mobility. 

The following language was added to Chapter 1 in response to these comments: 

Similarly, in the comments and responses on the updated Forest Service Manual and Handbook travel 

management planning guidance published on December 9, 2008 in the Federal Register, the agency states, 

“Consistent with section 504, FSM 2353.05, and Title V, Section 507(c), of the Americans With Disabilities 

Act, wheelchairs and mobility devices, including those that are battery powered, that are designed solely for 

use by a mobility-impaired person for location and that are suitable for use in an indoor pedestrian area are 

allowed on all NFS lands that are open to foot travel. There is no legal requirement to allow people with 

disabilities to use motor vehicles on roads, on trails, or in areas that are closed to motor vehicle use. 

Restrictions on motor vehicle use that are applied consistently to everyone are not discriminatory. Generally, 

granting an exemption from designations for people with disabilities would not be consistent with the resource 

protection and other management objectives of designation decisions and would fundamentally alter the nature 

of the Forest Service’s travel management program (29 U.S.C. 794; 7 CFR 15e.103).” 

Subject: Miscellaneous Response #: MISC-10, Season of Use Dates

Letter-Comment #:

28-7 e. Summary of miles by Alternative, Table 2 -3 Do you mean August 31 to December 1: 

Response: The table displays when motorized routes can be used by the public, the “season of use”, not when they are 

closed to the public. August 31 to December 1 is the period when the routes cannot be used for public motorized use, 

which is the opposite of the “season of use”.

Subject: Miscellaneous Response #: MISC-11, Mixed Use

Letter-Comment #:

28-9 

b. Mixed Use; If your decision to allow Mixed Use on any road or groups of roads, then at a 

later date, your analysis concludes that is not wise, How do you correct the Decision and 

explain to your motorized public why the change? Shouldn't the inventory be made first, or at 

least designation of the affected mixed roads is held in abeyance until the inventories are 

completed? 

Response: The 2005 Motorized Travel Rule does not require an exhaustive inventory of all routes on the District. The 

decision can be modified at any time based on new information or changed conditions, including the identification of 

important routes not previously considered. Because there was a very robust inventory of the routes conducted in 1999-
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-15 

Subject: Miscellaneous Response #: MISC-11, Mixed Use

2000 and cross-country vehicle travel was eliminated in 2001 and because the public has been involved in commenting 

on this proposal, there is a fairly low risk that any important non-system routes have not already been identified. 

The mixed motorized use analysis has been completed for Alternative B Modified. No extraordinary safety concerns 

with these designations were identified. 

Subject: Miscellaneous Response #: MISC-12, Accurate Maps

Letter-Comment #:

29-1 

The maps as they are currently drawn up are not accurate. Our main access trail from the South 

to the North pasture isn't correctly on the map. There are currently roads on the map that are not 

roads. There is no mention of the trails along our water pipelines which aren't shown anywhere. 

Response: An inventory of the routes was conduced in 1999-2000 of all system and non-system routes using GPS 

technology. Through the public involvement process, we asked the public to identify errors on the maps and we 

corrected errors or determined that the map was correct and made no change. Our field review of many of the routes 

indicates that the maps were accurate.

Subject: Miscellaneous Response #: MISC-13, View Shed

Letter-Comment #:

42-3 

I am also asking that you consider the visuals of the landscape and remove roads to improve the 

view shed. 

Response: All of the action alternatives are consistent with the Forest Plan visual quality objectives. Alternative B and 

B Modified would reduce the number of miles of motorized routes, which would reduce potential impacts to viewsheds, 

however there is no guidance in the Forest Plan that requires reducing the number of roads in management areas that 

permit motorized use.

Subject: Miscellaneous Response #: MISC-14, ATV Routes

Letter-Comment #:

13-4 

All roads to be closed to full-sized vehicles should be converted to atv routes. This is a 

reasonable alternative for all existing roads. 

Response: In Alternatives B and B Modified, routes were not designated because of resource concerns; human health 

and safety concerns; the route has naturally re-vegetated; the route is parallel to another motorized route; or because 

there was no legal public right-of-way. Designating these routes for any motorized use would be counter to the 

rationale used to develop Alternatives B and B Modified. In Alternative A, only a limited number of routes were not 

designated, which would not be designated regardless of vehicle type (i.e. no legal public right-of-way).

RECREATION 

Subject: Recreation Response #: R-1, Walk-In Hunting Opportunity

Letter-Comment #:

4-1 

I am requesting that you look at making a minimum of 30% of the district available to walk in 

hunting and horse riding recreation experience during hunting seasons. I requested previously 

that seasonal closures be implemented and only 18 miles of roads were looked at for closure. 

According to your numbers provided, that is less than 2% of the roads were seasonally closed. 

It also only created 3 very small walk in areas. This is inadequate compared to the number of 

acres that are open to driving and the number of roads that are open. I once again request that 

you provide additional walk in hunting areas. Minimum size should be approximately 5 miles 

by 5 miles an hour in the field. That would give a good half days hunt without running into 

vehicles. 

4-2 

I am also requesting that you look beyond management area D and include other areas where 

wildlife may be prevalent on the forest. I am specifically asking to seasonally close road 

#4797 during September. This would allow a nice sized closure in the Southwest where one 

does not currently exist. There would still be walking or horseback riding access from road 

#4095, #40954, #795 and #4794. 

4-3 

I am requesting that you close Road #4502 seasonally as well during September. See 

comments below for rationale. I request that you make more road closure areas and increase 

the opportunity for walk in hunting. The Custer has very mild terrain, and it is important for 
Chapter 5: Response to Comments 

Page 5-16 Ashland Travel Management Final EIS 

Subject: Recreation Response #: R-1, Walk-In Hunting Opportunity

walk in hunting. The Custer is one place I can hunt with my Dad who is 69 years old because 

of the mild terrain, he is able to walk and enjoy a recreation opportunity that is not available to 

him in Western Montana. 

4-4 

Your current plan does not conform the MT FWP recommendation for the Custer EMU. It also 

does not conform to research that would improve recreational hunting opportunities on the 

Custer. It has been shown time and again that roads decrease hunting opportunity. Roads only 

increase driving opportunity. 

4-11 

According to Executive Order #13443 Facilitation of Hunting Heritage and Wildlife 

Conservation, the FS is specifically supposed to be responsive to State Wildlife Management. 

According to the MT FWP Custer EMU in the Elk Management Plan, the State has called for 

increasing walk-in hunting areas. This excluded all current hiking a riding areas, since they 

existed prior to the most current State Elk Management Plan. You have not actively promoted 

additional walk in hunting areas in your current travel plan, and I request that you make create 

walk in hunting areas on the District. Specifically, I have asked that the walk in hunting areas 

be seasonally walk in areas, during Archery season to provide an alternate recreation 

opportunity to the nearly 100% motorized opportunity that is currently in the preferred 

alternative. 

12-4 I would ask that you consider additional road closures to allow for more walk in hunting 

recreational opportunities. 

12-5 

I ask than you increase road closure areas or consider seasonal closures, specifically during 

archery season. I ask that you look at the areas with the highest concentrations of elk. You 

currently offer three hiking and riding areas, but theses areas have very few elk. The archery 

hunting for elk takes place mostly on other areas. The three hiking and riding areas offer good 

deer hunting, but not archery elk. 

12-6 

I would ask that you look at providing much more seasonal road closures, specifically during 

archery season to benefit archery hunters. I would ask that the size of the closure be large 

enough for a day hunt. I would like the size to be roughly three miles square. 

18-6 

First, the CNF failed to consider a reasonable range of alternatives that would provide nonmotorized opportunities on trails. The DEIS explains, “Those seeking non-motorized hunting 

experiences did indicate some difficulty in finding non-motorized opportunities. They 

indicated that escaping from motorized disturbances could be challenging on the District,” and 

that “There are no system trails within the three hiking and riding areas,” (p.3-5). A new action 

alternative should offer quiet trail experiences in the semi-primitive non-motorized ROS 

setting, either by designating non-system routes, or converting roads to non-motorized trails. 

38-1 

I would like to specifically say that I hope you consider additional seasonal closures. I would 

like to see more permanent closures, but understand the politics behind such a decision. I 

would like to see you provide some larger areas for walking. I am getting up in age, and find 

that the Ashland area is one of the few areas I am still able to get out and walk. 

42-1 

I would ask that you create some additional roadless areas or road closed areas to provide some 

opportunity for both walk in hunting and horseback hunting. I would like to see some 

additional roadless areas in key wildlife areas for elk and deer that are roughly 5 miles across. 

This would allow for a nice hiking or horseback riding experience. 

42-2 You should consider some additional seasonal closures during big game hunting season to limit 

vehicle traffic, which will improve hunting opportunity and hunting satisfaction. 

43-1 

I ask that you consider some seasonal closures, specifically during archery season. I realize 

that many rifle hunters are also 4x4 and ATV users. I think it is good that they have the 

opportunity to have some roads as provided in your Alternative B, but roads just cause 

problems during archery season....What does ruin the hunt is when you try and hunt a drainage, 

and a truck drives right through it, whether it is a hunter or a permitted use such as a cattle 

permit holder. I am asking that you add more seasonal closure areas in areas that are known to 

have elk, such as the North end of the District, the area parallel to Bloom Creek Road, The 

area West of Three Mile Buttes, near Yager Butte Lookout, and the Southeast part of the 

district around Poker Jim Lookout. I am also asking that you add more seasonal closures in 

other areas during archery season to improve the quality of hunting for archers. 

Response: In response to these comments, additional routes with a December 2-August 31 season of use have been 

identified in Alternative B Modified. See Appendix C for the specific routes designated with this season of use. 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-17 

Subject: Recreation Response #: R-2, Road and Trail

Letter-Comment #:

4-8 

Your intent to convert roads to motorized trails will have a negative effect on recreation, elk 

secure cover and will degrade hunting quality and opportunity. Currently, any person under 

legal driving age may not drive an ATV on Forest roads, therefore, they are forced to carpool. 

Field observations have shown that most underage drivers must ride along with legal drivers. 

The change may not increase the number of individuals, but will increase the number of 

vehicles. Where a family of 4 may have previously taken a pickup, they will now be able to 

have 4 OHV's. This adds to the noise and animal harassment. There would potentially be a line 

up of vehicles traveling down the trail, where previously a single pickup would have driven. 

This will increase the problem of finding non-motorized experiences and will increase conflict 

with recreation users who are looking for a non-motorized experience. You are creating a major 

conflict with users classifying the roads as both roads and trails. 

28-5 

d. Motorized Trail Designation. Pp - 1-9: In paragraph 4, you state that classification of road 

or motorized trail does not imply that you are encouraging use by any specific class of vehicle 

or imply that the route is passable, actively maintained or safe for travel. What you state in this 

paragraph is incorrect!!! This proposed Plan actively encourages motorized recreation. Given 

the intense interest by the 4 x 4 users, as reflected in this document, both Alt A and Alt B, 

actively encourage and invite motorized recreationalists to the Ashland District. The change in 

route classification from Road to Motorized Trails is from zero to 392 miles as in Plan B, 

certainly is a green flag to motorized recreationalists. 

Response: Information on the exact numbers of users and types of use do not currently exist. Field observations 

indicate that the District is routinely used by unlicensed vehicles at this time. Designating system motorized trails 

would allow this use, operation of unlicensed vehicles, to continue. There is no information that suggests that 

providing opportunities for some of this existing use will either increase or decrease use in the future. 

Subject: Recreation Response #: R-3, Conflict

Letter-Comment #:

4-12 

You are creating a major conflict between recreation users, hunters, walk in hunters, recreation 

trail riders, and hunters who ride ATV's by converting your roads to trails. You are going to 

cause many conflicts that currently don't exist. I am asking that you do not covert your roads to 

trails or that you specifically limit trails to vehicles less than 50" and convert no more than 10% 

of your roads to trails. You are creating a destination area where any rider can ride an 

unlicensed ATV and in so doing are creating conflicts between previously established 

recreation uses. Haven't you heard the saying "if you build it, they will come"? Well, you may 

not intend on promoting ATV use, but by opening the forest to previously restricted drivers, 

you are now creating a destination for families to recreate. This will cause increased summer 

use and increased use during the hunting season, which will have negative impacts on other 

previously established recreation uses such as hunting, and non-motorized walk in hunting. 

24-10 As a sideline note, we could not find documentation concerning user conflicts which happened 

in the past which might influence the planning process. 

27-4 

The recommended proposal by the forest service to eliminate a large number of roads will lead 

to increased conflicts between sportsmen by congregating them into smaller areas due to road 

access. 

Response: There is no significant documentation of conflicts on the District, and conflict was not used as criteria for 

route evaluation. However, public comments associated with this project indicate that there are very differing 

recreational preferences related to the amount and types of motorized recreation opportunities that should be provided, 

especially during the fall big-game hunting season. The alternatives under analysis considered different levels of 

motorized access in response to these different levels of recreational preferences. 

Subject: Recreation Response #: R-4, Dual-Use Routes

Letter-Comment #:

13-16

We request that a system of dual-purpose roads, and OHV roads and trails that interconnect be 

one of the primary objectives of the travel management plan and that this objective be 

adequately addressed in the document and decision. 

13-17 We request that all reasonable routes be designated for dual-use so that a system of roads and 

trails can be used by motorized recreationalists. 
Chapter 5: Response to Comments 

Page 5-18 Ashland Travel Management Final EIS 

Response: This was one of the objectives used in developing Alternatives A, B and B Modified. Screens or criteria 

that were unique to each alternative were used to identify the base set of motorized routes. Then, every route that was 

suitable for mixed motorized use or motorized trails was designated as such, and designations were reviewed to insure 

they formed an interconnected network. If needed, adjustments were made to the alternatives to provide connections. 

Subject: Recreation Response #: R-5, Route Specific 

Letter-Comment #:

8-1 

Roads such as the 4410 series (44102, 44106, 44101), 44234, 44601C, 44502, 4441, 44191, 

47725 provide important loop links or access to otherwise accessible areas. Allowing these 

roads and others similar to them, will provide additional access for the hunting public to 

conduct such activities as game retrieval. Game retrieval is a critical component of the hunting 

process and if the distance is too great or time of day becomes too late the hunter will abandon 

the carcass in the field. 

9-2 

There are a few roads that I would like to see changed during the fall: Open rds 44237A, 

44237, 4512, 44271A. Close roads 41338A, 44271B, 41337 to 4427 this rd is to steep and 

imposes an unsafe travel route. The rest of the roads off private lands are not accessible to the 

public anyway. See attached map copy. These suggestions would allow for hiking from rd to 

rd and make game retrieval easier, it would also allow for wood getting. 

10-1 

Enclosed are two maps, plan A and plan B. The green represents the two tract roads that I 

would like to stay open to the public....I do not or want to be forced to give up a sport that I 

have enjoyed for 50 years because I can not retrieve game that I have harvested because of the 

steep terrain in this area. 

Alternative B 

Roads that should be open 

41335, 41338, 41337, 44271, 4422 

Roads that should be closed 

44237, 44237A, 44272, 44271B, 44271A, 41339, 47692 

Alternative A 

Roads that should be open 

44094, 41338, 41337, 4422, 44271 

Roads that should be closed 

44093, 44237, 44237A, 41338A, 41338B, 41338C, 41339, 47692, 47963, 44271A, 

44271B, 44272 

24-5 

Trail 7032, which was part of a prior decision, is an example of a potential looped trail which 

would include trails 47032, 4778 and 4703. By designating trail 7032 as 50" travel, this would 

again make this area into a fair and usable trail looping experience. Going from full trails to 

50" trails, then back to full trails is not unusual in other forests an areas. The Punchbowl area 

in the Beartooth District is one example. The DEIS and Alternative B do not appropriately 

address this situation. 

24-11 

Route 47696 shown as administrative use only on the agency preferred alternative B map needs 

to be open of public motorized use as it provides access to remote area for all recreational 

activities. 

24-12 

Route 47704 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use as it provides access to a remote area for all recreational 

activities. 

24-13 

Route 47704A is not shown on the agency preferred alternative B map or on the alternative A 

map because of not having access across private land should be addressed. The preferred way 

of dealing with this problem would be the agency working with the land owner to achieve legal 

permission to cross the short distance needed to connect to route 4770. If unable to get consent 

from the land owner then an alternative route needs to be put in place around this small section 

of private land to again connect with route 4770. In dealing with the agency on various travel 

plans it has always been stated that you would like the public to work toward developing 

looped routes as it will make a enjoyable experience plus disperse the traffic to a larger area 

without going back and forth over the same route. This route combining routes 4770, 47704A 

falls perfectly under the agency's direction. 

24-14 Route 44091 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use as it provides access to a remote area for all recreation 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-19 

Subject: Recreation Response #: R-5, Route Specific 

activities. 

24-15 

Route 44094 shown as only a short turn off from route 4409 in section 23 on the agency 

preferred alternative B map but in fact goes north to connect with route 41334 in section 14. 

This route should be considered for fifty inch vehicle travel only. This will create a quality 

loop opportunity as per agency direction and allow for all recreational activities. 

24-16 

Route 47692 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use as it provides access to a remote area for all recreational 

activities. 

24-17 

Route 4422 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use to the private land as it provides access to a remote area for 

all recreational activities. 

24-18 

Route 41338 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use to where it intersects with route 4133 in section 13 of 

T2SR46E, making a loop. Many comments have been voiced via telephone and face to face 

from concerned people in out represented organizations having to do with hunting and game 

retrieval opportunities. 

24-19 

Route 40291 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use as it provides access to a remote area for all recreational 

activities. 

24-20 

Route 40294 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use as it provides access to a remote area for all recreational 

activities. 

24-21 

Route 40299 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use as it provides access to a remote area for all recreational 

activities. 

24-22 

Route 44392 shown as administrative use only on the agency preferred alternative B map needs 

to be open for public motorized use as it provides access to a remote area for all recreational 

activities. 

24-23 

Route 44234 shown as administrative use only on the agency preferred alternative B map needs 

to be opened for public motorized use from the junction of route 42125 to where it meets 

private land to provide access to a remote area for all recreational activities. 

24-24 

Route 44601C shown as administrative use only on the agency preferred alternative B map 

needs to be open for public motorized use as it provides a quality loop opportunity from route 

44234 and route 44601. Opening routes 44234 and 44601C to the public would be a good 

example of working toward agency direction to form looped routes. 

24-25 

Route 47032 located in section 35 and shown as administrative use only on the agency 

preferred alternative B map needs to be open for public motorized use. The continuation of 

47032 through section 1 in T4SR46E and ending in section 7 of T4SR47E needs to be opened 

for public motorized use. 

24-26 Route 44501 located in section 16 and shown as administrative use only on the preferred 

alternative B map needs to be open for public motorized use to where it joins with route 44502. 

24-27 

Route 44502 and shown as administrative use only on the preferred alternative B map needs to 

be open for public motorized use. Combining routes 44501 and 44502 will form a quality loop 

opportunity with route 4425 as has been requested by the agency. 

24-28 

Route 4809 located in section 11 is not shown on the preferred alternative B map. The agency 

has stated this route been closed by prior decision. This portion of route 4809 needs to be 

opened for public motorized use to provide access to a remote area for all recreational 

activities. If the agency feels the proposed route would not accommodate all form soft 

motorized travel it could be restricted to fifty inch width. Again, at the December scoping 

meeting information given by the agency said this route is open for consideration. 

24-29 

Route 4410B starting in section 28 and intersecting with route 4092 in section 4 of T5SH46E 

needs to be considered for opening for public motorized use. This route has been slated for 

closure under a previous decision but should be reconsidered under this current travel plan. If 

the agency feels the route will not be conducive for full size traffic it could still be restricted to 

fifty inch wide vehicles. By opening route 4410B a quality loop would be created to provide 

access to a remote area for all recreational activities. 
Chapter 5: Response to Comments 

Page 5-20 Ashland Travel Management Final EIS 

Subject: Recreation Response #: R-5, Route Specific 

24-30 

Route 44105 shown as administration use only on the agency preferred alternative B map needs 

to be open for public motorized use as well as the extension of the route from section 20 into 

section 17. The latter portion of this route came under a previous decision but should be 

considered for opening under this travel plan to provide access to a remote area for all 

recreation activities. 

24-31 

Route 44108 shown as administrative use only on the preferred alternative B map needs to be 

opened for public motorized use to provide access to a remote area for all recreational 

activities. 

24-32 

Route 441042 located in sections 15, 22, and 23 needs to be reconsidered for opening to public 

motorized use. This route was addressed previously by the agency but without it only limited 

access can be gained to this area. Consideration by the agency may be given to restrict this 

route to fifty inch wide access. 

24-33 

Route 44671 is not shown on the agency provided alternative A or alternative B map. This 

route is located in sections 29, 30, 31, and 32. This route needs to be considered for opening 

for public motorized use as it will complete a quality loop opportunity for all recreational 

activities. 

24-34 

Route 41313 as shown on the agency preferred alternative B map shows a small portion open 

for public motorized travel with the major portion of the route restricted to administrative use 

portion be opened for public motorized use to provide access to a very remote area for all 

recreational activities. 

24-35 

Route 41314 shown as administrative use only on the preferred alternative B map needs to be 

open for public motorized use to provide access to a remote are for all recreation activities as 

well as well as possibility creating a loop with O'Dell Creek Road and route 4805. The agency 

provided map is not very clear as to if legal access can be gained to O'dell Creek Road and 

route 4805. The agency provided map is not very clear as to if legal access can be gained to 

O'Dell Creek Road. 

24-36 

Route 41316 located in section 27 is not shown on the agency preferred alternative B map or 

on the alternative A map. The scoping map shows that the agency has right of way through the 

private land. If this is in fact the case, the public needs to have motorized access to the portion 

of the route off the private land for all recreational activities. 

24-37 

Route 44681 located in sections 9, 8, and 17 has not been shown as being closed under any 

previous decision yet is not shown on either alternative A or B maps. This route gives access 

to a remote area and needs to be opened for public motorized travel. If the agency feels the 

route will not support full size vehicle traffic it should be considered for fifty inch width 

vehicle travel. 

24-38 

Route 48021 located in sections 32 and 33 is not shown on either alternative A or B maps. The 

agency has not provided any information as to the route being closed under any previous 

decision. This route should be considered for public for public motorized use to provide access 

to a remote area for all recreational activities. 

24-39 

Route 48058 located in section 24 and continuing into T5SR45E section 24 and continuing into 

T5SR45E sections 19, 30, and 29 shown as administrative use only on the agency preferred 

alternative B map needs to be open for public motorized use. Opening of this route will create 

a quality loop opportunity. The agency has advised that this route has a previous decision 

attached but may qualify as a fifty inch only route. 

24-40 

Route 4420 located in section 33 is not shown on either alternative A or B map. The portion 

not shown has not come under any previous decision and should be considered for opening to 

the public motorized users to the private land boundary. The agency may wish to consider fifty 

inch width restrictions for this route. 

24-41 

Route 48061 located in sections 7 and 8 is not shown on either alternative A or B maps. This 

route comes under a previous decision but should be considered for motorized use as it gives 

access to a remote area for all recreational activities. 

24-42 

Route 40948 located in section 27 does not show up on either alternative A or B map. The 

route does show up on either alternative A or B map. The route does show up on the 1999-

2000 route inventory. This route if connected with route 4094 would create a quality loop 

opportunity as per direction from the agency. 

24-43 Route 44241 shown as administrative use only on the agency preferred alternative B map needs 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-21 

Subject: Recreation Response #: R-5, Route Specific 

to be opened for public motorized use as it creates a quality loop opportunity for all 

recreational activities. 

24-44 Route 4509 located in section 10 needs to be opened for public motorized use to the end of the 

route, which is located on the south line of section 10. 

24-45 Route 48011 extending from the end of route 4800 into sections 5 and 8 then connecting with 

route 4801 would create a quality loop for public motorized use for all recreational activities. 

24-46 

Route 44211 shown open for public motorized use in sections 11, 14, and 13 needs to be 

opened through sections 13 and 24. This will allow access to a remote area for all recreational 

activities. 

24-47 

Route 4432D shows open to the center of section 16 for public motorized use on the agency 

preferred alternative B map. This route needs to be extended to its end at the north side of 

section 16. 

24-48 

Route 44334 located in section 36 and T7SR47E section 1 should be considered for opening to 

the public for motorized use. This route is currently shown as administrative use only on the 

agency preferred alternative B map. This route allows access to a remote area for all 

recreational activities. 

24-49 

Route 47835 located in section 6 and shown as administrative use only on the agency preferred 

alternative B map should be considered for opening for public motorized use. Route 47835 

extends from its shown end and could connect to route 47832 creating a loop opportunity. This 

connecting portion of route 47835 is not shown on either alternative A or B map. 

24-50 

Route 47874 is not shown an either Alternative A or B map but is shown on other scoping 

material provided by the agency. This route should be considered for opening for public 

motorized use. When connected between route 4432 to the north route 4787 to the south it 

creates a quality loop as per agency direction. 

24-51 

Route 44331 beginning in section 32 and extending into T7SR47E shown as administrator use 

only on the agency preferred alternative B map should be considered for use by public 

motorized means. This route allows access to a remote area for all recreational activities. 

24-52 

Route 4795 starting in T7SR45E section 7 and traveling north into section 12 and 1 in 

T7SR44E is not shown on either alternative A or B map. Material supplied by the agency 

during the scoping period shows this route. This route reaches a remote area and should be 

considered for public motorized use for all recreational activities plus giving access to Wolff 

Reservoir. 

24-53 

Route 40321 is not shown on either alternative A or B map but shown on material provided by 

the agency during the scoping process. This route should be considered for public motorized 

use. The route starts in section 35 and ends in section 26 and will give access to a remote area 

for all recreational activities. 

24-54 

Route 47941 originating in section 5 and connecting with route 47943 in T6RS45E section 32 

is not shown on either agency provided alternative A or B maps. These routes do show on 

either agency provided alternative A or B maps. These routes do show on other material 

provided by the agency and should be considered for opening to public motorized use as they 

create a quality loop and reach remote areas. 

24-55 

Route 44343 is not shown on either alternative A or B map. This route is shown on other 

material provided by the agency. The route is located in sections 24 and 15 and should be 

considered for opening for public motorized use as it creates a loop opportunity as provides one 

of the few routes to get back to Taylor Creek Road from this area. 

24-56 

Route 4401A is not shown on either alternative A or B map but is shown on other material 

provided by the agency. This route should be considered for opening to public motorized use 

as it provides access to a remote area for all recreation activities. 

24-57 

Route 45200 shown as administrator use only on the agency preferred alternative B map needs 

to be opened for public motorized use as it provides access to a remote area for all recreational 

activities. 

24-58 

Route 44383 was shown open for public motorized use on the scoping map but administrative 

use only on the agency preferred alternative B map. This route needs to be open for public 

motorized use as it gives access to a remote area for all recreational activities. 

24-59 Route 44333 (on the map, but not on the list). 

33-3 I have particular concerns regarding the seasonal closure of road 4419. This road is bounded 
Chapter 5: Response to Comments 

Page 5-22 Ashland Travel Management Final EIS 

Subject: Recreation Response #: R-5, Route Specific 

on three sides by private land. Closing this road would make it almost 5 miles away from the 

furthest edge of the forest, which would limit harvest even by most hunters looking for a nonmotorized opportunity. If this road is closed I would recommend visibly signing the forest 

boundary along road 4095 and potentially providing a parking area or pull out in order to 

minimize trespassing across private land and to provide better access to hunters. 

33-4 

It appears from the motor vehicle use map that road 4424 appears to cross private land. This 

road may not cross private land or the Forest Service may have an easement across the 

property. However if there is not guaranteed public access to this road, I would recommend 

not closing road 44241. 

35-2 

I support leaving all roads open that make a loop and or connect to other major roads. The 

roads into Fly Creek are a concern as there are areas that we have used for picnicking and 

getting away from the main roads with a family with small children that can not walk miles to 

reach a spot. 

36-1 and 37-1 

I use Roads 4450 (T3SR47E Sec 15, 16, 21), 44501, 44502 and 42123 (sec 22, 14) over 25 

times per year for trail rides with my family and hunting. I Strongly disagree with Alternative 

"B" that closes these roads to the public. 

36-3 and 37-3 

I propose Roads 4450, 44501, 44502 (T3SR47E Sec 9, 15, 16, 21) remain open to the public. 

Road 4450 is less that 1/10th of a mile from the intersection of Road 4703 (Lemonade Road) 

and highway 212. If these roads remained open, it would allow access to Road 4425 (Cabin 

Creek) and Road 4776 (Wilbur Creek) of which you could then access the rest of Custer 

National Forest north of highway 212. 

Response: All of the above proposals were reviewed. Some suggestions were incorporated into Alternative B 

Modified, while others were not included because, (1) of resource or administrative concerns, (2) they required making 

a determination about trade-offs between competing recreational preferences, or (3) they conflicted with criteria used 

to develop the alternative. See Appendix G for individual responses to these route-specific comments.

Subject: Recreation Response #: R-6, Motorized Use Growth

Letter-Comment #:

13-18 

The Ravalli County Off-Road Users Association has found that "at the end of 2006, there were 

approximately 2500 "stickered" OHV's in Ravalli County. For the past five years, the growth 

rate of "stickered" OHV's has been about 20% per year. If this growth rate continues, the 

number of OHV's in the forest will double every four years. On the Bitterroot National Forest 

there have been no new OHV "system" routes designated for OHV travel since 1996. History, 

experience and common sense tell us that when adequate4, responsible, sustainable routes with 

attractive destinations are provided, OHV enthusiasts will ride responsibly. On the Bitterroot 

National Forest this means more routes, not more restriction". The same analysis must be done 

for the Custer National Forest and it will find the same no growth trend and a lack of an 

adequate number of existing routes that is further made worse by a lack of new routes that is 

further made worse by a lack of new routes to address growth. 

Response: The addition of nearly all of the unauthorized routes to the road and trail system is considered in 

Alternative A. The construction of new routes (inferred by this comment) is outside the scope of this analysis.

Subject: Recreation Response #: R-7, No Net Loss 

Letter-Comment #:

13-1 

The continual loss of motorized recreational opportunities is our primary concern. Because of 

the significant cumulative effect of motorized closures at this point in time, we feel strongly 

that there can be "no net loss" of motorized recreational opportunities with Ashland Ranger 

District Travel Management Plan. 

Response: Crafting an alternative that resulted in no net loss of motorized opportunities would require construction of 

new motorized routes to offset routes that cannot be designated (no legal public right-of-way) or are undesirable to 

designate (human health and safety or resource concerns). Construction of routes is outside the scope of this process.
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-23 

Subject: Recreation Response #: R-8, Motorcycle Trails

Letter-Comment #:

13-5 

In order to recognize the different needs and impacts, the evaluations must be differentiated 

between ATV and motorcycle trails. Figure 2.2 and 2.7 on page 14 Chapter 2 in the 3-state 

OHV EIS and Decision clearly shows that existing tracks used by motorcycles are to be 

considered as motorized trails (http://www.mt.blm.gov/ea/ohv/Chapter2.pdf). The evaluation 

must consider these routes in order to meet the requirements of the 3-state OHV agreement. 

Response: The Tri-State OHV considered game and livestock trails with motorized "regular use and continuous 

passage over a period of years" as motorized routes. No single track routes of this nature have been identified on the 

District

Subject: Recreation Response #: R-9, Value of Road or Trail to 

Motorized Recreationists

Letter-Comment #:

13-6 

The site specific analysis of each road or trail to be closed must address or identify where the 

public would go to replace the motorized resource proposed for closure. In other words, the 

analysis must adequately evaluate the site specific value of a road or trail proposed for closure 

to motorized recreationalists. 

Response: The Recreation analysis in Chapter 3 evaluates the direct, indirect, and cumulative effects that changes to 

the road system will have on opportunities for motorized and non-motorized activities. The analysis does not, and 

likely could not, identify where individuals may go if a specific route is designated or not designated, because the 

agency does not currently have this type of information and it would not be practical to collect such information. 

Rather, the analysis indicates, based on the proposed changes, whether more or less opportunities are available under 

each alternative and how the quantity of opportunities may be affected by other recent actions on areas potentially 

frequented by recreational users of the District. 

Subject: Recreation Response #: R-10, Equal Recreation Opportunities

Letter-Comment #:

13-12 

We request that this data be used to guide the decision-making to a preferred alternative that 

adequately meets the public by increasing motorized recreational opportunities in the project 

area...In order to bring equality to the allocation of non-motorized trails in the Custer National 

Forest must either convert 136 miles ((288/2)-8) of non-motorized trails to motorized trails to 

motorized trails or 272 miles (280-8) of new motorized trail must be constructed. The 

proposed Travel Plan does not adequately address this imbalance. 

Response: Forest Service policy is to provide a range of opportunities in compliance with the Forest’s Land and 

Resource Management Plan. The Custer NF Land and Resource Management Plan does not mandate that equal 

quantities of recreational opportunities be provided across the Forest. Furthermore, this approach is largely arbitrary 

because it assumes there is equal demand, and does not take into consideration route-specific characteristics such as 

suitability for motorized/non-motorized types of uses.

Subject: Recreation Response #: R-11, Popularity of Motorized 

Recreation

Letter-Comment #:

13-14 

The evaluation must adequately consider the growing popularity of motorized recreation, the 

aging population and their needs for motorized access, and the increased recreation time that 

the aging population has and looked forward to enjoying public lands in their motor vehicles. 

Response: The analysis evaluates the effects each alternative will have on motorized and non-motorized opportunities, 

especially on hunting, the primary recreation activity on the District. 

Subject: Recreation Response #: R-12, Visitor Use Data

Letter-Comment #:

13-19 

An important note, agency planning staff has overlooked one important aspect of the visitor 

use data. The visitor use data cited above is based on a percent of the total population. 

However, the percent of the total population visiting our public lands is a fraction of the total 

population. Public lands should be managed for those people that actually visit them. We 

request that this adjustment be made in this evaluation. 

Response: DEIS Page 3-8 stated that NVUM data collected for the Forest was not appropriate for use in this analysis, 
Chapter 5: Response to Comments 

Page 5-24 Ashland Travel Management Final EIS 

Subject: Recreation Response #: R-12, Visitor Use Data

because the relatively high visitor use on the Beartooth District heavily influenced the NVUM results which are 

consequently not reflective of the Ashland Ranger District. This information has been included in the FEIS.

Subject: Recreation Response #: R-13, Additional Recreation Data

Letter-Comment #:

13-20 

Furthermore, we request that the data in the next two tables be updated to reflect the significant 

reduction in miles of roads and motorized trails that decisions have produced since this data 

was assembled. This revised data should be used to guide the decision-making to forest plan 

and travel plan alternatives that adequately meet the needs of the public by increasing 

motorized recreational opportunities in the national forest system. 

Response: Data that indicates there are certain percentages of opportunities does not necessarily mean there is a need 

for more or less of those opportunities. The 2005 Motorized Travel Rule required route specific determinations based 

on local factors and does not require the use of national or regional quantities of motorized and non-motorized 

opportunities to determine designations. The cumulative effects are based on the primary users and their primary area 

of use based on available information.

Subject: Recreation Response #: R-14 Develop Non-motorized Trails

Letter-Comment #:

17-1 

I believe the Ashland Ranger District Travel Plan should provide for quiet trails on a portion of 

the forest. The preferred alternative provides for 405 miles of motorized trails, but no quiet, 

non-motorized trails. As a hiker, I know that motorized trails may be fine for the riders of 

ATVs, but can make the hiking experience miserable, due to noise, air pollution, safety 

concerns and tearing up the trails. 

17-2 I would urge the travel planners to create a system of quiet non-motorized trails to restore some 

balance in use and provide greater opportunities for solitude and non-motorized activities, such 

as traditional hunting, hiking, horseback riding, and mountain biking. 

18-2 Alternative B does not provide a variety of non-motorized opportunities throughout the 

Ashland District due to the absence of any non-motorized trails in the analysis area. 

19-1 I suggest the forest create and protect a system of non-motorized quiet trails for the many 

people who are interested in tradition activities like hiking, horse use and quiet recreation. 

20-1 I urge you to create system of quiet non-motorized trails to restore some balance in use and 

provide greater opportunities for solitude and non-motorized activities, such as traditional 

hunting, hiking, horseback riding, and mountain biking. 

26-2 Create a system of quiet non-motorized trails to restore some balance in use and provide 

greater opportunities for solitude and non-motorized activities, such as traditional hunting, 

hiking, horseback riding, and mountain biking. 

39-1 Create a system of quiet non-motorized trails to restore some balance in use and provide 

greater opportunities for solitude and non-motorized activities, such as traditional hunting, 

hiking, horseback riding, and mountain biking. 

40-1 1. Create a system of quiet non-motorized trails to restore some balance in use and provide 

greater opportunities for solitude and non-motorized activities, such as traditional hunting, 

hiking, horseback riding, and mountain biking. 

Response: Construction of non-motorized trails is outside the scope of this project.

Subject: Recreation Response #: R-15, Motorized Use Trends

Letter-Comment #:

22-1 

It is a provable fact that the use of ATVs, motorcycles and snowmobiles has been on a steady 

increase in recent years, yet this is not reflected in either proposal. 

Response: Alternative A specifically emphasizes motorized recreation opportunities on the District. Over snow 

vehicles (snowmobiles) are not a part of this decision. The alternatives were developed based on issues identified 

through public comments and internal scoping. 

Subject: Recreation Response #: R-16, Unlicensed Administrative Use

Letter-Comment #:

28-8 

a. pp 3-5 Motorized Recreation par.2; How can you justify use of FS unlicensed vehicles on 

System Routes and expect to ticket public users of unlicensed vehicles on the same routes? 

Response: We apologize for the confusion - this paragraph will be revised. The Forest Service does not operate 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-25 

Subject: Recreation Response #: R-16, Unlicensed Administrative Use

unlicensed vehicles on system roads. The administrative use of unlicensed vehicles was meant to indicate that the 

Forest Service has observed unlicensed vehicle use by permittees on the District. 

Subject: Recreation Response #: R-17, Displacement

Letter-Comment #:

33-2 

The management plan indicates Alternative B will provide increased opportunity for nonmotorized recreation. This is a benefit for many hunters who are looking for this type of 

opportunity. The potential negative consequence is that there may be displacement of 

motorized hunters from these areas leading to an even greater density of hunters and potential 

overcrowding on the areas where motorized travel is still allowed. 

Response: Displacement of recreation users is considered in the Recreation section of Chapter 3.

Subject: Recreation Response #: R-18, Non-Motorized Opportunity

Letter-Comment #:

42-4 

I would like some areas on the District where the noise of the cars doesn't interfere with a day 

hike. Currently, there are really no areas you can escape the vehicle noise, and I would like 

some quiet areas. 

Response: There are currently three Hiking and Riding areas on the District that provide non-motorized opportunities. 

Alternative B and Alternative B Modified provide additional opportunities for non-motorized experiences during 

specific seasons and yearlong.

SOILS 

Subject: Soils Response #: S-1, Hazard Rating

Letter-Comment #:

3-4 

However, we still recommend that Alternative B be revised or amended to include further 

reductions in motorized routes, particularly routes in areas with high hazard (erosive) soils. 

Table 2-6 (page 2-19) indicates that Alternative B would increase risks to water resource on 17 

miles of routes, and would have 338 miles of routes in areas with high/very high erosion 

hazard ratings, andTable 3-22 (page 3-68) shows that Alternative B would designate nonsystem routes that would add 16.9 miles of routes with increased water resources risks. Table 

3-21 (page 3-67) showing route miles by moderate and high erosion risk watersheds indicates 

that the preferred alternative would increase erosion hazard risks on 37.9 miles of routes and 

decrease risk on 140.5 miles. While Alternative B is clearly an improvement over no action 

and Alternative A, we believe additional reductions in motor vehicle route designations for 

moderate and high hazard soils be included in the preferred alternative. 

3-6 

We believe it would be appropriate to revise or amend Alternative B to reduce erosion and 

watershed risks further, particularly reduction of motorized routes on soils with severe erosion 

hazards and in poorly suited areas and in high hazard watersheds (i.e., Otter Creek-Brian 

Creek, Ash Creek, Otter Creek-Horse Creek, Upper Beaver Creek, Elk Creek, Fifteen mile 

Creek, Taylor Creek, Bloom Creek, Ten mile Creek, Lee Creek, Home Creek, East Fork 

Hanging Woman Creek), and do not support the net increases in water resources risks in high 

risk watersheds proposed with Alternative B (i.e., Bloom Creek and Upper Beaver Creek 

watersheds, Table 3-21). 

18-10 

Next the CNF should include an action alternative that better protects soils. The DEIS explains 

that the preferred alternative will designate 388.41 miles for motorized use on soils that have a 

severe erosion hazard rating, and 299.26 miles on routes that have a poor Native Surface Road 

Suitability Rating. (p.3-87). Unfortunately, more information was not provided to further 

qualify these numbers. Regardless, a new action alternative should protect routes from 

motorized use that: have a greed of 15% or greater; are located above tree line an dare rated as 

highly erosive and poorly suited; are located within 300 ft of fish bearing streams and lakes; 

have stream crossings without bridges; and it should only allow dispersed camping at 

designated sites where the erosion hazard rating is moderate or low. 

18-36 

However, the CNF does not propose limiting route designations because of these problems: 

"These ratings do not mean that management (i.e. roads and trails) should not occur or exist on 

soils with a specific rating but rather what types of mitigation and management are needed to 
Chapter 5: Response to Comments 

Page 5-26 Ashland Travel Management Final EIS 

Subject: Soils Response #: S-1, Hazard Rating

minimize the impact..." (p. 3-84). Unfortunately, the CNF does not explain what mitigation it 

will apply to specific roads and trails located in poorly suited soils, but states generally that it 

will implement Best Management Practices to address these problems: "An indirect effect fom 

the action alternatives would take place as roads and trails identified as system routes 

(including conversion from non-system routes) are maintained to meet standards and 

incorporate BMPs, which would reduce soil effects from these roads and trails." (DEIS, p. 3-

86). This approach is especially problematic because the CNF does not specifically explain 

how the BMPs will improve soil effects from non-system routes. The DEIS does explain that, 

"Incorporating adequate BMPs into the design, construction and maintenance phases of all 

routes can minimize negative effects to the greatest extent feasible and still provide a long-term 

transportation network." (p. 3-62). However, non-system routes were established without 

design and construction parameters that meet BMPs, so it is unclear how they can minimize 

negative effects. 

18-45 

The CNF fails to provide a rational as to why all these routes are needed to "adequately 

administer, utilize and protect" forest resources. Per the Executive Order's primacy of resource 

protections over motorized use, we recommend the CNF not designate routes on highly 

erodible and poorly suited soils where the only reason to do so is to provide for motorized 

opportunities. In other cases, the CNF needs to provide a rationale as to why these routes are 

needed, and the measures it will take to minimize impacts. 

28-12 

Given the limited resources to manage the roads, you should give consideration of closing 

routes located on highly erodible soils. The fall and winter hunting period is also a wet season 

and all Facilities (i.e. roads and motorized trails) are vulnerable to rutting and accelerated 

erosion. Such activity increases the maintenance costs. 

Response: As stated in the Soils section of Chapter 3 in the FEIS “Soil map units may contain one or more ratings 

based on soil components of the map unit. Since the locations of the different components are not mapped, the map 

unit ratings depict the most severe rating for the soils within the map unit. For example, if one soil component has a 

moderate rating while another soil component in the same map unit has a slight rating, the map unit was given a 

moderate rating. In some map units the most severe or limiting rating may comprise the lowest percentage of the map 

unit. For example in the Powder River Soil Survey, the Ringling-Relan association, 6 to 25 percent slopes, map unit 

Ru, is rated as having severe erosion hazard, but only 45% of the map unit actually has that rating, while 55% of the 

unit may have a more favorable rating. These ratings do not mean that management (i.e. roads and trails) should not 

occur or exist on soils with a specific rating but rather what types of mitigation and management are needed to 

minimize the impact, and are used as a comparison in the analysis of effects.” These interpretations are a guide to how 

soils identified in these map units respond to management. In most cases, on site investigation is needed to accurately 

identify soils and hazard ratings. These ratings are used as a comparison tool between the alternatives. Because this 

rating is based on the most severe rating for the map unit, it is highly likely that the miles of routes on high erosion 

hazard soils is less than that identified, due to the effect of components within a map unit. In addition, Alternative B 

and Alternative B Modified decreases the miles of roads on high erosion hazard soils compared to the No Action 

Alternative and Alternative A. 

Subject: Soils Response #: S-2, Sediment

Letter-Comment #:

13-10 

A sense of magnitude must be used when making decisions about road closures based on 

indicators such as sediment production. For example, a route should not be closed because it is 

estimated to produce 10 cube yards less sediment. The sediment yield must be compared to 

naturally occurring conditions which includes fires. The recent fires in the Custer National 

Forest discharged thousands of cubic yards of sediment to the area streams which is more than 

all of the motorized routes in the project area for the next 100 years. 

Response: It is difficult to determine the exact amount of sediment generated by roads and trails, or the amount of 

sediment generated as a result of wildfires. The soils analysis does not try to quantify the erosion from roads and trails 

but describes the hazard of potential erosion and suitability of the soils for natural surface roads and trails. We do 

recognize that many factors contribute to erosion and sedimentation. Determining which roads and trails are 

designated for public use, administrative use, and which ones are not designated was based on many factors, not just 

soils and erosion hazard. 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-27 

Subject: Soils Response #: S-3, Mitigation

Letter-Comment #:

18-36 

However, the CNF does not propose limiting route designations because of these problems: 

"These ratings do not mean that management (i.e. roads and trails) should not occur or exist on 

soils with a specific rating but rather what types of mitigation and management are needed to 

minimize the impact..." (p. 3-84). Unfortunately, the CNF does not explain what mitigation it 

will apply to specific roads and trails located in poorly suited soils, but states generally that it 

will implement Best Management Practices to address these problems: "An indirect effect fom 

the action alternatives would take place as roads and trails identified as system routes 

(including conversion from non-system routes) are maintained to meet standards and 

incorporate BMPs, which would reduce soil effects from these roads and trails." (DEIS, p. 3-

86). This approach is especially problematic because the CNF does not specifically explain 

how the BMPs will improve soil effects from non-system routes. The DEIS does explain that, 

"Incorporating adequate BMPs into the design, construction and maintenance phases of all 

routes can minimize negative effects to the greatest extent feasible and still provide a long-term 

transportation network." (p. 3-62). However, non-system routes were established without 

design and construction parameters that meet BMPs, so it is unclear how they can minimize 

negative effects. 

18-37 

Furthermore, the CNF places much emphasis on work to be completed sometime in the future 

through regular maintenance: "...as long as most impacts are limited to the immediate area of 

disturbance, the road or trail can be maintained at a reasonable cost, and permits use as long 

as it's needed." (DEIS, p. 3-84). This assertion is in direct conflict with earlier statements that 

the CNF cannot maintain its current transportation system, and has not used any trail funds. 

The DEIS should have specifically identified which routes need BMPs, the type of work 

involved (such as relocation), the funding necessary to implement the work and where those 

funds would come from. 

Response: Specific mitigation on specific roads and trails is identified in our deferred maintenance inventory. These 

maintenance issues are addressed through project level work and as funding is available. For those roads that will be 

designated for public use or for administrative use, many options exist to help address BMP and resource concerns, if 

excessive resource damage occurs. These options can include route closure, identifying season of use periods, 

improving drainage, and surfacing, and others. Exact actions will be site specific. 

VEGETATION 

Subject: Vegetation Response #: V-1, Weed Spread

Letter-Comment #:

3-14 

Table 3-32 (page 3-100) evidences that Alternative B has the lowest risk of weed invasion, 

although 46, 665 acres are still shown with risk of week invasion under Alternative B. We 

encourage additional limitations of motorized uses to reduce threat of weed spread...Weed free 

seed forage should be required for backcountry users. 

Response: There is potential for weed spread along motorized routes, just as there is potential for weed spread in 

some areas that are not disturbed, or areas that could be disturbed by other elements such as wildfire. Although 46, 665 

acres were identified in Alternative B as being susceptible to infestation, 3% of the area (1, 646 acres) includes low 

density infestations that are annually monitored and treated as necessary. When compared to No Action, Alternatives 

B and B Modified reduces risk of vehicle related potential weed impacts by 10, 941 and 11,616 acres, respectively, 

while Alternative A increases risk of impacts by 5, 111 acres. Routes proposed for closure under Alternatives B and B 

Modified (# 47941, 47943, 44383, and 44401A) bisect the more problematic infestations. Weeds will continue to be 

spread as a result of motorized and non-motorized resource management, recreational use, other human activities, 

wildlife, and natural processes. To reduce the effects of weed spread, the Forest Service will monitor routes for early 

detection of new weed infestations and treat when they are still small. The impacts of weed management were analyzed 

in the 2006 Custer National Forest Weed Management EIS and were incorporated into this analysis by reference. Weed 

free seed forage is required for backcountry users.
Chapter 5: Response to Comments 

Page 5-28 Ashland Travel Management Final EIS 

Subject: Vegetation Response #: V-2, Correction

Letter-Comment #:

8-11 

Page 3-44: There is a reference to the alpine tundra in the Ashland District. I do not believe 

this is an accurate comment. 

Response: This observation has been corrected in the Final EIS.

Subject: Vegetation Response #: V-3, Livestock Grazing

Letter-Comment #:

8-15 

3-101: Livestock grazing may transport seeds. Your omission of birds, game animals and 

animals within the ecosystem falsely implies that only livestock transport seeds. The 

movement of the livestock is from the Forest District to the private lands when seeds are 

mature-in the late summer and fall. Therefore, the livestock are not major transporters of seeds 

from the private land to the forest. The non-domesticated species present in the District move 

between the private and forest at will, carrying seeds both directions. The implication that 

livestock are the primary culprits in weed transport onto the forest is not supported or justified 

in the discussion. 

Response: DEIS page 3-101 outlined that various spread vectors exist. The discussion on page 3-101 does not imply 

that livestock are the primary culprits in weed transport. The paragraph that is referenced will be clarified to remove 

references to private lands.

Subject: Vegetation Response #: V-4, Transport of Weeds

Letter-Comment #:

18-12 

Finally, the CNF should include an action alternative that better protects vegetation in relation 

to the spread of invasive, non-native plants. Table 3-32 shows that the preferred alternative 

will designate 77 miles bisecting weed infested acres, representing 41 percent of inventoried 

acres. (DEIS, p. 3-100). A new action alternative should reduce this value to zero.... 

Response: Many agents will continue to transport weeds and weed seeds, regardless of the decision on travel, but the 

fewer the agents, the less weed spread. However, removing all use would still not totally eliminate the spread of 

weeds. Therefore, noxious weed management requires a balance of use restriction, public education, implementation 

of best management practices (BMPs), and effective treatment measures. The 77 miles referenced go through 

infestations that are low density and steeper slopes where it is unlikely that there would be dispersed vehicle camping 

spread vector issues. These route right-of-ways are routinely monitored and treated when necessary.

Subject: Vegetation Response #: V-5, Pregnant Sedge

Letter-Comment #:

18-13 

...emphasize protection in areas known to contain Pregnant sedge. In relation to sensitive plant 

species generally, the new alternative should not designate motorized use along the routes 

identified in Table 3-36. 

Response: Pregnant sedge population exposure to potential impacts are moderate due to route proximity. However 

population landscape position does not encourage dispersed vehicle camping. An occasional hiker or rider may impact 

individuals but are not likely to contribute towards Federal listing or loss of viability to the population or species. 

Therefore, a new alternative was not considered for closing major capital investment routes (Cow Creek campground 

and Stocker Branch) 

Subject: Vegetation Response #: V-6, Habitat Quality

Letter-Comment #:

18-14 

3-97: 'Weeds' can significantly alter the composition of the plant community. Your statement 

that weeds decrease the habitat quality is not accurate. Some 'weeds' are beneficial as 

evidenced by the reseeding of the roads and other restoration projects using species such as 

'Crested wheatgrass' or 'Kentucky bluegrass' both introduced species and both used by the 

Forest Service on revegetation projects in the past. 

Response: Habitat quality was based on native plants generally having higher quality aspects rather than invasive 

weed plants. Invasive weed plants can dominate a site an impair habitat quality. You are correct that non-native 

species such as crested wheatgrass or Kentucky bluegrass were used in the past on Forest Service revegetation projects. 

However, current policy and practices incorporate use of native species, rather than non-native species in order to 

promote native ecosystem function and integrity.
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-29 

WATER QUALITY 

Subject: Water Quality Response #: WQ-1, Affected Environment

Letter-Comment #:

3-1 

The DEIS states that Alternative B would include 37.5 miles of route miles with increased risks 

to water resources, and adds 16.9 miles of routes with increased water resources risks. 

Alternative B would result in a net increase in water resources risks in the Bloom Creek, Lyon 

Creek, Threemile Creek, and Upper Beaver Creek watersheds (i.e., more miles with increase 

in risk than decrease in risk), and we note that the Bloom Creek and Upper Beaver Creek 

watersheds are shown in the DEIS as "high risk" watersheds. Forty miles of roads and trails 

would be designated on landscapes that have a "severe erosion hazard" rating (10 miles Public 

use and 30 miles Administrative use). Alternative B would have 338.41 miles of routes 

designated for public motorized uses on soils with "severe erosion hazards", and 299.26 miles 

on soils that are "poorly suited" for roads and trails. We do not support the addition of new 

routes with high risk of erosion and water quality impacts to the road system, especially when 

road maintenance is already inadequate to address resource impacts from exiting roads. 

3-5 

It is not entirely clear to us how these risk ratings were developed, but the tables show that 

Alternative B would reduce water resources risks more than Alternative A and no action. 

18-8 

Third, the CNF should add an action alternative that better protects water quality limited 

streams that are still in need of Total Maximum Daily Load (TMDL) determination, that 

protects streams that have not had all beneficial uses assessed, and watersheds listed as high 

risk. Specifically this means routes crossing and adjacent to Hanging Woman Creek (category 

5), and Beaver, Little Pumpkin, Otter, Powder, and Pumpkin Creeks (category 3), as well as all 

those watersheds listed as high risk in Table 3-19 of the DEIS. 

18-43 

The CNF needs to develop and choose an alternative that better protects water quality limited 

streams that are still in need of TMDL determinations, that protects water quality limited 

streams that have not had all beneficial uses assessed, and watershed listed as high risk. 

Specifically, this means routes crossing and adjacent to Hanging Woman Creek (category 5), 

and Beaver, Little Pumpkin, Otter, Powder, and Pumpkin Creeks (category 3), as well as all 

those watersheds listed as high risk in Table 3-19 of the DEIS. The CNF should decommission 

routes within these watersheds that cause resource damages and which cannot be adequately 

maintained. 

Response: The water resource affected environment analysis is a broad scale, risk based assessment. Risks to water 

resources from the existing transportation system are determined at the 6 HUC watershed scale from GIS spatial data 

concerning stream length, route length and number of stream crossings. Presence of category 5 TMDL streams also 

elevate watershed risk ratings. Direct, indirect or cumulative route risk is based on whether the proposed action for the 

individual route will increase, decrease or have no effect on risk. Individual route risks have not been evaluated from 

site specific GIS spatial data or field data as this data has not been generated or collected. Additionally, cumulative 

impacts of individual routes at the watershed scale have also not been measured on-ground and quantified. 

The preferred alternative proposes actions that increase net risk to water resources in only three (11%) of the 28 

moderate and high risk watersheds on the District, while actions that decrease net risk are proposed in 24 watersheds 

(86%). Risk remains unchanged in one watershed. None of the watersheds with a net increase are high risk 

watersheds or have TMDL category 5 streams. The reasons for the decrease in risk are due to changing system routes 

to administrative use only, applying a season of use to converted roads, and not designating some system routes. From 

a District-wide cumulative summary, the proposed actions could be expected to result in a net reduction in risk along 

36 percent of the 904 total route miles evaluated (see Chapter 3, Water Resources). 

Subject: Water Quality Response #: WQ-2, TMDLs

Letter-Comment #:

3-3 

The Plan should also be consistent with Total Maximum Daily Loads (TMDLs) and Water 

Quality Plans that are being developed to restore water quality and beneficial use support in 

impaired 303(d)-listed waters in the area (e.g., Hanging Woman Creek, East Fork of Armells 

Creek, Little Porcupine Creek). 

3-5 It is not entirely clear to us how these risk ratings were developed, but the tables show that 

Alternative B would reduce water resources risks more than Alternative A and no action. 

3-7 It is not clear to us if any portions of these impaired stream segments may be located on 
Chapter 5: Response to Comments 

Page 5-30 Ashland Travel Management Final EIS 

Subject: Water Quality Response #: WQ-2, TMDLs

National Forest land, but we compared vs. the most current 2006 303 (d) list (available at, 

http://www.deq.state.mt.us/CWAIC/default.aspx), to be sure that all listed streams within the 

District are identified. 

18-8 

Third, the CNF should add an action alternative that better protects water quality limited 

streams that are still in need of Total Maximum Daily Load (TMDL) determination, that 

protects streams that have not had all beneficial uses assessed, and watersheds listed as high 

risk. Specifically this means routes crossing and adjacent to Hanging Woman Creek (category 

5), and Beaver, Little Pumpkin, Otter, Powder, and Pumpkin Creeks (category 3), as well as all 

those watersheds listed as high risk in Table 3-19 of the DEIS. 

Response: No TMDLs are located within the Forest boundary and only one is located immediately downstream; 

Lower Hanging Woman. Tributaries to Lower Hanging Woman that are within the Forest boundary are identified in 

Chapter 3, Table 3-24. The TMDL for Hanging Woman has not yet begun. EF Armells and Little Porcupine Creeks 

are located far from the District, in fact, Little Porcupine Creek is all the way on the north side of the Yellowstone 

River. Category 3 TMDL streams have not had beneficial uses assessed, and therefore causes and sources have not 

been identified. However, moderate and high risk Category 3 TMDL streams carried forward to effects analysis 

include the following watersheds: Upper Beaver Creek, Lower Little Pumpkin Creek, Otter Creek-Brian, Otter CreekHorse, Otter Creek-Newell and Powder River-Plum (Chapter 3, Table 3-24). The preferred alternative proposes 

actions that decrease net risk to water resources in all of these Category 3 watersheds. 

Subject: Water Quality Response #: WQ-3, Wetlands

Letter-Comment #:

3-10 We did not see much other discussions, however, regarding potential impacts of travel 

management alternatives on wetlands, and if any impacts occur, how they will be mitigated 

(i.e., mitigation means sequence of avoidance, minimization, rehabilitation, and compensation 

for unavoidable impacts). We believe the wetlands, and if no impacts are expected, at least 

state that. 

Response: A discussion of wetlands is now included in the FEIS under Water Quality, Human Influences, 

Transportation Systems and under Environmental Consequences. 

Subject: Water Quality Response #: WQ-4, Water Regime

Letter-Comment #:

8-13 

Page 3-61: Timber harvest and prescribed burns on 30, 000 acres haven't impacted the water 

regime but what about the 121, 000 acres of catastrophic wildfires (stated on page 3-60) during 

the past decade. This acreage should be included in the assessment of the water regime. 

Conversations with permittees indicate t here is a positive impact to the water regime after the 

initial year following the burn with increased spring and creek flows due to the removal of the 

tree cover. 

Response: Water regime, i.e., water yield, was not specifically addressed for this analysis because 1) increases in 

water yield is generally not an issue on the Ashland District, 2) although road networks can influence water movement 

across landscapes, effects to stream flow is difficult to evaluate due to many highly variable drivers, including high 

intensity rain events, and 3) the errors associated with any cumulative results which included the effects of timber 

harvest and fire on water yield, would be so high that interpretation of the results would be highly uncertain. 

Subject: Water Quality Response #: WQ-5, Methodology

Letter-Comment #:

18-18 

The CNF needs to better assess the impacts to water quality. Specifically, the DEIS explains 

that, “Individual routes have not been evaluated on the ground for impacts or risks to water 

resources. Instead, route networks were evaluated for their potential to impact water quality at 

the 6 HUC (hydrologic unit code) watershed scale (10, 000-40, 000 acre) using GIS." (p. 3-62). 

While we certainly understand the Custer's lack of resources as a limiting factor in evaluating 

water quality impacts, we assert the Forest Service still has an obligation to demonstrate this 

modeling is an effective measure in determining those impacts. Furthermore, there are 12 

watersheds with a high risk rating, one category five and five category three water quality 

limited streams. At the very least, the CNF should perform site-specific analysis along these 

streams and assess the potential impacts, especially at stream crossings. 

18-23 The CNF needs to include the potential for increased sedimentation due to erosion in its 

methodology for determining impacts to water quality and riparian areas. The DEIS explains, 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-31 

Subject: Water Quality Response #: WQ-5, Methodology

"There are three basic types of erosion; 1) detachment an routing of individual soil particles 

from the eland surface; 2) mass wasting such as landslides and slumps: and 3) detachment and 

mobilization of stream channel banks or bottom material, i.e., in stream erosion. All of these 

processes produce "sediment,” and all stream systems transport sediment." (p. 3-59). From 

reading the DEIS, it is clear that erosion and resulting sedimentation are major factors that 

could affect water quality. 

18-25 Therefore it is not unreasonable to incorporate this information into the water quality analysis 

in order to estimate stream segments that have the potential for increased sedimentation and the 

resulting impacts to the watershed. 

Response: The water resource analysis is a broad scale risk based assessment, not an absolute quantified impact 

assessment. It uses 6 HUC watersheds as reasonable cumulative effects areas to summarize the spatial extent of 

existing and proposed activities. Increased erosion and sediment delivery to streams is accounted for indirectly through 

the risk assessment. From a travel route management standpoint, as roads and stream crossings increase, risk of erosion 

and sediment delivery to streams also increase. More variables and more spatial layers could be incorporated to refine 

the evaluation of watershed risk, but the main drivers of risk will still be road miles and stream crossings. Due to the 

extensive area involved (1, 008, 934 6 HUC watershed acres) and the high number of route miles across the District 

and adjacent lands (2, 470 miles), quantifying absolute impacts is not practical. The high risk watersheds, which 

include the two tributaries to the only stream requiring a TMDL, are accounted for in the Effects by Alternative 

section. 

Subject: Water Quality Response #: WQ-6, Direct Effects

Letter-Comment #:

18-19 

The DEIS incorrectly assumes that the only direct impacts to water quality comes from, “...the 

installation, reconstruction or removal of stream crossing structures..." (p. 3-66). Direct 

impacts come from stream crossings where no such structures exist or where existing structures 

are in need of maintenance. 

Response: Direct effects are caused by the action and occur at the same time and place [as the action] (40 CFR 1508.8 

(a)). In this analysis, fords are considered a stream crossing structure as approaches and channel substrate generally 

require some level of excavation and therefore can result in direct effects if they are part of the proposed action as new 

construction or reconstruction. Direct effects, by this definition, cannot occur from existing stream crossings if no 

action is proposed for an individual crossing. Existing crossings with existing impacts and impacts from vehicles 

fording streams are a cumulative effect, not a direct effect from an action that is not proposed. 

Subject: Water Quality Response #: WQ-7, Stream Crossings

Letter-Comment #: 

18-20

The DEIS explains, "Since impacts to water quality generally occur from concentrated road 

surface flows routed directly to streams at crossing locations (bridges, culverts or fords), 

stream crossings were a key variable in the evaluation." (p. 3-62). However, even though 

stream crossings were supposed to be a key variable, there is no listing of the current 

conditions for each stream crossing or crossings that have no structures. Furthermore, no maps 

exist illustrating where the stream crossings occur in relation to the alternatives, which we 

learned when we requested them from the project files. Without this information, we are at a 

loss on how to comment on specific sections that may have stream crossings and ask this 

information be included in the Revised DEIS with an opportunity to comment. 

Response: All stream crossings are considered a high risk for this analysis, regardless of the condition or type. 

Existing stream crossings were accounted for through the GIS spatial analysis and therefore maps were not required. 

The results of this analysis are displayed in Table 3-23 and summarized by total crossings, FS intermittent crossings 

and FS perennial crossings for each 6 HUC watershed. This information was used to help identify existing risk levels 

for 6 HUC watersheds. 

Subject: Water Quality Response #: WQ-8, 303(d) Listed Stream Segments

Letter-Comment #:

18-22 

It is important to note that 303 (d) listed stream segments are fed from corresponding 

tributaries, and any TMDL needs to factor in all sources of pollutants. The DEIS methodology 

is not specific enough to analyze impacts to these tributaries from proposed route designations. 

We urge the CNF to consult with Montana DEQ and appropriate EPA staff to ensure route the 

Ashland travel plan does not hinder their efforts to address water quality. 
Chapter 5: Response to Comments 

Page 5-32 Ashland Travel Management Final EIS 

Response: Per Table 3-24, the only stream near the District that currently requires a TMDL is Lower Hanging 

Woman. Tributaries of Lower Hanging Woman that are within the District include the EF Hanging Woman and Lee 

Creek, both of which are identified as high risk watersheds, in part, because TMDLs are required. Under Alternatives 

B and B-Modified, the proposed actions result in a substantial net decrease in risk in both of these watersheds. 

Subject: Water Quality Response #: WQ-9, Erosion and Sediment

Letter-Comment #:

18-24 

However, in analyzing these potential impacts, the DEIS makes some contradicting statements. 

Specifically, it explains, “Numerous studies have identified unpaved roads as a major source of 

sediment in streams (Elliot 2000). Sudden and Woods (2007) measured 20 unsurfaced road 

plots in western Montana and found average annual sediment yields to be 5.4 Mg/ha/yr (14.7 

tons/ac/yr)." (DEIS, p. 3-61. Even though sedimentation is important, the DEIS states, 

“Sediment modeling was not incorporated into the effects analysis for water quality for many 

reasons." (p. 3-69). However, the CNF was able to determine areas that have highly erosive 

soils (see DEIS section 3.3.2.1 Affected Environment-Soils). 

Response: These are not contradicting statements. The analysis recognizes that travel routes can cause erosion and 

produce sediment. Refer to references cited on page 3-61 and 62 of the DEIS. This erosion and sediment can be 

accounted for directly through sediment modeling efforts, or indirectly through surrogate variables, i.e., road miles and 

stream crossings. The discussion in the DEIS provides the rationale for why sediment modeling was not used in this 

analysis. Soil erosivity was a component of the soils analysis, not the watershed risk analysis. 

Subject: Water Quality Response #: WQ-10, Indirect Effects

Letter-Comment #:

18-29 

We also challenge the CNF's assertion that road to trail conversions do not change risk to 

watersheds. (DEIS, Table 3-22, p. 3-68). The DEIS directly contradicts this assumption with 

the statement, “One of the four watersheds with a net increase is a high risk in these watersheds 

is the conversion of system roads to trails." (DEIS, p. 3-67). This net increase seems to 

contradict the earlier assertion that road to trail conversions do not "substantially change risk." 

From this observation it is clear that the road to trail conversion has some impact to specific 

stream segments, and the assertion that this action results in no change of risk to the watershed 

is arbitrary and capricious, and in violation of NEPA. 

Response: The indirect effects by alternative have been corrected to read “The sole reason for the net increase is due 

to the addition of non-system roads to the transportation system.” As stated in the DEIS (p. 3-66), “converting roads to 

trails is not expected to change the type or level of use, nor the priority for maintenance along these routes.” If these 

key factors remain the same whether the route is a road or a trail, risks to water resources will also remain the same. 

Subject: Water Quality Response #: WQ-11, Road and Trail

Letter-Comment #:

18-27 

The CNF asserts that "...converting roads to trails is not expected to change the type or level of 

use, nor the level or priority for maintenance along these routes. Therefore, these actions would 

not substantially change risk." (p. 3-66). This is a false statement because the maintenance level 

will surely change from road based classifications (ML 1, 2, etc.) to trail based (T1, T2, etc.). 

Accordingly, each conversion would require a change from road management objectives to trail 

management objectives. Trails are not maintained in the same manner or by the same schedule 

as roads. The maintenance standards are weaker for trails, as is the frequency of maintenance. 

Therefore, it is possible that impacts from these trails, such as erosion and sedimentation in 

nearby watercourses, will be increased...Furthermore, in assessing cultural impacts the CNF 

recognized that, “Discontinued use of the road, or change in use to lower standard such as a 

conversion to a motorized trail could result in less maintenance and could threaten the 

preservation of the road as a road." (DEIS, p. 3-25). Even though this observation relates to 

historic roads the admission that lesser maintenance could result from a road to trail conversions 

prove that this factor should be included in the water quality effects analysis. 

18-30 

Furthermore, the CNF incorrectly states that, "Changing the mode of travel from highway legal 

vehicle to all motorized vehicles is not expected to change the type of vehicle that currently uses 

these routes...Therefore, these actions would not substantially change risk." (DEIS, p. 3-66). 

Keep in mind that the purpose and need of this project is, in part, to provide opportunities for 

unlicensed off-highway vehicle use, and to meet this need the preferred alternative will "Convert 

system roads to motorized trail (392 miles)." (DEIS, 2-3, 2-9). Indeed the need must be great to 

propose so many miles for conversion. Yet, the CNF asserts that such an action will not 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-33 

Subject: Water Quality Response #: WQ-11, Road and Trail

substantially change the risk to watersheds, but it did not take into account the change in levels of 

use. Obviously there will be an increase in use based on the CNF's own admission that there is a 

need, yet there was no analysis as to the level of increase or the potential impacts to water 

quality. It seems apparent that there will be a change in types of vehicles that use the converted 

roads, since that is the purpose of such action. If the CNF predicts there will be no change in the 

types of vehicles currently using these roads, then why change them to trails in the first place? 

18-31 

This point aside, the CNF falsely asserts that changes in the type of vehicles used on the 

converted roads will not result in significant impacts. Off-road vehicle (ORV) travel on roads 

and trails can have significant impacts on stream habitat. While driving on roads has long been 

identified as a major contributor to stream sedimentation (for review see Gucinski 2001), recent 

studies have found ORVs to be a significant cause of stream sedimentation as well (Sack and 

daLuz 2004, Chin et al. 2004, Ayala et al. 2005, Welsh et al. 2006). While roads often have 

greater erosion and contribute to stream sedimentaiton more than trails, this not always the case. 

One ongoing study (Welsh et al. 2006) found that ORV trails produced five times more sediment 

than unpaved roads. It has also been demonstrated that sediment loss increases with increased 

ORV traffic (Foltz 2006). Stream sedimentation can greatly reduce aquatic habitat. (Newcomb 

and MacDonald 1991). For example, Chin et al. (2004) found that watersheds with ORVs 

exhibited higher percentages of sands and fines, lower depths, and lower volume - all 

characteristics of degraded stream habitat. Even a single stream crossing can have a negative 

impact on aquatic habitat. For example, a modeling exercise found that the average annual 

sediment yield from one ORV stream crossing to be 126.8 tons/ha (Ayala et al. 2005). 

Additionally, a study by Sack and da Luz (2003) found that off-road vehicle use resulted in a loss 

of more than 200 pounds of soil off every 100 feet of trail each year. 

Response: The water resource analysis did not assert that changes in the type of vehicles used on the converted roads 

will not result in significant impacts, but did assert that these changes would not substantially change risk. The water 

resource analysis provided a number of references that document the adverse effects ORV use can have on soil erosion 

and stream sedimentation (p. 3-61 and 62). Thank you for the additional references documenting these impacts. 

Subject: Water Quality Response #: WQ-12, Maintenance

Letter-Comment #:

28-14 

a. pp 3 - 66 Indirect Effects par 3; While I don't agree that the act of conversion of "user built 

routes to the System is the only action that increases risk to the water quality, it certainly is 

important. In my view, deferring road and trail maintenance year after year is the biggest 

threat. The author's point on conversion or System roads to a lower standard of maintenance 

certainly will place many routes to high risk routes as far as potential adverse effects to the 

watersheds You should take his point seriously. 

Response: Deferring road and trail maintenance year after year is not a proposed action under this analysis. Actions 

that have the potential to change risk to water resources and the rationale for why actions increase, decrease or do not 

change risk was provided in the DEIS, page 3-66. The effect on route risk of converting system roads to a lower 

standard of maintenance was not discussed in the water resource analysis. 

Subject: Water Quality Response #: WQ-13, Season of Use

Letter-Comment #:

28-15 

b. Pp 3 - 67; Watersheds at risk; Plan B points to 4 Watersheds, where this Alternative would 

result in increased risk. It appears that considerable thought should be given to a Fall early 

Winter seasonal closure on a large number of Motorized Trails, both to protect roads from 

rutting and to reduce gravitational sediment flows downstream in the watersheds. 

Response: The broad-scale watershed risk analysis was used to provide a coarse level picture of relative risk across 

the District and a way to focus the effects analysis. It is not appropriate to use this coarse assessment to fine-tune 

proposed actions of individual routes in order to adjust watershed risks. 

As discussed in the DEIS, applying a seasonal use period related to the fall hunting season has the potential to reduce 

surface erosion, rutting and maintenance needs when roads are wet before freeze-up, although not to the level that 

could be attained during a spring break-up closure period. Additionally, reducing miles of non-system routes 

designated, or increasing miles of roads open only to administrative use may result in a more meaningful reduction in 

risk for some watersheds than simply applying a broad reach, fall seasonal closure period. 
Chapter 5: Response to Comments 

Page 5-34 Ashland Travel Management Final EIS 

Subject: Water Quality Response #: WQ-14, Site Specific

Letter-Comment #:

28-16 

c. PP 3 - 68 - I fail to understand the interpretation of Risk as used in these tables and narrative. 

The Travel Plan, is the action being analyzed, thus there can be no routes without risk. 

28-19 f. Pp 3-70 The Author loses me in his separation of routes by proposed action. My view is that 

all the routes are under consideration in this analysis. 

Response: The water resource affected environment analysis is a broad scale, risk based assessment. Risks to water 

resources from the existing transportation system are determined at the 6 HUC watershed scale from GIS spatial data 

concerning stream length, route length and number of stream crossings. Presence of TMDL streams, and exceptionally 

high fire acres and intermittent stream crossings also elevate watershed risk ratings. 

Existing individual route risks have not been evaluated from site specific GIS spatial data or field data as this data has 

not been generated or collected. Additionally, cumulative impacts of individual routes at the watershed scale have also 

not been measured on-ground and modeled quantitatively. However, individual route risk is evaluated for direct, 

indirect or cumulative effects based on whether the proposed action for the individual route will increase, decrease or 

have no effect on risk. Therefore, from a NEPA standpoint, only routes with proposed actions will have an associated 

risk. In contrast, routes with no proposed actions, e.g., existing system routes with no proposed change in management 

will have no change in risk. 

Subject: Water Quality Response #: WQ-15, Modeling

Letter-Comment #:

28-17 

d. Pp 3-69 bottom paragraph. Why discuss modeling if the inherent errors are such as this tool 

is inappropriate to the decisions being made in this Analysis? 

Response: It is important to discuss why sediment modeling is not used in the analysis because there are those that 

suggest it should be. 

Subject: Water Quality Response #: WQ-16, Decommissioning

Letter-Comment #:

18-21 

The CNF appears to rely on BMPs and future actions, such as those listed in Appendix D, to 

meet regulations. However, those BMPs may not be sufficient to satisfy 

"reasonable....conservation practices,” especially given the lack of funding available. Also, 

Appendix D only lists three opportunities to address water quality concerns, and given the 

amount of stream crossings listed in Table 3-19, we question if more can be done to improve 

water quality in areas of high risk and in watersheds with 303(d) listed streams. 

28-18 e. Pp 3 - 70; Conclusion; The Author states; that some routes may not comply with the FP 

Direction and various State and Federal Regulations. These routes should be fixed up or 

withdrawn from the System. 

28-20 In my view, the NEPA analysis, as documented in the FEIS, must sort out the roads and 

motorized routes which are not in compliance with the rules of management. Specific action 

must then be prescribed to bring the entire System into compliance. 

Response: As discussed in the DEIS, Chapter 1, decisions that will not be made include, among other things, 

decommissioning or obliterating routes, including routes that may not be in compliance with standards. Additionally, 

later in this chapter, a discussion of maintenance funding indicates that future funding levels will likely be insufficient 

to maintain standards on all routes, but the Forest will prioritize maintenance work and apply for supplemental funding 

whenever possible. Appendix D provides the best information on routes with existing impacts to water resources and 

the best mechanism for correcting these impacts. 

WILDLIFE 

Subject: Wildlife Response #: WL-1, Walk-in Hunting

Letter-Comment #:

4-4 

Your current plan does not conform the MT FWP recommendation for the Custer EMU. It also 

does not conform to research that would improve recreational hunting opportunities on the 

Custer. It has been shown time and again that roads decrease hunting opportunity. Roads only 

increase driving opportunity. 

Closing roads to increase big game security cover should be done in concert with other 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-35 

Subject: Wildlife Response #: WL-1, Walk-in Hunting

4-5 management strategies. Road closures should be prioritized in areas where other management 

activities such as timber harvest or hazardous fuel reduction efforts are not a priority. The 

increased benefits to big game of closing a road are greatly reduced or eliminated if subsequent 

management actions reduce the habitat quality of the area. 

4-11 According to Executive Order #13443 Facilitation of Hunting Heritage and Wildlife 

Conservation, the FS is specifically supposed to be responsive to State Wildlife Management. 

According to the MT FWP Custer EMU in the Elk Management Plan, the State has called for 

increasing walk-in hunting areas. This excluded all current hiking and riding areas, since they 

existed prior to the most current State Elk Management Plan. You have not actively promoted 

additional walk in hunting areas in your current travel plan, and I request that you make create 

walk in hunting areas on the District. Specifically, I have asked that the walk in hunting areas 

be seasonally walk in areas, during Archery season to provide an alternate recreation 

opportunity to the nearly 100% motorized opportunity that is currently in the preferred 

alternative. 

Response: Currently under the No Action Alternative, the Ashland RD supports about 47, 533 acres of hiking and 

riding area that kind be used for walk-in hunting. The Preferred Alternative B Modified proposes an additional 61, 678 

acres of habitat, minimum size of 2, 500 acres, that can be used for walk-in hunting. The Preferred Alternative B 

Modified would provide for walk-in hunting opportunities on about 22% of the District. 

Subject: Wildlife Response #: WL-2, Elk Security

Letter-Comment #:

20-3 

In addition, the plan should create and expand core habitat without roads and motorized trails 

to maintain a viable and healthy elk population, and prevent user created routes and off-road 

damage by limiting travel off-road for dispersed camping to designated routes or the length of a 

vehicle, as in other national forests. 

Response: When comparing core habitat from the No Action Alternative to the Preferred Alternative B Modified, 

core habitat would increase by 10% (from 18% to 28%). Elk security habitat increases from 25% to 38%. Open 

motorized route density goes from 1 mile/mile2 to 0.82 mile/mile2.

Subject: Wildlife Response #: WL-3, Core Habitat

Letter-Comment #:

4-4 

Your current plan does not conform the MT FWP recommendation for the Custer EMU. It also 

does not conform to research that would improve recreational hunting opportunities on the 

Custer. It has been shown time and again that roads decrease hunting opportunity. Roads only 

increase driving opportunity. 

4-5 

Closing roads to increase big game security cover should be done in concert with other 

management strategies. Road closures should be prioritized in areas where other management 

activities such as timber harvest or hazardous fuel reduction efforts are not a priority. The 

increased benefits to big game of closing a road are greatly reduced or eliminated if subsequent 

management actions reduce the habitat quality of the area. 

17-3 Please create and expand core habitat without roads and motorized trails to maintain a viable 

and healthy elk population. 

26-4 Create and expand core habitat without roads and motorized trails to maintain a viable and 

healthy elk population. 

39-3 Create and expand core habitat without roads and motorized trails to maintain a viable and 

healthy elk population. 

40-3 3. Create and expand core habitat without roads and motorized trails to maintain a viable and 

healthy elk population. 

Response: When comparing core habitat from the No Action Alternative to the Preferred Alternative B Modified, 

core habitat would increase by 10% (from 18% to 28%).

Subject: Wildlife Response #: WL-4, Cumulative Effects

Letter-Comment #:

33-1 

Closing roads to increase big game security cover should be done in concert with other 

management strategies. Road closures should be prioritized in areas where other management 

activities such as timber harvest or hazardous fuel reduction efforts are not a priority. The 

increased benefits to big game of closing a road are greatly reduced or eliminated if subsequent 
Chapter 5: Response to Comments 

Page 5-36 Ashland Travel Management Final EIS 

Subject: Wildlife Response #: WL-4, Cumulative Effects

management actions reduce the habitat quality of the area. 

Response: Under the Preferred Alternative B Modified, about 163 miles of existing road would be undesignated, 161 

miles would be administrative use only, and 27 miles would have a seasonal closure during the hunting season. Several 

fuels reduction and/or timber projects are scheduled on the in the foreseeable future (See 3.1.2.1). All of these projects 

are designed with wildlife habitat management in mind. Much of the prescribed burning or mechanical fuel treatments 

are partially funded by wildlife organizations such as the Rocky Mountain Elk Foundation and National Wild Turkey 

Federation. 

Subject: Wildlife Response #: WL-5, Big Game Security

Letter-Comment #:

4-5 

Closing roads to increase big game security cover should be done in concert with other 

management strategies. Road closures should be prioritized in areas where other management 

activities such as timber harvest or hazardous fuel reduction efforts are not a priority. The 

increased benefits to big game of closing a road are greatly reduced or eliminated if subsequent 

management actions reduce the habitat quality of the area. 

Response: Under Preferred Alternative B Modified elk habitat management parameters would be within the 

recommendations of Lyon and Christensen (1992) and Hillis et al. (1991). 

Subject: Wildlife Response #: WL-6, References

Letter-Comment #:

4-6

I ask that you reevaluate the elk cover and look specifically at timbered stands. Hillis's the 

research was assuming much steeper terrain with a heavily forested canopy, not the relatively 

flat open ponderosa pine terrain that you see on the Custer. Given the fact that the Custer NF is 

much more open, I ask that you look at the recommendation by Hillis to the Big Horn NF, to 

use secure cover definition of >1 mile for any road and >500 areas in size for elk secure cover. 

4-7 

I also ask that you increase secure cover area to 30% to 50% of forested areas, not just 30% of 

the Custer National Forest. I would like you to remove open meadows from your analysis and 

just considered timber stands. See "A Rocky Mountain Elk Habitat Conservation Plan for the 

WGFD Sheridan Region, May 2004." 

Response: Lyon and Christensen (1992) and Hillis et al. (1991) are both peer reviewed documents that have been 

used in Region One for years. Hillis's non-peer reviewed recommendations to the Bighorn National Forest were 

considered, but Hillis's earlier science was used in this analysis because it is peer reviewed.

Subject: Wildlife Response #: WL-7, Human Activities

Letter-Comment #:

4-10 

According to research, a road negatively effects elk whether driven or not. I ask that all roads 

be used in the security cover analysis. 

Response: The majority of literature and research regarding the effects of human activities on wildlife support the 

conclusion that motorized use has greater adverse impacts than non-motorized use. The literature does not support the 

notion that OHV use has a positive impact on wildlife. Detailed discussions and literature citations regarding effects of 

roads, motorized (including ATV’s) and non-motorized use on wildlife are in the Affected Environment – Sensitive 

Species: Grizzly Bear, Affected Environment – Management Indicator Species: Elk, and Affected Environment - 

General Wildlife sections of the FEIS. Additional information is in the wildlife report in the project file. 

Subject: Wildlife Response #: WL-8, Management Area

Letter-Comment #:

8-3 

In fact, Appendix B indicates that 35% of the forest is being managed as habitat for elk, bear, 

moose and big horn sheep. (Actually, I am not aware that bighorn sheep or moose are present 

on the Custer National Forest Ashland District as stated on Page B-2). 

Response: Appendix B describes Management Area (MA) direction from the Custer Forest Plan. Areas designated as 

MA D are scattered across the Forest. Some of these areas support moose and bighorn sheep. Approximately 35% of 

the Ashland Ranger District is designated as MA D. 

Subject: Wildlife Response #: WL-9, Mortality

Letter-Comment #:

8-5 

While the plan seems intent on reducing the number of available travel ways it also indicates 

that there are 178, 419 acres with the management goal of bear and elk habitat. In the plan 

discussion it states that an elk is 'secure' if it has access to 250 acres of roadless habitat. If the 
Chapter 5: Response to Comments 

Ashland Travel Management Final EIS Page 5-37 

Subject: Wildlife Response #: WL-9, Mortality

goal is to maintain a herd of 500 elk at the end of each hunting season, why is FS intent on 

providing habitat for over 700 elk. (178, 419/250=713.7). Isn't is sufficient to have secure 

habitat for no more than the number of elk that you intend to maintain at the end of each 

hunting season? Why do you have to provide habitat for 40% more than the goal? 

Response: The Affected Environment - General Wildlife section of the FEIS discusses types of wildlife susceptible to 

being killed by motorized vehicles on various types of roads. Additional information is in the Affected Environment - 

General Wildlife – Mortality section of the wildlife report in the project file. 

Subject: Wildlife Response #: WL-10, Corrections

Letter-Comment #:

18-15 

In determining the general impacts to wildlife, the DEIS explains, "To analyze the general 

effects of motorized routes on wildlife, a one km buffer on each side of a route was used as 

suggested by Ruediger (1996), " and that "The percent of the Ashland Ranger District 

untouched by the two kilometer buffer on motorized routes is referred to as "core". (DEIS, p. 

3-51, 52). When comparing the "core" between alternatives, the DEIS states, "The percent of 

the project area available as core habitat would be essentially the same under all alternatives 

(see table above). (p. 3-52). Looking at the table, there is a 6% - 10% difference between 

alternatives but the DEIS does not demonstrate how this is essentially the same. Furthermore, 

the DEIS should provide acres affected in addition to the percent. Finally, these acres and 

percents should correlate with focal species' habitat. In other words, the DEIS should answer 

the questions of how man acres of core habitat for each focal species will be affected by each 

alternative for both "mortality" and "habitat modification/changes to behavior" indicators. 

Simply providing percents, and then claiming the difference between alternatives is 

"essentially the same, " without adequate explanation for this conclusion, appears to be an 

arbitrary and capricious conclusion and in violation of NEPA. 

18-16 

Furthermore, the DEIS analysis contains an obvious error in the evaluation of "habitat 

modification/changes to behavior." For each alternative the DEIS states, "The potential for 

mortality would be the same for all alternatives." (p. 3-52-53). It is apparent that these sections 

should NOT be evaluating mortality. The DEIS lists the factors for evaluating habitat 

modification and changes to behavior. In relation to the physical presence of a road, they are 

"...shifts in home range, altered movement patterns, altered reproductive success, and altered 

escape response, an altered physiological state (Trombulak and Frissell 1999)." (p. 3-50). A 

comparison of alternatives should address each of these factors. Additionally, motorized 

routes can have similar impacts as roads, and should be included in any analysis of indirect 

effects. 

Response: Thanks for your comments. These corrections have been included in the FEIS.

Subject: Wildlife Response #: WL-11, Decibel Levels

Letter-Comment #:

18-17 

In measuring the impacts from noise, it is important to note that the DEIS states, "Decibel 

levels for other vehicles pertinent to the Ashland Travel Management, including ATV's, were 

not found." (3-51). We suggest that impacts be measured according to the industry standard 

and Montana state law (MCA 61-9-418) that requires noise emissions not exceed 96 db (A). 

The DEIS should have discussed the potential impacts for each alternative and listed those 

impacts for each focal species based not only on percent, but also on number of acres. We 

look forward to seeing this section corrected in the Revised DEIS. 

Response: A discussion of decibel levels of motorized vehicles is included in the FEIS Affected Environment – 

General Wildlife- Habitat Modification/Changes to Behavior - Motorized. Response of wildlife in general to noise is 

also discussed in this FEIS section. Response of songbirds to specific noise levels is in the FEIS Affected 

Environment – Migratory Birds – Disturbance. Apparent effects of specific noise levels are quite variable depending 

on species, vegetation, terrain and other factors. Thus, specifying acceptable decibel ratings relative to wildlife 

during the project planning process is not practical. However, the Montana sound law (MCA 61-9-418) requires a 96 

decibel sound limit maximum for motorcycles and ATVs operated off-highway on public lands.
Chapter 5: Response to Comments 

Page 5-38 Ashland Travel Management Final EIS 

- End of Chapter 5 -