Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-1

Chapter 3: BAffected Environment and 

Environmental Consequences 

3.1 OVERVIEW OF CHANGES FROM DRAFT TO FINAL EIS 

• The tables of past, present, and reasonably foreseeable activities were updated. 

• Changes in resource analyses are noted at the beginning of each resource section. 

3.2 INTRODUCTION 

This chapter describes the affected environment, methodology for analysis, and the direct, indirect and 

cumulative effects of the alternatives. The resource summaries focus on those aspects of the physical, 

biological, and human environment most likely to be affected by the alternatives. More detailed 

information on certain resources can be found in the resource specialist’s reports in the project record. 

3.2.1 DIRECT AND INDIRECT EFFECTS 

Direct effects are caused by an action and occur at the same time and place. Indirect effects are caused 

by an action and occur later in time or farther removed in distance, but are still reasonably foreseeable 

(40 CFR 1500-1508). Direct and indirect effects analysis for each alternative and each resource area 

are based on the factors outlined in alternative descriptions of the alternatives provided in Chapter 2. 

3.2.2 CUMULATIVE EFFECTS 

Cumulative impacts on the environment result from the incremental impact of actions when added to 

other past, present, and reasonably foreseeable future actions. For each resource, an analysis area was 

identified and used to adequately measure cumulative effects of the proposed alternative. Unless 

otherwise stated, the cumulative effects area, or the geographic scope, is the District. 

3.2.2.1 Past, Present, and Reasonably Foreseeable Activities 

Past Actions are addressed by the Council on Environmental Quality1

 (CEQ) in the following manner, 

“Generally, agencies can conduct an adequate cumulative effects analysis by focusing on the current 

aggregate effects of past actions without delving into the historical details of individual past actions.” 2

 

Past actions include grazing, timber harvest, mining and exploration, recreational camping, prescribed 

burning, and small product removal (i.e., post and poles, and firewood). 

Present Actions are typically ongoing activities and are treated similarly to past actions. Anticipated 

future changes in these activities are included under reasonably foreseeable actions. 

Reasonably Foreseeable Actions are those which are formal proposals or decisions not yet 

implemented at the time of the analysis. Activities that add to the effects of designated travel routes 

 

1

 CEQ is the agency responsible for promulgation of regulations and guidance for the National Environemental Policy Act. 2 CEQ’s June 24, 2005 Memo
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-2 Ashland Travel Management Final EIS – Chapter 3

include wildfires, timber harvesting, fuel reduction, livestock grazing, and recreational uses (hunting, 

hiking, motorized recreation, etc.). These activities will continue to influence the landscape. 

Past, present, and reasonably foreseeable activities with the most potential to cumulatively impact 

resources are shown in the following two tables and are considered in various manners within each of 

the resource analyses in this chapter. An extensive catalog of past, present, and reasonably 

foreseeable activities for the Ashland Ranger District can be found in Appendix F. 

Table 3-1. Reasonably Foreseeable Activities 3

Project Name Type of Project 

Custer National Forest – Sioux Ranger District Travel Management 

Planning 

Travel Management 

Whitetail Hazardous Fuels Reduction Project Fuels Management 

Ten Mile Prescribed Fire Fuels Management 

Hanson Fuels Reduction Fuels Management 

Ashland Roads Pile Burning Fuels Management 

Whitetail Cabin Toilet Replacement, Fencing, and Entry Road Project Recreation Management 

Poker Jim Picnic Area Toilet Replacement Recreation Management 

Holiday Spring Campground Toilet Replacement Recreation Management 

Geothermal Leasing Analysis Minerals Management 

Table 3-2. Past and Present Activities Considered in Cumulative Effects 

Project Name Type of Project 

Recreational Use – hunting, camping, viewing, etc. Recreation Management 

Weed Treatment – District-wide Weed Management 

Fuels Treatments Fuels Management 

Permitted Grazing (~367,200 suitable acres) Grazing Management 

Montana Fish, Wildlife, and Parks Block Management Recreation Management 

2001 Tri-State OHV Decision (FS) Recreation Management 

2003 Tri-State OHV Decision (BLM) Recreation Management 

Helena NF - Elkhorn Vegetation and Travel Management Planning Fuels and Travel Mgmt 

Helena NF - Clancy-Unionville Travel Planning Travel Management 

Lewis and Clark NF – Badger-Two Medicine Travel Planning Travel Management 

Upper Missouri River Breaks RMP (BLM) Land Management Planning 

Custer NF – Beartooth Ranger District Travel Management 

Lewis and Clark NF – Big Snowy Mountains Travel Planning Travel Management 

Bighorn NF– Hunt Mountain Travel Planning Travel Management 

Helena NF– North and South Belts Travel Planning Travel Management 

Gallatin NF– Forest-Wide Travel Planning Travel Management 

Lewis and Clark NF – Rocky Mountain District, Birch Creek South Travel Management 

Lewis and Clark NF – Little Belt, Castles, and North Half Crazy 

Mountains Travel Planning 

Travel Management 

 

3

 Source: July 2008 Quarterly Schedule of Proposed Actions (SOPA), Custer National Forest. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-3

Use of travel routes will continue on privately-owned and public lands within and adjacent to the 

Custer National Forest. Government agencies and local municipalities of Montana all use travel 

routes, and to varying degrees, manage them to different standards and restrictions. 

3.2.3 ENVIRONMENTAL JUSTICE 

Executive Order 12898, “General Actions to Address Environmental Justice in Minority Populations 

and Low Income Populations” requires all Federal agencies to incorporate environmental justice into 

their mission. No effects to the well-being and the health of minorities and low income groups were 

identified during scoping and the proposed action would not disproportionately affect minority or lowincome populations. Three Indian Reservations are located within the region. No issues of 

disproportionate distribution of project impacts were found regarding any racial minorities or 

impoverished populations within the project area that might be affected by implementation of this 

project. Minority and low income populations will be treated the same as all with respect to travel 

opportunities. 

3.2.4 NATIVE AMERICAN TREATY RIGHTS 

Many tribes have aboriginal ties and use area within the Custer National Forest, including Northern 

Cheyenne, Crow, Assiniboine, Shoshone, Arapahoe, Shoshone-Bannock, and Three Affiliated and the 

Great Sioux Nation. The Crow, the Sioux, and Gros Ventre have treaty rights under the Fort Laramie 

Treaties to use the National Forests for hunting and gathering. None of the alternatives would affect 

treaty rights. 

3.2.5 UNAVOIDABLE ADVERSE EFFECTS (40 CFR 1502.16) 

Chapter 3 of this EIS addresses the potential environmental consequences of the alternatives for 

Travel Management on the District. In general, any adverse “environmental” effects can be avoided 

through increased restrictions on human use. However, increased restrictions also limit recreation 

opportunities. The alternatives were created, in part, to address issues and provide a clear basis for 

comparison. Adoption of Ashland Ranger District Travel Management direction does not necessarily 

mean that adverse environmental effects cannot be avoided. However, some resource impacts may be 

determined to be acceptable in light of providing for a variety of recreation uses. No unavoidable 

adverse effects to the various resources that are located within or adjacent to the project area were 

found. Implementation of any of the alternatives is not expected to move any sensitive wildlife 

species toward federal listing or threatened/endangered species to be in jeopardy.

3.2.6 RELATIONSHIP BETWEEN SHORT TERM USE AND LONG TERM PRODUCTIVITY 

(40 CFR 1502.16) 

Chapter 3 of this EIS discusses the potential resource impacts of each of the alternatives including the 

potential consequences to soil, vegetation, water quality and biological diversity. Otherwise human 

travel within the Ashland Ranger District would not be considered a short-term consumptive use such 

as timber harvest or mining. In general travel would not affect the ability of the land to produce 

continuous supplies of other Forest resources. Selection of any of the alternatives considered in this 

analysis is expected to affect the long term productivity of the soil and vegetation resources within 

system route prisms while they are in use. Soil and vegetation function and productivity on roads and 

trails can be recovered if at some future time it is deemed as a need. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-4 Ashland Travel Management Final EIS – Chapter 3

3.2.7 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES (40 CFR 

1502.16) 

An “irreversible” commitment of resources results from a decision to use or modify resources that are 

renewable only over a long period of time. Non-renewable resources, such as minerals, are an 

irreversible commitment if used. An “irretrievable” commitment of resources refers to resources, 

resource production or the use of renewable resources that are lost because of land allocation or 

scheduling decisions. Proposed actions can result in certain effects to various resources which are 

described throughout Chapter 3 of this EIS. The decision for Ashland District Travel Management 

would not result in any irreversible commitment of resources. The decision for Ashland District 

Travel Management could result in irretrievable commitment of soil and vegetation resources for as 

long as the road or trail exists. 

3.2.8 ENERGY REQUIREMENTS AND CONSERVATION POTENTIAL (40 CFR 1502.16) 

The Forest determined that the action alternatives would not affect energy consumption. People will 

continue to recreate on the District and consume energy for that purpose. The alternatives are not 

anticipated to change the amount of motorized or non-motorized use of the District, and therefore 

there would be no change in the amount of energy consumption due to the alternatives. Use on the 

District is anticipated to increase based on other factors, such as increases in population, but these 

factors would not be influenced by the alternatives. 

3.3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES – SIGNIFICANT ISSUES 

The affected environment and environmental consequences (direct, indirect, and cumulative effects) 

for each alternative are organized by issue topic area and are addressed below. 

3.3.1 RECREATION 

Overview of Changes from Draft to Final EIS 

• ROS acreages were updated based on refined mapping of the ROS settings. 

• Cumulative effects portion was expanded to include additional present and reasonably 

foreseeable activities. 

• A limited amount of minor edits were made in this section. 

This topic addresses general recreation, which focuses on opportunities for recreational activities and 

potential for travel planning to impact these activities. 

3.3.1.1 Affected Environment – Recreation 

Introduction 

Comments related to recreation on the Ashland Travel Management proposed action could generally 

be categorized as issues associated with the loss of recreation opportunities or activities. Losses of 

opportunities were typically portrayed as loss of opportunities for motorized recreation, hunting, OHV 

use opportunities, non-motorized recreation, and dispersed vehicle camping. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-5

Regulatory Framework 

The Custer Forest Plan identifies both Forest-wide and management area-specific direction for 

recreation management. The Forest-wide goal “is to provide a broad spectrum of recreation 

experience opportunities”. The more specific guidance provided in the management area direction of 

the Plan reflects this goal and represents providing a broad range of differing recreation opportunities. 

Effects Analysis Methodology 

The analysis area for the recreation analysis direct and indirect effects contains all Forest Service 

administered lands within the Ashland Ranger District. 

Motorized and non-motorized recreation opportunities were evaluated based on the acres available in 

each Recreation Opportunity Spectrum (ROS) setting by season of use, as well as the miles of 

motorized routes available by alternative. 

The ROS under this analysis includes the following settings: roaded natural, semi-primitive 

motorized, and semi-primitive non-motorized. (Full definitions of each of the ROS settings are 

provided later in this section.) For this analysis, the Forest Service began by assigning ROS 

classifications using the National ROS Inventory Mapping Protocol (USDA, 2003). The protocol 

assigns a one half mile width along each side of motorized wheeled vehicle routes to include in the 

total acres as the area utilized by motorized activities primarily due to noise. Areas that are more than 

1⁄2 mile from roads or motorized trails are suitable for a semi-primitive non-motorized ROS setting as 

long as an individual area is equal to or greater than 2,500 acres in size. Areas less than 2,500 acres in 

size are added in with adjacent semi-primitive motorized or roaded natural settings, as appropriate. 

This ROS information was used to determine differences between the alternatives in terms of 

opportunities for motorized and non-motorized recreation. 

The miles of designated motorized routes available by alternative were also used to evaluate relative 

differences in the motorized and non-motorized recreation opportunities provided by each alternative. 

The Recreation Setting 

The majority of recreation activities occur in conjunction with the motorized travel corridors on the 

District. The majority of the activity occurs during fall and spring hunting seasons. District staff field 

observations indicate that OHV use, and in particular ATV use, is relatively low outside of hunting 

seasons. 

Public feedback and staff input during the Forest’s Recreation Facilities Analysis, finalized in May 

2008, indicated that local communities have a relatively strong connection to recreation opportunities 

provided by the District. This connection appears to include a general connection with the District as 

well as connections with site-specific locations such as Poker Jim Butte, Red Shale Campground, and 

Whitetail Cabin. 

Approximately 40,000 acres, or slightly more than nine percent, of the District lies within three areas 

where public motorized use is prohibited – the Cook Mountain, King Mountain, and Tongue River 

Breaks hiking and riding areas. These areas provide opportunities for solitude and non-motorized 

activities, such as non-motorized hunting. There are no system trails within the three hiking and 

riding areas. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-6 Ashland Travel Management Final EIS – Chapter 3

District staff experience and public input did not indicate any significant conflicts exist between types 

of recreational activities on the District. 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. 

Motorized Recreation 

Existing system road mileages by type of restriction are shown in Chapter 2, Tables 2-3 and 2-4. The 

tables show there are 676 miles of road open yearlong in the analysis area. 

National Forest system roads are only open to highway legal vehicles. Currently, Forest staff have 

observed unlicensed off-highway vehicle use on forest system roads by recreation visitors and 

permittees. While riding on forest system roads with unlicensed vehicles is not uncommon, it is not 

consistent with state and federal regulations. Under specific circumstances, system roads can be 

designated as motorized mixed use to all use by both licensed and unlicensed vehicles. There are 

currently no motorized mixed use routes on the District. The motorized mixed use designation can 

only be authorized on individual roads following an analysis and evaluation of the risks involved. The 

opportunity to mix highway legal and unlicensed vehicles has not been evaluated on the District in the 

past. A preliminary assessment of the Preferred Alternative indicated that the routes proposed for 

motorized mixed use were suitable for mixing licensed and unlicensed vehicles. The required risk 

analysis would be completed if any mixed motorized use roads are selected in the final decision. 

There are currently no motorized system trails on the District. Motorized system trails allow 

operation of all off-highway vehicles, licensed or unlicensed. 

Implementation of the 2001 Tri-State OHV decision restricted motor vehicles to existing routes 

(USDA Forest Service 2001), whether system or non-system routes. Some OHV opportunities on the 

District are located on existing non-system routes. Non-system routes are those that were not 

designed, constructed, identified, or managed as a part of the forest transportation system. State motor 

vehicle laws do not address vehicle licensing requirements for non-system routes.

Off-Route Motorized Travel 

There are no designated cross-country vehicle areas on the District. 

Dispersed Vehicle Camping 

The 2001 Tri-State OHV decision and subsequent regulations implemented in 2001 allow motorized 

travel up to 300 feet off existing motorized routes but only to access dispersed campsites. Dispersed 

vehicle camping occurs along routes throughout the District. Heaviest use occurs during the fall 

hunting seasons. 

Hunting 

Big-game hunting is the primary recreation activity on the District. Turkey hunting is also an 

important activity on the District, but because the use numbers are highest during big-game hunting, 

this season will be used as the indicator for determining if there are potentially significant effects. 

The primary hunting seasons include archery deer (September to mid-October), and general deer/elk 

(late-October through November). The State of Montana Fish, Wildlife, and Parks (FWP) administer 

hunting within Montana. Hunting locations vary somewhat depending on the game species. 

Motorized routes provide hunters with access, with some hunters using this access to seek areas more 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-7

removed from motorized influences, while other hunters may choose to hunt along or near motorized 

routes. 

The District lies within the FWP hunting district 704. The hunting district is generally bounded by the 

Tongue River on the west, the Powder River on the east, the Yellowstone River on the north, and 

Montana/Wyoming state line on the south. This area also includes private, state, and other Federal 

lands. The District represents roughly 10-15 percent of the hunting district. 

Recreation Opportunity Spectrum 

Forest Service recreation management is guided by the Recreation Opportunity Spectrum (ROS), 

which models outdoor recreation opportunities and activities by natural resource setting. The Forest 

Service published an ROS Users Guide in 1981 along with an updated Primer and Field Guide in 

1990. A National ROS Inventory Mapping Protocol was implemented in 2003. ROS has been used 

by the Forest Service nationwide for recreation planning and management to provide opportunities 

and settings consistent with public expectations to realize a desired set of experiences. 

Within the District, ROS settings vary from areas dominated by roads classified for highway vehicle 

use (Roaded Natural), to areas through which high clearance roads and motorized trails pass (Semiprimitive Motorized), to areas away from the sights and sounds of civilization (Semi-primitive Nonmotorized). The following are definitions and examples of each setting on the District: 

“Roaded Natural” settings extend about one-half mile on each side of a road used by standard 

highway-type vehicles. All roads used by the public or permittees, and all roads used by private 

landowners outside the Forest boundary were considered as affecting the recreation setting. Nonmotorized recreation is available on within this setting. Quiet areas and opportunities for solitude 

would be hard to find during the summer and fall. Forest development roads and well-used 

private roads typically are examples of roaded-natural corridors. 

“Semi-Primitive Motorized” settings extend about one-half mile on each side of a road or trail 

where high clearance vehicles or motorized vehicles are legal to be used. The lack of vegetative 

screening or the influence of intervening ridges may allow the zone to be wider or narrower than 

one-half mile. This ROS setting is available to both non-motorized and motorized recreation. By 

definition, quiet areas and the opportunity for solitude would not occur in this setting during the 

time of year the routes are open to motorized travel. 

“Semi-Primitive Non-Motorized” settings denote areas where stock, hiking, and/or bicycling are 

the predominant modes of travel (motor vehicles would not be legal to operate in this setting and 

motorized travel corridors would be at least one half mile in distance). The lack of terrain 

screening or vegetative screening may occasionally allow the sights and sounds of humans within 

three miles to influence the setting. The area does not meet the size, distance, or lack of human 

disturbance criteria established for “primitive” settings. By definition, this would be a primary 

area for quiet areas and an appropriate setting to provide opportunities for solitude. 

District ROS Settings 

Added together, the data in the following table shows that 94% of the analysis area is influenced by 

motorized use based on ROS settings under the No Action Alternative. Six percent of the District is 

in non-motorized settings. (Although the hiking and riding areas on the District represent 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-8 Ashland Travel Management Final EIS – Chapter 3

approximately nine percent of District lands, the effects of motorized route corridors adjacent to the 

boundaries of these areas extend into these areas based on the 2001 ROS Mapping Protocol.) 

Table 3-3. Current (No Action) ROS Classification by Acres and Percent 4

ROS Classification Acres Percent 

Roaded Natural 116,928 23% 

Semi Primitive Motorized 337,798 67% 

Semi Primitive Non-Motorized 47,533 10% 

Recreational Use 

Recreation Activities – National Visitor Use Monitoring 

The Custer National Forest conducted a National Visitor Use Monitoring (NVUM) survey in 2001-

2002 with the data resulting from the survey compiled and made available in 2003. The NVUM 

protocol is designed to be repeated every 5 years. Locations for surveys are established by the Forest 

based on field observation of potential sites to interview visitors about their activities as they exit the 

forest, a trail, or developed recreation site. The survey dates, times and places are assigned on a 

random basis and capture a range of use levels at different sites and areas across the Forest. The 

schedule is assigned to the Forest by the national NVUM working group. 

The relatively high recreational use on the Beartooth Ranger District resulted in selection of only a 

handful of NVUM surveys on the District. The result is that the data generated from this effort is 

relatively reliable for the Beartooth District, but does not appear to be representative of recreational 

activities on either the Sioux or Ashland Ranger Districts. Consequently, NVUM data is not helpful 

in conducting site-specific analysis for the Ashland District, but can be useful in identifying national 

and regional trends. 

Hunting 

It is difficult to determine how many hunters use the District during big-game hunting season, or how 

many may be on the District at any one time. FWP issues unlimited permits for general and archery 

deer in the area. For elk, they issue unlimited archery permits (approx. 600 issued in 2008) and 300 

general permits. Hunter surveys conducted by FWP indicate that in the past three years 3,000-5,000 

deer hunters have used the 704 hunting unit (FWP 2008a). FWP staff suspect that the majority of 

these hunters use the District National Forest lands for deer hunting (FWP 2008b). 

The opening weekend of big-game hunting season typically has the highest number of hunters on the 

District. 

Recreation Trends 

Recreational OHV use in Montana grew by 40% in the last decade and is expected to continue to grow 

(Montana Fish, Wildlife and Parks 2000). Similarly, the analysis area has experienced additional use 

over the last decade based on District staff field observations. 

 

4

 Calculations were based on National Forest system lands within the District boundary. Acres were derived from GIS mapping. All 

numbers were rounded to the nearest whole percent. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-9

The Forest Service produced a national report on OHV use titled Off- Highway Vehicle Use on 

National Forests: Volume and Characteristics of Visitors, Special Report to the National OHV 

Implementation Team - 5 August 2004. Data used in this analysis came from the National Visitor Use 

Monitoring (NVUM) program. The research methodology for this program is documented in a 

General Technical Report (English, et al., 2002). The first sampling cycle occurred from January 1, 

2000 to September 30, 2003. During that period, on-site surveying occurred on nearly 23,000 sample 

days around the country. Over 90,000 visitors finishing a recreation visit were interviewed about their 

activities, experiences, length of stay, and demographic characteristics. The survey data shows that 

OHV use is a specialized use of forests and not a major recreational use for most forests. Slightly 

more than 2,000 of surveyed visitors indicated OHV use was a primary activity, and a little less than 

5,400 indicated participation in OHV activity during their visit. 

Nationally, about 2.5% (5.2 million visits) of the 205 million recreational visits to National Forest 

have OHV use as their primary activity5. A slightly larger percentage (3.1%) has OHV use as a 

secondary activity. That is, about 6.3 million visitors reported participating in OHV use, but not as 

their primary activity. These would include people who engaged in OHV riding during their visits, 

but who came to the forest primarily for some other activity. 

The total numbers of National Forest visits that have OHV use as either a primary or secondary 

activity is about 11.5 million. The estimates of primary OHV use visitation are similar for most 

National Forest regions (range 12 – 16% of the national total), except Region 1 (includes the Custer 

National Forest) and 10 (Alaska). Only 5% (about 274,000 visits) of the total primary OHV use for 

all National Forests occurs on forests in Region 1. None of the visitors surveyed in Region 10 

indicated that OHV use was their primary recreational activity. 

Trends in Other Recreation Activities 

Recently, a decline in overall participation in outdoor activities has been noted, attributed partially to 

the growth of leisure choices now available such as the Internet and satellite TV (Roper 2003). 

Despite this recent trend, with increasing population and growth in income, outdoor recreation 

participation is expected to grow (Cordell 1999). 

A U.S. Fish and Wildlife Service (2004) report indicates that overall hunting participation decreased 

nationally between 1991-2001, although big-game hunting participation generally remained level and 

turkey hunting increased. The report indicated that big-game hunting in Montana reflected this trend. 

Studies sponsored by FWP and the Forest Service concur with these trends (USDA 2005). However, 

they also indicate that demand for big-game hunting opportunities is expected to exceed supply for 

opportunities beginning in 2010. This suggests that hunting opportunities in Montana are expected to 

level off in the near future (the supply will be at a maximum). 

 

5

 Percentages presented here include visitors who did not provide information on their primary and/or secondary recreation activities. 

Using just those who did provide that information as a base yields primary OHV use at 3.0%, and those listing OHV as a secondary 

activity at 3.5%. (English: Off- Highway Vehicle Use on National Forests: Volume and Characteristics of Visitors, Special Report to 

the National OHV Implementation Team - 5 August 2004) 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-10 Ashland Travel Management Final EIS – Chapter 3

3.3.1.2 Environmental Consequences - Recreation 

The following tables provide a summary of the ROS settings by acres and miles for each alternative. 

These are used to form much of the analytical basis for comparing the alternatives. 

Table 3-4. ROS Setting by Alternative (percent/acres) 

Alternative 

A Alternative B Alternative B Modified No Action 

ROS Setting Season of 

Use 

Yearlong 

Season of 

Use 

12/2-8/31 

Outside 

Season of Use 

9/1-12/1 

Season of 

Use 

12/2-8/31 

Outside 

Season of Use 

9/1-12/1 

Season of 

Use 

Yearlong 

Roaded Natural 23% 

(114,108) 

23% 

(114,027) 

23% 

(114,027) 

23% 

(114,004) 

23% 

(114,004) 

23% 

(116,928) 

Semi-Primitive 

Motorized 

64% 

(320,418) 

58% 

(292,260) 

56% 

(281,485) 

59% 

(296,192) 

55% 

(279,049) 

67% 

(337,798) 

Semi-Primitive NonMotorized 13% 

(67,734) 

19% 

(95,972) 

21% 

(106,746) 

18% 

(92,063) 

22% 

(109,206) 

10% 

(47,533) 

Table 3-5. Summary of Miles 6 of System Roads and Motorized Trails Designated for Public 

Motorized Use by Alternative.

Alternative 

A Alternative B Alternative B Modified No Action 

Route Designation Season of 

Use 

Yearlong 

Season of 

Use 

12/2-8/31 

Outside 

Season of 

Use 

9/1-12/1 

Season of 

Use 

12/2-8/31 

Outside 

Season of 

Use 

9/1-12/1 

Season of 

Use 

Yearlong 

Road – Highway legal 

vehicles only 101 101 101 101 101 676 

Road – All types allowed 

(motorized mixed use) 37 37 37 37 37 0 

Motorized Trail – All 

motor vehicles allowed 612 405 387 406 379 0 

Motorized Trail – Vehicles 

50 Inches or Less 0 0 0 17 17 0 

Total 750 543 525 561 534 676 

Direct and Indirect Effects - Recreation 

Alternative A 

Recreation Opportunity Spectrum 

The above table indicates the District would contain 87 percent (434,526 acres) in motorized settings, 

and 13 percent (67,734 acres) in non-motorized settings. This is an approximately 20,000 acre shift 

from motorized to non-motorized settings compared to the No Action Alternative. This is a result of 

those system routes that could not be designated because there is no public right-of-way. 

 

6 Comparison between tables may not be exact due to rounding error. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-11

There is no season of use associated with this alternative, so there would not be a seasonal change in 

ROS settings under this alternative. 

Motorized Recreation Miles 

There would be 750 miles of roads and trails available yearlong for motorized recreation 

opportunities. 

Motorized Opportunities 

Implementation of this alternative would maximize the opportunities for motorized recreation on the 

District. It provides the greatest number of miles of routes designated for public motorized use, and 

includes the greatest number of miles of motorized trail. This would be expected to increase the 

opportunities for motorized recreationists compared the other alternatives. In addition, this alternative 

would be attractive to users that are seeking semi-primitive motorized types of experiences given the 

number of motorized trails. 

Motorized users have the greatest opportunity to be able to find the type of motorized experience they 

are seeking under this alternative than Alternative B, B Modified or the No Action Alternative, based 

on the miles of routes available, variety of vehicle use designations available, and yearlong season of 

use on all motorized routes. 

This alternative would provide a considerable amount of opportunities to operate licensed and 

unlicensed motor vehicles on the District. Families and those desiring to operate unlicensed motor 

vehicles would find opportunities to day long trips and motorized loop experiences. 

Based on miles of routes, this alternative would be expected to provide more opportunities for persons 

with disabilities or limited mobility to access the District with motor vehicles than the other 

alternatives. 

 

Non-Motorized Opportunities 

The quality of the outdoor experience for those seeking non-motorized recreational activities would 

have the second greatest potential to be diminished of all of the alternatives. Although this alternative 

has more miles of routes than no action, the ROS mapping indicates that there would be more nonmotorized settings than under no action. District staff field observations indicate that recreational use 

is low during the majority of year, so finding non-motorized experiences may not be a cause for 

concern other than during big-game hunting seasons – the season of heaviest visitor use. 

There would be approximately 28,000 acres in non-motorized settings outside of the Hiking and 

Riding Areas (approximately 40,000 acres). 

Dispersed Vehicle Camping 

This alternative would provide more dispersed vehicle camping opportunities than the other 

alternatives being analyzed. Compared to no action, there would be an additional 74 more miles of 

motorized routes that would provide potential dispersed vehicle camping locations. 

Hunting 

This alternative provides the maximum opportunity to hunters who desire to scout and retrieve their 

game by motorized means. Big-game hunters would be likely to find experiences similar to the No 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-12 Ashland Travel Management Final EIS – Chapter 3

Action Alternative based on ROS settings, and would not be expected to be displaced under this 

alternative. 

Hunters seeking opportunities to hunt without disturbance by motorized vehicles could expect to have 

more difficulty doing so under this alternative when compared to Alternative B and Alternative B 

Modified, and slightly more than under the No Action Alternative. This alternative would have a 

higher potential to displace hunters interested in non-motorized hunting opportunities compared to 

Alternatives B and B Modified, and slightly less potential than the No Action Alternative. If hunters 

are displaced, their opportunities to find this experience on the District would be limited, but slightly 

better than under the No Action Alternative. 

Since this alternative represents the existing condition, the overall number of hunters is not expected 

to be affected by this alternative and is unlikely to be substantively different than total hunter numbers 

under the No Action Alternative given the limited difference in ROS settings. 

Alternative B 

Recreation Opportunity Spectrum 

The above table indicates that under Alernatives B the District would contain 81 percent (406,287 

acres) in motorized settings, and 19 percent (95,972 acres) in non-motorized settings from December 

2 to August 31. This is an approximately 48,439 (Alternative B) acre shift from motorized to nonmotorized settings compared to the No Action Alternative. The additional non-motorized acres would 

be dispersed in pockets throughout the District. 

From September 1 to December 1, the big-game hunting season, ROS settings on the District would 

shift two percent more towards non-motorized settings under Alternative B. Semi-primitive nonmotorized acres would increase by 10,775 acres. These acres are distributed across three areas on the 

southern end of the District (see map package) and are separate from the hiking and riding areas. 

Motorized Recreation Miles 

There would be 543 miles of roads and trails available for motorized recreation opportunities. During 

the big game hunting season, motorized season of use designations would reduce the number of miles 

of roads and trails available for public use to 525 miles. 

Motorized Opportunities 

Implementation of this alternative would provide the least amount of miles for motorized recreation of 

all the alternatives. Because of the lack of specific user information and numbers, it is difficult to say 

if the reduced number of miles would actually result in displacement of motorized users, but this 

alternative does have the greatest potential to displace motorized use. District staff field observations 

indicate that visitor use is low outside of big-game hunting seasons. Consequently, it is likely that the 

only real potential to displace motorized users is during the big-game hunting season. 

The 18-mile reduction in route miles during the big-game hunting season is unlikely to have much 

additional affect on motorized users in general, but may impact individuals if they have a connection 

with the specific routes that would not be available at that time of year. 

Based strictly on miles of routes, this alternative would be expected to provide fewer opportunities for 

persons with disabilities or limited mobility to access the District than the other alternatives. It is 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-13

difficult to assess the degree of this impact given the absence of user data for the District, but again 

the real potential for impacts may only be during the big-game hunting season since observed use is 

relatively low the remainder of the year.

Non-motorized Opportunities 

The quality of the outdoor experience has the second highest potential to be improved under this 

alternative for those interested in non-motorized recreation opportunities during the big-game hunting 

seasons. The areas created by the season of use designation will give visitors three new areas in 

addition to the three existing hiking and riding areas to seek out non-motorized opportunities. 

District staff field observations of low visitor use outside of the big-game hunting seasons suggests 

that opportunities for non-motorized experiences for the majority of the year are readily available. 

Thus, the change in miles and ROS setting proposed under this alternative may essentially enhance 

non-motorized experiences during a portion of the year when those opportunities are already relatively 

abundant. Consequently, the value to non-motorized opportunities outside of the big-game hunting 

season may be limited. 

There would be approximately 56,000 acres in non-motorized settings outside of the Hiking and 

Riding Areas (approximately 40,000 acres) from 12/2-8/31, and approximately 67,000 acres from 9/1-

12/1. 

Dispersed Vehicle Camping 

This alternative would provide fewer dispersed vehicle camping opportunities than the other 

alternatives being analyzed. Compared to no action, there would be 133 fewer miles of motorized 

routes that would provide potential dispersed vehicle camping locations during the season of use, and 

151 fewer miles during the big-game hunting season. 

There is uncertainty about how this may actually impact recreational use, since there is only very 

limited visitor use information for the District. Those individuals accustomed to using dispersed 

vehicle camping site adjacent to a route that is not designated may feel a sense of loss. In general, 

there is a greater potential under this alternative for visitors to find or perceive it harder to find a 

dispersed camping location. 

Hunting 

Hunters seeking opportunities to hunt without disturbance by motorized vehicles would have a better 

chance of doing so under this alternative, when compared to Alternative A and the No Action 

Alternative, but slightly less than under Alternative B Modified. The increase in semi-primitive nonmotorized acres of this alternative outside of the season of use will clearly provide more opportunity. 

However without specific information on demand for this type of experience, it is difficult to assess 

whether the demand would be satisfied. 

This alternative provides the fewest opportunities for hunters who desire to scout and retrieve their 

game by motorized means. This alternative would have the highest potential to displace hunters 

interested in these hunting opportunities. If hunters are displaced, they may be able to find similar 

opportunities elsewhere on the District since 79 percent of the District would remain in motorized 

settings under this alternative during the big-game hunting season. 

FWP staff generally believes that changes proposed in this alternative may not result in a net loss of 

hunters. Their impression is that if some hunters are displaced by the proposed actions in this 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-14 Ashland Travel Management Final EIS – Chapter 3

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

proposed actions (FWP 2008b). Recreation trend information for Montana, cited in the Trends in 

Other Recreation Activities section above, 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. 

Alternative B Modified 

Recreation Opportunity Spectrum 

The above table indicates the District would contain 82 percent (383,196 acres) in motorized settings, 

and 18 percent (92,063 acres) in non-motorized settings from December 2 to August 31. This is an 

approximately 44,530 acre shift from motorized to non-motorized settings compared to the No Action 

Alternative. The additional non-motorized acres would in pockets dispersed throughout the District. 

From September1 to December 1, the big-game hunting season, ROS settings on the District would 

shift four percent more towards non-motorized settings. Semi-primitive non-motorized acres would 

increase by 17,143 acres. These acres are distributed across six areas on the southern end of the 

District (see map package), five of which are separate from the hiking and riding areas. 

Motorized Recreation Miles 

There would be 561 miles of roads and trails available for motorized recreation opportunities. During 

the big game hunting season, motorized season of use designations would reduce the number of miles 

of roads and trails available to 534 miles. 

Motorized Opportunities 

Implementation of this alternative would provide the second lowest amount of miles for motorized 

recreation of all the alternatives. Because of the lack of specific user information and numbers, it is 

difficult to say if the reduced number of miles would result in displacement of motorized users. 

District staff field observations indicate that visitor use is low outside of big-game hunting seasons. 

Consequently, it is likely that the only real potential to displace motorized users is during the biggame hunting season. This alternative would have less potential to displace hunters during the biggame hunting season than Alternative B, because routes important for hunter access are proposed to 

be designated in response to hunter comments that were not included in Alternative B. 

The 27-mile reduction in route miles during the big-game hunting season is unlikely to have much 

additional affect on motorized users in general, but may impact individuals if they have a connection 

with the specific routes that would not be available at that time of year. 

Based strictly on miles of routes, this alternative would be expected to provide fewer opportunities for 

persons with disabilities or limited mobility to access the District than the No Action Alternative or 

Alternative A, but slightly more than Alternative B. It is difficult to assess the degree of this impact 

given the absence of user data for the District. 

Non-motorized Opportunities 

The quality of the outdoor experience has the greatest potential to be improved under this alternative 

for those interested in non-motorized recreation opportunities during the big-game hunting seasons. 

The areas created by the season of use designation will give visitors six new areas in addition to the 

three existing hiking and riding areas to seek out non-motorized opportunities. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-15

District staff field observations of low visitor use outside of the big-game hunting seasons suggests 

that opportunities for non-motorized experiences for the majority of the year are readily available. 

Thus the change in miles and ROS setting proposed under this alternative may essentially enhance 

non-motorized experiences during a portion of the year when those opportunities are already relatively 

abundant. Consequently, the value to non-motorized opportunities outside of the big-game hunting 

season may be limited. 

There would be approximately 52,000 acres in non-motorized settings outside of the Hiking and 

Riding Areas (approximately 40,000 acres) from 12/2-8/31, and approximately 69,000 acres from 9/1-

12/1. 

Dispersed Vehicle Camping 

This alternative would provide the second fewest dispersed vehicle camping opportunities of all the 

alternatives being analyzed. Compared to no action, there would be 115 fewer miles of motorized 

routes that would provide potential dispersed vehicle camping locations during the season of use, and 

142 fewer miles outside of the season of use. 

There is uncertainty about how this may actually impact recreational use, since there is only very 

limited visitor use information for the District. Those individuals accustomed to using dispersed 

vehicle camping site adjacent to a route that is not designated may feel a sense of loss. In general, 

there is a greater potential under this alternative for visitors to find or perceive it harder to find a 

dispersed camping location. 

Hunting 

Hunters seeking opportunities to hunt without disturbance by motorized vehicles would have the best 

chance of doing so under this alternative than the other alternatives analyzed. The increase in semiprimitive non-motorized acres of this alternative during big-game hunting season will clearly provide 

more opportunity. However without specific information on demand for this type of experience, it is 

difficult to assess whether the demand would be satisfied. 

This alternative provides the second lowest amount of opportunity (based on miles of routes) for 

hunters who desire to scout and retrieve their game by motorized means. This alternative would have 

the the second highest potential to displace hunters interested in these hunting opportunities. If 

hunters are displaced, they may be able to find similar opportunities elsewhere on the District since 78 

percent of the District would remain in motorized settings under this alternative during big-game 

hunting season. 

FWP staff generally believed that changes proposed in Alternative B would not result in a net loss of 

hunters. Given the similarity between Alternative B and this alternative, it is reasonable to assume a 

similar result under this alternative. Their impression is that if some hunters are displaced by the 

proposed actions in Alternative B, they are likely to be replaced by other hunters looking for the 

opportunities created by the proposed actions (FWP 2008b). Recreation trend information for 

Montana, cited in the Trends in Other Recreation Activities section above, supports the assumption 

that the types of changes proposed in this alterantive would not be likely to affect the overall total 

hunter numbers given the strong demand for big-game hunting opportunities. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-16 Ashland Travel Management Final EIS – Chapter 3

No Action Alternative 

Recreation Opportunity Spectrum 

The above table indicates the District would contain 90 percent (454,726 acres) in motorized settings, 

and ten percent (47,533 acres) in non-motorized settings. All of the non-motorized acres would be 

within the hiking and riding areas. 

Motorized Recreation Miles 

There would be 676 miles of roads available for motorized recreation opportunities. No mixed use 

roads or motorized trails would be designated. 

Motorized Opportunities 

The miles designated for public motorized use include routes for which the Forest Service has no legal 

right-of-way for public access. This could have a couple of implications. The actual miles of roads 

available to the public may in effect be less, since some of these system roads may not be accessible. 

There are 55 miles with no legal right-of-way for public access included in this alternative. The 

public may or may not be able to access them with motor vehicles, and would need to have permission 

from landowners to be able to use them. This could lead to confusion and may encourage inadvertent 

motorized trespassing on private lands. 

Under this alternative, motorized users may not find opportunities for the types of motorized 

experiences they are accustomed to on the District. This is primarily because there would be no 

opportunities to operate unlicensed motor vehicles on the District; all motor vehicles would need to be 

licensed to operate on the District. 

Individuals may find that routes they had grown accustomed to using over the last few years are no 

longer available for motorized use since only existing system roads would be designated for public 

motorized use and no non-system routes would be designated. However, it is likely, based on the total 

miles to be designated, that visitors could find similar motorized experiences and opportunities on the 

District. The situation would be expected to be similar for District visitors with disabilities or limited 

mobility seeking motorized opportunities. 

Non-motorized Opportunities 

Although this alternative has fewer miles of roads than Alternative A, it also has less semi-primitive 

non-motorized acres. The quality of the outdoor experience for those visitors seeking non-motorized 

activities may be mixed compared to other alternatives. This is unlikely to meet the desires of those 

commenters that expressed an interest in having more non-motorized opportunities. 

There would be approximately 8,000 acres in non-motorized settings outside of the Hiking and Riding 

Areas (approximately 40,000 acres). 

 

Dispersed Vehicle Camping 

There would be 74 fewer miles of roads available under no action, than under Alternative A, but 133-

151 more miles than under Alternative B, depending on the time of year. Visitors are generally 

believed to be able to find adequate dispersed vehicle camping locations to meet their needs under the 

existing condition, and most likely would still be able to find ample opportunities under no action. 

However, individuals that have a connection to a particular dispersed camping location may feel a 

sense of loss. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-17

Hunting 

This alternative provides numerous opportunities to hunters who desire to scout and retrieve their 

game by motorized means. Big-game hunters would be likely to find experiences similar to the 

Alternative A, based on ROS settings, and would not be expected to be displaced under this 

alternative. 

Hunters seeking opportunities to hunt without disturbance from motorized vehicles may have 

difficulty doing so under this alternative. This alternative would have more potential to displace 

hunters interested in non-motorized hunting opportunities than any of the other alternatives. If hunters 

are displaced, the only place on the District that they may be able to find the experience they are 

seeking is in the hiking and riding areas. The ROS settings indicate there is a low probability of 

finding non-motorized hunting opportunities anywhere else on the District. 

Cumulative Effects - Recreation 

Past, Present, and Reasonably Foreseeable Activities 

Based on public comments on the project, District staff observations, and informal discussions with 

users, visitors from south-central Montana, including the Billings metro area, and northeastern 

Wyoming commonly use the area for big game hunting, the primary recreation activity on the District. 

Discussions with motorized recreationists during the Beartooth Travel Management Planning effort 

indicated that they commonly travel to the Gallatin National Forest and Lewis and Clark National 

Forest to recreate, and to a lesser degree to the Helena National Forest. These two user groups, 

hunters and motorized-focused visitors, are probably not identical, but they may overlap. To provide 

a broad analysis of the cumulative effects, this analysis will consider recent travel management 

decisions on the Gallatin, Lewis and Clark, Big Horn, Helena, and Custer National Forests, along with 

other travel management decisions on public lands in the vicinity of the District. 

The following are past, present, or reasonably foreseeable activities that have affected or have the 

potential to affect motorized and non-motorized recreation opportunities on or in the vicinity of the 

District. 

 

2001 Tri-State OHV Decision (Forest Service) 

The 2001 Tri-State OHV Decision prohibited cross-country vehicle use on Bureau of Land 

Management and Forest Service lands within Montana, North Dakota, and parts of South Dakota. 

The ROD for the 2001 Tri-State OHV Decision indicates that cross-country vehicle travel for the 

Custer, Gallatin, Lewis and Clark, and Helena National Forests was reduced by 64%, 43%, 72%, and 

59%, respectively. 

2003 Tri-State OHV Decision (Bureau of Land Management) 

The 2003 Tri-State OHV Decision prohibited cross-country vehicle use on Bureau of Land 

Management lands within Montana, North Dakota, and South Dakota. The ROD for the 2003 TriState OHV Decision indicates that cross-country motor vehicle travel was reduced by the following 

amounts: Miles City Field Office - 40%, Billings Field Office – 74%, and Lewistown Field Office – 

83%. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-18 Ashland Travel Management Final EIS – Chapter 3

Lewis and Clark National Forest - Little Belts, Castles, and North Half of the Crazy Mountains 

Decision 

The Lewis and Clark National Forest (Lewis and Clark NF) decision on the Little Belts, Castles, and 

North Half of the Crazy Mountains reduced motorized routes by approximately 884 miles (roughly 

39%) compared to the No Action Alternative in that analysis. Non-motorized routes increased by 

approximately 227 miles (roughly 65%) in that same decision. 

Helena National Forest - Elkhorn Decision 

The Helena National Forest’s 1995 decision on travel management in the Elkhorn Mountains area 

reduced designated motorized routes by approximately 15%, and areas open to motorized vehicle use 

by 66-95% depending on the season of use. 

Helena National Forest - Clancy-Unionville Decision 

The Helena National Forest’s decision on travel management for the Clancy-Unionville area reduced 

designated motorized routes by approximately 30%, and areas open to motorized vehicle use by 66-

95% depending on the season of use. 

Lewis and Clark National Forest – Badger-Two Medicine Decision 

The Lewis and Clark National Forest’s decision on travel management in the Badger-Two Medicine 

area reduced miles of motorized routes designated for public motorized use from approximately 200 

miles to approximately 1 mile. Non-motorized routes increased from approximately 17 miles to 192 

miles in that same decision. 

Lewis and Clark National Forest – Big Snowy Mountains Decision 

The Lewis and Clark National Forest’s decision on the Big Snowy Mountains reduced miles of 

motorized routes by 70 miles (roughly 69%) compared to no action in the analysis. 

Lewis and Clark National Forest - Rocky Mountain District – Birch Creek South Decision 

The Lewis and Clark National Forest’s decision on the Rocky Mountain District – Birch Creek South 

reduced miles of motorized routes by 143 miles (roughly 45%) compared to no action in the analysis. 

Non-motorized routes increased by approximately 118 miles (roughly 86%) in that same decision. 

Helena National Forest - North Belts Decision 

The Helena National Forest’s (Helena NF) Record of Decision on the North Belts Travel Planning 

reduced the number of miles of motorized routes by approximately 64 miles (roughly 16%) compared 

to their No Action Alternative. 

Helena National Forest - South Belts Decision 

The Helena NF’s South Belts Travel Plan, which addresses motorized use between 5/15 and 12/1, 

reduced motorized opportunities by approximately 25 miles (roughly 13%) compared to the No 

Action Alternative. 

Gallatin National Forest Decision 

The Gallatin National Forest’s Travel Management Record of Decision states the following: 

“The total amount of public open system road would remain generally unchanged (approx. 740 miles); 

however there would be a shift of about 10% of this system from road currently only suitable for high 

clearance vehicles to road that would accommodate passenger cars. Currently about 315 miles of road 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-19

are considered suitable for passenger cars, and under Alternative 7-M it would increase to 400 miles. 

This alternative also includes objectives to close and restore non-system and user-built roads. 

ATV opportunities provided on trails would be reduced from 281 miles to 143 miles (about 50%) and 

motorcycle opportunities on trails would be reduced from 458 miles to 278 miles (about 40%).” 

The miles of non-motorized routes on the Gallatin National Forest remained about the same compared 

to No Action. 

Big Horn National Forest – Hunt Mountain Decision 

The Bighorn National Forest’s Decision Notice for the Hunt Mountain Travel Management Planning 

reduced the miles of motorized routes by 19% (9.79 miles) compared to no action. 

Bureau of Land Management 

Three recent Bureau of Land Management travel management decisions were identified in the vicinity 

of the District, including the: Acton Recreation Area OHV Travel Management, Horsethief High 

Priority Area OHV Travel Management, and Shepherd Ah Nei Travel Management decisions. 

The Acton and Horsethief decisions did not change the miles available for motorized use. The 

Shepherd Ah Nei decision reduced motorized miles in that unit from 50 miles to 44 miles, or by 12%. 

Upper Missouri River Breaks National Monument Resource Management Plan (RMP) 

The BLM completed the RMP for the Upper Missouri River Breaks National Monument in 2008. 

Miles of motorized routes open to the public yearlong was reduced by 231 miles (44%). Miles of 

motorized routes open to the public seasonally was increased by 43 miles (63%). 

Beartooth Ranger District, Custer National Forest 

The Beartooth Ranger District Travel Management Planning record of decision reduced miles of 

motorized routes available for public motorized use by 7% (20 miles) compared to the No Action 

Alternative for that analysis. Non-motorized ROS settings were reduced by approximately 2% (3,622 

acres). 

Large Fire Events 

There have been multiple large fire events on the District in the past decade, and still more prior to 

that timeframe. Roads were temporarily closed during and immediately following large fire events, 

but there were no changes to the transportation system as a result of large fires in the last decade. 

Sioux Ranger District Travel Management Planning 

Motorized travel management planning is currently being evaluated on the Sioux Ranger District. 

The Forest expects a May 2009 decision on Sioux travel management planning. The preferred 

alternative would result in approximately 99 fewer miles (25% less) of system roads designated for 

public motorized use for the majority of the year compared to no action, and an additional 116 fewer 

miles during big-game hunting season. In terms of motorized ROS settings, 94% of the Sioux District 

would be in motorized ROS settings for the majority of the year and 65% during big-game hunting 

season under the preferred alternative versus 100% in motorized ROS settings year-round and 76% 

during the big-game hunting season under the No Action Alternative. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-20 Ashland Travel Management Final EIS – Chapter 3

Montana Fish, Wildlife, and Parks Block Management 

FWP works with private landowners to obtain hunter access on private lands, known as the Block 

Management Program. FWP Region 7 contained approximately 3.5 million acres under Block 

Management in 2008. Carter County, the county containing all of the District’s lands in Montana, 

contained approximately 230,000 acres under Block Management. Lands enrolled in the Block 

Management Program can vary from year to year, but generally do not tend to fluctuate dramatically. 

The type of access permitted on lands under Block Management is determined by the landowner. 

Generally, landowners restrict motor vehicle use to existing routes on the property or require hunters 

to use designated parking areas and then access the property on foot. In some cases, the number of 

hunters is controlled in addition to the access. All of the areas are receive considerable hunter use, 

and many hunters have indicated that they hunt on both Block Management areas and National Forest 

lands. 

Timber Harvest, Range Management Planning, and Vegetation Management 

There have been a number of timber harvests, range management planning or vegetative management 

activities on the District in the past. Timber harvest and vegetation management activities often 

included creation of temporary roads that were only used during the project and then closed. Some of 

these projects included construction and/or decommissioning of system roads. 

The Forest identified 29 of these types of activities dating back to 1984 on the District. It was clear 

that the older the activity was, the less influential the activity appeared to be in terms of potential 

cumulative effects. For example, the older a project was the more potential there was for subsequent 

activities, decisions, and forest use to have altered the network of routes on the landscape envisioned 

in these earlier decisions. 

The IDT used the seven most recent projects for this assessment, and determined that decisions prior 

this appeared to have little, if any, identifiable influence on the current transportation system. The 

seven projects include: 

• 1997 Lyon Creek Timber Sale (12 added, 12 ML1, 12 decomm) 

• 1998 Goodspeed Timber Sale (included in Lyon Creek Timber Sale quantity) 

• 2000 Fly Wilber Timber Sale (4 added, 5 ML 1, 1 decomm) 

• 2002 Threemile Stewardship Project (36 decomm, 28 admin [these are both system & nonsystem routes]) 

• 2006 Stag Rock Range Analysis (0 added, 3 decomm, 3 ML1, 9 admin) 

• 2008Whitetail Hazardous Fuels Reduction (1 decomm, 1 added, 4 ML1, 4 admin) 

• 2009 East Otter Hazardous Fuels Reduction (Reasonably Foreseeable) (added 2 miles) 

Net Cumulative Effects 

The above information suggests that the 2001 and 2003 Tri-State OHV Decisions substantially 

changed motor vehicle use with respect to cross country vehicle travel in the area evaluated for 

cumulative effects (see above for description). The alternatives under consideration in this analysis do 

not include any actions that would further change cross-country vehicle use; therefore no cumulative 

effects from the proposed alternatives are anticipated specifically related to cross-country vehicle use. 

However, in terms of overall motorized and non-motorized opportunities, the 2001 Tri-State OHV 

Decision had a significant impact on reducing motorized opportunities and increasing non-motorized 

opportunities. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-21

The above information also indicates that several activities contribute to or may potentially contribute 

to substanstive changes in recreation opportunities available to visitors that use the District: 

• 2001 Tri-State OHV Decision (Forest Service), 

• 2003 Tri-State OHV Decision (Bureau of Land Management) , 

• Custer National Forest 

o Proposed travel management changes on the Sioux Ranger District, 

o Beartooth Ranger District Travel Management Decision 

• Lewis and Clark National Forest 

o Little Belts, Castles, and North Half of the Crazy Mountains Travel Management 

Decision, 

o Rocky Mountain District – Birch Creek South Travel Management Decision, 

o Badger-Two Medicine Travel Management Decision 

• Helena National Forest 

o North Belts Travel Management Decision, 

o South Belts Travel Management Decision, 

o Elkhorn Mountains Travel Management Decision, 

o Big Snowy Mountains Travel Management Decision, 

o Clancy-Unionville Vegetation Manipulation and Travel Management Decision, 

• Gallatin National Forest Travel Management Decision, 

• Bureau of Land Management - Upper Missour River Breaks National Monument RMP, 

• And the various vegetation management activities on the Ashland District in the past decade. 

All other identified activities appear to only consist of minor, if any, changes to motorized and nonmotorized recreation opportunities. 

The alternatives in this analysis represent the following changes in miles of motorized routes 

compared to the No Action Alternative, a key measurement in determining opportunities: 

• Alternative A would increase motorized route miles by 74 miles (11% increase) compared to 

no action. 

• Alternative B would decrease motorized route miles by 133 miles (20%) during the majority 

of the year and by 151 miles (22%) during the big-game hunting season, compared to no 

action. 

• Alternative B Modified would decrease motorized route miles by 115 miles (17%) during the 

majority of the year and by 142 miles (21%) during the big-game hunting season, compared to 

no action. 

Alternative A would lessen the cumulative impact of the above activities on motorized recreation 

opportunities, while decreasing the non-motorized opportunities that they would create. A number of 

routes would be added to the system expanding the network of motorized routes available for public 

motorized use. This alternative would have the greatest potential to provide additional opportunities 

for recreationists that may be displaced by the other decisions and proposals affecting motorized 

opportunities. 

Alternative B and B Modified would contribute to the cumulative decrease in miles of 

routes/motorized opportunities. Conversely, non-motorized recreation opportunities would 

cumulatively expand. Cumulatively, the above cited actions, activities, and proposals in combination 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-22 Ashland Travel Management Final EIS – Chapter 3

with either of these alternatives have potential to displace motorized users and to decrease their 

chances of finding similar opportunities elsewhere within the area analyzed for cumulative effects. 

No threshold for determining when effects on motorized recreation opportunities are significant has 

been identified. 

3.3.1.3 Conclusion - Recreation 

The following conclusions are based on the indicators identified in Chapter 2 related to Recreation 

resources and the analysis in this section. 

Concerns related to the loss of motorized recreation opportunities. 

Alternative A best responds to concerns related to opportunities for motorized recreation and 

motorized hunting access, including providing the most miles of system road and motorized trails 

(750 miles) and nearly the same amount of acres in motorized ROS settings (434,526 acres) as the 

No Action Alternative. 

The remaining alternatives respond to this issue to lesser and varying degrees than Alternative A. 

The No Action Alternative, while providing roughly the same amount of motorized ROS settings, 

provides 74 fewer miles of motorized routes. Alternative B and B Modified are very similar and 

would provide both the fewest miles of motorized routes and acres in motorized ROS settings. 

Alternative B Modified, however, is likely to be preferable to Alternative B because it proposes to 

designate routes that were identified as important for big-game hunting and motorized use during 

public comment on the DEIS for this project. 

Concerns related to the loss of non-motorized opportunities. 

Alternative B Modified best responds to concerns related to opportunities for non-motorized 

recreation, especially non-motorized hunting experiences. There would be 92,063 acres in nonmotorized settings during the majority of the year (approximately 52,000 acres outside of the 

Hiking and Riding Areas) and 561 miles of motorized routes. During the big-game hunting 

seasons, there would be 109,206 acres non-motorized ROS setting acres (approximately 69,000 

outside of the Hiking and Riding Areas) and 27 fewer miles of roads and trails. 

Alternative B would respond to this concern nearly the same as Alternative B Modified, but would 

not provide additional non-motorized areas during the big-game hunting season. The remaining 

alternatives respond to this issue to a lesser degree. Alternative A and the No Action Alternative 

respond to this concern about the same, although the No Action Alternative may be slightly better 

since there are fewer miles of system routes associated with this alternative. 

Concerns related to opportunities for off-highway legal vehicle operation. 

Alternative A best responds to concerns related to opportunities for unlicensed off-highway 

vehicle operation, including providing the most miles of motorized mixed use roads and motorized 

trails. There would be 649 combined miles of motorized mixed use roads and motorized trails on 

the District. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-23

The remaining alternatives respond to this issue to a lesser degree than Alternative A. In descending 

order of responsiveness, they are: 

Alternative B Modified (433 to 460 miles, depending on the time of year) 

Alternative B (424 to 442 miles, depending on the time of year) 

No Action (0 miles) 

Consistency with Laws, Regulations, and Policy 

The recreation goal in the Custer National Forest Management Plan is to “provide a broad spectrum of 

recreation experience opportunities”. All alternatives are consistent with the Custer National Forest 

Management Plan direction. 

3.3.2 CULTURAL RESOURCES 

Overview of Changes from the Draft to the Final EIS 

 Refined effects analysis based on WO direction and final alternative descriptions.

 Added the no action alternative to summary table. 

 Results of the historic road analysis are included. 

Regulatory Framework 

This section contains information on the Archaeological Resources and Traditional Cultural 

Properties. Cultural resource is a broad term that refers to cultural properties and traditional life way 

values. A cultural property may be the physical remains of archeological, historical and architectural 

sites and/or a place of traditional cultural use. Traditional life way values refer to the connection 

between the landscape and a groups’ traditional beliefs, religion or cultural practice. 

Since these resources are nonrenewable and easily damaged, laws and regulations exist to help protect 

them. These include the National Historic Preservation Act (NHPA), the Archeological Resources 

Protection Act (ARPA), the American Indian Religious Freedom Act (AIRFA) and the Native 

American Graves Protection and Repatriation Act (NAGPRA). Sacred and culturally important 

places fall under this purview of the NHPA, AIRFA and the Sacred Lands Executive Order (Executive 

Order 13007). Native American graves are protected under NAGPRA. 

The NHPA and its implementing regulations require that federal agencies take into account the effects 

of their undertakings on historic properties and provide the Advisory Council on Historic Preservation 

with an opportunity to comment on those undertakings. The term “historic property” refers to any 

prehistoric or historic district, site, building, structure or object included in, or eligible for inclusion 

on, the National Register of Historic Places (NRHP). 

The Forest Service has been directed to satisfactorily address the National Environmental Policy Act 

(NEPA) and other related statutes involving cultural resource management and historic preservation 

which apply for such projects. As stated in the CNF Management Plan (USDA Forest Service 

1986:4) "The goal of cultural resource management is to maintain and enhance historic and prehistoric 

cultural resource values." In 1995, the Custer National Forest (CNF) became a participant in the 

Montana Programmatic Agreement (MTPA) between the Montana State Historic Preservation Office 

(MTSHPO), the Advisory Council for Historic Preservation and the Northern Region of the Forest 

Service regarding the management of cultural resources on National Forest lands in Montana. Goals 

of the MTPA are to extend beyond the narrow-scoped management perspective of the 1970s and 

1980s that focused upon “site identification/recordation and avoidance or mitigation” to a more 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-24 Ashland Travel Management Final EIS – Chapter 3

informative approach of “cultural resources stewardship”. The PA was updated in 2001 to reflect the 

changes in National Historic Preservation Act Section 106 regulations. 

Compliance with the National Historic Preservation Act (NHPA) of 1966, as amended through 2000, 

is being conducted as directed in the USDA Forest Service Policy for NHPA compliance in Travel 

Management: Designated Routes for Motor Vehicle Use prepared by the Forest Service in 

consultation with the Advisory Council on Historic Preservation (USDA Forest Service 2005). Under 

this policy, three specific travel management proposals are considered undertakings: 1) construction 

of a new road or trail; 2) authorization of motor vehicle use on a route currently closed to vehicles; 

and 3) the formal recognition of a user-developed (unauthorized) route as a designated route open to 

motorized vehicles. Existing or formally established system (classified) roads and trails already open 

to motor vehicle will not be evaluated since their current designation is not considered an undertaking 

under this policy. The terms and conditions of the MTPA will be followed when user-created 

(unauthorized) routes are designated as routes open to motorized vehicles. 

Coordination with pertinent Tribes has been through project scoping letters, public meetings, agency 

meetings, letter correspondences, and meetings which outlined the proposed project specifics and 

requested any concerns that they may have regarding cultural resources or traditional cultural 

properties. This coordination effort was intended to insure that any tribal concerns or comments were 

addressed throughout the NEPA process in regards to ARPA, AIRFA, NHPA, NAGPRA and/or 

Bulletin 38 issues. 

3.3.2.1 Affected Environment – Archaeological Resources and Tradition Cultural Properties 

The District lies within the Ponderosa Pine Parkland of southeastern Montana which is part of the 

Northwestern Plains Region. This unique landscape exhibits a mosaic character of upland grasslands, 

pine forests and woody draws along with dissected plateaus and rugged badlands. Ten major 

ecozones or environmental land units have been delineated primarily on differences between 

topography, soil and vegetation (Beckes and Keyser 1983: 57-66). 

Human occupation in the Ashland area spans over 10,000 years and is represented by a basic activity 

pattern consisting of seasonal ventures by small groups of people who exploited various faunal and 

floral resources in a variety of ways (Beckes and Keyser 1983: 269). Three cultural periods—

including Paleo-Indian, Plains Archaic and Late Prehistoric—are represented within the prehistoric 

time period. 

The earliest time period, the Paleo-Indian, is characterized by a human population heavily dependent 

on hunting of now extinct fauna such as giant bison and mammoth. Large lanceolate projectile points 

are common diagnostic indicators of this period. The Archaic Period, saw a warming trend referred to 

as the Altithermal Climatic Episode which was related to modern flora and fauna and saw a shift to a 

more diversified economy. Big game hunting was supplemented with the processing of plant 

resources. A variety of large projectile points, including both lanceolate and notched, are diagnostic 

indicators of this period. The Late Prehistoric Period is marked by the appearance of the bow and 

arrow on the Northwestern Plains. An increased specialization toward upland living and the 

utilization of open prairie resources, most importantly bison, characterizes this period. A variety of 

smaller projectile points are diagnostic indicators of this period. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-25

The Historic Period is usually associated with Euro-American activities such as exploration, military 

excursions, mining, ranching, trapping and homesteading but Native American tribes predated the 

Euro-Americans influx into the area. Crow, Cheyenne, Shoshone and Sioux lived or traveled through 

the area long before contact with Euro-Americans and considered the area encompassing the District 

as their territory. In 1884 an Executive Order established the Tongue River Reservation for the 

Northern Cheyenne. The Northern Cheyenne reservation is located to the west of the Ashland District 

across the Tongue River. 

Concurrent with early 1900s homesteading era, within and around the District, the Otter Forest 

Reserve (later to become the Custer National Forest) was created in 1907. The Forest Service brought 

a whole new realm of government sponsored activities including logging, livestock grazing, 

building/road development, fire suppression and recreation. The Civilian Conservation Corps (CCC) 

played a significant role on the District during the 1930s and was responsible for building or 

improving a variety of structures including ranger stations and CCC camps, fencelines, range 

improvements (dams, springbox headworks/cedar tanks and reservoirs), roads and telephone lines. 

Previous Investigations 

Three early archaeological investigations on the District were conducted during the 1970s (Beckes 

1976, Hagen and Kallem nd, McLean 1975) and relied on interviews with local informants for site 

leads followed by select area field reconnaissance efforts. Nearly two hundred prehistoric or historic 

sites, consisting of bison kills, cairns, cribbed log structures, lithic artifact scatters, rock art panels and 

rock shelters—were recorded during these investigations. 

A comprehensive prehistoric overview of the District was completed in 1983 (Beckes and Keyser 

1983) followed by a broader prehistoric cultural resource overview of southeastern Montana 

completed in 1988 (Deaver and Deaver 1988). In 1989, as part of a Master’s Thesis project, a model 

of land use patterns was developed for the District in order to predict where archaeological sites 

should, or should not, be found (Wettstaed 1989). 

During the 1990s a unique plant collecting area on the District was investigated utilizing several 

Northern Cheyenne elders and volunteers. This CNF grant-funded project mapped the density and 

distribution of a medicinal plant traditionally used by the Northern Cheyenne for ceremonies and 

healing for over one hundred years. The District location for this plant is the only known collecting 

area and is identified as a Traditional Cultural Property. 

In 1995 an ethnographic overview of the District was completed. This overview identified culturally 

sensitive sites defined as “Cultural resources associated with traditional Indian ceremonies, cultural 

practices and important events in tribal history...” and include “...burials, rock art, stone circles of 

greater than 7m in diameter, monumental rock features, fasting structures, eagle catching pits, sweat 

lodges, wooden structures, Sun Dance lodges and grounds, offering and prayer locales and historic 

battle sites.” Forty-two culturally sensitive sites were identified on the District by this 1995 overview 

(Deaver and Kooistra-Manning 1995: 4.88-4.94). Additional culturally sensitive sites have been 

recorded on the district since this overview was completed. 

In 2004 an ethnographic overview of the Tongue River/Powder River Plateau was initiated through a 

participatory grant between Chief Dull Knife College, Native Action and the CNF. This overview 

collected cultural site and heritage information including areas of historical and current use by the 

Northern Cheyenne. Field trips with knowledgable Northern Cheyenne representatives identified 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-26 Ashland Travel Management Final EIS – Chapter 3

several areas on, and adjacent to, the District that are considered sacred. This information will be 

used in determining future land management decisions and will provide for valuable general education 

purposes on the Northern Cheyenne culture, history and their relationship with the lands. 

From 1881 up through 1900 at least forty-six Northern Cheyenne families homesteaded along the east 

side of the Tongue River until they were forced to move west, across the river, onto the reservation. 

An overview to determine if any of these homesteads were situated on the District, along with seven 

interviews with descendants of the original homesteaders, was conducted in 2005. Although this 

research did not locate any homesteads on the District, it did provide a historical overview of the area 

and locations of Northern Cheyenne homesteads along the east side of the Tongue River immediately 

adjacent to the District (Brownell 2005). 

A recent rock art inventory conducted on the District focused on relocating a limited number of 

known rock art sites as well as recording several new rock art sites. This research offered possible 

interpretations of the rock art, ethnic identities and patterns of site utilization (Keyser 2006). 

Formal cultural resource investigations, in support of programs such as minerals, range and timber, 

were initiated on the District during the mid 1970s and have continued to the present. In 1988, 

immediately following the 16,000 acre Schiller Wildfire, a large block inventory of 6065 acres was 

conducted and 119 sites were recorded. In 2000 two wildfires (Tobin and Fort Howes Complex) 

burned over 70,000 acres. Approximately 5500 acres were inventoried following these wildfires and 

21 new sites were recorded. The aftermath of these wildfires—resulting in the discovery of numerous 

sites—attests to the high degree of ground exposure that results with the removal of vegetation and 

duff material. 

Other cultural resource inventories conducted on the District during the past few years have supported 

Engineering/Roads, Prescribed Fire and Special Use Permit programs. During the past eight years 

large-scale contract inventories for cultural resources on the District have been conducted in support 

of range recission, proposed mineral development, roads and vegetation treatment projects. 

An overview of Civilian Conservation Corps (CCC) activity on the District during the 1930s was 

completed in 2002. This overview documented the locations of two CCC camps and discussed in 

detail five primary work projects conducted by the CCC workforce. These included forest products, 

range improvements, ranger station construction, road construction and telephone line construction. 

Several CCC features still present on the district (including stone-armored reservoirs and roads with 

dry-laid stonework retaining walls and drainage crossing structures) were identified. Five CCC boys 

who worked on the District were contacted and interviewed regarding recollections of their 

experiences. Several CCC constructed roads on the District were evaluated and recommended 

eligible for nomination to the NRHP (Brownell 2002). 

Methodology 

As of summer 2008, there are 1401 recorded prehistoric or historic sites on the District represented by 

bison kills, cairns, campsites (containing bone, ceramic, fire-cracked rock and/or stone artifacts) 

cribbed log structures, drive lines, fasting beds, fire lookouts, historic and prehistoric petroglyphs, 

homesteads, lithic artifact scatters, quarries, ranger stations, range improvements (livestock tanks, 

reservoirs), roads, rock shelters, stone circles, and many sites associated with the CCC. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-27

Following the direction provided in the 2005 USDA Forest Service Policy for NHPA Compliance in 

Travle Management Designated Routes for Motor Vehicle Use, the effects analysis focused on the 

three specific categories: 1) the construction of a new road or trail; 2) the authorization of motor 

vehicle use on a route currently closed to motorized vehicles; and 3) the formal recognition of a userdeveloped (unauthorized) route as a designated route open to motor vehicles. Under this direction 

existing or formally established system roads and trails that are already open to motor vehicles will 

not be evaluated since their current designation is not considered an undertaking. Upon comparison 

of the categories with the proposed changes in the Ashland Travel Management plan, category three 

was found to apply and will be addressed as the undertaking. The terms of the MTPAwill be followed 

when designating motor vehicle use on user-developed (unauthorized) routes. 

To determine the potential effects to historic properties within the Area of Potential Effect (APE), 

existing system and non-system roads and trails were intersected with the GIS site database of 

recorded and known cultural resource sites lying within a 600 foot wide corridor. This 600 foot wide 

corridor is in accordance with the 2001 decision to allow motorized wheeled cross-country travel to 

access dispersed camping sites (USDA Forest Service 2001) and it defines the Area of Potential Effect 

when analyzing both direct and indirect effects under all alternatives. 

In addition, two historic maps of the District dating to 1928 and to 1957 were compared with the APE 

maps in an effort to define roads and trails that may be over 50 years old and deserving of further 

analysis as potential historic properties. Historic reference material, on file at the CNF, was also used 

to identify roads that had been constructed or reconstructed by the CCC during the 1930s. 

A sample of these potentially historic roads were ground truthed and no structural features (bridges, 

culverts, stonework) or association was found. Any future proposals to change these routes would be 

evaluated in terms of their potential historic significance. 

The GIS analysis and map resources identified 359 recorded cultural resource sites and 50 possible 

historic roads located within the 600 foot wide road and trail corridor on the District. This represents 

one quarter of the recorded sites on the District. At least 22 sites are prehistoric sites that have been 

tentatively dated, ranging from Paleo-Indian Period to Late Prehistoric Period, based upon the 

presence of diagnostic projectile points. Fifty-seven historic sites are within the APE and include 19 

sites associated with the CCC. The following tables describe the CCC asoociated roads and the 

possible historic roads within the APE. 

Table 3-6. CCC Constructed Roads Located Within The APE 

Route ID Route Name Site Number NRHP Status 

4030 Tenmile-Fifteenmile Unrecorded Undetermined 

4092 Tenmile Creek 24PR1965 Eligible 

4094 Fifteenmile Creek 24PR2136 Eligible 

4095 Poker Jim/Cow Creek 24PR2017, 24RB2064 Eligible 

4131 O'Dell Creek 24PR2018, 24RB2089 Undetermined 

4133 Beaver Creek 24PR2441 Not Eligible 

4135 Horse Creek 24PR2025 Undetermined 

4422 Whitetail Creek 24PR2137 Undetermined 

4434 Indian-Taylor Creek Divide Unrecorded Undetermined 

4703 Lemonade 24PR2031 Eligible 

4767 Beaver-Liscom 24PR2134 Eligible 

4769 Beaver-Stacey 24PR2135 Eligible 

40941 40941 Unrecorded Undetermined 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-28 Ashland Travel Management Final EIS – Chapter 3

Table 3-6. CCC Constructed Roads Located Within The APE 

Route ID Route Name Site Number NRHP Status 

Bloom Creek - County 24PR2049 Undetermined 

Taylor Creek - County 24PR2057 Undetermined 

Table 3-7. Possible Historic Roads Located Within the APE 

Route ID Route Name Route ID Route Name 

409412 409412 470313 470313 

409412A 409412A 47704 47704 

409412C 409412C 4772 Ash Creek 

40955 40955 47721 47721 

40957 40957 47725 47725 

4410 Yager 4773 Cook Creek 

41277 41277 47732 47732 

41277B 41277B 47733 47733 

41313 41313 47753 47753 

421212 421212 47754 47754 

44091 44091 4776 Wilbur Creek 

4421 Stag Rock 4777C 4777C 

4425 Cabin Creek 4783 South Ash Creek 

4431 Griffin Pass 4784 Taylor-Fifteenmile Creek 

4432 Bridge Canyon 47845 47845 

4436 Taylor Divide 47847 47847 

4436B 4436B 47848 47848 

4437 Upper South Fork 4785 Pumpkin-Otter Divide 

44372 44372 47853 47853 

44372A 44372A 47854 47854 

4440 South Plum Creek 47857 47857 

44404 44404 478515 478515 

4450 Fly Creek 4786 Lyon Creek 

4460 Coalmine Project 4787 North Fork Taylor Creek 

44601 44601 47902 47902 

4464 Doonan Draw 47903 47903 

4467 Threemile & Tenmile Divide 47904 47904 

44672 44672 47908 47908 

4469 Newell Creek 47911 47911 

45015 45015 4794 Horse Creek Butte 

4502 North Fork Bloom Creek 47944 47944 

45051 45051 47944A 47944A 

45200 45200 47944B 47944B 

47033 47033 47954 47954 

4797 Poker Jim-North Fork Lee 4800 South Fork Poker Jim 

47971 47971 4804 Paget Creek 

47973 47973 4805 King Creek 

4798 Wild Hog Butte 4806 Brian Creek 

The National Register defines four criteria to be used in the evaluation of sites: (a) that are associated 

with events that have made a significant contribution to the broad patterns of our history; or (b) that 

are associated with the lives of persons significant in our past; or (c) that embody the distinctive 

characteristics of a type, period, or method of construction, or that represent the work of a master, or 

that possess high artistic values, or that represent a significant and distinguishable entity whose 

components may lack individual distinction; or (d) that have yielded, or may be likely to yield, 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-29

information important in prehistory or history (36 CFR Section 60.4). Twenty-eight sites located 

within the APE have been found eligible for nomination to the NRHP to date. 

Six roads are associated with the CCC and considered eligible to the NRHP under criteria (a) and (c). 

Six archaeological sites are considered eligible to the NRHP based on criterion (d). A summary of the 

NRHP eligibility status for the 359 sites located in the APE is included in the following table. 

Table 3-8. National Register of Historic Places Eligibility Status

NRHP Status Number 

Listed on the NRHP 0 

Eligible for nomination to the NRHP 12 

Undetermined 341 

Not eligible for nomination to the NRHP 6 

Total 359 

Six recorded sites within the APE have been formally determined Not Eligible (NE) for nomination to 

the NRHP and are not considered historic properties. These sites will not be further considered. Of 

the 341 remaining sites, those that are currently defined as “undetermined” with respect to NRHP 

eligibility status will be considered eligible for the purposes of analysis under this travel management 

plan. 

In 1999, the Custer National Forest identified sites that met the national criteria for “priority heritage 

assets”. Priority asset sites are those sites that have had a significant value investment; and/or are 

eligible for nomination to the National Register of Historic Places (NRHP); and/or are considered “at 

risk” due to substantial effects to site integrity. Presently on the District, there are 67 sites on this list 

that are monitored on a five-year cycle. Thirty-six sites within the APEs for the alternatives A , B, 

and B Modified were identified as priority asset sites (table below). 

Table 3-9. Priority Assets within the APE for Alternatives A, B and B Modified. 

Site Number Site Name Site Type 

24PR0174 Cow Creek Lithic Scatter 

24PR0204 Petroglyph 

24PR0301 North Fork Lithic Scatter 

24PR0302 Lithic Scatter 

24PR0442 Lithic Scatter 

24PR0627 Highwalker Lithic Scatter 

24PR0639 Lithic Scatter 

24PR1026 Holiday Spring Lithic Scatter 

24PR1034 Griffin Pass Lithic Scatter 

24PR1039 Morris Spring Lithic Scatter 

24PR1135 Lithic Scatter 

24PR1181 Lithic Scatter 

24PR1566 Whitetail Guard Station Guard Station 

24PR1780 Lithic Scatter 

24PR1782 Lithic Scatter 

24PR1841 Otter Creek School Schoolhouse 

24PR1922-1924; 24PR1927-1929; 

24PR1940; 24PR1965 

Tenmile Road CCC road 

24PR1955-1957; 24PR2136 Fifteenmile Road CCC Road 

24PR2017 Cow Creek/Poker Jim Road CCC Road 

24PR2018 O’Dell Creek Road CCC Road 

24PR2025 CCC Drainage Structure 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-30 Ashland Travel Management Final EIS – Chapter 3

Table 3-9. Priority Assets within the APE for Alternatives A, B and B Modified. 

Site Number Site Name Site Type 

24PR2031 Lemonade Road CCC Road 

24PR2049 Bloom Creek Road Abandoned CCC Road Segment 

24PR2057 Taylor Creek Road Abandoned CCC Road Segments 

24PR2073 Historic Rock Art 

24PR2134 Beaver-Liscom Road CCC Road 

24PR2135 Beaver-Stacey Road CCC Road 

24PR2159 Lithic Scatter 

24RB0379 Lithic Scatter 

24RB1074 Rifle Pit Site Stone Feature 

24RB1998 CCC Drainage Crossing 

24RB2064 Cow Creek/Poker Jim Road CCC Road 

24RB2065 Poker Jim Ranger Station Ranger Station, CCC Spike Camp 

24RB2089 O’Dell Creek Road CCC Road 

At least 27 culturally sensitive sites (consisting of an alignment, cairns, a fasting bed, stone circles and 

stone structures) are located within the APEs near or adjacent to roads. The following table 

summarizes these culturally sensitive sites. 

Table 3-10. Culturally Sensitive 

Sites Located Within The APE.

Site Type Number of Sites 

Alignment 1 

Cairn 17 

Cairn & Stone Circle 1 

Fasting Bed 1 

Stone Circle 5 

Stone Structure 2 

Total 27 

In addition to the culturally sensitive sites described above, consultation with the Northern Cheyenne 

tribe revealed that the Tongue River Breaks, from the Tongue River to the King Mountain Divide 

south, should be considered a traditional cultural property/ethnographic “landscapes”. The 

characteristics of the ethnographic landscape that contribute to the use of a traditional cultural 

property (TCP) may include visual setting, qualities of spiritual reflection, renewal and sanctuary; 

natural setting; and unique ecosystem. The physical environment provides a basis upon which the 

integral relationships to the TCPs depend. Maintenance of the setting and its relationship with the 

surrounding lands become vital to the preservation of these sites and to the cultural landscape. 

To comply with a 2005 Washington Office directive (USDA Forest Service 2005) for travel 

management, all non-system routes (roads and trails) that are proposed to be added to the system 

under the selected alternative will be inventoried for cultural resources and the results analyzed and 

disclosed in the FEIS. The proposed non-system roads and trails will be inventoried utilizing 

pedestrian transects within a 600 foot wide corridor centered on these routes. All new cultural 

resources will be analyzed for any effects to the sites that may be the result from the new route 

designation. 

With the final selection of one of the alternatives any potential negative effects to sites may require 

review in order to determine what actions are needed that will reduce, remove or mitigate the effects. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-31

Where appropriate, consultation with interested tribes and the MTSHPO will occur during these site 

reviews. 

3.3.2.2 Environmental Consequences – Archaeological Resources and Tradition Cultural 

Properties 

Direct and Indirect Effects 

Effects Common to All Alternatives 

An effect, according to 36 CFR 800.9(a) of the NRHP, may include an alteration to the historic 

property’s characteristics of location, setting or use. Adverse effects are defined as those that may 

diminish the integrity of the property’s location, design, setting, materials, workmanship, feeling or 

association and include but are not limited to 1) physical destruction, damage or alteration of all or 

part of the property; 2) alteration of the character of the setting when that character contributes to the 

property’s qualification for the National Register and 3) introduction of visual, audible or atmospheric 

elements that are out of character with the property or that alters its setting. The number of historic 

properties that may potentially be adversely affected by each alternative is the measure used to 

compare the alternatives. 

Recreational motorized use, especially that of four-wheel drive and other off-highway-vehicles (OHV) 

has seen an ever-increasing trend since the 1960s. Numerous studies beginning during the early 1970s 

have documented the detrimental impacts of OHV use on archaeological sites by means of direct or 

indirect effects (Lyneis et al. 1980: 14; USDA Forest Service 2001: 55; USDA Forest Service 2002: 

33). In comparing the motorized travel system on the District from 1928 and 1957 there are only a 

few recognized road additions during a span of nearly thirty years. But in the following years since 

then, the number of roads have at least tripled. More roads result in more access to areas and 

increased effects to cultural resources.

A direct effect occurs when the action of the undertaking itself affects the cultural resource. Direct 

effects may be described as the breaking, crushing and scattering of cultural material when motorized 

vehicles are driven across or through sites. Soil compaction from wheel pressure and soil erosion 

processes may occur following removal of protective ground cover (i.e. vegetation and ground litter). 

Not only is there soil compaction and erosion as the ground surface becomes exposed, but the ground 

surface may become deflated. These types of site damage are especially apparent where concentrated 

and/or repeated vehicle travel occurs that causes rutting. Sites that consist of surface artifacts or 

features, or that contain intact subsurface cultural materials, are especially prone to damage and losses 

of valuable information due to motorized vehicle travel (ASPPN I-13 1989). 

Actions associated with travel management which could have the potential to adversely affect 

prehistoric and historic cultural properties include increases in the type, intensity and duration of trail, 

road or land use. Of particular concern is the increase through the years of user-created roads and 

trails. The majority of these travel ways has been, and continues to be, created without engineering 

design and without input from a variety of other resource specialists, including archaeologists. 

Attempts to use these roads during inclement weather or when the roads are impassible may result in 

either deep/severe rutting or in the creation of parallel tracks along the initially established road. This 

action exposes buried cultural material and often churns up the matrix so that artifacts loose their 

context. Often, sites associated with these user-created travel ways are discovered by chance, 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-32 Ashland Travel Management Final EIS – Chapter 3

exposing them to archaeologists and public visitor alike. Site damage has already occurred or is 

ongoing. Visually, as these user-created roads increase in number they become unsightly and may 

become permanent scars on the landscape. 

Actions that have the potential to benefit cultural properties include decreases (but not necessarily 

closure or obliteration) in the type, intensity or duration of trail and road use where cultural properties 

are present or where the character of the historic route can be maintained or restored through a travel 

management decision. Motorized use on, and its effects to, roads must also consider the age of roads 

and whether or not they represent cultural resources. For example, in the 1930’s the CCC workforce 

built and/or improved at least fifteen roads on the District. Nearly all of these roads are considered 

historic properties because most of their original alignment and stone work is still intact and in use. In 

many cases continued use and maintenance of these and other historic roads have a favorable effect to 

the property, preserving the qualities that make the road eligible for the NRHP. Discontinued use of 

the road would result in less maintenance and could threaten the preservation of the road. Any 

proposed changes by the Forest Service to the property would require evaluation and consultation 

with the MT SHPO. 

All routes proposed to be added to the system will require inventory and determination as to whether 

or not they are historic properties. This additional inventory will add to the historical record on the 

District and provide new information on the recent past. 

An indirect effect is not caused by the action itself but is the secondary result of the undertaking. 

Increased site access and exposure of sites to the elements may result in a greater chance for looting 

and artifact displacement from erosion. Soil compaction and artifact displacement can result from 

foot, horse and motor vehicle traffic and from dispersed camping on prehistoric sites. Soil erosion 

and artifact looting associated with vegetative cover removal due to traffic and livestock use may also 

lead to site degradation. 

An example of an indirect effect to sites involves the improved or increased access that a road may 

offer to a motorized vehicle user. In the past, where vehicle access to sites may have been nonexistent or limited, so too was the degree of site damage, artifact theft and vandalism. Studies have 

shown that increased access to public lands display a concurrent increase in the amount of vandalism 

of cultural resources (ASPPN I-13, 1989). The ability to access distant areas, relatively quickly and 

with relative ease, via motorized vehicles can result in subsequent looting or vandalism. Highly 

visible structures are more prone to visits due to their attractive nature as destination points. Large 

numbers of people, along with inappropriate behavior, can alter or damage the very attributes that 

make the structure important or attractive as a destination. These behaviors include trampling 

(leading to erosion or feature damage), theft, wall or feature damage and other types of vandalism. 

Sites that contain features, such as cairns, cribbed log structures, stone circles or historic buildings, 

may become damaged by actually driving over them or simply through acts of theft or vandalism. 

Motorized vehicles can easily transport equipment (i.e. shovels, screens, hammers, crowbars, highpowered rifles) used to damage or vandalize sites. These same vehicles can be used in theft to remove 

large items of value, whether this is weathered logs or lumber from a historic building or old mining 

equipment. These types of damage lessen the sites’ integrity and are irreversible. 

The simple act of theft or removal of one or more artifacts from a site results in a loss of information 

about that site. During the 1970s several sites near or crossed by roads were located based on 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-33

interviews with local informants. Site 24PR1038 was well known by local artifact collectors who 

stated that nearly thirty stone circles and several cairns had been obliterated during clearing activity by 

ranchers. At least one cairn had been completely dismantled by “treasure hunters.” Local informants, 

recollecting their early childhood years, recalled Northern Cheyenne utilizing this site (Beckes 1976: 

24). 

Site 24PR1048 at one time consisted of two cairns that may have served as aboriginal trail markers 

along the Otter Creek drainage. A local informant admitted tearing apart one of the cairns but finding 

no artifacts (Beckes 1976: 31). Site 24RB1074 was referred to by local informants as a “Rifle Pit” 

from which many 45-70 cartridge cases were found (Beckes 1976: 60). This site has been monitored 

several times during the past 17 years and at present does not exhibit any evidence of disturbance or 

dismantling, but during the spring of this year motorized vehicle tracks were observed off the nearby 

road a few meters from the structure. 

Site 24PR1034 is a lithic artifact scatter located along both sides of a road in the northeast portion of 

the District. When first recorded, local informants had indicated that the site had produced artifacts 

for years. Monitoring of this site in 2002 observed several small piles of discarded lithic artifacts—

including many flakes and several bifacially and unifacially retouched flakes—left by artifact 

collectors. Site 24RB1990 is located at the end of a road now accessible to the public but gated 

beyond for administrative use only. Vehicle travel on the road and parking at the gate have damaged 

the site. 

Beneficial indirect effects may include reduction in type and amount of traffic into the more remote 

areas through a decision to not designate certain routes for motorized use. Should cultural properties, 

and especially culturally sensitive sites, be located along a road or be crossed by a road, reducing the 

type and amount of traffic to the site may limit additional site disturbance and help preserve the site. 

Designating new roads and/or trails would require more archaeological inventory and environmental 

assessments which may result in the identification of more TCPs and/or more information on the 

distribution of culturally significant plant, animal, mineral and fossil resources. This information 

could be useful to traditional Indian Communities. It is possible that non-system routes converted to 

system roads and trails can increase or ease access to traditionally significant ceremonial or gathering 

places. However, increasing or easing of access to traditionally significant ceremonial or gathering 

areas would make them available for all. There is the potential to decrease the seclusion and quiet 

necessary for many traditional cultural practices. 

Alternative A 

Under this alternative, at least 513 recorded cultural resource sites are located within the APE 

corridor, of which 119 cultural resources may potentially be affected by the proposed actions. As 

described above, some of these proposals have the potential to cause detrimental effects, such as 

designating routes that may increase the type, intensity and duration of trail, road or land use where 

significant cultural resources may occur. This may be the case for the designation of non-system 

routes proposed to be system roads or motorized trails. Other proposals may beneficially affect some 

cultural resources by decreasing the type, intensity or duration of trail and road use (but not 

necessarily closure or obliteration). This may be the case for proposals to add non-system routes for 

administrative use only. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-34 Ashland Travel Management Final EIS – Chapter 3

The following table describes the cultural resources that may be affected by each type of proposed 

action. Appendix C further describes the number and locations of routes considered under this 

alternative. 

Table 3-11. Alternative A Summary of Cultural Resource Effects by Type of Action. 

Type of Proposed Action For Alternative A Cultural 

Resources 

within APE 

Priority 

Asset Sites 

within APE 

Culturally 

Sensitive 

Sites within 

APE 

Number of cultural resources within the 600 foot corridor of all 

designated motorized routes 513 46 42 

Actions with Potential to Increase Effects 

Number of sites located within the 600 foot corridor for Non-System 

routes Proposed to be System Roads or Motorized Trails 85 13 5 

Actions with Potential to Decrease Effects 

Number of cultural resources located within the 600 foot corridor for 

Non-System Routes Proposed for Administrative Use Only 0 0 0 

Number of cultural resources located within the 600 foot corridor for 

System Roads proposed for Administrative Use Only 26 4 2 

Number of cultural resources located within the 600 foot corridor for 

System Roads Not proposed to be Designated for Public Motorized Use 8 0 0 

Direct Effects 

Under this alternative, at least 85 recorded cultural resource sites are located within the APE corridor 

that could be adversely affected by the designation of non-system routes. Most of these sites consist 

of lithic artifact scatters with intact subsurface cultural material and the direct effects consist of rutting 

or down-cutting of the new trails that pass through the sites. Allowing motor vehicle use on these 

routes could further expose these deposits resulting in loss of valuable information. Thirteen priority 

asset sites, four of which are NRHP eligible archaeological sites, could be physically damaged by 

motorized vehicle use. Site 24PR1034, mentioned earlier may see an increase in vandalism. Nine of 

the thirteen priority assets are road segments associated with the CCC. 

Five sites are considered culturally sensitive sites and, while the direct effects include the same for 

lithic scatters, the possibility of dislodging stone from cairn, stone circles, and stone features would 

damage the physical character as well as its traditional qualities. Three of these culturally sensitive 

sites are cairns. 

Designating dispersed camping within 300 feet of designated roads and trails could affect some of the 

85 sites identified within the APE under Alternative A. These effects include vehicle rutting on sites 

or damage to artifacts or features due to being driven over. Permitting dispersed vehicle camping 

within 300 feet of designated roads and trails may affect some of these sites identified if this activity 

occurs frequently at the same locations. However, monitoring during the past seven years has not 

revealed any adverse effects to cultural resources as a result of dispersed vehicle camping. 

 

CCC road segments for Ten Mile, 15 Mile, Beaver-Liscom, O’Dell, Lemonade and Cow Creek/Poker 

Jim roads would be added to the road system and one CCC road would be added to the motorized trail 

system. For the CCC road added to the trail system, no change in maintenance and standard is 

anticipated based upon maintenance guidance for roads and trail found in FSH 7709.59 and FSH 

2309.18. Nine historic roads would also be converted to the motorized trail system and 3 historic 

roads would be added to the road system. These historic roads would be formally recorded and 

evaluated, adding to our knowledge of the historic road system on the District. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-35

The conversion of several system routes to administrative use only may reduce effects to 26 sites, two 

of which are cairn sites considered culturally sensitive. A similar reduction of effects for eight sites 

may occur as a result of not designating several system roads for public motorized use. 

Indirect Effects 

By adding a number of non-system (user created) roads to the system, access to the more remote areas 

of the District would increase. As studies have shown, increased access often leads to increased 

vandalism and theft. The 85 sites located along the added routes could be exposed to vandalism and 

illegal artifact collection. 

Increased access may also affect four culturally sensitive sites by infringing on the isolated character 

surrounding these sites. This could affect any traditional use that may be associated with these site 

types. 

Designating dispersed camping within 300 feet of designated roads and trails would likely affect some 

of the 85 sites identified within the APE under Alternative A. These effects include discovery of sites 

and illegal collection of artifacts or possibly the dismantling of sensitive site features—such as cairns 

or stone circles—as intentional acts of vandalism or for the construction of campfire rings. 

Decreased access along the west side of the Tongue River Breaks may have a beneficial effect for the 

Tongue River ethnographic landscape and traditional cultural properties by reducing the type and 

amount of traffic into this area and preserving the seclusion and quiet necessary for many traditional 

cultural practices. 

But decreased access may also make it difficult for traditional practitioners to travel to traditionally 

significant ceremonial or gathering places. Access for traditional Indian practices is facilitated, 

however, through E.O.13007 and, more recently, the 2009 Farm Bill. 

Alternative B 

Under this alternative, at least 440 recorded cultural resource sites are located within the APE 

corridor, of which 46 cultural resources may be potentially affected by the proposed actions under 

Alternative B. As described above, some of these proposals have the potential to cause detrimental 

effects, such as designating routes that may increase the type, intensity and duration of trail, road or 

land use where significant cultural resources may occur. This may be the case for the designation of 

non-system routes proposed to be system roads or motorized trails. Other proposals may beneficially 

affect some cultural resources by decreasing (but not necessarily closure or obliteration) the type, 

intensity or duration of trail and road use. This may be the case for proposals to add non-system 

routes for administrative use only. 

Most of these sites consist of lithic artifact scatters with intact subsurface cultural material and the 

direct effects consist of vehicle-caused rutting or down-cutting of the routes that pass through the 

sites, exposure of cultural deposits, and loss of valuable archaeological information. The following 

table further describes the cultural resources that may be affected, and under what proposed action 

may affect these resources. Appendix C further describes the number and locations of routes 

considered under this alternative. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-36 Ashland Travel Management Final EIS – Chapter 3

Table 3-12. Alternative B Summary of Cultural Resource Effects by Type of Action. 

Type of Proposed Action For Alternative B Cultural 

Resources 

within APE 

Priority 

Asset Sites 

within APE 

Culturally 

Sensitive Sites 

within APE 

Number of cultural resources within the 600 foot corridor of all 

designated motorized routes 440 45 35 

Actions with Potential to Increase Effects 

Number of sites located within the 600 foot corridor for Non-System 

routes Proposed to be System Roads or Motorized Trails 18 8 0 

Actions with Potential to Decrease Effects 

Number of cultural resources located within the 600 foot corridor for 

Non-System Routes Proposed for Administrative Use Only 0 0 0 

Number of cultural resources located within the 600 foot corridor for 

System Roads proposed for Administrative Use Only 12 3 1 

Number of cultural resources located within the 600 foot corridor for 

System Roads Not proposed to be Designated for Public Motorized Use 16 2 2 

Direct Effects 

Eighteen recorded sites could be affected by the designation of non-system routes proposed to be 

system routes or trails. Eight of these sites are considered priority assets and include a total of seven 

CCC road segments for 10 Mile, O’Dell Creek, Bloom Creek, Beaver-Liscom, and 15 Mile, along 

with one lithic scatter. No recorded culturally sensitive sites would be affected by these route 

additions. 

Three CCC roads (Tenmile-Fifteen #4030, Horse Creek #4135, and Indian-Taylor Creek Divide 

#4434) are proposed to be converted to motorized system trails. No change in maintenance and 

standard is anticipated based upon maintenance guidance for roads and trails found in FSH 7709.59 

and FSH 2309.18. 

Twelve recorded sites are located within the 600 foot corridor along system roads proposed for 

administrative use only. This may have a beneficial effect for one culturally sensitive site (a cairn), 

and three priority asset sites (one lithic scatter and two CCC segments). No change in maintenance 

standard is foreseen for the CCC route segments proposed for administrative use only. 

For system roads that will not be designated for public motorized use, there are 16 sites within the 600 

foot corridor. Two priority assets along these roads are CCC road segments and two culturally 

sensitive sites, a stone feature and a cairn. This action may reduce detrimental effects to these 

culturally sensitive sites. The CCC route segments, however, will no longer be maintained to standard 

and could fall into disrepair. 

Indirect Effects 

The addition of non-system (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. This can have detrimental effects to culturally sensitive sites where site integrity and 

setting are important values to protect. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-37

Access to one archaeological site that is eligible to the NRHP would be allowed by the addition of a 

user created route to the motorized trail system. Increasing access threatens the remote location of the 

site that has thus far protected the valuable information it contains. 

Designating dispersed camping within 300 feet of the added user created could affect eighteen sites 

identified within the APE under Alternative B. These effects include discovery of sites and illegal 

collection of artifacts or possibly the dismantling of culturally sensitive site features—such as cairns 

or stone circles—as intentional acts of vandalism or for the construction of campfire rings. 

Restricting access along the Tongue River Breaks may have a beneficial effect for the Tongue River 

ethnographic landscape and traditional cultural properties by reducing the type and amount of traffic 

into this area and preserving the seclusion and quiet necessary for many traditional cultural practices. 

Alternative B Modified 

Effects for Alternative B Modified differs from Alternative B with three more cultural sites (443) 

located within the APE. One less cultural resource site and one less priority asset would be affected 

by the designation of non-system routes (user created roads) to system routes. No recorded culturally 

sensitive sites would be adversely affected by the addition of non-system routes. 

 

Direct Effects 

Alternative B Modified may have beneficial effects for 27 sites, located along the corridors for system 

routes proposed for Administrative use only and system routes not proposed to be designated for 

public motorized use, by limiting access and use of these routes. Two culturally sensitive sites may be 

beneficially affected due to the reduction of use through the change of system roads open to public use 

to administrative use only. 

Seven CCC road segments along non-system roads proposed to be system roads or motorized trails 

would benefit from increased maintenance and preservation of these routes. Two CCC segments 

along system routes proposed for administrative use only would still be maintained to standard, but 

three CCC segments along system routes not proposed to be designated for public motorized use have 

reduced maintenance. 

The following table further describes the cultural resources that may be affected by each type of action 

for this alternative. Appendix C further describes the number and locations of routes considered under 

this alternative. 

Table 3-13. Alternative B Modified Summary of Cultural Resource Effects by Type of Action. 

Type of Proposed Action For Alternative B Modified 

Cultural 

Resources 

within APE 

Priority Asset Sites 

within APE 

Culturally 

Sensitive Sites 

within APE 

Number of cultural resources within the 600 foot corridor of all 

designated motorized routes 443 45 35 

Actions with Potential to Increase Effects 

Number of sites located within the 600 foot corridor for NonSystem routes Proposed to be System Roads or Motorized Trails 17 0 0 

Actions with Potential to Decrease Effects 

Number of cultural resources located within the 600 foot corridor 

for Non-System Routes Proposed for Administrative Use Only 0 0 0 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-38 Ashland Travel Management Final EIS – Chapter 3

Table 3-13. Alternative B Modified Summary of Cultural Resource Effects by Type of Action. 

Type of Proposed Action For Alternative B Modified 

Cultural 

Resources 

within APE 

Priority Asset Sites 

within APE 

Culturally 

Sensitive Sites 

within APE 

Number of cultural resources located within the 600 foot corridor 

for System Roads proposed for Administrative Use Only 13 4 1 

Number of cultural resources located within the 600 foot corridor 

for System Roads Not proposed to be Designated for Public 

Motorized Use 

19 0 2 

Indirect Effects 

The addition of non-system (user created) motorized trails opens up new access to areas previously 

considered somewhat remote and, as studies have found, could increase the occurrence of site 

vandalism and theft. No recorded culturally sensitive sites or archaeologically eligible to the NRHP 

were identified under Alternative B Modified along the non-system routes proposed to be system 

roads or motorized trails. 

Designating dispersed camping within 300 feet of the added user created routes could affect seventeen 

sites identified within the APE under Alternative B Modified. Seven of the 17 sites are CCC road 

segments and will not be affected by dispersed camping activities. 

Further preservation and protection of the Tongue River cultural landscape and traditional cultural 

properties may be a beneficial effect from restricting and decreasing access under this alternative. 

No Action Alternative 

The No Action Alternative sets a baseline by considering the existing system road and trails as 

defined by the CNF Forest Plan, Plan amendments, and all existing Forest Orders. Under the No 

Action Alternative 494 cultural resource sites have been recorded, of which 46 are classified as 

priority assets and 27 are considered culturally sensitive sites. The CCC built at least 15 system roads 

on the District that are still in use. Maintenance of these historic properties as system roads has added 

years to their preservation and protection. 

Direct Effects 

Under this alternative, no new historic information would be gained through the addition of new 

routes to the system. The CCC built system roads would continue to be maintained and protected 

through their identification as system roads. No new potential CCC routes would be recorded, 

however, and added to the system. The 46 priority assets would continue to be monitored and any 

adverse change in their condition would be reported in the MT Annual report. 

Indirect Effects 

The remote location for three of the NRHP prehistoric locations would be protected through limited 

access. The culturally sensitive sites would not be subjected to increased access since no new routes 

would be added to the system. The Tongue River Cultural Landscape would be maintained at its 

present condition. 

Cumulative Effects 

There are a number of ongoing and reasonably foreseeable activities on the District that have the 

potential to affect cultural resources such as fuel treatments, special use permits, and range allotment 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-39

plans. Mitigation of the potential effects associated with these activities and site protection measures 

will continue to be employed in consultation with the MT SHPO. Monitoring site conditions will 

continue in support of travel management as well as other Forest undertakings such as range 

development, fuels and timber management. Additional inventory in response to this and future 

undertakings will add to the understanding of the area prehistory and history. 

3.3.2.3 Conclusion – Archaeological Resources and Traditional Cultural Properties 

In overall comparisons, Alternative A consists of the highest count of cultural resource sites that may 

be affected due to the designation of non-system routes to system roads or motorized trails, and the 

increase of dispersed vehicle camping activities. Alternative B and Alternative B Modified strike a 

balance between adding to our knowledge of the area through additional inventory, while protecting 

and preserving the highest number of recorded cultural resource sites, culturally sensitive sites, 

priority asset sites, historic and CCC roads, and cultural landscapes. The following table compares 

the action alternatives. 

Table 3-14. Summary of Cultural Resource Sites, Priority Asset Sites, and Culturally Sensitive 

Sites within the APE by Alternative.

Type of Resource Alternative A Alternative B Alternative B 

Modified 

No Action 

Alternative 

Total Number of Cultural 

Resource Sites within the APE 513 440 443 494 

Number of Priority Asset Sites 

within the APE 46 45 45 46 

Number of Culturally Sensitive 

Sites within the APE 42 35 35 39 

For all alternatives, compliance with the NHPA through the MT PA is required. Cultural resource 

monitoring will be implemented within the Project Area in order to assess the effectiveness of the new 

plan relative to the protection and preservation of significant heritage resources. This monitoring 

program will be based upon an adaptive management approach that may necessitate specific changes 

if site disturbances are observed. Should detrimental effects occur, site evaluative testing and formal 

consultation with the MT SHPO to identify measures to reduce, remove or mitigate these effects will 

be necessary. The monitoring results will be presented in the Annual Heritage Report required by the 

MTPA. 

3.3.3 WILDLIFE 

Introduction 

Public concerns relative to wildlife can be summarized into two primary issues: 1) changes to habitat 

quality, and 2) effects to wildlife behavior. Habitat concerns include fragmentation, loss, 

connectivity, and availability of security habitat. Wildlife behavior effects include disturbance, 

displacement, and responses to noise. Effects for both issues are discussed in general terms in the 

General Wildlife section as well as in specific species sections relative to those species. Winter overthe-snow travel (i.e. snowmachines, cross-country skiing, etc.) is not part of the current District travel 

plan process and thus is not discussed. However, winter wheeled motorized vehicle use was 

considered during analysis. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-40 Ashland Travel Management Final EIS – Chapter 3

The District provides habitat for a variety of wildlife species including federally threatened species, 

ungulates, carnivores, small mammals, resident and migratory birds, amphibians, and reptiles. Travel 

routes can affect the way many animals use an area because they may bring humans and their 

associated disturbances into wildlife habitat. The following table displays threatened, endangered, 

sensitive, and management indicator species on the District, plus other species identified during the 

public scoping process. 

Table 3-15. Wildlife Analysis Table

Species Name Basic Habitat Description and 

Occurrence in Project Area 

Included in 

EIS 

Rationale and Other 

Information 

Effects 

Determination

For 

Alternative B7

Modified 

Threatened, Endangered, and Proposed Species 

Black-footed 

Ferret 

(Mustela nigripes) 

(Endangered) 

Live within large complexes 

(6,000 to 7,500 acres) of occupied 

prairie dog colonies (>100 acres) 

and complexes. Ferrets depend on 

prairie dog colonies for food, 

shelter and denning. The Ashland 

Ranger District supports about 

1,100 acres of black-tailed prairie 

dog colonies. Black-footed ferrets 

are not known to be present. 

Analysis in EIS. Primary concerns are 

maintenance of prey base 

(black-tailed prairie dog 

colonies). 

NLAA 

Forest Service Sensitive Species 

American 

peregrine falcon 

(Falco peregrinus 

anatum) 

Cliff habitat over 200’ high with 

suitable ledges for nest 

construction. Not known to occur 

in the project area. 

No further 

analysis will be 

conducted. 

Not in project area NI 

Baird’s sparrow 

(Ammodramus 

bairdii) 

Prefers native prairie but structure 

is more important so may nest in 

tame grasses. Species present in 

project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

NI

Bald Eagle 

(Haliaeetus 

leucocephalus) 8

Riparian habitats, forested areas 

along rivers and lakes, wetlands, 

and major water bodies. May use 

uplands and game winter range 

during winter. Nesting sites 

usually in large forested areas near 

large water bodies. The project 

area used primarily as winter 

foraging habitat. No known nest 

sites. 

No further 

analysis will be 

conducted. 

Little nesting habitat and 

no known nests in project 

area. Bald eagle presence 

on District is primarily 

during winter, and winter 

over-the-snow travel is not 

part of the current District 

travel plan process. 

NI

Black-backed 

woodpecker 

(Picoides arcticus) 

Primary habitat is recently burned 

forested areas, secondary habitat is 

spruce/fir forests. Habitat present 

Analysis in EIS. Included in Migratory 

Birds discussion 

NI

 

7 Options for effects determinations are: For federally listed species NE = No effect; NLAA = May effect – not likely to 

adverse affect; LAA = May effect – likely to adversely affect; and BE = Beneficial effect. For Forest Service sensitive 

species NI = No impact; MIIH = May impact individuals but is not likely to cause a trend to Federal listing or loss of 

viability; WIFV = Likely to result in a trend to Federal listing or loss of viability; and BI = Beneficial impact. For 

management indicator species: + = Positive effect; 0 = Neutral effect; and - = Negative effect. For other species of 

concern: NE = No effect. 

8 Bald eagle delisted effective August 8, 2007 and subsequently managed as a Forest Service Sensitive Species.
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-41

Table 3-15. Wildlife Analysis Table

Species Name Basic Habitat Description and 

Occurrence in Project Area 

Included in 

EIS 

Rationale and Other 

Information 

Effects 

Determination

For 

Alternative B7

Modified 

in project area and species is 

known to be present. 

Blue-gray 

gnatcatcher 

(Polioptila) 

Open stands of juniper and limber 

pine with intermixed sagebrush. 

Habitat is not present in the 

project area. 

No further 

analysis will be 

conducted 

Not in project area. NI

Burrowin gowl 

(Athene 

unicularia) 

Open grasslands, nesting and 

roosting in burrows dug by 

mammals or owls. Species is 

associated with prairie dogs 

burrows in the project area. 

Habitat present in project area and 

species is known to be present. 

No further 

analysis will be 

conducted. 

No increased access to 

occupied black-tailed 

prairie dog habitat is 

proposed in any alternative. 

NI 

Greater sage 

grouse 

(Centrocercus 

urophasianus) 

Sagebrush with intermixed 

grasslands. No leks are located in 

project area. Brood-rearing and 

winter habitat maybe present but 

the species is not known to occur 

in the project area. 

No further 

analysis will be 

conducted. 

No increased access to 

habitat is proposed in any 

alternative. 

NI

Grizzly Bear 

(Ursus arctos)

9

Remote, well connected forested 

generalist. Species is not present 

in the project area. 

No further 

analysis will be 

conducted 

Not in project area. NI

Harlequin duck 

(Histrionicus 

histrionicus) 

Inhabit fast moving, low gradient 

clear mountain streams. Species 

is not present in the project area. 

No further 

analysis will be 

conducted 

Not in project area. NI

Loggerhead Shrike 

(Lanius 

ludovicianus) 

Grassy pastures that are well 

grazed, nest in shrubs or small 

trees, preferably thorny such as 

hawthorn. Species and habitat are 

present in project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

NI

Long-billed 

curlew (Numenius 

americanus) 

Open grasslands or prairie usually 

near water. No habitat in project 

area. 

No further 

analysis will be 

conducted. 

Not in project area. NI

Long-eared myotis 

(Myotis evotis) 

Use a variety of habitats but are 

strongly associated with 

coniferous forests. Species present 

in project area. 

Analysis in EIS. Included in Bats 

discussion. Primary 

concern is disturbance at 

roosting sites and 

hibernacula. 

MIIH 

Long-legged 

myotis 

(myotis volans) 

Primarily a coniferous-juniper 

forest bat found at moderate 

elevations (>6000ft) but may also 

inhabit riparian cottonwood 

bottoms and desert areas. Species 

present in project area. 

Analysis in EIS. Included in Bats 

discussion. Primary 

concern is disturbance at 

roosting sites and 

hibernacula. 

MIIH 

Pallid bat 

(Antrozous 

Arid deserts and grasslands with 

rock outcrops. Species present in 

Analysis in EIS. Included in Bats 

discussion. Primary 

MIIH

 

9 Grizzly bear delisted effective April 30, 2007 and subsequently managed as a Forest Service Sensitive Species as directed 

in “Final Conservation Strategy for the Grizzly Bear in the Yellowstone Ecosystem, Interagency Grizzly Bear Study Team, 

March 2003.”
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-42 Ashland Travel Management Final EIS – Chapter 3

Table 3-15. Wildlife Analysis Table

Species Name Basic Habitat Description and 

Occurrence in Project Area 

Included in 

EIS 

Rationale and Other 

Information 

Effects 

Determination

For 

Alternative B7

Modified 

pallidus) project area. concern is disturbance at 

roosting sites and 

hibernacula. 

Spotted bat 

(Euderma 

maculatum) 

Desert to montane coniferous 

forests. Species present in project 

area. 

Analysis in EIS. Included in Bats discussion. 

Primary concern is 

disturbance at roosting sites 

and hibernacula. 

MIIH

Townsend’s bigeared bat 

(Corynorhinus 

townsendii) 

Cave and cave-like structures 

along with forested foraging 

habitat. Species present in project 

area. 

Analysis in EIS. Included in Bats 

discussion. Primary 

concern is disturbance at 

roosting sites and 

hibernacula. 

MIIH

Black-tailed 

prairie dog 

(Cynomys 

ludovicianus) 

Relatively flat grasslands with 

diggable soils, throughout the 

central plains. Species present in 

project area. 

See blackfooted ferret 

analysis, no 

further analysis 

for prairie dogs 

will be 

conducted. 

No increased access to 

habitat is proposed in any 

alternative. 

MIIH 

White-tailed 

prairie dog 

(Cynomys 

leucurus) 

Xeric sites with mixed stands of 

shrubs and grasses from the 

Bighorn Basin in Montana to 

Utah. Species is not present in 

project area. 

No further 

analysis will be 

conducted. 

Not in project area. NI

Wolverine 

(Gulo gulo) 

Remote subalpine and spruce/fir 

forested areas. Species is not 

present in project area. 

No further 

analysis will be 

conducted. 

Not in project area. NI

Greater shorthorned lizard 

(Phrynosoma 

hernandesi) 

Areas with short, sparse grass or 

sagebrush; flats with pebbly or 

stony soil; and rock outcrops. 

Species present in project area. 

Analysis in EIS. Included in General 

Wildlife Species 

discussion. Primary 

concern is direct mortality 

while crossing roads. 

MIIH

Milk Snake 

(Lampropeltis 

triangulum) 

Open sagebrush/grasslands, 

usually in or near rocky areas. 

Species present in project area. 

Analysis in EIS. Included in General 

Wildlife Species 

discussion. Primary 

concern is direct mortality 

while crossing roads.

MIIH

Western hognosed snake 

(Heterodon 

nasicus) 

Sagebrush/grassland; arid areas 

with gravelly or sandy soil. 

Species present in project area. 

Analysis in EIS. Included in General 

Wildlife Species 

discussion. Primary 

concern is direct mortality 

while crossing roads.

MIIH

Management Indicator Species 10

Northern Goshawk 

(Accipiter gentilis)

(H) 

Mature forest generalist. Species 

present in project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0 

White-tailed deer 

(odocoileus 

Grassland to montane conifer 

forest. Species present in project 

Analysis in EIS 

under elk 

Analysis for elk serves as 

surrogate for white-tailed 

0 

 

10 H = Habitat Indicator Species; K = Key Species
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-43

Table 3-15. Wildlife Analysis Table

Species Name Basic Habitat Description and 

Occurrence in Project Area 

Included in 

EIS 

Rationale and Other 

Information 

Effects 

Determination

For 

Alternative B7

Modified 

virginianus) 

(H, K) 

area. section. deer because they occupy 

the same habitats in the 

project area and elk have 

more restrictive habitat 

requirements. Impacts of 

travel are expected to be 

similar for the two species. 

Ruffed grouse 

(Bonasa umbellus)

(H) 

Primary habitat includes dense 

early seral staged forests 

dominated by aspen, secondary 

habitat includes other dense 

deciduous or conifer woodland 

areas. Species is not present in 

project area. 

No further 

analysis will be 

conducted. 

Not in project area. 0

Western kingbird 

(Tyrannus 

verticalis) (H) 

Open or partially open country 

with scattered trees, including 

agricultural lands. Habitat not 

present in project area. 

No further 

analysis will be 

conducted. 

Not in project area. 0

Bullock’s 

(Northern) oriole 

(Icterus bullockii) 

(H) 

Open deciduous woodland and 

riparian areas. Habitat present in 

project area. Species presence 

unknown. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Yellow warbler 

(Dendroica 

petechia) (H) 

Brushy riparian especially with 

willows. Species present in 

project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Ovenbird (Seiurus 

aurocapillus) (H) 

Mid-late successional, closedcanopied deciduous or 

deciduous/conifer forests with 

limited understory. Species 

present in project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Spotted (Rufoussided) towhee 

(Pipilo maculatus)

(H) 

Shrubby riparian areas, woody 

draws, and woodland 

undergrowth. Species present in 

Pryors Unit. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Brewer’s sparrow 

(Spizella Breweri)

(H) 

Strongly associated with 

sagebrush, but also uses other 

areas with scattered shrubs and 

short grasses. Species present in 

project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Sharp-tailed 

grouse 

(Tympanuchus 

phasianellus) 

(H, K) 

Mosaic of dense grass and shrubs 

with forbs for nesting, woody 

riparian areas in winter. Species 

present in project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Yellowstone 

Cutthroat trout 

(Oncorhynchus 

clarkii bouvieri)

(H, K) 

Upper Yellowstone and Upper 

Snake River drainages. Species is 

not present in project area. 

No further 

analysis will be 

conducted. 

Not in project area. 0

Elk (Cervus Grassland to forested alpine areas. Analysis in EIS. Main concerns are potential 0
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-44 Ashland Travel Management Final EIS – Chapter 3

Table 3-15. Wildlife Analysis Table

Species Name Basic Habitat Description and 

Occurrence in Project Area 

Included in 

EIS 

Rationale and Other 

Information 

Effects 

Determination

For 

Alternative B7

Modified 

canadensis) (K) Species present in project area. for displacement due to 

recreational travel, and 

vulnerability during 

hunting season. 

Golden eagle 

(Aquila 

chrysaetos) (K) 

Open hilly to mountainous areas. 

Habitat and species present in 

project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Merlin (Falco 

columbarius) (K) 

Patchy shrub/grassland habitats 

with large trees to support nesting 

(secondary nester). Habitat and 

species present in project area. 

Analysis in EIS. Included in Migratory 

Birds discussion 

0

Mule deer 

(Odocoileus 

hemionus) (K) 

Rugged grassland to forested 

alpine areas. Species present in 

project area. 

Analysis in EIS 

under elk 

section. 

Analysis for elk serves as 

surrogate for mule deer 

because they occupy the 

same habitats in the project 

area and elk have more 

restrictive habitat 

requirements. . Impacts of 

travel are expected to be 

similar for the two species. 

0 

Bighorn sheep 

(Ovis Canadensis)

(K) 

Remote, steep, rugged terrain, 

such as mountains, canyons, and 

escarpments where precipitation is 

low and evaporation is high. 

Species is not present in project 

area. 

No further 

analysis will be 

conducted. 

Not in project area. 0

Pronghorn 

antelope 

(Antilocapra 

Americana) (K) 

Rolling grasslands to mixed 

sagebrush shrublands. Species 

present in project area. 

No further 

analysis will be 

conducted. 

No increased access to 

habitat is proposed in any 

alternative. 

0

Potential effects of the alternatives on the following species and/or their habitats are analyzed in 

detail: Black-footed ferret; bats (includes Long-eared myotis, long-legged myotis, Pallid bat, Spotted 

bat, and Townsend’s big-eared bat); big game (includes Elk, White-tailed deer and Mule deer); 

migratory birds (includes Baird’s sparrow, Black-backed woodpecker, Loggerhead shrike, Golden 

eagle, Merlin, Northern goshawk, Bullock’s oriole, Yellow warbler, Ovenbird, Spotted Towhee, 

Brewer’s sparrow and Sharp-tailed grouse); and general wildlife species (includes Greater shorthorned lizard, Milk Snake, Western hog-nosed snake and other Focal Species). 

The list of federally Threatened and Endangered species for the Custer National Forest and counties 

encompassed by the Ashland Ranger District was verified through the U.S. Fish and Wildlife Service 

in July 2008 (US Fish and Wildlife Service 2008). The bald eagle was delisted effective August 8, 

2007. The only listed species for the Ashland Ranger District is the black-footed ferret. 

Applicable background information regarding specific species biological requirements, and general 

effects including effects of roads and recreation on wildlife, were taken from the Beartooth Travel 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-45

Management FEIS, Gallatin National Forest Travel Plan FEIS, the Helena National Forest North Belts 

Travel Plan Wildlife Report, Effects of Recreation on Rocky Mountain Wildlife – A Review for 

Montana, and other literature as cited. 

3.3.3.1 Affected Environment – Threatened And Endangered Species Black-footed Ferret 

Regulatory Framework – Black-footed Ferret 

The black-footed ferret was listed as a federally endangered species under the Endangered Species Act 

(ESA) in March 1967. The recovery plan for the black-footed ferret (USFWS 1988) established the 

national recovery objectives where are to: increase the captive population of ferrets to 200 breeding 

adults by 1991; establish a prebreeding census population of 1,500 free-ranging breeding adults in 10 

or more different populations with no fewer than 30 breeding adults in each population by the year 

2010; and encourage the widest possible distribution of reintroduced animals throughout their historic 

range (FR Vol. 61, No. 55, March 1996). So far, reintroduction attempts have occurred in Wyoming, 

Montana, South Dakota, Colorado, and Utah. In January 2002, the Conservation Plan for Blacktailed and White-tailed Prairie Dogs in Montana was approved and implemented in Montana 

(MTFWP 2002). The overall goal of the plan is to “provide for management of prairie dogs 

populations and habitats to ensure long-term viability of prairie dogs and associated species” which 

included black-footed ferrets (MTFWP 2002). In 2003 an annual rule regulating prairie dog shooting 

on public lands was implemented by the State where prairie dogs could not be shot on public lands 

from March 1 thru May 31(MTFWP 2003). The no shooting rule was permanently remanded in 2007 

so prairie dog shooting on most public land remains open. On January 24, 2008, the U.S. Fish and 

Wildlife Service reintroduced 8 black-footed ferrets on the Northern Cheyenne Indian Reservation. 

The nearest release site was about seven miles from the Ashland Ranger District. More ferret releases 

are scheduled on Tribal lands in Fall 2008 or Winter 2009. 

 

Affected Environment – Black-footed ferret 

Black-footed ferrets are intimately tied to prairie dog colonies throughout their range. Research from 

ferret-occupied prairie dog colonies indicates that the most important attribute of ferret habitat is the 

distribution and abundance of prairie dogs. Ferrets are therefore limited to the same open habitat used 

by prairie dogs: grasslands, steppe, and shrub steppe (MTNHP 2008). To support a viable population 

of ferrets, a prairie dog colony complex of 2500-3000 ha (6,200-7,400 acres) composed of individual 

colonies at least 12 ha (30 acres) in size, with the majority 50 ha (125 acres) or larger, is needed 

(Forrest et al., 1988, p. 28). Miller et. al. (1996) found that females with young have never been 

found on prairie dog colonies less than 49 ha (121 acres). No black-footed ferrets have been 

documented on the Ranger District since 1936. 

Currently there are about 1,088 acres of active black-tailed prairie dog (Cynomys ludovicianus) 

colonies on NFS lands which occupy 0.3% of the 435,822 acres on the Ashland Ranger District. Of 

the 1,088 acres of colonies, no prairie dog colonies are greater than or equal to 120 acres which is the 

size required to support one female ferret with young. The four largest colonies range from 75 to 114 

acres with an average of 19 acres. 

The colony acreage on NFS lands and the distribution pattern of towns is currently inadequate to 

support black-footed ferrets. As of August 12, 2004 the USFWS removed the black-tailed prairie dog 

as a candidate for listing under the Endangered Species Act. The black-tailed prairie dog is 

considered as a USFS Northern Region Sensitive species. Approximately 770 acres (71%) of 

occupied prairie dog habitat falls within 100 feet of an open motorized route for each alternative. This 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-46 Ashland Travel Management Final EIS – Chapter 3

portion of the total acres of available prey for black-footed ferrets may be more vulnerable to 

recreational shooting. However since 2003 when black-tailed prairie dogs were first monitored in the 

project area, the amount of occupied habitat has increased approximately 50 to 100 acres per year. 

 

3.3.3.2 Environmental Consequences – Threatened And Endangered Species: Black-footed 

Ferret 

Direct and Indirect Effects – Black-footed Ferret 

The presence of roads and trails represents a direct loss of habitat that has already occurred, and their 

use can pose a direct threat of black-footed ferret mortality from vehicles. However, black-footed 

ferrets are not known to occur in the area and the project area does not support an adequate preybase 

of prairie dogs to support ferrets. Indirectly, the impacts of roads include increased access for prairie 

dog shooters that could have a negative impact on prey density. However since 2003 when blacktailed prairie dogs were first monitored in the project area, the amount of occupied habitat has 

increased approximately 50 to 100 acres per year. 

Effects Common to All Alternatives 

Direct habitat loss would not increase under any alternative because construction of new routes is not 

proposed. None of the alternatives analyzed in detail propose increased access to black-footed ferret 

or black-tailed prairie dog habitat. All of the alternatives provide the same amount of access to prairie 

dog colonies. 

Vehicle-related black-footed ferret mortality is unlikely given the relatively low speeds and traffic 

volumes on National Forest system roads and the lack of ferrets and adequate habitat. 

No vegetation treatment is proposed with this analysis and the components of available habitat would 

not change. 

Alternative A, Alternative B and No Action Alternative 

The availability of black-footed ferret habitat would be effectively the same under Alternatives A, B, 

B Modified, and the No Action. 

Cumulative Effects – Black-footed Ferret 

Based on the past and current vegetation management on the District, including timber harvest, 

livestock grazing, prescribed fire, the invasive species program, and other vegetation projects, 

grassland/shrub steppe vegetation conditions provide some habitat for black-footed ferret and their 

preferred prey species, black-tailed prairie dogs. The impacts of different types of dispersed 

recreation including the outfitter/guide program; hunting; recreational shooting; fire suppression; and 

the lands, minerals, and non-recreation special use programs on the District have been minor. Given 

that anticipated direct and indirect effects to black-footed ferrets and their habitats from any of the 

alternatives is small, cumulative effects of past, present, and reasonably foreseeable future activities is 

also expected to be small. 

Consistency with Laws, Regulations, and Policy 

All alternatives are consistent with the laws, regulations, policy, and Federal, Regional, and State 

direction, the Custer National Forest Land and Resource Management Plan, and the conservation Plan 

for Black-tailed and White-tailed Prairie dogs in Montana (2002). 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-47

Determination of Effects – Black-footed Ferret 

Implementation of the proposed Federal Action May Affect, But Is Not Likely To Adversely Affect The 

Black-Footed Ferret Or Their Habitat. This determination is based on the following rationale: 1) 

black-footed ferrets are not known to occur in the area; 2) the project area does not support an 

adequate preybase to support ferrets; 3) the amount of occupied black-tailed prairie dog habitat 

continues to increase each year; 4) direct habitat loss would not increase under any alternative 

because construction of new routes is not proposed; and 5) none of the alternatives propose increased 

access to black-footed ferret or black-tailed prairie dog habitat. Implementation of the proposed 

Federal Action May Impact Individuals Or Habitat But Is Not Likely To Cause A Trend To Federal 

Listing Or Loss Of Viability For Black-Tailed Prairie Dogs. This determination is based on the above 

rationale for ferrets along with the fact that prairie dogs will continue to be killed by recreational 

shooting until the State imposes an anti-shooting rule. 

No recommendations for removing, avoiding, or compensating adverse effects are necessary. 

3.3.3.3 Affected Environment – Sensitive Species: Bat Species 

Five Forest Service sensitive bat species (Long-eared myotis, long-legged myotis, Pallid bat, Spotted 

bat, and Townsend’s big-eared bat), occur on the District. 

Although different bat species have specific habitat needs, some generalizations can be made. During 

summer, which is the reproductive season, bats may use various roost sites such as rock crevices, 

caves, talus slopes, snags, buildings, and bridges. Hibernacula are located in underground caverns 

with temperatures above freezing. Deep limestone caverns are particularly important for hibernating 

bats in the Rocky Mountains (Adams 2003). Hibernating bats are especially vulnerable to disturbance 

because when aroused from hibernation, they use winter fat needed to support them until insects are 

available in the spring. A single arousal most likely costs a bat as much energy as it would normally 

expend during two to three weeks of hibernation. Thus, frequently aroused hibernating bats may 

starve before spring (Harvey et al. 1999). 

Most bats are very sensitive to disturbance (Schmidt 2003). Human-caused adverse impacts to bats 

include habitat destruction, direct mortality, vandalism, and disturbance of hibernating and maternity 

colonies. Disturbance to hibernacula and maternity colonies is a major factor in the decline of many 

bat species. Human-caused arousal from hibernation costs bats energy that may lead to starvation 

before spring (Harvey et. al. 1999). The body warmth from a person standing 10 feet below a 

hibernating bat may be enough to stimulate the bat’s arousal (Adams 2003). Disturbance to summer 

maternity colonies may cause parents to drop or abandon their dependent young (Harvey et. al. 1999). 

Activities such as rock climbing or caving may take a toll on nursery colonies (Adams 2003). 

Surveys for hibernacula, colonial roosts, and maternity colonies have not been conducted on the 

District. However, potential habitat for hibernacula and colonial roosting is present on the Unit. In 

addition, documentation of post-lactating females suggests that maternity colonies are also likely to be 

present. Potential effects of the alternatives on bats in the project area were analyzed in terms of miles 

of open motorized routes. The reason for using this method is that the presence of motorized routes 

can facilitate access to caves, thus potentially leading to adverse indirect effects by disturbance of bats 

at hibernacula, roosting, and maternity sites. Miles of open motorized routes are displayed in the 

following table. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-48 Ashland Travel Management Final EIS – Chapter 3

Table 3-16. Public Motorized Use Route Miles by Alternative – Ashland RD 

Alternative Motorized Route Miles 

Alternative A 750 

Alternative B 543 

Alternative B Modified 559 

No Action Alternative 676 

On the Ashland District, hibernacula are not expected to be present due to lack of caves. For the same 

reason, colonial roosts and maternity colonies are also not expected to occur. Non-colonial roosting 

and maternity sites are more likely to occur in rock crevices in sandstone, siltstone, and mudstone 

outcrops scattered throughout the District, as well as in tree snags and other habitats. Effects to bats 

in these settings are more likely to be caused by loss of habitat than by human disturbance at any 

particular site. 

3.3.3.4 Environmental Consequences – Sensitive Species: Bat Species 

Direct and Indirect Effects – Bat Species 

The presence and use of roads and trails are not expected to directly affect bats or their habitat. 

However, the presence of motorized routes can facilitate access to bat habitat, particularly to roosting 

or maternity sites, thus leading to adverse indirect effects by disturbance of bats at these sites. 

Alternative A 

Alternative A would have the highest number of open motorized route miles (750) in the project area. 

This alternative would provide the least protection to bat roosting and maternity sites because these 

sites may be more easily accessible than under the other alternatives. Hibernacula are not likely to 

occur on the District so no direct or indirect effects are expected on bats during this period of their life 

cycle when they are most vulnerable. 

Alternative B and Alternative B Modified 

Alternative B and Alternative B Modified would virtually have the same effects on bats. Both 

alternatives would have the lower open motorized route miles, 543 miles and 559 miles respectively. 

Both alternatives provide additional moterized routes that would be seasonally closed from September 

1 thru December 1. Hibernacula are not likely to occur on the District so no direct or indirect effects 

are expected on bats during this period of their life cycle when they are most vulnerable. 

No Action 

This alternative would have 676 miles of open motorized routes and thus would protect bat roosting 

and maternity sites overall more than Alternative A and less than Alternatives B and B Modified. 

Hibernacula are not likely to occur on the District so no direct or indirect effects are expected on bats 

during this period of their life cycle when they are most vulnerable. 

Cumulative Effects - Bat Species 

Several factors have likely contributed to cumulative effects to bats in the project area which include 

past wildfires and timber harvest. Effects of past timber harvest and fires are hard to assess. Most bat 

species tend to avoid large open habitats when possible. However, many species forage along forest 

edges. Heterogeneous habitats containing open, brushy, and forested areas provide optimal foraging 

conditions because of the presence of extensive habitat edge (Adams 2003). Vegetation across the 

District is comprised of about 50% ponderosa pine forest and 50% grassland/shrub so forest edge 

ecotones dominant the landscape. Since 2000 over 30% of the District has been burned in wildfires 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-49

with essentially no commercial harvest of fire killed trees. Timber harvest has occurred on the 

District over the last several decades. The extent that cutting units have regenerated is variable, with 

some naturally regenerated to dense shrub cover, others to seedling and sapling ponderosa pine of 

varying degrees of canopy cover. The combination of vegetative structure and forest edge likely 

provides suitable foraging conditions for bats. 

Current and future cattle grazing can damage sensitive habitats, particularly riparian systems. 

Shoreline damage can lead to erosion that lowers water quality and changes stream flow dynamics. 

Soil damage, particularly along stream and pond shorelines, can suppress vegetation growth and thus 

lower the diversity of insect prey (Adams 2003). Cattle grazing occurs across most of the District and 

will continue in the future. One goal of livestock management on the District is to bring nonfunctioning and functional-at-risk riparian systems up to properly functioning condition. 

Improvement over time of degraded riparian systems would improve foraging and water quality 

conditions for bats and thus reduce adverse cumulative effects. Future coal development may also 

have a potential for negative effects on bats or their habitat in the area. 

Consistency with Laws, Regulations, and Policy 

The National Forest Management Act (36 CFR 219.19) directs federal agencies to manage habitat to 

provide for viable populations of all native and desired non-native fish and wildlife species. The five 

bat species analyzed are native to this area, and are classified as Forest Service sensitive species. 

Sensitive species are those for which population viability is of concern. Direction for management of 

sensitive species is contained in the Forest Service Manual (FSM 2672.1), which states that these 

species must receive special management emphasis to ensure their viability and to preclude trends 

toward endangerment that would result in the need for Federal listing. This analysis considered 

potential for alternative scenarios to have adverse impacts on bats and thus is consistent with the 

above direction. 

Determination of Effects - Bat Species 

Implementation of the proposed Federal Action May Impact Individuals Or Habitat But Is Not Likely 

To Cause A Trend To Federal Listing Or Loss Of Viability For Bat Species. This determination is 

based on the following rationale: 1) hibernacula for the five bat species does not occur in the project 

area; 2) public access to potential roosting and maternity sites is most likely low across the project 

area; 3) the preferred alternative reduces open motorized routes by 324 miles (37% reduction); 4) 

direct habitat loss would not increase under any alternative because construction of new routes is not 

proposed; and 5) none of the alternatives propose increased access to sensitive bat species habitat. 

No recommendations for removing, avoiding, or compensating adverse effects are necessary. 

3.3.3.5 Affected Environment – Management Indicator Species: Big Game Species 

The elk analysis serves as a surrogate for mule deer and white-tailed deer. The rationale for this is 

based on the large amount of overlap in habitat use and needs between deer and elk on the District; the 

amount of scientific literature available for elk and the effects of roads; and impacts of travel 

management on the District are expected to be very similar for these three species. 

Big Game Habitat Use and Travel 

Many studies have shown that motorized access influences elk habitat use (Lyon 1983,, Frederick 

1991, Lyon and Christensen 2002, Rumble et al. 2005, Stubblefield et al. 2006). Elk have repeatedly 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-50 Ashland Travel Management Final EIS – Chapter 3

been shown to avoid habitat adjacent to open roads (Lyon et al. 1985, Millspaugh et al. 2000). 

Declines in habitat use have been reported within 0.25-1.8 miles of open roads (Lyon and Christensen 

2002), but substantial reductions in habitat use are normally confined to <0.5 miles of an open road. 

Many variables influence elk habitat use relative to open roads. 

Observed declines in habitat use adjacent to roads have led to the development of elk habitat 

effectiveness models. Habitat effectiveness refers to the percentage of available habitat that is usable 

by elk outside the hunting season (Lyon and Christensen 1992). The literature contains several 

recommendations for managing open roads within summer elk habitat. Using Lyon’s model for 

habitat effectiveness based entirely on road density (Lyon 1983), Christensen et al. (1993) 

recommended that in areas where elk are one of the primary resource considerations should have 

habitat effectiveness of 50% or greater (open road density <1.9 mi/sq mi). Areas with <50% habitat 

effectiveness (>1.9 mi/sq mi) were expected to make only minimal contributions to elk management 

goals (Christensen et al. 1993) (see the table below for motorized route density). However, the 2005 

Montana Elk Management Plan does not contain objectives or recommendations for management of 

open road density within summer elk habitat. 

Most studies involving the effects of motorized uses on elk involved roads with passenger vehicle use 

rather than motorized trails where ATVs and/or motorcycles are used. Therefore, there is very little 

data available to use in assessing the impacts of motorized trails on elk. Wisdom et al. (2004) 

discussed preliminary findings from a controlled experimental study evaluating the effects of ATVs, 

mountain bikes, hiking, and horseback riding on elk and mule deer. Their initial results indicate that 

elk exhibited much higher rates of movement (or greater displacement) and probability of flight 

response from ATVs and mountain bikes compared to horses and hikers. Canfield et al. (1999) and 

Toweill and Thomas (2002) both state that the effects of open motorized trail use are likely similar to 

those resulting from open roads. The two uses are similar in that both allow easier access to areas that 

would otherwise be inaccessible without considerable effort using non-motorized transportation. 

Therefore, travel route densities incorporating motorized trails cannot be compared to published 

habitat effectiveness models, but they can be used to compare Travel Plan effects among alternatives. 

As with open road density and habitat effectiveness values, the existing literature does not identify a 

clear link between open motorized route densities and elk population demographics. Therefore, 

conclusions on expected travel management planning impacts will only address disturbance and 

displacement of elk (big game) from suitable habitat and not population responses. 

Big Game Vulnerability and Travel 

Studies have been conducted to determine factors influencing elk vulnerability to hunting and 

management solutions to the problem of low mature bull elk numbers. One of the conclusions was 

that motorized access is one of the major factors influencing elk vulnerability, along with hunter 

numbers, availability of security cover, topography, hunting season structure and length, hunting 

equipment technology and others. Data have consistently shown that elk mortality rates increase with 

increasing open road density, because the number of hunters and their distribution both tend to 

increase with increasing road density (Skovlin et al. 2002, Millspaugh et al. 2000). This is especially 

true for bulls because hunting regulations have traditionally allowed greater opportunity for harvesting 

them compared to cows (Vore and Desimone 1991). 

Motorized access is one of the few factors affecting elk vulnerability that the Forest Service has 

management authority for. Hillis et al. (1991) provided guidelines for managing elk habitat to limit 

elk vulnerability. The key concept was to provide security areas for elk during the hunting season 

where they are less vulnerable to harvest. They defined secure areas as >250 acres in size and >0.5 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-51

mile from an open road, and recommended that they comprise >30% of the analysis unit (see the table 

below for elk security by alternative). Although open roads have the largest effect on elk 

vulnerability, restricted roads also have an impact because they provide easier access for hunters using 

non-motorized transportation (Skovlin et al. 2002). Lyon and Burcham (1998) found that elk hunters 

are likely to use closed roads to access areas farthest from open roads. The Hillis guidelines for 

secure areas included a recommendation to minimize closed roads within elk security areas, but did 

not provide standards for accomplishing this (Hillis et al. 1991). The 30% secure habitat level should 

be viewed as the minimum necessary to avoid excessive bull elk mortality during the hunting season, 

realizing that more may be necessary in some districts due to variables such as topography, vegetation 

cover, and hunting pressure. Elk security habitat and open motorized route density by alternative are 

displayed in the following table. 

Table 3-17. Percent Elk Security Habitat and Vulnerability by Alternative. 

Alternative 

A 

Alternative 

B 

Modified 

Alternative B 

No Action 

% Elk Security 28.33 36.25 35.53 24.90 

% Elk security w/ Seasonal Route 

Closures NA 37.69 37.5 NA 

Open Motorized Route Density 

(mi./sq.mi.) 1.09 0.83 0.85 1.00 

Open Motorized Route Density w/ 

Seasonal Route Closure (mi./sq.mi.) NA 0.80 0.82 NA 

The Montana Final Elk Management Plan gives population objectives and general habitat 

management strategies for each Elk Management Unit (EMU) (Montana Fish, Wildlife and Parks 

2005). Habitat objectives stated in the plan for the Custer Forest EMU (the EMU encompassing all of 

the District) are to work cooperatively with private and public land managers to maintain and improve 

existing elk habitat. The Custer Forest EMU is located in Big Horn, Treasure, Rosebud, Custer, 

Fallon, Powder River, and Carter Counties in southeastern Montana. The Custer Forest EMU 

encompasses 14,378 square miles of land where about 45% (6,400 square miles) provides elk habitat. 

About 25% of the EMU falls on public land with the rest falling on private property. Approximately 

12.3% of the suitable elk habitat in the EMU falls within the project area. About 63% of the current 

elk distribution is on private lands. State big game managers estimate that approximately 800 to 1000 

elk are present in the EMU. Elk numbers are currently managed based on the level of landowner 

tolerance to elk depredation on private lands. The State is currently trying to maintain 500 posthunting season elk in the EMU. 

3.3.3.6 Environmental Consequences – Management Indicator Species: Elk 

Direct and Indirect Effects – Big Game Species 

Effects Common to All Alternatives 

All alternatives meet the access management recommendations (see Big Game Habitat Use and Travel 

section above) for elk in the project area. Open motorized route densities would range from 0.83 to 

1.09 mi/sq mi which are below Christensen et al’s.(1993) recommendation to manage roads at <1.9 

mi/sq mi for areas where elk are one of the primary resource considerations. Secure elk habitat in the 

project area (see Big Game Vulnerability and Travel section above) would range from 19% to 23%, 

which is below the 30% minimum recommended by Hillis et al. (1991). Elk habitat within the project 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-52 Ashland Travel Management Final EIS – Chapter 3

area for all alternatives would be categorized as year-round habitat with no distinct areas for seasonal 

use (e.g. winter range).

Since elk analysis is used as a surrogate for mule deer and white-tailed deer, effects described for elk 

would also apply to deer. 

Alternative A 

Alternative A would have the highest open motorized route density (1.09 mi/sq mi) and would 

provide the lowest elk security cover (28%). Recommendations for access management would be met 

for elk under this alternative. Management recommendations for elk vulnerability would not be met 

by this alternative. 

Alternative B and Alternative B Modified 

Alternative B and Alternative B Modified would virtually have the same effects on elk. Both 

alternatives would have the low open motorized route density during most of the year and lower open 

moterized route densities during the hunting season (see previous table). Both alternatives would 

provide high elk security cover during year and higher yet during the hunting season (see previous 

table). Both Alternative B and Alternative B Modified would meet recommendations for access 

management and for elk vulnerability. 

 

No Action 

This alternative would have open motorized route density of 1.0 mi/sq mi and security cover of 25%, 

both similar to Alternative A. Recommendations for access management would be met for elk under 

this alternative. Management recommendations for elk vulnerability would not be met by this 

alternative. 

Cumulative Effects – Big Game Species 

Several past and ongoing habitat enhancement activities on the District have improved habitat for elk. 

These activities include thinning and prescribed burning on elk range to improve forage quality and 

availability, and to increase the acreage of available habitat by reducing conifer species that have 

gradually encroached onto year-round range. The long-term aspen regeneration program benefits elk 

by improving forage and cover. Spraying of invasive plant species reduces competition with native 

plants that provide forage for elk. 

Current and future cattle grazing can damage sensitive habitats, particularly riparian systems. Cattle 

grazing occurs across most of the District and will continue in the future. One goal of livestock 

management on the District is to improve vegetative condition in areas that have been degraded by 

past grazing practices. Improvement in the health of native vegetation may benefit elk in the short and 

long term time frames. 

Housing developments on private land adjacent to the Forest are not an issue, at least for the near 

future, because most private lands are large blocks with few owners. 

Density of motorized non-Forest Service roads within the Forest boundary is 0.15 mi/sq mi. for all of 

the alternatives. Contributions of these roads to adverse cumulative effects within the Forest 

boundary are expected to be minimal. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-53

Consistency with Laws, Regulations, and Policy 

The Custer National Forest Management Plan contains relevant direction for management of big game 

populations. The mitigation measure for key wildlife species, including big game species, relative to 

travel management planning states, “Where necessary to protect wildlife values, access and/or traffic 

will be restricted in key wildlife habitats during critical periods.” In addition, the 2005 Montana Final 

Elk Management Plan provides relevant management direction for elk habitat. This analysis 

considered guidance from the above documents as well as from pertinent literature. 

Determination of Effects – Big Game Species 

Implementation of the proposed Federal Action will have a Neutral Impact On Big Game Species. 

This determination is based on the following rationale: 1) all alternatives meet the access 

management recommendations; 2) the preferred alternative would have the low open motorized route 

density (0.85 mi/sq mi) and would provide a highest level of elk security cover (36%); 3) open road 

densities and elk security would be minimally improved with seasonal road closures; 4) the preferred 

alternative reduces open motorized routes by 324 miles (37% reduction); 5) direct habitat loss would 

not increase under any alternative because construction of new routes is not proposed; and 6) the 

alternatives are consistent with the Montana Statewide Elk Management Plan (2005). 

No recommendations for removing, avoiding, or compensating adverse effects are necessary. 

3.3.3.7 Affected Environment – Migratory Birds 

Regulatory Framework 

Migratory bird species are protected under the Migratory Bird Treaty Act (16 USC 703-711). A 

January, 2001 Executive Order requires agencies to ensure that environmental analyses evaluate the 

effects of federal actions and agency plans on migratory birds, with emphasis on species of concern. 

Species of concern include those listed under the Endangered Species Act, Forest Service Sensitive 

Species, and those identified as species of concern by the Montana Natural Heritage Program and the 

Montana Department of Fish, Wildlife and Parks (MTNHP 2007, MTFWP 2007). This discussion 

addresses potential effects of the Travel Plan alternatives on migratory bird species in general, 

including Forest Service Sensitive Species and Management Indicator Species. 

Affected Environment - Migratory Birds 

The following avian Forest Service Sensitive Species are present on the District: Baird’s sparrow, 

Black-backed woodpecker, and Loggerhead shrike. The following birds are Management Indicator 

Species on the District: Golden eagle, Merlin, Northern goshawk, Bullock’s oriole, Yellow warbler, 

Ovenbird, Spotted Towhee, and Brewer’s sparrow. It is difficult to address effects to migratory bird 

species collectively, since travel management actions can have adverse effects on some species, while 

being neutral or benefiting others. However, it would not be practical to attempt to address all 

migratory bird species separately. Therefore, the migratory bird discussion addresses effects of travel 

management actions on bird species and habitat in general, including that for sensitive and 

management indicator species, and resident species Northern goshawk. 

Migratory bird species are a very diverse group and thus occupy all types of habitat available on the 

District, including ponds, streams, wetlands, riparian areas, grasslands, shrub lands, deciduous forest, 

coniferous forest, mixed forest, recently burned forest, rock outcrops, talus, and sheer cliff walls. 

Many migratory bird species use habitat on the District as breeding grounds, while others breed in 

more northern climes and winter here. Some species are habitat specialists and are relatively 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-54 Ashland Travel Management Final EIS – Chapter 3

restricted to certain cover types such as wetlands, riparian, forest interior or cliff habitat. Others are 

habitat generalists and can occupy a wide variety of cover types. Some bird species are extremely 

sensitive to habitat modifications and human disturbance, particularly in breeding areas, while others 

are much more tolerant of human intrusions, and might actually benefit from habitat modifications 

resulting from human activities. 

 

Habitat Alteration 

Travel management can affect habitat fragmentation by dissecting contiguous vegetation types with 

road and trail corridors. Fragmentation effects have been reported to impact bird species in riparian 

habitat and grass/shrub lands (Joslin and Youmans 1999), but most of the attention to this issue has 

been focused on fragmentation of forest habitat. 

Road and trail corridors through continuous forest habitat can lead to increased nest predation rates 

since smaller forest patches may be easier for predators to penetrate, and roads and trails provide 

travel corridors for predators to access forest interior from nearby open habitat (Joslin and Youmans 

1999, Askins 1994). 

Road and trail corridors are relatively permanent features on the landscape, and can result in forest 

fragmentation by creating permanent openings in the forest canopy. Since road and trail corridors 

remain in the same location for many years, they can become learned features used by multiple 

generations of predatory and/or parasitic species (Askins 1994). 

Rich et al (1994) studied the impacts of forest fragmentation associated with cleared road corridors on 

bird species in southern New Jersey. They found significantly greater relative abundance of forest 

interior bird species in edge habitat along narrow (approximately 8 m or 26 ft wide) unpaved forest 

roads than along wider (16 m or 53 ft wide) paved secondary roads. No significant differences in 

forest interior bird species abundance was found between narrow unpaved Forest road edges and 

forest interior habitat. Based on these findings, they concluded that forest interior nesters did not 

perceive a difference between forest interior habitat and edge habitat along unpaved forest roads. 

However, although most forest interior nesting species did not appear to avoid edge habitat along 

paved or unpaved forest road corridors, there were differential rates of nest predation and brood 

parasitism along varying widths of road corridors, suggesting that some corridors, particularly wider 

corridors with mowed edges, may be creating ecological traps for some migratory species of forest 

interior nesting songbirds. 

Hutto et al. (1995) examined the rate of bird detections between on-road and off-road point counts in 

Montana. The majority of all species detected were found in both on-road and off-road points. 

However, points along roads less than 10 m (33 ft) wide did not show a difference in number of 

species detected from off-road points, whereas point counts along wider roads detected significantly 

more bird species than found in corresponding off-road points. Most species detected in the on-road 

points were those that typically forage in forest openings and shrubby habitat often present along road 

corridors. Those species detected in greater proportions in off-road points were forest interior 

associates. The most notable differences in number of species detected for on-road and off-road 

points occurred in forested cover types, with closed canopy forest showing the greatest difference, 

followed by open forest, and then early succession forest types. 

Corridor width appears to influence bird species composition and associated nest predation and 

parasitism rates along roadways. Studies that specifically addressed the fragmentation impacts of road 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-55

corridors on bird species (Rich et al. 1994, Askins 1994 and Hutto et al. 1995) generally reported that 

narrow (8-10 m, 26-33 ft) road corridors had few notable impacts on nesting bird species, whereas 

wider corridors, particularly where shoulders were maintained with mowing, had more notable effects 

associated with nest predation and brood parasitism. Roadside vegetation on the Forest is periodically 

managed through brush removal, but only the high use roads receive treatment, and only when the 

need arises (i.e., there is no set schedule for brush removal). Unpaved Forest road edges are rarely 

ever mowed, and therefore do not typically provide the type of grassy roadside vegetation preferred by 

cowbirds and some edge-associated nest predators. 

Disturbance 

The presence of travel facilities on the landscape generally affects bird species through habitat 

modification and associated impacts discussed above. The presence of humans using travel facilities 

typically affects birds through disturbance mechanisms. Knight and Gutzwiller (1995) stated: 

“human occupation and activity are clearly and directly correlated with declines in breeding 

populations of birds.” Human disturbance associated with travel management can elicit both 

physiological and behavioral responses from birds, which can affect reproductive success and 

survival. 

Forman et al. (2003) reported that breeding birds seem to be affected by noise disturbance associated 

with traffic on roads and trails. Songbirds appear to be sensitive to very low noise levels. The noise 

level that population densities of woodland birds declined at averaged 42 decibels (dB), with a density 

decline occurring at 35 dB for the most sensitive woodland species. For grassland species, population 

densities declined when noise levels reached an average of 48 dB, with a decline occurring at 43 dB 

for the most sensitive species (Foreman and Alexander 1998). While most studies have shown 

grassland and forest birds to appear adversely affected by traffic noise, other studies have found most 

species to be neutral or to increase in numbers (Kaseloo and Tyson 2004). 

Although noise associated with human travel is certainly a disturbance factor that can influence bird 

behavior, birds are able to adapt and habituate more quickly to mechanical (or motorized) noise than 

to human presence (Knight and Gutzwiller 1995). Therefore, non-motorized use on and off trails may 

be a more severe disturbance factor for some birds than motorized travel restricted to designated 

routes. 

3.3.3.8 Environmental Consequences – Migratory Birds 

Direct and Indirect Effects 

 

Effects Common to All Alternatives 

Most of the habitat alteration (e.g. modification, loss and fragmentation) associated with District travel 

management has already occurred. The consequences of past habitat change are likely beneficial for 

some bird species and detrimental to others. 

Alternative A 

Of the three Alternatives considered, Alternative A represents a maximum for both habitat alteration 

effects and disturbance impacts to migratory bird species. At a route density of 1.09 mi/sq mi, 

Alternative A would contain an overall higher motorized travel route density as well as total 

motorized route miles on the District. Adverse effects would be greatest on bird species susceptible to 

changes in habitat and to human disturbance. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-56 Ashland Travel Management Final EIS – Chapter 3

Alternative B, Alternative B Modified, and No Action 

Average motorized route density across the District would range from 0.83 to 1.00 mi/sq mi for 

Alternatives B, B Modified, and No Action. The total number of motorized route miles would be 

similar for these two alternatives. Adverse affects to susceptible bird species would therefore be 

essentially the same, but slightly less than under Alternative A. 

Cumulative Effects – Migratory Birds 

It is difficult to address cumulative effects to migratory bird species collectively since various 

management actions can have adverse effects on some species, while having no effect or benefiting 

others. It would not be practical to attempt to address all species individually. Therefore, this section 

summarizes cumulative effects of land uses to bird species in general, focusing on activities 

considered to have the greatest impacts on birds. 

Timber harvest and fuel reduction projects on the District have involved removal of understory 

vegetation such as shrubs, young conifers and lower tree branches, as well as removal of mature trees. 

Such manipulation of habitat components can influence survival and reproductive rates of migratory 

bird species by altering cover, forage and predator/prey relationships. Changing habitat structure 

through fuel reduction projects could ultimately influence bird species composition in treated areas 

(USDA Forest Service. 2006.) 

 

Large-scale wildfires and human-caused fires have altered bird habitat. Most bird species native to 

this area are adapted to our fire dependent ecosystem. Large-scale high intensity burns are largely 

responsible for maintaining natural forest succession patterns and providing habitat diversity. 

Lightning-caused fires typically occur mid to late summer when most young birds are fledged and are 

capable of rapid and prolonged flight to escape wild fire. Human-caused fire can occur any time of 

year, and prescribed fires on the District are often planned for spring-time ignition in order to use high 

fuel moisture levels, standing water and/or snow to help contain fire within prescribed burn units. 

Spring burns occur during the nesting season when birds are vulnerable, and could result in 

reproductive failure for some individuals. 

Fire suppression has increased the proportion of mature forest on the landscape, potentially to the 

detriment of some grass and shrub nesting bird species. Natural fire regimes are responsible for 

maintaining forest succession patterns and providing habitat diversity. However, past fire suppression 

efforts have resulted in unnatural levels of fuel buildup, which is now having the effect of producing 

proportionately more catastrophic wild fires, and consequently having severe impacts on native 

habitat. 

Livestock grazing can affect migratory birds in a number of ways, such as destruction or disturbance 

of ground and shrub nests, removal of ground cover, and attraction of cowbirds. Grazing on the 

District has lead to degradation of bird habitat in some areas, particularly in certain riparian habitats. 

However, improved grazing standards are helping reduce negative effects. 

Construction, maintenance, and use of campgrounds, picnic areas, and other developed recreation sites 

have altered the vegetation at those sites. Reduction in vegetation, particularly riparian shrubs, has 

likely reduced key nesting habitat for some bird species. Dispersed recreation sites have likely 

resulted in similar impacts as developed campgrounds. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-57

Projected effects of reasonably foreseeable programs and activities have potential for both positive 

and negative cumulative effects to migratory birds and their habitat. Unmanaged recreation, invasive 

species, unnatural fuel buildup, and loss of open space are four major ecological threats recognized by 

public land management entities. Generally speaking, traditional land management practices are 

trending toward more ecologically sensitive programs. Accordingly, management practices are being 

redesigned to have less negative impacts on the land, while still allowing for the maximum spectrum 

of land uses within the capability of resources. On the other hand, private development is occurring 

adjacent to the Forest boundary, resulting in permanent habitat loss and greater potential for direct 

mortality than most actions predicted to occur on public land (USDA Forest Service. 2006). 

Consistency with Laws, Regulations, and Policy 

Management of migratory bird species and their habitats are governed by a wide variety of authorities. 

Most direction regarding conservation of these species falls under the umbrella of the Migratory Bird 

Treaty Act (16 USC 703-712) and an associated Presidential Executive Order. Under this Act, which 

implements various treaties and conventions for the protection of migratory birds, it is unlawful to 

take, kill or possess any migratory birds, except as regulated by authorized hunting programs. 

Executive Order 13186 directs Federal agencies whose actions have a measurable negative impact on 

migratory bird populations to incorporate migratory bird conservation into planning processes and 

take reasonable steps that include restoring and enhancing habitat. The proposed District Travel 

direction has taken migratory bird conservation issues into account through effects analyses, and thus 

is consistent with the above direction. 

 

Determination of Effects – Migratory Birds 

Implementation of the proposed Federal Action will have a Neutral Impact On Migratory Bird 

Species. This determination is based on the following rationale: 1) the preferred alternative would 

have the low open motorized route density (0.85 mi/sq mi); 2) the preferred alternative reduces open 

motorized routes by 324 miles (37% reduction); and 3) direct habitat loss would not increase under 

any alternative because construction of new routes is not proposed. 

No recommendations for removing, avoiding, or compensating adverse effects are necessary. 

3.3.3.9 Affected Environment – General Wildlife 

Focal species are species used as surrogates in assessing ecological integrity (FR Vol 65 No 218, 

November 2000). The distribution and abundance of focal species can indicate the integrity of the 

larger ecosystems that they belong to. They also can “play key roles in maintaining community 

structure and processes” (Gaines et al, 2003) and thus can be indicators of species diversity. Focal 

species associated with each wildlife group (as selected by Gaines et al 2003) that are relevant to this 

analysis are shown in the following table. 

Table 3-18. Focal Wildlife Species 

Wildlife Group Focal Species 

Wide-ranging carnivore Mountain lion 

Ungulates Mule deer, elk 

Late-successional-forest associated species Northern goshawk, brown creeper, white-breasted nuthatch 

Riparian-associated species Bald eagle, black-capped chickadee 

Primary cavity nesters Three-toed woodpecker 

Grassland/Shrub-Steppe-associated species Greater short-horned lizard, Milk Snake, Western hog-nosed snake 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-58 Ashland Travel Management Final EIS – Chapter 3

Gaines et al (2003) conducted a literature review to document the effects of roads, motorized trails, 

non-motorized trails, and other linear recreation routes on focal wildlife species. The most common 

interaction identified in the literature relative to motorized roads and trails was displacement and 

avoidance, where animals altered their use of habitats in response to the motorized routes. 

Disturbance at a specific site was also commonly identified and was usually associated with wildlife 

nesting, breeding, or rearing of young. Other frequently reported interactions associated with roads or 

road networks included collisions between animals and vehicles, and edge effects. 

The interactions associated with non-motorized trails were similar to that of motorized trails and 

include displacement, avoidance, and disturbance at a specific site during a critical period. The 

interaction varied depending upon wildlife species, with some more sensitive to motorized trail use 

and others more sensitive to non-motorized trail use. Although both forms of recreation have effects 

on wildlife, motorized trails showed a greater magnitude of effects, such as longer wildlifedisplacement distances, for a larger number of focal species (Gaines et al. 2003). The following table 

details documented effects of roads and trails on wildlife habitat or populations. 

Table 3-19. Documented Effects Associated with Roads and Trails 

Road- and trail-associated factors Effects of factors Wildlife group affected 

Hunting & trapping Mortality from hunting or trapping as facilitated by 

road and trail access 

Wide-ranging carnivores 

Ungulates 

Poaching Increased illegal take of animals as facilitated by 

trails and roads 

Wide-ranging carnivores 

Ungulates 

Collisions Death or injury resulting from a motorized vehicle 

running over or hitting an animal 

Wide-ranging carnivores 

Late successional 

Riparian associated 

Ungulates 

Negative human interactions Increased mortality of animals owing to increased 

contact with humans, as facilitated by road and trail 

access 

Wide-ranging carnivores 

Late successional 

Ungulates 

Movement barrier or filter Alteration of dispersal or other movements as posed 

by a road or trail itself or by human activities on or 

near a road or trail or network 

Wide-ranging carnivores 

Late successional 

Riparian associated 

Ungulates 

Displacement or avoidance Spatial shifts in populations or individual animals 

from a road or trail or network in relation to human 

activities on or near a road or trail or network. 

Wide-ranging carnivores 

Late successional 

Riparian associated 

Ungulates 

Habitat loss and fragmentation Loss and resulting fragmentation of habitat owing to 

the establishment of roads and trails, road and trail 

networks, and associated human activities 

Wide-ranging carnivores 

Late successional 

Riparian associated 

Ungulates 

Edge effects Changes to habitat microclimates associated with the 

edge induced by roads or trails 

Late successional 

Snag or downed log reduction Reduction in density of large snags and downed logs 

owing to their removal near roads or campsites, as 

facilitated by road access 

Late successional 

Riparian associated 

Primary cavity 

excavators 

Route for competitors or predators A physical human-induced change in the 

environment that provides access for competitors or 

predators that would not have existed otherwise 

Wide-ranging carnivores 

Late successional 

Riparian associated 

Primary cavity 

excavators 

Disturbance at a specific site Displacement of individual animals from a specific 

location that is being used for reproduction and 

Wide-ranging carnivores 

Late successional 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-59

Table 3-19. Documented Effects Associated with Roads and Trails 

Road- and trail-associated factors Effects of factors Wildlife group affected 

rearing young Riparian associated 

Ungulates 

Physiological response Changes in heart rate or level of stress hormones as a 

result of proximity to a road or trail 

Ungulates 

Late successional 

For this analysis, road and trail factors will be grouped and discussed under the topics of Mortality 

and Habitat Modification/Changes to Behavior. 

 

Mortality 

Large numbers of animals are killed annually on roads. The rate of mortality is directly related to 

vehicle speed (Lyon 1985), although road width and traffic volume also affect roadkill rates (Forman 

and Alexander 1998). Since forest roads are not designed for high-speed traffic, direct mortality on 

forest roads is usually not important relative to large mammals (Lyon 1985). Forest carnivores are an 

exception because their large home ranges make them especially vulnerable to road mortality (Baker 

and Knight 2000). Amphibians and reptiles are particularly susceptible on two-lane roads with low to 

moderate traffic (Forman and Alexander 1998). 

A study that analyzed over 100 bird and mammal species in England concluded that roadkill rates may 

not affect population size on a national scale (Forman and Alexander 1998). However, rates of 

roadkill mortality can be high enough to reduce population densities at the local level (Forman et al. 

2003). 

The presence of roads can lead indirectly, as well as directly, to wildlife mortality. Roads provide 

human access that can result in hunting, trapping, and poaching. The numbers of miles of designated 

motorized routes on the District are as follows: 

Table 3-20. Public Motorized Use Route Miles by Alternative – Ashland RD 

Alternative Motorized Route Miles 

Alternative A 750 

Alternative B 543 

Alternative B Modified 559 

No Action Alternative 676 

Since small, slow-moving animals are susceptible to mortality even on narrow roads, motorized trails 

were included in the above road mileages. 

Habitat Modification/Changes to Behavior 

Animals may respond either positively or negatively to the presence of a road. Response can occur 

through the mechanisms of shifts in home range, altered movement patterns, altered reproductive 

success, altered escape response, and altered physiological state (Trombulak and Frissell 1999). 

Trombulak and Frissell reference numerous studies that document behavioral changes due to roads. 

Both black bears and grizzly bears shifted their home ranges away from areas with high road densities 

(Brody and Pelton 1989, McLellan and Shackleton 1988). Elk in Montana preferred spring feeding at 

sites away from visible roads (Grover and Thompson 1986). Mountain lion home ranges are in areas 

with lower densities of improved dirt roads (Van Dyke, et al. 1986). In contrast, turkey vultures 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-60 Ashland Travel Management Final EIS – Chapter 3

preferentially establish home ranges in areas with greater road densities (Coleman and Frasier 1989), 

probably because of increased carrion resulting from roadkill. 

Roads may also act as barriers to movement, particularly for small mammals and wetland species such 

as amphibians and turtles. Road width and traffic density are major factors contributing to barrier 

effect, whereas road surface is generally a minor factor. Some large mammals, such as wolverine, 

appear to not be affected by the presence of roads as far as home range size and shape is concerned 

(Forman and Alexander 1998). Others including pronghorn antelope (Bruns 1977) and mountain 

lions (Van Dyke et al 1986) seem reluctant to cross roads. 

Knight and Cole (1995a) presented specific effects of recreational activities typically associated with 

roads and trails on wildlife. Backpacking, hiking, and horseback riding elicited flight and/or elevated 

heart rates, and displacement. Motorized vehicles including motorcycles, ATVs, quadricycles, dune 

buggies, amphibious vehicles, and air-cushion vehicles potentially cause disturbance (flight and/or 

stress) and redistribution. 

Noise is one of the major factors in wildlife displacement and habitat loss. Noise can be defined as 

any “human-made sound that alters the behavior of animals or interferes with their normal 

functioning” (Bowles 1995). Some sounds are either higher or lower than what humans and some 

terrestrial animals can hear. Characteristics such as a species hearing ability, ability to escape sound, 

habituation to noise, and other factors need to be considered when assessing effects of noise on 

wildlife (Finegold, et al 2004). Kaseloo and Tyson (2004) discuss numerous studies of effects of 

noise on specific species and species groups. Review of the results indicates that apparent affects of 

specific noise levels is quite variable between on species. 

Decibel levels (dB) of some vehicles commonly used on the National Forest include: 1) automobile 

from a distance of 25 feet – 80 dB (Truax 1999); 2) diesel truck from 50 feet – 84 dB (Federal 

Interagency Committee on Noise 1992); 3) motorcycle - 88 to 100 dB (Galen Carol 2007, Truax 

1999); and 4) truck without muffler – 90 dB (Earthlink 2008) Decibel levels for other vehicles 

pertinent to the Ashland Travel Management, including ATV’s, were not found. 

A number of studies have shown that wild ungulates and carnivores increase movement in response to 

aircraft, snowmobiles, construction noise, road traffic, and walking visitors. Large mammals alter 

habitat use for 1-2 days after being disturbed by noise. Large mammals are able to adapt to 

predictable disturbance by avoiding an area during this time period. Mammals will habituate to noises 

without negative consequences, but do not habituate to being hunted, which actually amplifies their 

responses. Mammals can track noise and respond to noise that is approaching directly rather than to 

noise approaching them tangentially. Mammals may also abandon newborn young in response to 

noise. Startled carnivores may kill and eat their own young. Short-term aversive responses in 

mammals vary from mild reactions such as becoming alert to more severe activity such as running 

away while urinating or defecating (Bowles 1995). 

In general, with repeated exposures to either motorized or non-motorized activity, animals habituate 

or adapt both physiologically and behaviorally. Unfamiliar noise is more likely to arouse an animal 

than a harmless, familiar noise. Animals may have one of three responses to noise: attraction, 

tolerance or aversion. Mild responses may be difficult to detect. If mammals are repeatedly exposed 

to the same noise stimulus without negative associations, responses decline rapidly. Vertebrates can 

track the direction of movement and typically respond more strongly to direct approaches than to 

tangential passes (Knight and Gutzweiler 1995). 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-61

Some species do respond positively to the presence of roads and trails. Routes may increase habitat 

for some species that prefer edges. New microhabits may be created along roads, such as at bridges 

that bats may use for roosting. Habitat enhancements may occur along roads, such as perches for 

raptors, increased forage from planted species, and carrion from road kills (Forman et al 2003). 

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). This is considered the “virtual footprint” (Forman et al. 

2003) of the route on the land. This is an average, but the true impacts of routes vary significantly 

with terrain, vegetation, amount and types of use on the route, species-specific behavior, and other 

factors. Only Forest Service motorized routes on the Ashland Ranger District were analyzed. The 

percent of the Ashland Ranger District untouched by the two kilometer corridor along motorized 

routes is referred to as “core”. The results are shown in the following table. The percent of the 

District outside the two kilometer footprint is the area where wildlife generally is undisturbed by 

travel routes and the activities that accompany them. Research has been conducted on the specific 

response of some wildlife species to motorized routes. Refer to other analyses for species such as 

black-footed ferrets and elk. These analyses are tailored to the species, with reviews of speciesspecific research, while the analysis presented here is very general. 

Table 3-21. Percent of Ashland Ranger District That is Core for Habitat Wildlife

Alternative A Alternative B Alternative B 

Modified 

No Action 

22% 28% 28% 18% 

In general, effects of motorized roads and trails on most wildlife species are negative (Boyle and 

Samson 1985). The effects may vary by wildlife species and by individual. Effects also vary by the 

type of activity occurring on the road or trail. Seasonal closures of routes may offer some benefit to 

wildlife. Some routes were selected for seasonal closures during important times of year for a 

particular species, particularly big game. If motorized routes are closed when and where these 

activities occur, animals can function with less energy expenditure and more efficiency. 

3.3.3.10 Environmental Consequences – General Wildlife 

Direct and Indirect Effects 

Effects Common to All Alternatives 

Mortality: Approximately 78 miles of higher speed unpaved roads (maintenance level 3) are on the 

District. These roads are rated for passenger vehicles with speeds up to 35 miles per hour. No 

changes are proposed for higher speed unpaved roads. The potential for animal mortality caused by 

collision with vehicles on maintenance level three roads would be the same under all alternatives. 

Habitat Modification /Changes to Behavior: Ruediger (1996) estimates that displacement of some 

species, or indirect habitat loss due to roads, may average 1 km on each side of a highway in a 

forested area and up to 3 km on each side in open habitats. For the affected area for general wildlife, 

we assumed a 1 km buffer on each side of both motorized and non-motorized routes, recognizing that 

this is probably an overestimate of some effects and an underestimate of others in all alternatives. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-62 Ashland Travel Management Final EIS – Chapter 3

The percent of the project area available as core habitat would be progressively increase from the No 

Action Alternative to Alternative B Modified (see previous table). Core habitat is the same for 

Alternative B and Alternative B Modified. 

Alternative A 

Mortality: This alternative has the highest number of open motorized route miles and thus the 

greatest potential for mortality, particularly of small, slow moving animals such as reptiles. 

Habitat Modification /Changes to Behavior: The potential for habitat modification and changes to 

behavior would mostly likely be the highest for this alternative since 750 miles of public motorized 

routes are available. 

Alternative B 

Mortality: With the lowest open motorized route miles (543), this alternative has the lowest potential 

for leading to wildlife mortality and supports the highest percentage of core habitat. 

Habitat Modification /Changes to Behavior: The potential for habitat modification and changes to 

behavior would mostly likely be the lowest for this alternative since it provides the lowest amount, 

750 miles, of public motorized routes. 

 

Alternative B Modified 

Mortality: With the second lowest open motorized route miles (559), this alternative has a low 

potential for leading to wildlife mortality and supports the same percentage of core habitat as 

Alternative B. 

Habitat Modification /Changes to Behavior: The potential for habitat modification and changes to 

behavior would mostly likely be low for this alternative since it provides only 559 miles of public 

motorized routes. 

No Action 

Mortality: The open motorized route miles, and thus the potential for mortality, would be less than 

Alternative A but higher than Alternative B. This alternative provides the lowest amount of Core 

Habitat.

Habitat Modification/Changes to Behavior: The potential for habitat modification and changes to 

behavior would mostly likely be the second highest for this alternative since 676 miles of public 

motorized routes are available. 

Cumulative Effects – General Wildlife 

Mortality: Most of the mortality that occurs to wildlife species occurs on high speed, paved routes 

such as highways. Mortality on these types of roads can be significant for some species at some times 

of year. This is a cumulative effect that adds to effects on National Forest System routes. 

Habitat Modification /Changes to Behavior: The analysis of indirect habitat loss or displacement was 

presented for public Forest Service motorized routes on the Ashland Ranger District only. There is 

also a cumulative effect of private, county, state and federal roads on the National Forest or adjacent 

lands that were not considered in this analysis. The impacts to wildlife on private land and 

displacement of wildlife from private land are a cumulative effect that is likely to continue to increase. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-63

There are cumulative effects of the human activity associated with the use of roads and trails. There 

are also effects of the activities that humans do when they use roads and trails, including hunting, 

fishing, trapping, firewood cutting, viewing wildlife, etc. All of these activities can potentially disturb 

wildlife, and some can cause direct mortality (Knight and Cole 1995). Hiking, biking, fishing, ATV 

use, horseback riding, dispersed camping, and other recreational activities are projected to increase 

sizably over the next ten to twenty years. This will gradually add to cumulative impacts over time. 

Dispersed recreation has increased on the Forest, and the appreciation for nonconsumptive uses of 

wildlife has also increased. Increased human use of the Forest displaces wildlife and can degrade 

habitat. Recreational residence sites remove wildlife habitat and may displace wildlife in those areas. 

Outfitter/guides offer non-consumptive wildlife activities as well as take many hunters into the Forest. 

Outfitter/guiding is regulated, and probably is less impactive to wildlife than non-outfitted activities 

(USDA Forest Service 2006). Conservation easements on private lands outside the Forest protect 

habitat and are beneficial to wildlife. 

The presence of hiking and riding areas has led to the availability of habitat that is non-motorized and 

where wildlife is relatively undisturbed by large numbers of people. 

Livestock grazing will continue on the District. Improved range management practices and 

monitoring of range condition are expected to improve wildlife habitat. Control of noxious weeds is 

important for maintaining high quality wildlife habitat and will continue in the future. Efforts to 

restore native vegetation to the landscape or enhance species that are declining are beneficial to 

wildlife. 

Future improvements of FS roads and motorized routes may increase the impact of these facilities to 

wildlife by encouraging greater use. Other routes would be closed to public use, which would benefit 

wildlife in general. 

An increase in dispersed recreation in which many of the dispersed users are interested in wildlife may 

actually be somewhat detrimental to the resource they wish to see, photograph, or hunt. Additional 

education of the public on their wildlife resource is important so that wildlife habitat is protected as 

are the animals that use it. Increasing public use will decrease the ability of wildlife to fully occupy 

available habitat, and some species are more likely to be affected than others. 

Consistency with Laws, Regulations, and Policy 

The wildlife goal in the Custer National Forest Management Plan is to “manage and/or improve key 

wildlife and fisheries habitats, to enhance habitat quality and diversity, and to provide wildlife and 

fish-oriented recreation opportunities.” Forest Service Manual 2672.4 requires review of “all Forest 

Service planned, funded, executed, or permitted programs and activities for possible effects on 

endangered, threatened, proposed, or sensitive species.” All alternatives are consistent with the Custer 

National Forest Management Plan and Forest Service Manual direction. 

Determination of Effects – General Wildlife 

Implementation of the proposed Federal Action will have a Neutral Impact On General Wildlife 

Species And May Impact Individuals Or Habitat But Is Not Likely To Cause A Trend To Federal 

Listing Or Loss Of Viability For Reptile Species. This determination is based on the following 

rationale: 1) the preferred alternative would have the second lowest number of open motorized routes 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-64 Ashland Travel Management Final EIS – Chapter 3

(559); 2) the preferred alternative reduces open motorized routes by 324 miles (37% reduction); 3) 

direct habitat loss would not increase under any alternative because construction of new routes is not 

proposed; 4) the preferred alternative supports the highest percentage of core habitat; and 5) even with 

the proposed travel plan modifications some wildlife mortality will continue to occur across the 

District’s road system. 

No recommendations for removing, avoiding, or compensating adverse effects are necessary. 

3.3.3.11 Conclusion - Wildlife 

Wildlife effects analysis was conducted based on regulatory framework for threatened, endangered, 

sensitive, management indicator, and other species of concern. Conservation strategy standards and 

guidelines and literature-based recommended guidelines were also considered. Analysis for blackfooted ferret was based on motorized route density and potential effects on black-tailed prairie dog 

colonies. Analysis for elk was based on both motorized route density and secure habitat. Relative 

comparisons of available habitat and/or motorized route density were also conducted between 

alternatives for species and groups lacking conservation strategies, standards, or guidelines. The 

following table outlines effects determinations for wildlife species. 

Table 3-22. Wildlife Effects Determinations F

11

Species Name Alternative A Alternative B Alternative B 

Modified No Action 

Threatened, Endangered, and Proposed Species 

Black-footed Ferret 

(Mustela nigripes) 

(Endangered) 

NLAA NLAA NLAA NLAA

Forest Service Sensitive Species 

American peregrine falcon 

(Falco peregrinus anatum) NI NI NI NI 

Baird’s sparrow (Ammodramus 

bairdii) NI NI NI NI

Bald Eagle (Haliaeetus 

leucocephalus) 12 NI NI NI NI

Black-backed woodpecker 

(Picoides arcticus) NI NI NI NI

Blue-gray gnatcatcher 

(Polioptila) NI NI NI NI

Burrowing owl (Athene 

cunicularia) NI NI NI NI

Greater sage grouse 

(Centrocercus urophasianus) NI NI NI NI

Grizzly Bear (Ursus arctos) F

13 NI NI NI NI

 

11 Options for effects determinations are: For federally listed species: NE = No effect; NLAA = May effect – not likely to adverse 

affect; LAA = May effect – likely to adversely affect; and BE = Beneficial effect. For Forest Service sensitive species: NI = No impact; 

MIIH = May impact individuals but is not likely to cause a trend to Federal listing or loss of viability; WIFV = Likely to result in a trend 

to Federal listing or loss of viability; and BI = Beneficial impact. For management indicator species: + = Positive effect; 0 = Neutral 

effect; and - = Negative effect. For other species of concern: NE = No effect. 12 Bald eagle delisted effective August 8, 2007 and subsequently managed as a Forest Service Sensitive Species. 13 Grizzly bear delisted effective April 30, 2007 and subsequently managed as a Forest Service Sensitive Species as directed in “Final 

Conservation Strategy for the Grizzly Bear in the Yellowstone Ecosystem, Interagency Grizzly Bear Study Team, March 2003.” 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-65

Table 3-22. Wildlife Effects Determinations F

11

Species Name Alternative A Alternative B Alternative B 

Modified No Action 

Harlequin duck 

(Histrionicus histrionicus) NI NI NI NI

Loggerhead Shrike 

(Lanius ludovicianus) NI NI NI NI

Long-billed curlew 

(Numenius americanus) NI NI NI NI

Long-eared myotis (Myotis 

evotis) 

MIIH MIIH MIIH MIIH

Long-legged myotis (myotis 

volans) 

MIIH MIIH MIIH MIIH

Pallid bat (Antrozous pallidus) MIIH MIIH MIIH MIIH

Spotted bat 

(Euderma maculatum) 

MIIH MIIH MIIH MIIH

Townsend’s big-eared bat 

(Corynorhinus townsendii) 

MIIH MIIH MIIH MIIH

Black-tailed prairie dog 

(Cynomys ludovicianus) 

MIIH MIIH MIIH MIIH

White-tailed prairie dog 

(Cynomys leucurus) NI NI NI NI

Wolverine (Gulo gulo) NI NI NI NI

Greater short-horned lizard 

(Phrynosoma hernandesi) 

MIIH MIIH MIIH MIIH

Milk Snake (Lampropeltis 

triangulum) 

MIIH MIIH MIIH MIIH

Western hog-nosed snake 

(Heterodon nasicus) 

MIIH MIIH MIIH MIIH

Management Indicator Species F

14

Northern Goshawk (Accipiter 

gentilis) (H) 0 0 0 0

White-tailed deer (Odocoileus 

virginianus) (H, K) 0 0 0 0

Ruffed grouse (Bonasa 

umbellus) (H) 0 0 0 0

Western kingbird (Tyrannus 

verticalis) (H) 0 0 0 0

Bullock’s (Northern) oriole 

(Icterus bullockii) (H) 0 0 0 0

Yellow warbler (Dendroica 

petechia) (H) 0 0 0 0

Oven bird (Seiurus 

aurocapillus) (H) 0 0 0 0

Spotted (Rufous-sided) towhee 

(Pipilo maculatus) (H) 0 0 0 0

Brewer’s sparrow (Spizella 

Breweri) (H) 0 0 0 0

Sharp-tailed grouse 0 0 0 0

 

14 H = Habitat Indicator Species; K = Key Species 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-66 Ashland Travel Management Final EIS – Chapter 3

Table 3-22. Wildlife Effects Determinations F

11

Species Name Alternative A Alternative B Alternative B 

Modified No Action 

(Tympanuchus phasianellus)

(H, K) 

Elk (Cervus canadensis) (K) 0 0 0 0

Golden eagle (Aquila 

chrysaetos) (K) 0 0 0 0

Merlin (Falco columbarius) (K) 0 0 0 0

Mule deer (Odocoileus 

hemionus) (K) 0 0 0 0

Bighorn sheep (Ovis 

Canadensis) (K) 0 0 0 0

Pronghorn antelope 

(Antilocapra Americana) (K) 0 0 0 0

3.4 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES – OTHER ISSUES 

3.4.1 WATER QUALITY, FISHERIES, AND AQUATICS 

Overview of Changes from the Draft to the Final EIS 

 Changes involved additional narrative to clarify analysis results and address comments 

received on the DEIS. 

 Changes were also made in a few watershed risk categories and action risk categories. Two 

low risk watersheds were changed to moderate; South Fork Grand River- Sand Creek and 

Snow Creek. The action risk category for season of use changed from an action that decreases 

risk to an action that does not change risk. The action risk category for addition of non-system 

roads for public and administrative use changed and is now relative to whether this action is 

compared to the existing condition or the no-action condition. See Table 3-25 and discussion 

under the section Relative Route Risks by Action. 

Introduction 

This section outlines affected environment and environmental effects of travel management to water 

resources. This section also addresses the impacts of motorized uses on Forest Service Region 1 

sensitive fish and amphibian species, management indicator aquatic species, and aquatic habitat. 

Changes between DEIS and FEIS: Most of the changes involved additional narrative to clarify 

analysis results and address comments received on the DEIS. Changes were also made in a few action 

risk categories. The action risk categories for addition of non-system roads for public and 

administrative use changed and are now relative to whether this action is compared to the existing 

condition or the no-action condition. See Table 3-25 and discussion under the section Relative Route 

Risks by Action. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-67

3.4.1.1 Affected Environment – Water Quality 

Applicable Laws, Regulations, and Policy 

Federal Clean Water Act requires Federal Agencies to comply with all federal, state, and local 

requirements, administrative authority, process and sanctions related to the control and abatement of 

water pollution (CWA, Sections 313(a) and 319(k)). The Act gives authority to individual States to 

develop, review, and enforce water quality standards under Section 303. This section also requires the 

States to identify existing water bodies that do not meet water quality standards, and develop plans to 

meet them. These plans are commonly called TMDLs, an acronym for total maximum daily load. 

Federal Multiple Use Sustained Yield Act of 1960 sets policy to define why the national forests were 

established and how they should be administered relative to outdoor recreation, range, timber, 

watershed, and wildlife and fish purposes. [T]hat some land will be used for less than all of the 

resources; and harmonious and coordinated management of the various resources, each with the other, 

without impairment of the productivity of the land, with consideration being given to the relative 

values of the various resources, and not necessarily the combination of uses that will give the greatest 

dollar return or the greatest unit output (16 USC 2 (I); Sec 528). 

The Montana Department of Environmental Quality (MTDEQ) has classified all waters within the 

Montana portion of the analysis area as C-3 waters. The beneficial uses associated with this 

classification include; bathing, swimming, and recreation; growth and propagation of non-salmonid 

fishes and associated aquatic life, waterfowl, and furbearers. The quality of these waters is naturally 

marginal for drinking, culinary and food processing purposes, agricultural and industrial water supply. 

Degradation which will impact established beneficial uses will not be allowed. (Administrative Rules 

of Montana (ARM) 17.30.611 2008). 

The Montana Surface Water Quality Standards require that land management activities must not 

generate pollutants in excess of those that are naturally occurring, regardless of the stream’s 

classification. Under ARM 17.30.623 (2) (f) “No increases are allowed above naturally occurring 

concentrations of sediment, settleable solids, oils, or floating solids, which will or are likely to create a 

nuisance or render the waters harmful, detrimental, or injurious to public health, recreation, safety, 

welfare, livestock, wild animals, birds, fish, or other wildlife.” Naturally occurring is defined in ARM 

17.30.602 (19) as: “the water quality condition resulting from runoff or percolation, over which man 

has no control, or from developed lands where all reasonable land, soil and water conservation 

practices have been applied”. Reasonable land, soil and water conservation practices are similar to 

Best Management Practices (BMPs). BMPs are considered reasonable only if beneficial uses are fully 

supported. BMPs are further discussed under the section Soil and Water Conservation Practices. 

Riparian and stream conditions are assessed by MTDEQ to determine the level of beneficial uses 

support. Streams that do not fully support their uses do not fully meet water quality standards. The 

status of water quality assessment and Total Maximum Daily Load (TMDL) development of streams 

are identified in a biennial report from MTDEQ (2006). The 2006 Montana 305(b)/303(d) Water 

Quality Assessment Database lists one stream adjacent to the analysis area where one or more uses are 

impaired and a TMDL is required (Category 5). Refer to the Table 3-24 for more detail on TMDL 

streams. 

The State of Montana has the authority to develop TMDLs. On streams with multiple ownerships, the 

Forest Service cooperates with the State and other adjacent landowners in the development process. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-68 Ashland Travel Management Final EIS – Chapter 3

Additionally, the fact that a particular stream is listed does not preclude management activities from 

occurring. Montana Code Annotated (MCA) 75-5-703(10)(c), states: (10) Pending completion of a 

TMDL on a water body listed pursuant to MCA 75-5-702: (c) new or expanded non-point source 

activities affecting a listed water body may commence and continue their activities provided those 

activities are conducted in accordance with reasonable land, soil, and water conservation practices 

(MCA 2008). 

2005 Travel Management Final Rule provides the following direction related to water quality: (b) 

Specific criteria for designation of trails and areas. [C]onsider effects on the following, with the 

objective of minimizing: (1) Damage to soil, watershed, vegetation and other forest resources. (36 

CFR 212.55). 

Custer National Forest Land and Resources Management Plan identifies management goals for soil, 

water and riparian resources under Chapter II - Forest Wide Management Direction and Chapter III – 

Management Area Direction. The Forest Plan goal for watershed management is to: [E]nsure that soil 

productivity is maintained and that water quality is maintained at a level which meets or exceeds state 

water quality standards (page 4). The objectives for soil and water resources are: Continue to produce 

water that meets State water quality standards. National Forest System lands will be managed so that 

the soil and watershed conditions are in a desirable condition and will remain in that condition for the 

foreseeable future. Soil and water quality objectives are designed to assure that these resources meet 

State water quality objectives and BMPs (Best Management Practices) are incorporated to assure this 

(page 5). The goal for riparian areas include: [M]anage for water quality, provide diverse vegetation, 

and protect key wildlife habitat in these areas from conflicting uses and uses and activities that 

adversely impact these areas will be mitigated (page 3). The objectives for riparian areas include 

recognition of their unique values, and management direction is to be designed to protect these key 

wildlife habitats and improve water quality: [T]hese areas will be managed in relation to various 

legally mandated requirements including, but not limited to, those associated with floodplains, 

wetlands, water quality, dredged and fill material, endangered species, and cultural resources (page 5). 

The goals for Management Area M (Riparian) are: Manage to protect from conflicting uses in order to 

provide healthy, self-perpetuating plant and water communities that will have optimum diversity and 

density of understory and overstory vegetation (page 80). 

Soil and Water Conservation Practices (or BMPs) are the primary mechanism to comply with state 

and federal water quality law by minimizing water quality impacts from non-point source pollution 

while still allowing dispersed land management activities to occur on National Forest System land. To 

reach these objectives the Forest Service developed the R1/R4 Forest Service Soil and Water 

Conservation Practices Handbook (USDA Forest Service 1995). This handbook is not available on the 

Region 1 internet website, but is available from the project file. A revised handbook is anticipated 

from the Washington Office in 2008. 

Practices specific to travel management include: 11.01 - Determination of Cumulative Watershed 

Effects, 11.09 - Management by Closure to Use, 12.10 - Management of Off-Road Vehicle Use, 12.11 

- Protection of Water Quality Within Developed and Dispersed Recreation Areas, 12.12 - Location of 

Pack and Riding Stock Facilities in Wilderness, Primitive, and Backcountry Areas, 15.01 - General 

Guidelines for Transportation Planning, 15.02 - General Guidelines for the Location and Design of 

Roads and Trails, 15.03 - Road and Trail Erosion Control Plan, 15.21 - Maintenance of Roads, 15.23 - 

Traffic Control During Wet Periods, and 15.27 - Trail Maintenance and Rehabilitation. The 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-69

effectiveness of these BMPs and other road maintenance and construction BMPs can be found in 

Logan (2001), Seyedbagheri (1996), and USDA-FS (2002). 

Introduction - Water Quality 

Both natural events and human activities have the potential to impact soil, water and riparian 

resources across both forest and range land. Significant natural events include wildfire and floods, 

while the most significant human activities include mining, livestock grazing, roads/trails, floodplain 

development, timber harvest and recreation. The degree of impact depends upon the soil and 

hydrologic characteristics of the watershed and how sensitive and resilient they are to these 

disturbances. Soil and hydrologic characteristics vary extensively across the landscape and are 

dictated by local landform, geologic material and climate. 

Natural Characteristics and Processes 

Watersheds, undisturbed by human influences, are not static systems. Deep snow packs and heavy 

spring rains can cause substantial flooding, landslides and instream erosion. Wildfire, wind, or insect 

and disease mortality can drastically alter the vegetative composition of a watershed. Depending on 

the extent of mortality and rate of stand decomposition, impacts to stream systems can also be 

substantial. Beneficial uses, including fisheries habitat, can be negatively affected by these natural 

events. However, watersheds left undisturbed after natural events, can and do recover rapidly, and 

ultimately provide conditions that fully support all beneficial uses within a relatively short period of 

time. These natural disturbances occur infrequently, which allows for significant and generally rapid 

recovery of hydrologic and erosional processes prior to the next major disturbance event. This results 

in pulse effects to water resources, which are moderate to high in magnitude, but low in frequency. 

Within the current climatic regime and prior to significant human influence, stream systems have 

developed under pulse type disturbances. 

Geology, Landform, Erosion and Sediment 

The underlying geology within the project area is intermixed sedimentary beds of clay, silt and sand. 

These structures have weathered to form steep cliff features along portions of the perimeter of most 

land units, while landforms along the remaining perimeter are less steep and more convex in nature. 

Erosion is a natural process of geologic decomposition that occurs in all watersheds. The rate at 

which it occurs is a function of soil and stream characteristics, precipitation and flow regimes, and 

vegetative cover. There are three basic types of erosion; 1) detachment and routing of individual soil 

particles from the land surface; 2) mass wasting such as landslides and slumps; and 3) detachment and 

mobilization of stream channel banks or bottom material, i.e., instream erosion. All of these processes 

produce “sediment,” and all stream systems transport sediment. Sediment is a loosely used term that 

can refer to a wide range of channel substrate particle sizes, i.e., silt, sand, gravel, cobble, boulder, etc. 

The larger particle sizes are generally produced through instream erosion or mass wasting and are 

commonly referred to as bedload. The finer particles that are suspended in flowing water can be 

produced through all of the erosion processes mentioned above. 

Geology and landforms within the analysis area have produced soils that are generally stable and not 

highly erodible when adequately vegetated. MacDonald and Stednick (2003) suggest that undisturbed 

forested watersheds typically have very low erosion rates because of high infiltration rates and limited 

surface runoff. Erosion rates have been estimated at less than 0.1 tons per acre per year for most 

forested areas in the interior western U.S. (Patric et al. 1984). Stednick (2000) summarized research 

concerning timber management in the Northern Rockies which also suggests that erosion rates for 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-70 Ashland Travel Management Final EIS – Chapter 3

undisturbed forested landscapes (control watersheds, no harvest/roads) are very low (0 - 0.09 t/ac/yr). 

Therefore, in the absence of wildfire, hillslope surface erosion within undisturbed areas across the 

analysis area is considered to be nearly non-existent. The exception to this occurs on steep, high 

energy (south facing) landforms composed of fine textured material. Due to dry site conditions and 

steep slopes, vegetation can be sparse. Episodic precipitation events that saturate these soils can result 

in landslides (rotational slumps) that release substantial amounts of sediment downslope. However, at 

the broad scale, instream erosion is considered the dominant erosion process across the analysis area. 

Precipitation and Flow Regimes 

Elevations across the land units range from under 3400 to over 4300 feet. Based on a 30 year period of 

record, the average annual precipitation associated with these elevations range from 14 to 20 inches 

(MTNRIS 2008). The majority of the precipitation falls as spring snow or rain from April through 

June. 

Precipitation levels and geologic formations result in the ephemeral flow regimes for the majority of 

the drainages within the land units. Short perennial streams do however, occur below many spring 

sites. Spring (groundwater) discharge results in relatively constant flow throughout the year, although 

infrequent but significant peaks can occur during heavy spring snow and rain events that produce 

overland flow. 

Historically, beaver played a significant role throughout the project area through the development of 

extensive dam/pond networks. Beaver populations have been reduced relative to historic levels. 

Although temporary, beaver dams and ponds are an important component of riparian systems. They 

help to trap and store both sediment and water. A reduction in beaver populations over the years has 

likely resulted in lower water tables and lower late season streamflows along small, low elevation 

streams. 

Vegetative composition is largely defined by climate and soils, but natural agents including fire, 

insects or disease, and wind can drastically alter vegetative cover. Over the last three decades, timber 

stands have been affected by wildfire on just under 131,000 acres across the District. Wildfire events 

have likely resulted in substantial increases in localized surface erosion although sediment delivery to 

perennial streams has not been quantified. Surface erosion and sediment transport subsides to back 

ground levels generally within five years as ground vegetation recovers. 

Human Influences 

Humans have influenced watersheds and water quality for centuries. Prior to European settlement, 

Native Americans used fire to manipulate vegetation which influenced hydrologic processes at the 

local scale. As European settlement occurred, so did uncontrolled beaver harvest, timber harvest and 

forage harvest through livestock grazing. All of these activities had long term impacts to watershed 

characteristics and hydrologic processes. 

Currently, many activities influence water quality and natural channel processes including livestock 

grazing, crop production, floodplain development, timber harvest and transportation systems. Some of 

these activities are constant or occur on an annual basis, e.g., transportation systems or livestock 

grazing. The effects from these types of activities are considered chronic. Although chronic effects are 

generally low to moderate in magnitude, they occur with moderate to high frequency. In contrast to 

pulse effects discussed previously, chronic effects may not allow for significant recovery of the soil 

and water resource over time. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-71

Livestock Grazing 

Livestock grazing has occurred within the analysis area since the late 1800s. Livestock numbers have 

decreased over the years; in some allotments quite substantially. Currently there are 52 allotments 

providing 130,262 AUMs on 367,000 acres of suitable range on the District. Recent range analyses 

have identified issues concerning livestock grazing impacts to riparian systems and water quality. In 

general, livestock grazing can impact riparian systems through overuse of streamside vegetation and 

destabilization of streambanks. Water quality impacts can occur by increasing levels of fine sediment, 

increasing water temperature or changing flow regimes. The 2004 Lee Creek, 2007 Stag Rock, and 

2009 Home Creek Range Analysis Decisions proposed changes in range management to address these 

issues. Range management planning across the remainder of the analysis area is ongoing. 

Floodplain Development 

Residential development in floodplains has the potential to affect natural floodplain processes by 

reducing the ability of floodwaters to access their historic floodplain. These developments include 

building structures, elevated driveways, bank rip-rap and stream crossing structures. When 

floodwaters are more confined to the main channel, streamflow velocities generally increase, which 

results in more damage to streambanks and human structures downstream. The cumulative effect on 

floodplain processes from of all structures within a given valley bottom can be substantial. Floodplain 

development within the Forest boundary occurs on the District along Home Creek, Otter Creek and 

tributaries of Otter Creek. 

Timber Harvest and Prescribed Fire 

Timber harvest over the last three decades encompasses just over 9000 acres on the District. 

Prescribed fire over the last two decades encompasses approximately 22,000 acres on the District. On 

a watershed basis, neither harvest nor prescribed burn activities are substantial enough to be 

detrimental to water resources. Both of these activities have helped to reduce fuel loads and potential 

for future catastrophic wildfires. 

Transportation Systems- General Influences on Water Resources 

Roads modify natural drainage networks and accelerate erosion processes. These changes can alter 

physical processes in streams, leading to changes in streamflow regimes, sediment transport and 

storage, channel bank and bed configurations, substrate composition, and stability of slopes adjacent 

to streams (Furniss et al. 1991). Numerous studies have identified unpaved roads as a major source of 

sediment in streams (Elliot 2000). Sudgen 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). In 

relation to other transportation systems (motorized/non-motorized trails), roads open to full size 

vehicles pose the greatest risk of impact to water resources due to 1) largest tread width, 2) largest 

weight, size and force of vehicle, and 3) generally higher use levels. 

Motorized two-track trails can also negatively affect streams. Meadows (2007) suggests that ATV 

trails are high-runoff, high-sediment producing strips on low-runoff, low-sediment producing 

landscapes. For six study sites across six states, he found that sediment concentrations generally 

tended to increase with increasing disturbance levels. Although runoff did not appear to increase for 

the Montana site, sediment increased by approximately 625%, compared to the undisturbed, pretraffic forest floor. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-72 Ashland Travel Management Final EIS – Chapter 3

Motorized and non-motorized single track trails can also negatively affect streams, but the degree of 

affect is determined by the mode of travel. Deluca et al. (1998) found a substantial increase in 

sediment supply from horse traffic when compared to foot or llama traffic. Wilson and Seney (1994) 

documented similar conclusions concerning horse traffic. They also suggest that two-wheeled cycle 

traffic (motor/bi-cycle) results in less sediment than either horse or foot traffic, although the actual 

data appears to suggest foot traffic produces the least sediment. These two studies documented 

opposite results concerning sediment production on wet trails. Wilson and Seney (1994) documented 

increased sediment production on wetted trails, whereas Deluca et al. (1998) found no increase. Cole 

(1991) found, in a study of three trails in the Selway-Bitterroot Wilderness of Montana, that although 

most individual trail segments experienced change, there was no net erosion over an 11 year period. 

Unplanned (user created) routes have the potential to be the most detrimental to water quality when 

routes are improperly located adjacent to streams. 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. 

Transportation route impacts on wetlands were identified where routes are known to intersect 

wetlands, or narrow riparian/stream corridors. Thirteen routes with unimproved crossings occur on the 

District. Appendix D provides observations and recommendations for these sites. Anticipated effects 

on these wetland sites from the proposed actions are disclosed in the Environmental Consequences 

section. 

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 across the District. Additionally, cumulative impacts of 

individual routes at the watershed scale have also not been quantified on-ground or instream. Instead, 

existing route networks were evaluated cumulatively at the watershed scale through GIS to determine 

relative risks to water resources. 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. All routes, regardless of ownership were included in 

the evaluation, although routes with Forest Service jurisdiction were also summarized separately as 

these are the routes potentially affected by the proposed actions. Refer to the next section for the 

results of this evaluation. 

Affected Environment Summary 

The water resource affected environment analysis is a broad scale, risk based assessment. Risks are 

determined at the 6 HUC (hydrologic unit code) watershed scale from GIS spatial data. A summary of 

selected natural characteristics and human activities are provided in Table 3-23. Quantifiable Forest 

Service activities include past timber harvest, fire (prescribed fire and wildfire), and existing 

transportation system attributes (route miles and number of stream crossings). All watersheds have 

some level of past and present agricultural activity (crop production and/or livestock grazing). Other 

than the information provided above on Forest Service range allotments, the effects of agricultural 

activities to water resources have not been assessed. Six HUC watersheds were used as the analysis 

area for the affected environment because the area encompassed (10,000 to 40,000 acres) provides a 

reasonable and manageable number of analysis units across the District (40). Smaller or larger 

watersheds would not provide better information for the deciding officer concerning water resource 

effects. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-73

Watersheds were assigned a risk level to help focus cumulative effects analysis for water resources. 

The risk level is based on 1) perennial stream crossings by FS routes, 2) total perennial stream miles, 

3) intermittent stream crossings by FS routes, and 4) TMDL listed streams. High risk watersheds have 

Forest Service roads with perennial stream crossings, exceptionally high number of intermittent 

crossings on Forest Service Roads, or are TMDL category 5 streams with intermittent crossings on 

Forest Service roads. Moderate risk watersheds have more than one mile of Forest Service roads and 

some level of perennial streams downslope. The remaining watersheds are Low risk and were not 

carried forward to the direct and indirect effects analysis, but are included in cumulative effects. Of 

the 40 watersheds on the District, 12 are rated high risk, 16 moderate and 12 low. 

As mentioned previously, riparian and stream conditions are also assessed by the MTDEQ to 

determine the level of beneficial use support. Impaired streams with known pollutant related sources 

require a TMDL (Category 4A and 5 streams). Category 4A streams have all necessary TMDLs in 

place, while category 5 streams still need TMDLs developed. Impaired streams with no known 

pollutant related sources do not require a TMDL (Category 4C streams). Category 1 streams fully 

support all beneficial uses, while category 3 streams have not had all beneficial uses assessed. This 

assessment provides the best information on current stream conditions below the Forest boundary. A 

summary of streams identified on the 2006 303(d) List are provided in Table 3-24. 
Page 3-74 Chapter 3: Affected Environment and 

Ashland Travel Mana

Table 3-23. Summary of Watershed Characteristics and Watershed Scale Influences on the District 

Watershed # Watershed Name 

Watershed Acres 

Percent Watershed 

Forest Service 

Total Perennial 

Stream Miles 

FS Perennial Stream 

Miles 

Harvest Acres 

Fire Acres 

Total Road Miles 

FS Road Miles 

Total Stream 

100901020210 Otter Creek-Brian Creek 36062 78 37 21 376 19851 104 50 18100901020602 Ash Creek 10779 71 2 2 0 1673 17 5 3100901020203 Otter Creek-Horse Creek 21585 90 21 19 47 7891 47 27 67 100901020601 Upper Beaver Creek 14298 98 5 5 478 886 41 30 4100901020209 Fifteenmile Creek 22566 66 2 2 86 3790 60 29 6100901020208 Elk Creek 19754 68 5 5 0 48 58 24 7100901020205 Taylor Creek 29059 100 2 2 268 5690 87 41 8100902070206 Bloom Creek 30311 82 2 2 266 4832 56 28 64 100901020301 Tenmile Creek 27351 89 1 1 0 2983 63 22 9100901010803 Lee Creek1 30049 63 1 1 0 5617 78 24 11100901020303 Home Creek 37810 89 5 4 2860 13879 128 66 16100901010804 East Fork Hanging Women Creek1 22019 94 2 2 538 3187 54 36 7100901020104 Lower Bear Creek 13516 94 9 9 3 2120 39 26 5100901020404 Poker Jim Creek 12811 89 6 6 165 1399 19 13 3100901020406 O'Dell Creek 29692 92 5 5 603 20867 64 43 9100901020603 Middle Beaver Creek 18883 50 6 1 0 35 49 20 8100901020204 Indian Creek 33062 49 1 1 72 168 87 19 10100901020501 Tongue River-Double E Creek 15151 23 8 1 0 428 39 3 44 100901020206 Lyon Creek 19615 100 1 1 785 1962 51 29 4100901020103 Little Bear Creek 18833 14 1 1 0 302 49 3 5100902070204 Powder River-Plum Creek 22555 25 12 1 0 5386 39 9 44 100901020302 Threemile Creek 32925 88 1 1 160 19113 81 36 9100901021102 Lower Little Pumpkin Creek 39175 12 1 1 59 150 115 9 14100901020409 Tongue River-King Creek 31387 34 14 0 0 9686 71 17 10100901020407 Tongue River-Poker Teechee Creek 21367 24 11 0 0 1 50 6 7
Chapter 3: Affected Environment and 

Page 3-75 Ashland Travel Mana

Table 3-23. Summary of Watershed Characteristics and Watershed Scale Influences on the District 

Watershed # Watershed Name 

Watershed Acres 

Percent Watershed 

Forest Service 

Total Perennial 

Stream Miles 

FS Perennial Stream 

Miles 

Harvest Acres 

Fire Acres 

Total Road Miles 

FS Road Miles 

Total Stream 

100901020304 East Fork Otter Creek 29127 90 1 0 1985 3681 89 35 11100901010801 Lower Hanging Women Creek1 33404 8 23 0 0 1 72 3 9100901020305 Otter Creek-Newell Creek 30339 18 38 0 0 4191 66 4 8100901020504 Tongue River-Colbert Coulee 26625 5 8 0 0 348 17 1 1100901021002 Pumpkin Creek-Doonan Gulch 35691 17 0 0 31 2410 85 12 11100901021101 Upper Little Pumpkin Creek 27095 76 0 0 356 9 94 20 11100901020703 Liscom Creek 30444 32 0 0 0 31 93 14 16100901020207 Paget Creek 9042 96 0 0 194 8250 31 22 3100901021003 Pumpkin Creek-Fiftyfour Creek 38844 11 0 0 0 16 97 4 11100901021001 Headwaters Pumpkin Creek 27201 6 0 0 0 5 90 4 9100901020403 Tongue River-Birney Creek 27298 8 18 0 0 0 60 1 8100901020411 Tongue River-Walking Horse Coulee 17669 6 9 0 0 949 57 0 5100901020604 Lower Beaver Creek 15080 9 10 0 0 0 22 0 3100901020505 Tongue River-Bringoff Creek 33093 7 11 0 0 1090 26 0 3100902070209 Fire Creek 17365 2 0 0 0 0 26 0 4SUM 40 watersheds 1008934 na 277 93 9332 152924 2470 736 32

1 TMDL listed stream or tributary to. 
Page 3-76 Chapter 3: Affected Environment and 

Ashland Travel Mana

*P= partial use support 

Table 3-24. Summary of Streams on the 2006 Montana 303(d) List Within or Immediately Adjacent to the Distr

Stream Probable Impaired Use Probable Cause of Impairment Probable Source of Impairment 

TMDL Category 5 Streams (TMDLs Required)

Hanging Woman Creek 

Aquatic Life Support (P) Warm Water Fishery (P) Drinking Water (na) 

Sediment/siltation Grazing in Riparian or Shoreline Zones

Streambank Modifications/destablization 

TMDL Category 3 Streams (TMDLs Not Currently Required- insufficient data) 

Beaver Creek All uses not assessed Little Pumpkin Creek All uses not assessed Otter Creek All uses not assessed Powder River All uses not assessed Pumpkin Creek All uses not assessed 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-77

The 2006 Montana 305(b)/303(d) Water Quality Report lists only one stream adjacent to the analysis 

area that requires TMDLs: Lower Hanging Woman Creek (MTDEQ 2006). Impaired uses include 

aquatic life and warm water fisheries. Probable causes for impairment are sediment/siltation. Probable 

sources are grazing in riparian areas and streambank modification. Transportation systems on National 

Forest System land have the potential to influence aquatic life and warm water fisheries in this stream 

by contributing sediment to tributary channels in Lee Creek and EF Hanging Woman Creek. 

Category 3 TMDL streams have not had beneficial uses assessed, and therefore causes and sources 

have not been identified. However, moderate and high risk watersheds with Category 3 TMDL 

streams carried forward to effects analysis include the following watersheds: Upper Beaver Creek, 

Lower Little Pumpkin Creek, Otter Creek-Brian, Otter Creek-Horse, Otter Creek-Newell, and Powder 

River-Plum. 

3.4.1.2 Environmental Consequences – Water Quality 

Effects Common to All Action Alternatives - Water Quality 

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. 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. These routes are accounted for in the cumulative effects section. 

Direct Effects 

Relative to transportation systems, only the installation, reconstruction, or active removal and 

restoration of stream crossing structures result in direct effects to water quality, because the effect 

occurs during implementation of the action. For this analaysis, fords are also considered a stream 

crossing structure. Since there are no actions proposed to actively change specific stream crossings 

under this analysis, there are no direct effects to evaluate. 

Indirect Effects 

Indirect effects occur at a later time or distance from the proposed action. For example, a non-system 

route upslope from a stream and proposed for public use could potentially result in sediment delivery 

to the stream during wet periods. However, this potential effect would likely occur at a later time than 

the decision to designate the route, and would be some distance downslope from the designated route, 

hence a indirect effect. 

Only routes with proposed actions are evaluated for indirect effects. Existing system routes that are 

designated without further actions, or non-system routes not converted to system routes, are not 

considered proposed actions under this analysis. However, these routes are incorporated into the 

cumulative effects analysis below as default actions. Proposed actions for individual routes under this 

analysis include designating non-system routes for public or administrative use, not designating 

existing system routes, designating system roads for administrative use only, converting system roads 

to trails, applying a season of use, or changing the mode of travel (vehicle). 

Relative Route Risks By Action 

Indirect and cumulative effects are based on whether the action for an individual route will increase, 

decrease or have no effect on route risk to water resources. For indirect effects, as presented in Tables 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-78 Ashland Travel Management Final EIS – Chapter 3

3-26 and 27, the influence of the proposed action on risk is based on a comparison with the no action 

condition. For cumulative effects, as presented in Table 3-28, the influence of the proposed and 

default actions on risk are based on a comparison with the existing condition. This rationale is 

displayed in the following table. 

Table 3-25. Summary of Relative Route Risks by Action and Condition

Action 

Change in Route Risk as 

Compared to Existing 

Condition 

Change in Route Risk 

as Compared to No 

Action Condition 

Proposed Actions Under Action Alternatives 

Add (designate non-system routes for public use) No Change Increase 

Add (designate non-system routes for administrative use) Decrease Increase 

Administrative (designate system routes for administrative use) Decrease Decrease 

Do Not Designate (system routes) Decrease Decrease 

Convert/Season (change from roads to trails and apply season of 

use 12/1-8/31) 

Decrease Decrease 

Vehicle (change mode of travel) No Change No Change 

Convert (change roads to trails) No Change No Change 

No Camping No Change No Change 

Default Actions Under No Action Alternative 

Do Not Designate (non-system routes) Decrease na 

Designate (system routes) No Change na 

The only action that would tend to increase risk to water resources is designating non-system roads for 

public or administrative motorized use. Designating non-system roads adds additional route miles to 

the landscape for the long-term, thereby maintaining the risk of indirect and cumulative effects to 

water resources. However, this is only an increase in risk when compared to the No-Action 

Alternative, because under the No-Action these routes would not be designated. Under the existing 

condition, these routes are already on the landscape and available for public use, and therefore 

designating them for public use is no change in risk. Additionally, designating them for administrative 

use only should reduce existing use and therefore risk. 

Changing the mode of travel from highway legal vehicle to all motorized vehicles is not expected to 

change the type of vehicles that currently use these routes. Likewise, converting roads to trails is not 

expected to change the type of vehicle or level of use, nor the level or priority for maintenance along 

these routes. Therefore, these actions would not substantially change risk to water resources. 

The remaining actions would tend to decrease risk to water resources. Changing the seasonal use 

period (yearlong to 12/1-8/31) related to the fall hunting season has the potential to reduce surface 

erosion, rutting and maintenance needs when roads are wet prior to freeze-up. This decrease in risk 

overrides the no change in risk identified for converting roads to trails where the actions coincide. 

Converting system routes to administrative use reduces traffic and allows revegetation of the road 

surface to occur, both of which reduce erosion over the long-term. Not designating system and nonsystem routes reduces route miles on the landscape over the long-term, thereby reducing potential 

erosion and risk to water resources. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-79

Effects by Alternative - Water Quality 

The proposed actions for individual routes are summarized for moderate and high risk watersheds by 

whether the actions increase or decrease risk. Refer to the following table. Low risk watersheds are 

not evaluated for indirect effects because they either do not contain perennial streams, or roads on 

National Forest System land, or are Category 5 TMDL streams. They are however, accounted for 

under cumulative effects. 

Alternative A - Indirect Effects 

This alternative proposes actions that increase risk to water resources in 26 of the 28 moderate and 

high risk watersheds on the District, while actions that decrease risk are proposed in 21 watersheds. 

Overall, there is a net increase in risk in 19 (68%) watersheds, while net risk decreases in eight 

watersheds. Nine of the 19 watersheds with a net increase are high risk watersheds. The sole reason 

for the increase is due to the addition of non-system roads to the transportation system. Risk remains 

unchanged in one watershed. 

Under Alternative A, one route previously identified with potential wetland concerns will have actions 

proposed to address these concerns. This is a system route that will be converted to administrative use 

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

One watershed that is a tributary to a category 5 TMDL stream has proposed actions that result in a 

net decrease in risk, while two other watersheds with category 5 TMDL issues have actions that result 

in a net increase in risk. Of the six moderate and high risk watersheds with category 3 TMDL 

streams, three have actions that increase net risk to water resources, while two have actions that 

decrease net risk and one has no net change. 

Alternative B and B Modified - Indirect Effects 

This alternative proposes actions that increase risk to water resources in 21 of the 28 moderate and 

high risk watersheds on the District, while actions that decrease risk are proposed in 27 watersheds. 

Overall, there is a net increase in risk in only three (11%) watersheds, while net risk decreases in 24 

watersheds. None of the watershed with a net increase are high risk watershed or have category 5 

TMDL streams. The reasons for the decrease in risk are due to designating system routes for 

administrative use only, applying a season of use to converted roads, and not designating some system 

routes. Risk remains unchanged in one watershed. 

Under these alterntives, two routes previously identified with potential wetland 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. 

All three watersheds with category 5 TMDL issues have actions that result in a net decrease in risk. 

Additionally, all six moderate and high risk watersheds with category 3 TMDL streams have actions 

that decrease net risk to water resources. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-80 Ashland Travel Management Final EIS – Chapter 3

Table 3-26. Summary of Route Miles by Action Risk for Moderate and High Risk Watersheds 

When Compared to the No-Action Condition 

Alternative A Alternative B Alternative B Modified 

Watershed Increase 

Risk 

Decrease 

Risk 

Increase 

Risk 

Decrease 

Risk 

Increase 

Risk 

Decrease 

Risk 

Ash Creek 0.1 0.4 0.0 0.4 0.0 0.7 

Bloom Creek 9.2 1.3 5.2 7.6 5.2 8.9 

East Fork Hanging Women Creek1 7.0 0.0 1.8 7.3 1.8 11.1 

East Fork Otter Creek 3.5 8.7 1.6 17.6 1.6 17.2 

Elk Creek 3.8 2.7 0.2 7.6 0.2 7.6 

Fifteenmile Creek 2.4 0.8 0.4 4.7 1.4 4.7 

Home Creek 9.5 3.8 4.8 9.7 4.8 8.2 

Indian Creek 4.0 3.1 2.4 5.9 2.4 7.7 

Lee Creek1 2.9 3.7 0.6 11.4 0.0 11.4 

Little Bear Creek 1.4 0.1 0.8 0.1 0.8 0.3 

Lower Bear Creek 2.3 0.0 1.5 4.8 1.5 4.8 

Lower Hanging Women Creek1 1.4 0.4 1.0 2.4 1.0 2.4 

Lower Little Pumpkin Creek 0.8 1.2 0.8 2.3 0.8 1.2 

Lyon Creek 8.9 1.9 3.5 1.9 3.5 2.6 

Middle Beaver Creek 0.2 3.0 0.0 12.6 0.0 7.7 

O'Dell Creek 3.4 3.0 0.9 12.1 1.1 12.0 

Otter Creek-Brian Creek 2.6 3.3 1.8 9.7 1.8 10.2 

Otter Creek-Horse Creek 5.2 0.2 0.0 9.5 0.2 9.3 

Otter Creek-Newell Creek 0.0 0.0 0.0 0.0 0.0 0.0 

Poker Jim Creek 0.1 0.0 0.1 1.6 0.1 9.6 

Powder River-Plum Creek 2.8 1.7 0.0 4.3 0.0 4.3 

Taylor Creek 9.1 1.5 4.3 6.7 4.3 8.8 

Tenmile Creek 2.7 0.3 1.8 2.6 1.8 2.6 

Threemile Creek 7.0 0.0 3.3 0.1 6.1 3.3 

Tongue River-Double E Creek 0.0 2.9 0.0 2.9 0.0 2.9 

Tongue River-King Creek 1.1 0.0 0.0 0.3 0.0 2.2 

Tongue River-Poker Teechee Creek 0.4 2.9 0.3 2.9 0.3 2.5 

Upper Beaver Creek 4.7 0.0 0.5 8.2 2.9 3.3 

Total Miles by Action Risk 96.5 46.9 37.6 157.3 43.5 167.6 

Number of watersheds with a 

increase or decrease in risk 26 21 21 27 21 27 

Number of watersheds with a net

increase or decrease in risk 19 8 3 24 3 24 

1 TMDL listed stream or tributary to. 

Comparison of Indirect Effects 

The following table provides a summary of indirect effects for all actions in all watersheds by risk 

category; increase, decrease or no change in risk. For all actions across the District, a net increase in 

risk occurs under Alternative A (+8%), while a net decrease in risk occurs under Alternative B (-20%) 

and B Modified (-19%). Due to the coarse nature of this risk analysis, the difference between 

Alternative B and B Modified is likely not significant. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-81

Table 3-27. Summary of Route Miles with Proposed Actions When Compared to the No Action 

Condition

Actions that Increase Risk Alternative A Alternative B Alternative B 

Modified 

Add (designate non-system routes for public and administrative use) 124.7 55.0 62.4 

Total Miles that Increase Risk 124.7 55.0 62.4 

Actions that Decrease Risk 

Administrative (designate system routes for administrative use only) 44.1 91.1 80.7 

Do Not Designate (system routes) 21.9 75.2 80.7 

Convert/Season 0.0 16.9 25.7 

Total Miles that Decrease Risk 66.0 183.2 187.1 

Actions that Don’t Change Risk 

Vehicle 33.8 33.8 33.8 

Convert 491.7 374.9 374.4 

Total Miles –Actions that Do Not Change Risk 525.5 408.7 408.2 

Total Miles – All Actions 716.2 646.9 657.7 

Percent Net Increase or Decrease in Risk ((increase miles – decrease 

miles)/total miles) +8% -20% -19% 

No Action Alternative 

See discussion of No Action Alternative in the cumulative effects section below. 

Cumulative Effects - Effects of All Routes Including Those Without Proposed Actions 

All alternatives include routes without proposed actions. Actions for these routes are termed default 

actions and include some system routes that will be designated without further action, and some nonsystem routes that will not be designated without further action. These default actions are compared 

against the existing condition to determine risks. Designating system routes is not expected to change 

any characteristic of the route in terms of current use or impact and therefore this default action will 

not change risk to water resources. On the other hand, not designating non-system routes will remove 

the route from the landscape, thereby reducing any existing effects and future risks to water resources. 

The following table summarizes miles of routes with default actions, and cumulatively by including 

routes with proposed actions. 

Table 3-28. Summary of All Routes Across the District With and Without Proposed Actions When 

Compared to Existing Condition

Alternative

A 

Alternative

B 

Alternative

B Modified 

No Action 

Alternative 

NF System Road Miles – Designate System Routes for Public and 

Admin Use - No Change In Risk 144.7 144.7 141.3 736.6 

NF Non-system Road Miles – Do Not Designate - Decrease Risk 41.4 111.1 105.1 163.2 

Total Miles for Routes with Default Actions 186.1 255.8 246.4 899.8 

Miles for Actions that Increase Risk (no proposed actions increase 

risk when compared to the existing condition- see Table 3-25) 0.0 0.0 0.0 0.0 

Miles for Actions that Decrease Risk (designating system/nonsystem routes for administrative use only, applying a season of use 69.0 221.3 222.8 0.0 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-82 Ashland Travel Management Final EIS – Chapter 3

Table 3-28. Summary of All Routes Across the District With and Without Proposed Actions When 

Compared to Existing Condition

Alternative

A 

Alternative

B 

Alternative

B Modified 

No Action 

Alternative 

to converted roads, and not designating system routes) 

Miles for Actions that Don’t Change Risk (vehicle, convert, add 

non-system to public use) 647.2 425.6 434.9 0.0 

Total Miles for Routes with Proposed Actions 716.2 646.9 657.7 0.0 

Total Miles for All Routes with Increased Risk 0.0 0.0 0.0 0.0 

Total Miles for All Routes with Decreased Risk 110.4 332.4 327.9 163.2 

Total Miles for All Routes with No Change in Risk 791.9 570.3 576.2 736.6 

Total Miles - All Routes 902.3 902.7 904.1 899.8 

Percent Net Increase or Decrease in Cumulative Risk ((increase 

miles – decrease miles)/total miles) -12% -37% -36% -18% 

Action Alternatives 

These alternatives designate varying levels of system routes without any additional actions to reduce 

risks to water resources. All action alternatives designate substantially less miles than the No Action 

Alternative. Alternatives B and B Modified designate less non-system miles than Alternative A, 

thereby further reducing risks from these routes. Cumulatively across the District, a net decrease in 

risk occurs under all action alternatives from -12 percent in Alternative A to -37 percent under 

Alternative B. Due to the coarse nature of this risk analysis, the difference between Alternative B and 

B Modified is likely not significant. 

. 

No Action Alternative 

This alternative designates the most system routes without any additional actions to reduce risks to 

water resources. However, it also designates the least amount of non-system routes. Not designating 

these routes reduces risk over the long-term as the routes disappear from the landscape, either 

naturally or through active rehabilitation. Cumulatively across the District, a net decrease in risk of -

18 percent occurs under the No Action Alternative. 

Under this alternative, no routes previously identified with potential wetland concerns will have 

actions proposed to address these issues. These routes and concerns are identified in Appendix D as 

future restoration opportunities. 

Effects Common to All Alternatives at the Watersheds Scale 

Sediment modeling was not incorporated into the effects analysis for water quality for many reasons. 

First of all, natural erosion rates specific to the Custer National Forest have not been developed and 

extrapolating rates from other Forests would only increase errors associated with the model results. 

Additionally, except for wildfire, road construction and harvest of green timber stands, surface erosion 

rates have not been developed for other frequent activities on the forest. Therefore, from a cumulative 

effects standpoint, existing sediment models are not adequate to quantify to a single cumulative value, 

the effects of all the diverse activities in individual drainages including wildfire/prescribed fire, 

dispersed camping, off-highway vehicle use, grazing, floodplain development, timber harvest, and 

transportation networks. Nor are they capable of distinguishing between all the different actions 

associated with this travel management analysis. A combination of individual models could prove 

useful, but a large amount of additional data (on-ground and spatial) would be necessary to obtain 

valid results. The only way to address these various activities cumulatively for this travel management 

analysis is to address each activity individually and then qualify, in general terms, the cumulative 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-83

effects between specific activities where appropriate. Additionally, thresholds for sediment yield 

increases are extremely difficult to identify and have not been identified for the Custer National 

Forest. Existing activities are discussed previously under the section – Affected Environment – Water 

Quality. 

Finally, existing models can have very high errors associated with their results. Elliot (2000) indicates 

that, at best, any predicted runoff or erosion value, by any model, will be within plus or minus 50 

percent of the true value. The high degree of error associated with cumulative effects models make it 

difficult, if not impossible, to compare results between alternatives because confidence intervals 

overlap. 

At the 6 HUC watershed scale, the proposed actions are not likely to be substantial enough to cause 

detectable changes in water quality, quantity or channel processes under any alternative. Although the 

effect of an individual action on a specific route could be detectable in the nearest watercourse 

immediately downslope, it is unlikely to be detectable at the mouth of watersheds ranging from 

10,000 to 40,000 acres. Additionally, the effects of all actions are indirect as previously discussed. 

They will occur at different times in different locations and at different magnitudes across these large 

watersheds. The effects are therefore diluted; temporally and spatially. 

Natural disturbance events will continue to influence hydrologic and erosional processes across all 

watersheds. Given the current vegetative conditions and associated fuel accumulations in some 

watersheds, there is potential for wildfires to occur that may be outside the range of conditions 

(intensity and duration) that have occurred over the last few hundred years. Depending on the 

intensity and area burned, accelerated soil erosion is likely, particularly where hydrophobic soils may 

be formed. Significant channel adjustments could be expected in these watersheds, especially during 

years of average or higher precipitation/runoff conditions. Stream systems will however stabilize as 

vegetative recovery occurs during post-fire years. Transportation systems could compound the effects 

of post-fire flood events, especially where routes are not maintained to standard. It is reasonable to 

assume that current road conditions and maintenance needs will continue into the future. Based on the 

2004 Ashland Landscape Assessment, the combination of existing roads and wildfire potential results 

in a relatively high risk of impact to water resources in two watersheds on the District; Threemile 

Creek and Home Creek (Nienow 2004). 

Past and present timber harvest activities and prescribed fire will continue to be a minimal influence 

on water resources as described under the affected environment. However, other human influences 

including transportation systems, grazing, recreation, and floodplain developments are likely to 

continue to cause chronic effects to water resources as discussed previously. 

3.4.1.3 Conclusion - Water Quality 

From a District-wide cumulative summary, the preferred alternative would decrease net risk along 36 

percent of the 904 total route miles evaluated. By comparison, Alternative A would decrese net risk 

along only 12 percent of the total route miles, while the no-action alternative would decrease net risk 

along 18 percent. Alternative B is very similar to the preferred alternative at 37 percent net decrease. 

Currently, some routes have documented water quality impacts and therefore, may not comply with 

Forest Plan direction or state and federal water quality regulations. Compliance relative to the 

Decision to be made for this EIS, only pertains to those routes with a proposed action. These routes 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-84 Ashland Travel Management Final EIS – Chapter 3

have actions proposed which are the first steps toward addressing water quality impacts. Additional 

activities, outside of this proposal, that would further reduce water quality impacts are identified in 

Appendix D - Opportunities. From a NEPA standpoint, routes with no proposed actions that have 

known water quality impacts are not a compliance issue relative to the Decision to be made, because 

this project is not the cause of those impacts (i.e. they are existing impacts). However, water quality 

impacts should still be addressed through measures outside this process and recommended actions for 

these routes are also identified in Appendix D - Opportunities. Full compliance with Forest Plan 

direction and state and federal water quality regulations under all alternatives would occur in the 

future as these actions or rehabilitation measures are implemented. 

3.4.1.4 Affected Environment – Fisheries and Aquatics 

Applicable Laws, Regulations, and Policy 

The Clean Water Act requires States to identify existing water bodies that do not meet water quality 

standards, and develop plans to meet them. Montana Water Quality Law, as directed by the Clean 

Water Act, developed a water quality classification system, developed water quality standards to be 

applied to various water classes, and identified water bodies that do not meet standards. 

The Montana Department of Environmental Quality (MTDEQ) has classified all waters within the 

analysis area as C-3 waters. The beneficial uses associated with this classification include; bathing, 

swimming, and recreation; growth and propagation of non-salmonid fishes and associated aquatic life, 

waterfowl, and furbearers. 

The 1995 Presidential Executive Order 12962 directs Federal agencies to “improve the quantity, 

function, sustainable productivity, and distribution of aquatic resources for increased recreational 

fishing opportunity by evaluating the effects of federally funded, permitted, or authorized actions on 

aquatic systems and recreational fisheries and document those effects relative to the purpose of this 

order.” 

As part of the National Environmental Policy Act (NEPA) decision-making process, proposed Forest 

Service programs or activities are to be reviewed to determine how an action will affect any sensitive 

species (FSM 2670.32). The goal of the analysis should be to avoid or minimize impacts to sensitive 

species. Three sensitive amphibian species are present in the project area. These include the Great 

Plains Toad Bufo cognatus, Northern Leopard Frog Rana pipiens, and Plains Spadefoot Spea 

bombifron. Sensitive fish species considered in this analysis include the Northern Redbelly Dace 

Phoxinus eos and Sturgeon Chub Macrhybopsis gelida. Although the project area is within the historic 

distribution of these sensitive fish species, there has been no documented occurrence of either fish 

species in the project area. 

The 1987 Custer National Forest Land and Resources Management Plan directs that management 

activities should enhance habitat quality and diversity, and to provide fish-oriented recreation 

opportunities. Most of the critical habitat areas have been incorporated into management areas that 

maintain or improve these key habitats. Fisheries management is considered in all management areas 

and the level of habitat management is projected to increase over time. 

Fish and Amphibian Distribution 

The Ashland District Travel Management Plan project area spans across 40 individual watersheds (6th

level hydrologic unit code). Custer National Forest system lands comprise about one-half (49.6 %) of 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-85

the total acreage of the 40 watersheds (500,928 acres of 1,008,934 acres total). The project area 

encompasses headwater tributaries, springs, and impoundments that support diverse populations of 

endemic fish and amphibian species. 

There are no sensitive fish species documented in the project area. However, waters on the Ashland 

Ranger District are within the historic distribution of the Northern Red Belly Dace and the Sturgeon 

Chub. These species are listed as Sensitive by Region 1 of Forest Service, although neither species has 

been observed or documented on the District. 

Other fish species considered in this analysis include: 1) native nonsensitive species, including the 

Black Bullhead Ameiurus melas, Brook Stickleback Cualea inconstans, Fathead Minnow Pimephales 

promelas, and Lake Chub Couesius plumbeus and, 2) exotic recreational species, including Black 

Crappie Pomoxis nigromaculatus, Green Sunfish Lepomis cyanellus, Large Mouth Bass Micropterus 

salmoides, Rainbow Trout Oncorhynchus mykiss, and Yellow Perch Perca flavescens.. 

Sensitive amphibian species present in the project area include the Great Plains Toad, Northern 

Leopard Frog, and Plains Spadefoot. Common nonsensitive amphibian species found throughout the 

project area include the Boreal Chorus Frog Pseudacris maculata, Tiger Salamander Ambystoma 

tigrinum, and Woodhouse’s Toad Bufo woodhousii. 

In 2005, 111 macroinvertebrate taxa were reported from 16 perennial sites inventoried on the Ashland 

Ranger District. Average macroinvertebrate taxa richness per site was 25 and the highest taxa richness 

reported at 2 sites was 38. Five of the 16 sites were ranked non-impaired (good to excellent biological 

integrity), 6 were slightly-impaired and 5 moderately-impaired (Stagliano et al. 2006). 

Great Plains Toad (Bufo cognatus) 

The Great Plains toad is recognized as a distinct species that ranges across the Great Plains from 

central Mexico to southeastern Alberta (Maxell 2000). In Montana, Great Plains Toads are found 

across the eastern plains, especially on the plateaus between and flanking the Yellowstone and 

Missouri Rivers, and have been documented east of Shelby, Great Falls, Lewiston, and Billings 

Montana (Maxell 2000; Werner et al. 2004). 

The Great Plains Toad is found in headwater drainages and onto prairies, where they are seen around 

glacial potholes, stock reservoirs, irrigation ditches, and smaller coulees (Werner et al. 2004). The 

Great Plains toad is a rapid burrower when active and occupies shallow burrows during the day 

(Fischer et al. 1999, MFWP 2008). This species enters water only to breed, and emergence and 

breeding periods are triggered by early summer thunderstorms after which the toads immediately 

move to breeding areas (Fischer et al. 1999, MFWP 2008). Breeding takes place anytime between 

mid-May and mid-July (Fischer et al. 1999). Females lay up to 45,000 eggs and communal egg laying 

is common; eggs hatch in two to three days and tadpoles metamorphose in three to six weeks (Werner 

et al. 2004). Sexual maturity is achieved at two to three years of age (Werner et al. 2004). 

Great Plains toads have only been documented at about 30 localities across the plains east of the 

Rocky Mountains and their status across this region is largely unknown (Maxell 2000). Risk factors 

relevant to the viability of populations of this species are likely to include grazing, use of pesticides 

and herbicides, nonindigenous species, road and trail development, on- and off-road vehicle use, 

development of water impoundments, habitat loss/fragmentation, and metapopulation impacts (Maxell 

2000). There are five documented observations of Great Plains Toads on the Ashland Ranger District. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-86 Ashland Travel Management Final EIS – Chapter 3

Northern Leopard Frog (Rana pipiens) 

The Northern leopard frog historically ranged from Newfoundland and northern Alberta in the north 

to the Great Lakes region, the desert Southwest and the Great Basin in the south (Maxell 2000). A 

number of isolated populations historically existed in the Pacific Northwest and California (Stebbins 

1985; as reported in Maxell 2000). In Montana they have been documented across the eastern plains 

and in many of the mountain valleys on both sides of the Continental Divide at elevations up to 6,700 

feet (Werner et al. 2004). 

The Northern leopard frog is found in, and adjacent to, permanent slow moving or standing water 

bodies with considerable vegetation, but may range widely into moist meadows, grassy woodlands 

and even agricultural areas (Nussbaum et al. 1983; as reported in Maxell 2000). Adults feed on 

invertebrates, but may cannibalize smaller individuals. Adults overwinter on the bottom surface of 

permanent water bodies, under rubble in streams or in underground crevices that don’t freeze. 

Northern leopard frogs breed from mid-March to early June (Maxell 2000). Mating occurs when 

males congregate in shallow water and begin calling during the day (Maxell 2000). Eggs are laid at 

the water surface in large, globular masses of 150 to 500 (Maxell 2000). Juveniles may move as 

much as 8 kilometers from their natal ponds to their adult seasonal territories (Dole 1971; as reported 

in Maxell 2000). Young and adult frogs often disperse into marsh and forest habitats, but are not 

usually found far from open water (Maxell 2000). 

Over the last few decades the Northern leopard frog has undergone declines across much of the 

western portion of their range (Stebbins and Cohen 1995; as reported in Maxell 2000). Most Northern 

leopard frogs in western Montana became extinct in the 1970’s or early 1980’s. The only 2 population 

centers known to exist in western Montana are near Kalispell and Eureka (Maxell 2000). However, 

the northern leopard frog is still abundant and widespread in southeastern Montana and northwestern 

South Dakota (Reichel 1995; as reported in Hendricks and Reichel 1996). Although this species is 

relatively common on Ashland District of the Custer National Forest, they are considered a Sensitive 

Species due to population declines in the western portion of their historic range. 

Plains Spadefoot (Spea bombifrons) 

The Plains Spadefoot is documented only sparsely in central and eastern Montana, including sightings 

in the mountain valleys of the upper Missouri watershed at elevations up to 5,000 ft (Maxell 2000, 

Werner et al. 2004). 

Spadefoots are a prairie species, associated with areas of sandy soil or gravel-loam (Werner et al. 

2004). Their lifestyle associates them with large temporary wetlands easily flooded after heavy rains 

(Fischer et al. 1999). When conditions are such that adults retreat underground, the spades on the hind 

feet are used to dig backwards into the soil until pockets of moist soil are encountered, sometimes at 

depths of almost a meter (MFWP 2008). Plains Spadefoots are seldom encountered outside the 

breeding season since they spend most daylight hours underground (Werner 2004). The Plains 

Spadefoot reaches sexually maturity at one to two years of age and breeding generally takes place 

from May to August following heavy rainfall at temperatures above 54o F (Fischer 1999, Werner et al. 

2004). Females lay close to one thousand eggs, tadpoles develop in two to six days, and 

metamorphosis occurs from three to six weeks (Werner at al. 2004). 

In the past 125 years, this species has been documented at about 40 localities across the plains and in 

the mountain valleys east of the Continental Divide and their status across this region is almost 

completely unknown (Maxell 2000). Risk factors relevant to the viability of populations of the Plains 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-87

Spadefoot are likely to include grazing, road and trail development, on- and off-road vehicle use, use 

of pesticides and herbicides, development of water impoundments, habitat loss/fragmentation, and 

metapopulation impacts (Maxell 2000). Six current, documented observations exist for the Plains 

Spadefoot on the Ashland Ranger District. 

Watershed Condition and Stream Habitat Characteristics 

For the purpose of this analysis generalizations of watershed condition, and potential impacts to 

aquatic habitat and biota relative to travel routes, were inferred from: 1) perennial stream crossings by 

FS routes, 3) total perennial stream miles, 3) intermittent stream crossings by FS routes, and 4) TMDL 

listed streams. Sediment delivery and riparian habitat loss are generally positively related to the 

aforementioned route related variables, and generally but not universally are indicative of reduced 

aquatic habitat capability (e.g., Furniss et al. 1991, Dunham and Rieman 1999, Forman et al. 2003). 

Habitat quality within watersheds is variable, in part because of other land use activities and because 

the ultimate effects of travel routes also depend on location of those routes, geology and soils of the 

watershed, maintenance of the routes, and other factors (Furniss et al. 1991). 

There is a distinction between travel route effects and the effects of various modes of travel. In some 

cases, the actual use, or mode of travel is inconsequential. Rather, it is the facility (road or trail) that 

has the potential to impact aquatic habitat and biota. Often, roads have more impacts than trails 

because of their wider prisms, larger cut-and-fill slopes and more extensive ditch routing systems. 

However, motorized and mixed use trails also hold potential to disturb soils and increase erosion. 

Sediment production from All Terrain Vehicle (ATV) use on 10 user created route segments was 

reported to be six times higher than sediment production on 21 forest road segments in the Upper 

South Platte River watershed in Colorado (Welsh 2008). Deluca et al. (1998) found horses 

consistently produced more sediment than hikers or llamas, and horses have also been reported to 

produce higher sediment yields than hikers, mountain bikers, and motorcycles on similar trails 

(Wilson and Seney 1994). Although all transportation routes and uses (motorized and nonmotorized) 

can produce sediment, Best Management Practices (BMP), facility improvements, and scheduled 

maintenance can minimize potential for adverse effects to aquatic systems on all routes. 

Influences of Transportation Systems on Aquatic Habitat and Biota 

Potential effects of travel routes and various modes of travel on aquatic habitat and species are 

combined under one primary aquatics issue (effects to aquatic habitat and biota). However, the issue 

is segregated into various components of concern. Those components are: 1) Travel route impacts on 

stream channel form and function, including sediment delivery to streams and subsequent effects on 

aquatic habitat and biota; 2) Travel route impacts on riparian ecosystems; 3) Travel route impacts on 

habitat fragmentation; and 4) Travel route impacts on exploitation and modification of recreational 

and native fisheries. 

Stream Channel Form and Function 

Travel routes may affect stream channel form and function, including sediment delivery to streams 

and subsequent effects on aquatic habitat and biota. Roads and trails constructed for Forest travel 

disturb soils and increase the potential for erosion and sediment transport and deposition in streams 

(Furniss et al. 1991, Forman et al. 2003). Likewise, motorized and non-motorized uses (motorcycles, 

ATVs, horses, mountain bikes, and hikers) can further disturb soils and increase potential for erosion 

and sediment delivery. Sediment concerns are generally highest when roads and trails are not 

sufficiently drained (Furniss et al. 1991). Water and sediment can concentrate on roads and trails 

during spring snowmelt runoff or periods of intense rain and be delivered to streams. With sufficient 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-88 Ashland Travel Management Final EIS – Chapter 3

drainage, water and sediment from upland segments of trails and roads can be diverted off trails or 

roads, filtered through forest vegetation, and not routed to streams (Furniss et al. 1991). As such, 

upland segments of roads and trails can generally be designed to mitigate sediment delivery concerns. 

One primary concern is erosion and sediment delivery from road and trail segments near stream 

crossings (Furniss et al. 1991, Forman et al. 2003). 

Sediment entering stream channels can affect channel shape and form, stream substrates, and the 

structure of fish and amphibian habitats (Everest et al. 1987, Hicks et al. 1991, Waters 1995, McIntosh 

et al. 2000, Werner et al. 2004). Common responses of macroinvertebrate communities to elevated 

concentrations of sediment can include decreased total abundance, decreased number of species, and a 

shift from a community of sediment intolerant species to a community of sediment tolerant species. 

To evaluate the effects travel routes and modes of travel have on sediment and aquatic habitats, one 

must project changes in erosion and sediment delivery against the structural framework of the 

channel. Streams are not similar in terms of their inherent sensitivity to changes in streamflow or 

sediment discharge, their inherent stability, or their ability to recover from sediment related change 

(Rosgen 1996, Hogan and Ward 1997). Furthermore, stream habitats described in terms of pools, 

riffles and spawning gravel are geomorphic entities that are selectively influenced or controlled by 

channel type, streamflows and sediment inputs (Rosgen 1996, Hogan and Ward 1997). 

Pools are the result of local scour or impoundment induced by structural controls (e.g., boulders, large 

woody debris) in the channel or streambank (Rosgen 1996, Hogan and Ward 1997). Pools are areas 

of higher velocity during peak flows, but at low flows their depth creates a depositional environment 

for fine sediment. Increased sediment from roads and trails can influence the amount and quality of 

pool habitat if sediment increases are sufficient to alter channel morphology by filling in pools and 

increase width/depth ratios. For lower-gradient, more sensitive channel types with moderate 

sensitivity to increased sediment, excessive sediment loading can reduce maximum pool depth and 

residual pool volume thereby reducing the quality and availability of pool habitats important to fish 

and amphibians (Rosgen 1996, Hogan and Ward 1997, Werner 2004). 

Riparian Ecosystems 

Forest roads and trails constructed for travel activities within riparian corridors can alter or remove 

riparian vegetative communities, with direct and indirect impacts on riparian and stream ecosystems 

(Furniss et al. 1991, Forman 2003). Riparian vegetation modification may directly remove security 

cover and reduce stream shading, resulting in increased water temperatures in summer and colder 

temperatures in winter. Removal of riparian vegetation may indirectly result in reduced streambank 

stability and sediment filtering capacity of vegetation, both of which can result in increased sediment 

delivery rates with effects as described above (e.g., Thornton et al. 1997). Riparian vegetation 

modification may also change stream channel form and function, and may modify aquatic food webs 

and nutrient cycles. Potential for changes in channel form and function is also related to the inherent 

stability of various channel types. 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). 

Habitat Fragmentation 

Roads and trails can fragment aquatic habitats where stream crossings create barriers for upstream 

movement of aquatic species (Furniss et al. 1991). This typically occurs where culverts and fords are 

not designed to allow for upstream fish and amphibian passage. Crossings with culverts can be 

barriers usually because of outfall barriers, excessive velocities, insufficient water depths, disorienting 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-89

turbulent flow patterns, lack of resting pools below the barrier or a combination of these conditions. 

Aquatic organisms upstream of the barrier are then geographically and hence, reproductively isolated 

from the downstream population. Habitat fragmentation can reduce viability of fish populations by a 

variety of stochastic, deterministic and genetic mechanisms (e.g., Rieman et al. 1993). Based on field 

reviews and recent culvert replacement information, no existing, perennial stream/route crossings on 

the District are known to hinder aquatic organism passage. 

Exploitation of Recreational and Native Fisheries 

Travel routes that lead to popular fishing destinations may have an indirect effect on fish populations 

by over-exploiting fish stocks that are vulnerable to high angling pressure. Over-exploitation of fish 

stocks may result in population declines (e.g., Rieman and McIntyre 1993). Population declines in 

small fish populations may render them at higher risk of extinction (Rieman et al. 1993). 

The Montana Department of Fish, Wildlife and Parks (MFWP) manage fish and wildlife populations 

throughout the state. Lake management plans have been developed for most lakes and reservoirs 

throughout the Custer National Forest. These plans address recruitment potential and angling pressure 

effects. Where natural recruitment does not meet population goals, supplemental stocking is generally 

prescribed. Lake management plans and special regulations effectively mitigate the over-exploitation 

component of the aquatics issue. Thus, this component is dismissed from further detailed analysis. 

Transportation Systems Analysis 

Roads and trails were evaluated for impacts to water quality or natural channel processes (Water 

Quality Section). This analysis evaluates the subsequent potential impacts to aquatic habitat and biota 

in relation to those impacts. An in depth review of effects of roads and trails on fish and amphibians, 

and their habitats is provided by Furniss et al. (1991), Maxell (2000), and Forman et al. (2003). 

The potential for routes to impact water quality was evaluated based on the number of perennial 

stream crossings by FS routes, total perennial stream miles, intermittent stream crossings by FS 

routes, and TMDL listed streams. 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. A summary of 

selected natural characteristics, human activities, and aquatic species presence are provided in Table 

3-29 by 6 HUC (hydrologic unit code) watersheds. Quantifiable Forest Service activities include past 

timber harvest, fire (prescribed fire and wildfire), and existing transportation system attributes. 

Potential effects to fish and amphibians and their habitats related to proposed actions are evaluated 

under indirect effects by action alternative.
Page 3-90 Chapter 3: Affected Environment and 

Ashland Travel Mana

Table 3-29. Summary of Watershed Characteristics, Watershed Scale Influences, Fisheries Resources, Seand Macroinvertebrate Communities on the Ashland Ranger District.

Watershed # Watershed Name 

Watershed Acres 

Percent Watershed 

Forest Service 

FS Perennial Stream 

Miles 

Harvest Acres 

Fire Acres 

FS Road Miles 

Total Stream Crossings 

FS Intermittent 

Crossings 

FS Perennial Crossings 

Watershed (Road) Risk 

100901020210 Otter Creek-Brian Creek 36,062 78 21 376 19,851 50 182 60 9 HIG100901020602 Ash Creek 1,0779 71 2 0 1,673 5 30 7 7 HIG100901020203 Otter Creek-Horse Creek 21,585 90 19 47 7,891 27 67 31 6 HIG100901020601 Upper Beaver Creek 14,298 98 5 478 886 30 42 28 2 HIG100901020209 Fifteenmile Creek 22,566 66 2 86 3,790 29 69 17 2 HIG100901020208 Elk Creek 19,754 68 5 0 48 24 77 27 1 HIG100901020205 Taylor Creek 29,059 100 2 268 5,690 41 83 35 1 HIG100902070206 Bloom Creek 30,311 82 2 266 4,832 28 64 40 1 HIG100901020301 Tenmile Creek 27,351 89 1 0 2,983 22 90 31 1 HIG100901010803 Lee Creek 30,049 63 1 0 5,617 24 116 33 1 HIG100901020303 Home Creek 37,810 89 4 2860 13,879 66 160 100 0 HIG100901010804 East Fork Hanging Women Creek1 22,019 94 2 538 3,187 36 75 54 0 HIG100901020104 Lower Bear Creek 13,516 94 9 3 2,120 26 59 34 0 MO100901020404 Poker Jim Creek 12,811 89 6 165 1,399 13 33 15 0 MO100901020406 O'Dell Creek 29,692 92 5 603 20,867 43 92 59 0 MO100901020603 Middle Beaver Creek 18,883 50 1 0 35 20 81 31 0 MO100901020204 Indian Creek 33,062 49 1 72 168 19 104 26 0 MO100901020501 Tongue River-Double E Creek 15,151 23 1 0 428 3 44 4 0 MO100901020206 Lyon Creek 19,615 100 1 785 1,962 29 45 29 0 MO
Chapter 3: Affected Environment and 

Page 3-91 Ashland Travel Mana

Table 3-29. Summary of Watershed Characteristics, Watershed Scale Influences, Fisheries Resources, Seand Macroinvertebrate Communities on the Ashland Ranger District.

Watershed # Watershed Name 

Watershed Acres 

Percent Watershed 

Forest Service 

FS Perennial Stream 

Miles 

Harvest Acres 

Fire Acres 

FS Road Miles 

Total Stream Crossings 

FS Intermittent 

Crossings 

FS Perennial Crossings 

Watershed (Road) Risk 

100901020103 Little Bear Creek 18,833 14 1 0 302 3 51 2 0 MO100902070204 Powder River-Plum Creek 22,555 25 1 0 5,386 9 44 10 0 MO100901020302 Threemile Creek 32,925 88 1 160 19,113 36 93 54 0 MO100901021102 Lower Little Pumpkin Creek 39,175 12 1 59 150 9 144 10 0 MO100901020409 Tongue River-King Creek 31,387 34 0 0 9,686 17 107 47 0 MO100901020407 Tongue River-Poker Teechee Creek 21,367 24 0 0 1 6 78 25 0 MO100901020304 East Fork Otter Creek 29,127 90 0 1,985 3,681 35 115 51 0 MO100901010801 Lower Hanging Women Creek1 33,404 8 0 0 1 3 92 0 0 MO100901020305 Otter Creek-Newell Creek 30,339 18 0 0 4191 4 82 7 0 MO100901020504 Tongue River-Colbert Coulee 26,625 5 0 0 348 1 15 1 0 LO100901021002 Pumpkin Creek-Doonan Gulch 35,691 17 0 31 2410 12 118 9 0 LO100901021101 Upper Little Pumpkin Creek 27,095 76 0 356 9 20 118 19 0 LO100901020703 Liscom Creek 30,444 32 0 0 31 14 168 44 0 LO100901020207 Paget Creek 9,042 96 0 194 8,250 22 30 23 0 LO100901021003 Pumpkin Creek-Fiftyfour Creek 38,844 11 0 0 16 4 117 13 0 LO100901021001 Headwaters Pumpkin Creek 27,201 6 0 0 5 4 98 5 0 LO100901020403 Tongue River-Birney Creek 27,298 8 0 0 0 1 85 0 0 LO100901020411 Tongue River-Walking 17,669 6 0 0 949 0 53 0 0 LO
Page 3-92 Chapter 3: Affected Environment and 

Ashland Travel Mana

Table 3-29. Summary of Watershed Characteristics, Watershed Scale Influences, Fisheries Resources, Seand Macroinvertebrate Communities on the Ashland Ranger District.

Watershed # Watershed Name 

Watershed Acres 

Percent Watershed 

Forest Service 

FS Perennial Stream 

Miles 

Harvest Acres 

Fire Acres 

FS Road Miles 

Total Stream Crossings 

FS Intermittent 

Crossings 

FS Perennial Crossings 

Watershed (Road) Risk 

Horse Coulee 

100901020604 Lower Beaver Creek 15,080 9 0 0 0 0 36 0 0 LO100901020505 Tongue River-Bringoff Creek 33,093 7 0 0 1,090 0 31 0 0 LO100902070209 Fire Creek 17,365 2 0 0 0 0 40 0 0 LOSUM 1,008,934 NA 93 9,332 152,924 736 3,228 981 31 

H-

M-

L-

1 TMDL listed stream or tributary to. *

Fisheries Resources: ER - Exotic Recreational Species, NNS - Native Nonsensitive Species. 

** Sensitive Amphibians Species: GPT - Great Plains Toad, NLF - Northern Leopard Frog, PSF- Plains Spadefoot. ***

Macroinvertebrate sites: R - Sites with rare taxa, P- Sites with potential to recover to biologically intact condition (Stagliano et al. 2006).
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-93

3.4.1.5 Environmental Consequences – Fisheries and Aquatic 

Effects Common to All Action Alternatives – Fisheries and Aquatics 

Direct Effects 

Direct effects are those resulting in the direct mortality of fish or amphibians, or the destruction of fish 

or amphibian habitat. Direct effects occur at the same time and place as the proposed activity. 

Relative to transportation systems, only the installation, reconstruction or removal of stream crossing 

structures, and route construction or decommissioning could result in direct effects to fish and 

amphibians. The proposed actions in the project area do not include any route related construction 

activities that would result in direct effects to aquatic habitats or biota. Therefore, no direct effects are 

evaluated in this analysis. 

Indirect Effects 

Indirect effects occur at a later time or distance from the proposed action. Indirect effects are those 

resulting in changes to fish and amphibian habitat, individuals, or populations as a result of changes in 

the aquatic environment. Detrimental effects to aquatic species could result from increased sediment 

levels entering stream channels, wetlands, springs or impoundments, changes in streambank stability 

due to near-bank activities, and modification in water temperature regimes induced by a reduction in 

riparian vegetation. 

Routes with proposed actions are evaluated for indirect effects to fisheries and amphibians. A 

summary of route related actions and the potential for these actions to reduce or not reduce the risk of 

impacting water quality can be found in the Water Quality Section, Related Route Risk By Action

(Table 3-25). In general terms, the only actions that would tend to increase risk are designating nonsystem roads or trails (routes) for public or administrative motorized use. These actions, when 

compared to the No Action Alternative, add additional route miles to the landscape, and do not reduce 

the risk of indirect and cumulative effects to aquatic ecosystems. However, these routes already exist 

on the landscape and are currently available for public use. Therefore, there would be no change in 

risk when comparing non-system route designation actions to the existing condition. All other 

proposed actions would tend to decrease risk or not change risk for comparisons to both the No Action 

Alternative and the existing condition. Decreased risk actions include: 1) converting system roads to 

administrative use, and 2) not designating system and non-system routes. 

Effects by Alternative – Fisheries and Aquatics 

Indirect effects to fisheries resources, sensitive amphibians, and macroinvertebrate communities for 

moderate and high risk watersheds are displayed in Table 3-30. Low risk watersheds are not 

evaluated for indirect effects to aquatic resources because they either do not contain perennial streams, 

or roads on National Forest System land, or both. 

Alternative A - Indirect Effects 

Fifteen of the 19 fisheries resource, sensitive amphibian, and macroinvertebrate watersheds (referred 

to hereafter as aquatic resource watersheds) have a net increase in risk under Alternative A (Table 3-

30). The increased risk to aquatic resource watersheds is attributed to the addition of 84 miles of nonsystem roads to the transportation system and only 36 miles of route related actions that reduce risk. 

Therefore, there is a net increase in risk of 48 miles under Alternative A. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-94 Ashland Travel Management Final EIS – Chapter 3

Table 3-30. Summary of Route Miles by Risk for Moderate and High Risk Watersheds and for 

Fisheries Resource, Sensitive Amphibian, and Macroinvertebrate Watersheds When Compared to 

the No Action Alternative 

Alternative A Alternative B Alternative B Modified 

Watershed Increase 

Risk 

Decrease 

Risk 

Increase 

Risk 

Decrease 

Risk 

Increase 

Risk 

Decrease 

Risk 

Ash Creek 0.1 0.4 0.0 0.4 0.0 0.7 

Bloom CreekA 9.2 1.3 5.2 7.6 5.2 8.9 

East Fork Hanging Women 

CreekA,M 7.0 0.0 1.8 7.3 1.8 11.1 

East Fork Otter CreekA 3.5 8.7 1.6 17.6 1.6 17.2 

Elk CreekA 3.8 2.7 0.2 7.6 0.2 7.6 

Fifteenmile CreekA 2.4 0.8 0.4 4.7 1.4 4.7 

Home CreekA 9.5 3.8 4.8 9.7 4.8 8.2 

Indian Creek 4.0 3.1 2.4 5.9 2.4 7.7 

Lee CreekA 2.9 3.7 0.6 11.4 0.0 11.4 

Little Bear CreekA 1.4 0.1 0.8 0.1 0.8 0.3 

Lower Bear CreekA,F,M 2.3 0.0 1.5 4.8 1.5 4.8 

Lower Hanging Women Creek1 1.4 0.4 1.0 2.4 1.0 2.4 

Lower Little Pumpkin Creek 0.8 1.2 0.8 2.3 0.8 1.2 

Lyon CreekA 8.9 1.9 3.5 1.9 3.5 2.6 

Middle Beaver CreekA 0.2 3.0 0.0 12.6 0.0 7.7 

O'Dell CreekA,F,M 3.4 3.0 0.9 12.1 1.1 12.0 

Otter Creek-Brian CreekA,F,M 2.6 3.3 1.8 9.7 1.8 10.2 

Otter Creek-Horse CreekA,F,M 5.2 0.2 0.0 9.5 0.2 9.3 

Otter Creek-Newell Creek 0.0 0.0 0.0 0.0 0.0 0.0 

Poker Jim CreekA,F 0.1 0.0 0.1 1.6 0.1 9.6 

Powder River-Plum CreekA 2.8 1.7 0.0 4.3 0.0 4.3 

Taylor CreekA,F,M 9.1 1.5 4.3 6.7 4.3 8.8 

Tenmile CreekA 2.7 0.3 1.8 2.6 1.8 2.6 

Threemile CreekA 7.0 0.0 3.3 0.1 6.1 3.3 

Tongue River-Double E Creek 0.0 2.9 0.0 2.9 0.0 2.9 

Tongue River-King Creek 1.1 0.0 0.0 0.3 0.0 2.2 

Tongue River-Poker Teechee Creek 0.4 2.9 0.3 2.9 0.3 2.5 

Upper Beaver Creek 4.7 0.0 0.5 8.2 2.9 3.3 

Total Miles by Action Risk 96.5 46.9 37.6 157.3 43.5 167.6 

Total Miles For Aquatic Resource 

Watersheds (Fisheries, Sensitive 

Amphibian, and 

Macroinvertebrate Combined) 

84 36 32.6 131.9 36.2 144.6 

A Sensitive Amphibian Watershed F Fisheries Resource Watershed 

M Macroinvertebrate Watershed 

Alternative B - Indirect Effects 

Alternative B proposes actions that result in a net decrease in risk in 16 of the 19 moderate and high 

risk aquatic resource watersheds (Table 3-30). The net decreased risk is attributed to 131.9 miles of 

route related actions that reduce risk and 32.6 miles that increase risk. The 3 aquatic resource 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-95

watersheds that have a net increase in risk include the Little Bear Creek, Lyon Creek, and Threemile 

Creek watersheds. All of these 3 watersheds harbor sensitive amphibian species. However, the net 

increased risk of 5.5 total miles for these watersheds is associated with 3.6 miles of actions that 

designate non-system routes to administrative use, and 1.9 miles related to designating non-system 

routes to public use routes. Therefore, although these routes will remain on the landscape, 3.6 miles 

will receive low levels of use and their designation should have negligible to nonexistent indirect 

effects to sensitive amphibian species. The designation of 1.9 miles of non-system routes to public use 

routes would occur in two moderate risk aquatic resource watersheds (Lyons Creek and Threemile 

Creek). 

Alternative B Modified - Indirect Effects 

Alternative B Modified proposes actions that result in a net decrease in risk in 16 of the 19 moderate 

and high risk aquatic resource watersheds (Table 3-30). The net decreased risk is attributed to 144.6 

miles of route related actions that reduce risk and 36.2 miles that increase risk. The 3 aquatic resource 

watersheds that have a net increase in risk include the Little Bear Creek, Lyon Creek, and Threemile 

Creek watersheds. All of these 3 watersheds harbor sensitive amphibian species. However, the net 

increased risk of 4.2 total miles for these watersheds is associated with 2.3 miles of actions that 

designate non-system routes to administrative use, and 1.9 miles related to designating non-system 

routes to public use routes. Therefore, although these routes will remain on the landscape, 2.6 miles 

will receive low levels of use and their designation should have negligible to nonexistent indirect 

effects to sensitive amphibian species. The designation of 1.9 miles of non-system routes to public use 

routes would occur in two moderate risk aquatic resource watersheds (Lyons Creek and Threemile 

Creek). 

No Action Alternative 

See discussion of No Action Alternative below in Cumulative Effects sections. 

Cumulative Effects 

Cumulative effects are defined as "the impact on the environment that results from the incremental 

impact of the action when added to other past, present, and reasonably foreseeable actions, regardless 

of what agency or person undertakes such other actions. Cumulative impacts can result from 

individually minor but collectively significant actions taking place over a period of time" (CFR 40 

1508.7). Past, present, and reasonably foreseeable events and activities that have and will likely 

continue to incrementally impact aquatic species and their habitats, in the 40 watersheds (on and off 

CNF) of the project area, include: wildfire/prescribed fire, mining, grazing, timber harvest, 

transportation networks, and recreation (camping, fishing, hunting, etc.). 

Effects Determination by Alternative 

No Federally listed threatened or endangered fish or amphibian species, designated critical habitat, 

fish or amphibian species proposed for Federal listing, or proposed critical habitat occur in the project 

area. Forest Service sensitive fish and amphibian species considered in this analysis include the 

Northern Redbelly Dace, Sturgeon Chub, Great Plains Toad, Northern Leopard Frog, and Plains 

Spadefoot. The following table summarizes the potential effects to aquatic species in the project area. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-96 Ashland Travel Management Final EIS – Chapter 3

Table 3-31. Determination of potential impacts to sensitive fish and amphibian species, 

recreational fisheries, and macroinvertebrate communities

Aquatic Species DeterminationF

15

Alternative Alternative A Alternative B 

Alternative 

B Modified 

No Action 

Alternative 

Northern Redbelly Dace 

Phoxinus eos NI NI NI NI 

Sturgeon Chub 

Macrhybopsis gelida NI NI NI NI 

Great Plains Toad 

Bufo cognatus NI NI NI NI 

Northern Leopard Frog 

Rana pipiens MIIH BI BI MIIH 

Plains Spadefoot 

Spea bombifron MIIH BI BI MIIH 

Recreational Fish Species MIIH BI BI MIIH 

Macroinvertebrate Communities MIIH BI BI MIIH 

Cumulative Effects - Effects of All Routes Including Those Without Proposed Actions 

Existing condition allows for motorized use of all routes on the Forest landscape unless signed 

otherwise, including system and non-system routes. Therefore, if the existing condition were to 

continue into the foreseeable future there would be no reduction in risk to aquatic species and habitat, 

and any existing impacts and risks in the 19 aquatic resource occupied watersheds (Table 3-29) would 

be expected to continue until route maintenance occurred. All alternatives, including the No Action 

Alternative, include routes without proposed actions. Under the action alternatives, actions would 

occur by default for these routes, whereby some system routes would be designated and some nonsystem routes would not be designated without further action. When these default actions are 

compared against the existing condition there is a marked difference among the action alternatives in 

the percent decrease in cumulative risk to water quality and consequently to aquatic biota and their 

habitat. Alternative B Modified has a 36% decrease in risk to water quality in relation to existing 

condition, while Alternative A would have a 12% decrease, Alternative B a 37% decrease and the No 

Action Alternative an 18% decrease (Table 3-28, Water Quality Section). 

Action Alternatives 

The cumulative effects of the individual action alternatives (A, B, and B Modified) when combined 

with past activities and natural processes, would result in minimal negative impacts to aquatic biota, 

including sensitive aquatic species, and their habitats throughout the project area. However, 

Alternative B Modified provides greater protection for aquatic resources than Alternatives A and B 

(net decrease in risk of 108.4 miles versus net decreases of 48 and 99.3 miles; Table 3-30), and all 

action alternatives designate substantially less miles than the No Action Alternative. 

No Action Alternative 

 

15 NI = No Impact; MIIH = May Impact Individuals or Habitat but will not likely contribute to a trend towards Federal 

listing or loss of viability to the population or species; WIFV = Likely to result in a trend to Federal listing or loss of 

viability; and BI = Beneficial impact.
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-97

Nineteen of 28 moderate and high risk watersheds and 3 of the 12 low risk watersheds on the Ashland 

District harbor fisheries, sensitive amphibians, or macroinvertebrate resources (Table 3-29). The No 

Action Alternative designates the most system routes within these watersheds without any additional 

actions to reduce risk to aquatic resources (736.6 miles; Table 3-28 Water Quality Section). 

Sedimentation produced from these additional routes would potentially impact aquatic habitat and 

species across the District.

Effects Common to All Alternatives at the Watersheds Scale 

The cumulative effects of the individual alternatives when combined with past activities and natural 

processes would result in negligible negative impacts to aquatic biota, including sensitive aquatic 

species, and their habitats throughout the project area. 

At the watershed scale, proposed actions are not considered to be substantial enough to cause 

measurable changes in water quality, quantity or channel processes under any action alternative. 

Consequently, cumulative effects to aquatic species and their habitats are not anticipated to result 

from any of the action alternatives. However, various actions proposed under the action alternatives 

have the potential to reduce or not reduce the risk of impacts to aquatic habitats and species. 

Alternatives B and B Modified include the most route mile actions that would result in beneficial 

impacts (reduce risk) to aquatic systems. 

3.4.1.6 Conclusion - Fisheries and Aquatics 

Proposed actions with site specific effects that potentially increase risk of adverse impacts to aquatic 

habitat and species are negligible under Alternatives B and B Modified. Compliance relative to the 

Record of Decision for this DEIS, only pertains to those routes with proposed actions. Under 

Alternatives B and B Modified, actions related to moderate and high risk routes are expected to 

benefit or maintain aquatic habitats, and fish and amphibian species. Only minimal indirect effects to 

sensitive aquatic species are anticipated under Alternative A. Therefore, the Ashland District is 

anticipated to move towards compliance with Forest Plan standards and state and federal water quality 

regulations under any action alternative. However, Alternatives B and B Modified initiate the most 

rapid rate of recovery and compliance should be achieved in the shortest timeframe under these 

alternatives. Alternative B Modified provides greater protection for aquatic resources than Alternative 

B (net decrease in risk of 108.4 miles versus a net decrease of 99.3 miles; Table 3-30). 

Appendix D includes opportunities to reduce impacts to water quality, aquatic habitat and biota 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. However, 

construction, reconstruction, maintenance and decommissioning proposals will require future and 

separate NEPA decisions. 

Relative to sensitive fish and amphibian species, none of the alternatives are likely to result in a trend 

towards Federal listing or loss of viability. The following table summarizes the effects determinations 

for sensitive aquatic species and aquatic species of concern. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-98 Ashland Travel Management Final EIS – Chapter 3

Table 3-32. Fisheries and Aquatics Effects Summary

Indicator Alternative A Alternative B Alternative B 

Modified No Action 

Sensitive Fish and Amphibian Species

Number of Species with No Impact or Beneficial 

Impacts 3 5 5 3 

Number of Species with potential to effect 

individuals or Habitat but will not Likely 

Contribute to a trend towards Federal Listing or 

Loss of Viability to the Population or Species 

2 0 0 2 

Number of Species likely to result in a trend to 

Federal listing or loss of viability 0 0 0 0 

Recreational Fish Species 

Alternatives with No Impact or Beneficial Impact No Yes Yes No 

Alternatives with potential to effect individuals or 

Habitat but will not Likely Contribute to a Loss of 

Viability to the Population or Species 

Yes No No Yes 

Rare Macroinvertebrate Populations

Alternatives with No Impact or Beneficial Impact No Yes Yes No 

Alternatives with potential to effect individuals or 

Habitat but will not Likely Contribute to a Loss of 

Viability to the Population or Species 

Yes No No Yes 

3.4.2 SOILS 

Overview of Changes from the Draft to the Final EIS 

 Additional narrative to clarify analysis results and address comments received on the DEIS. 

 Analysis of Alternative B Modified. 

Introduction 

Adding routes to the system and designating motorized uses on roads and trails could increase soil 

compaction and soil erosion leading to a decrease in soil productivity, and soil quality. 

3.4.2.1 Affected Environment – Soils 

The project area is located in southeast Montana on the Ashland Ranger District. The Ashland Ranger 

District is part of the Powder River Basin Section of the Great Plains-Palouse Dry Steppe Province. 

The area includes gently rolling to steep dissected plains on the Missouri Plateau. There are some 

steep, flat topped buttes, badland like topography, and eroded escarpments. The Soil Survey of 

Powder River Area, Montana (USDA SCS, 1971) was used to determine erosion hazards ratings, 

suitability of the landscape for natural surfaced roads, and describe landforms for the Ashland District. 

Soil survey information can be downloaded from the soil data mart on the World Wide Web at 

Hhttp://soildatamart.nrcs.usda.gov/. (Montana soil survey information is also available at 

(Hhttp://nris.state.mt.us/nrcs/soils/datapage.html or 

Hhttp://www.mt.nrcs.usda.gov/soils/mtsoils/official.html). Soil survey information reports can also be 

accessed directly from the web using Web Soil Survey (Hhttp://websoilsurvey.nrcs.usda.gov/app/). 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-99

Erosion risk ratings are provided from the county soil survey data. They are estimates of the potential 

for erosion after soil disturbance and are based on the inherent soil resistance to erosion and the 

erosive forces acting upon them. Slight hazard implies little to no potential for erosion; moderate 

hazard indicates that some erosion is likely, that the roads or trails may require occasional 

maintenance, and that simple erosion control measures are needed; and a severe hazard implies that 

considerable erosion is expected, that the roads or trails require frequent maintenance, and that costly 

erosion control measures are needed. Of the current Forest Service routes approximately 1% is 

classified in the slight hazard rating, 34% in moderate, 65% in severe, and a trace has not been rated. 

The ratings for the suitability for natural surface roads interpretation indicate the suitability for using 

the natural surface of the soil for roads. The ratings are based on slope, rock fragments on the surface, 

plasticity index, content of sand,, the Unified classification of the soil, depth to a water table, ponding, 

flooding, and the hazard of soil slippage. The soils are described as well suited, moderately suited, or 

poorly suited to this use. Well suited indicates the soil has features that are favorable for the specified 

kind of roads and has no limitations. Good performance can be expected, and little or no maintenance 

is needed. Moderately suited indicates the soil has features that are moderately favorable for the 

specified kind of roads. One or more soil properties are less than desirable, and fair performance can 

be expected. Some maintenance is needed. Poorly suited indicate the soil has one or more properties 

that are unfavorable for the specified kind of roads. Overcoming the unfavorable properties requires 

special design, extra maintenance, and costly alteration. Of the current Forest Service routes only a 

trace is classified as well suited for using the natural surface of the soil for roads, approximately 43% 

are moderately suited, 57% are poorly suited and a trace has not been rated. 

Not rated is used for those map units that do not have soil components that can be rated for the 

particular use. For example, rock outcrop would be not rated. 

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. 

The interpretations for the suitability for natural surface roads and trails are very similar to the erosion 

hazard rating. Information for both are displayed in the tables but discussion will focus on the erosion 

hazard, as that has the most direct effect on soil productivity. Data presented show the miles of roads 

and trails in soil map units that have at least one soil component that has a specific hazard rating, and 

depicts the most limiting rating for the soil map unit. These interpretations are a guide to how soils 

identified in these map units might respond to management. In most cases, on site investigation is 

needed to accurately identify soils and hazard ratings. It is highly likely that the miles of routes on 

high erosion hazard soils is less than that identified. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-100 Ashland Travel Management Final EIS – Chapter 3

Regulatory Framework 

Forest and Rangeland Renewable Resource Planning Act of 1974 and National Forest 

Management Act of 1976 

In response to requirements set forth in these two Acts, final rules on National Forest System Land 

and Resource Management Planning established specific minimum management requirements to be 

met in accomplishing the goals and objectives for National Forest System lands. These requirements 

were intended to guide the development, analysis, approval, implementation, monitoring, and 

evaluation of forest plans. Requirements specific to soils are found in 36 CFR 219.27, volume 47, 

#190, 09/30/82 (Federal Register 1982) as follows: 

(a) Resource protection. All management prescriptions shall: 

(1) Conserve soil and water resources and not allow significant or permanent 

impairment of the productivity of the land; 

(2) Consistent with the relative resource values involved, minimize serious or longlasting hazards from flood, wind, wildfire, erosion. 

(f) Soil and Water Conservation. 

Conservation of soil and water resources involves the analysis, protection, 

enhancement, treatment, and evaluation of soil and water resources and their responses 

under management and shall be guided by instructions in official technical handbooks. 

These handbooks must show specific ways to avoid or mitigate damage, and maintain 

or enhance productivity on specific sites. These handbooks may be regional in scope or, 

where feasible, specific to physiographic or climatic provinces. 

Multiple Use Sustained Yield Act of 1960 

It is the policy of the Congress that the national forests are established and shall be administered for 

outdoor recreation, range, timber, watershed, and wildlife and fish purposes (16 USC 2 (I); Sec 528 ). 

The terms multiple use and sustained yield are defined as: 

Multiple use: The management of all the various renewable surface resources of the national 

forests so that they are utilized in the combination that will best meet the needs of the 

American people; making the most judicious use of the land for some or all of these resources 

or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use to conform to changing needs and conditions; that some land will be used 

for less than all of the resources; and harmonious and coordinated management of the various 

resources, each with the other, without impairment of the productivity of the land, with 

consideration being given to the relative values of the various resources, and not necessarily 

the combination of uses that will give the greatest dollar return or the greatest unit output. 

Sustained yield: The achievement and maintenance in perpetuity of a high-level annual or 

regular periodic output of the various renewable resources of the national forests without 

impairment of the productivity of the land. 

Regional Direction 

The most recent soil quality standards were adopted by the Northern Region Regional Office effective 

November 12, 1999. (Forest Service Manual (FSM) 2500 - WATERSHED AND AIR 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-101

MANAGEMENT, R-1 SUPPLEMENT 2500-99-1). The objectives are: To meet direction in the 

National Forest Management Act of 1976 and other legal mandates. To manage National Forest 

System lands under ecosystem management principles without permanent impairment of land 

productivity and to maintain or improve soil quality. 

Custer National Forest Land and Resources Management Plan 

Management goals for soil, water and riparian resources are identified in the Forest Plan under 

Chapter II - Forest Wide Management Direction and Chapter III – Management Area Direction. 

The Forest Plan goal for watershed management is to: 

“[E]nsure that soil productivity is maintained and that water quality is maintained at a level 

which meets or exceeds state water quality standards.” (page 4) 

Forest Plan objectives for soil and water resources are: 

“National Forest System lands will be managed so that the soil and watershed conditions are in 

a desirable condition and will remain in that condition for the foreseeable future. Soil and 

water quality objectives are designed to assure that these resources meet State water quality 

objectives and BMP's (Best Management Practices) are incorporated to assure this.” (page 5) 

Soil Productivity 

The Region 1 soil quality standards apply to lands where vegetation and water resource management 

are the principal objectives, that is, timber sales, grazing pastures or allotments, wildlife habitat, and 

riparian areas (USDA Forest Service, 1999). Roads and trails are a “dedicated use” for lands that 

comprise the road prism and right of way. The affected land is managed for transportation uses and is 

not managed for vegetation production or water resources. Therefore, the R1 soil quality standards do 

not apply to this analysis. However, the decision made in this project will affect the amount of land in 

productive capability. By adding routes to the system and designating or not designating a route for 

specific use might have an impact on other projects and that project’s ability to meet Regional policy 

regarding soil quality. 

Roads and trails do have an impact on soil productivity, especially when users veer off the established 

travelway to bypass wet or muddy sections of the road or trail, bypass switchbacks, and create 

shortcuts. User created routes eliminates the protective vegetative cover, compacts the exposed soil 

surface, generates and concentrates runoff, and causes accelerated soil erosion. 

Some impacts to soils and soil productivity are normally accepted as a necessary cost to provide 

access to public lands, 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. 

Implementing Best Management Practices (BMPs) are intended to meet these objectives. There are 

some unclassified roads and trails that are not on the transportation system, as well as those that are on 

the system that are causing soil impacts beyond what is normally accepted because they fail to meet 

the standards of BMPs. Some of the reasons they may not meet standards is they are improperly 

located, do not have adequate drainage to prevent accelerated erosion and deposition, and are difficult 

to maintain for long term use. Often this leads to pioneering new routes or trails to get around 

sections that are difficult to traverse. This leads to more soil that is exposed, compacted, and eroded. 

The end result is an increasing amount of soil disturbance and associated impacts, both to the road and 

off-site. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-102 Ashland Travel Management Final EIS – Chapter 3

Soil Crusts 

Information on distribution and extent of soil crusts in the area is generally lacking. There are no 

references to soil crusts in the Soil Survey of the project area. Soil crusts are commonly found in 

more arid regions where vegetative cover is generally sparse, typically in semiarid and arid 

environments throughout the world. Areas in the United States where crusts are a prominent feature 

of the landscape include the Great Basin, Colorado Plateau, Sonoran Desert, and the inner Columbia 

Basin. (Hhttp://www.soilcrust.org/crust101.htm). Because of the environmental factors soil crusts are 

probably very limited in the Ashland Ranger District. 

Soil crusts most likely do not occur on existing roads and trails due to type and level of existing 

disturbance. Off-road travel by motor vehicle is currently prohibited except for dispersed camping 

within 300 feet of the road. The majority of dispersed campsites currently have some level of 

disturbance; soil crusts are probably not very prevalent in these areas. These dispersed campsites are 

most likely not located in the drier open areas in the area but are more generally found in areas with 

higher vegetative cover, some shade, and at higher elevations. (Also, see the section on vegetation for 

additional discussion on dispersed campsite availability.) Generally, soil crusts will not be affected by 

designating roads and trails, since no new construction is being considered at this time. 

3.4.2.2 Environmental Consequences - Soils 

Direct and Indirect Effects 

Effects Common to All Alternatives 

Soil effects resulting from development and use of forest roads and trails have been fairly well 

documented (Gucinski, et al, 2001, Wilson and Seney, 1994, Weaver and Dale, 1978). Effects from 

roads and trails can vary by standard and condition. 

Soil effects from roads and trails include removal of vegetative cover, compaction, degradation of soil 

structure, decreased infiltration and water holding capacity, reduction in soil organic material, 

accelerated erosion, and potential mass failure including landslides or slumps. These types of impacts 

can occur on motorized or non-motorized roads and trails. Erosion tends to be least on roads and 

trails with flat grades and more severe on roads and trails with steeper gradients. 

Soil crusts probably do exist in the project area though the extent and distribution are not well known. 

There might be impacts to soil crusts mainly due to off-trail travel. Off-trail travel by stock, foot, and 

motorized travel could have a negative impact on soil crusts where they exist. 

For roads identified as Administrative use only the less use they get the more vegetation will become 

established and potential erosion reduced. Some roads may be used consistently throughout the year 

while others may be used periodically, or maybe not at all some years. This should lead to an overall 

reduction in potential erosion and sediment generation from these roads. 

Effects Common to All Action Alternatives 

Effects on soils from roads vary by standard and condition. The area that roads and their associated 

disturbance occupy is removed from the productive soil base. Runoff from roads affects soil 

productivity by eroding soil from and adjacent to the road, and by depositing sediment on areas below 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-103

the road. These effects are slight on well maintained, high standard roads. Other roads have more 

serious effects that tend to be localized on road segments where surface drainage is inadequate. 

Routes that are not designated for public motorized use and for which no administrative use has been 

identified may be considered candidates for decommissioning or rehabilitation. These routes, with the 

exclusion of motorized traffic, should begin to revegetate and over time, continue to have improved 

soil productivity and eventually be brought back to the productive soil base. 

Roads and trails impact and disrupt the natural function of the soil resource, and are long-term 

commitments to that specific use. This is considered an irretrievable commitment of the soil resource 

for as long as the road or trail exists. Soil function and productivity on roads and trails can be 

recovered and the Forest Service has considerable experience in rehabilitating old roads with fairly 

successful results (Kolka and Smidt, 2004). 

An indirect effect from the action alternatives would take place as roads and trails identified as system 

routes (including conversion from non-system routes) are reconstructed, relocated, or maintained to 

meet standards and incorporate BMPs, which would reduce soil effects from these roads and trails. 

Comparisons of erosion hazard ratings by alternative are found in the following table. 

Table 3-33. Miles F

16 of Routes by Erosion Hazard Rating and Designation for Each 

Alternative

Road Erosion Hazard 

Rating Alternative A Alternative B Alternative B Modified 

No Action 

Alternative 

Administrative Use 

Slight 0 1 1 0 

Moderate 31 49 48 20 

Severe 61 124 110 39 

Subtotal 92 174 159 59 

Not Designated 

Slight 0 2 2 1 

Moderate 17 54 52 41 

Severe 24 109 107 104 

Subtotal 41 165 161 146 

Public Motorized Use 

Slight 6 4 4 5 

Moderate 252 196 204 239 

Severe 469 338 354 428 

Subtotal 742 539 562 672 

Alternative A 

Direct Effects 

This alternative would have the greatest impact on soils for the action alternatives. This alternative 

would add approximately 22 miles of routes for administrative use and 41 miles of routes for public 

motorized use on landforms with severe erosion hazard compared to the No Action Alternative. This 

includes adding routes to the system and changes in designation. 

 

16 Small differences in mileage figures between this and other tables are due to GIS analysis and rounding errors.
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-104 Ashland Travel Management Final EIS – Chapter 3

This alternative would prohibit motorized travel on 41 miles of routes (24 miles on landforms with 

severe erosion hazard, see table above), allowing vegetation to reestablish. This would reduce erosion 

and concentrated runoff from these sites. These areas would eventually be returned to productive 

capability. 

This alternative would add 123 miles of non-system roads and trails to the Forest transportation 

system. Of this, 89 miles (86 miles Public use and 3 miles Administrative use) would be on 

landscapes that have a severe erosion hazard rating 

Indirect Effects 

Off-site deposition of eroded material, soil erosion from roads and trails, and concentrated runoff 

would be reduced over time as more of the road and trail system is revegetated or is brought up to 

standard and BMPs are implemented. 

Alternative B 

Direct Effects 

This alternative would add 85 miles of routes for administrative use and decrease by 90 miles the 

routes available for public motorized use on landforms with severe erosion hazard compared to the No 

Action Alternative. This includes adding routes to the system and changes in designation. 

This alternative would prohibit motorized travel on 165 miles of routes (109 miles on landscapes with 

severe erosion hazard, see above table), allowing vegetation to reestablish. This would reduce erosion 

and concentrated runoff from these sites. 

There are approximately 55 miles of non-system roads and trails being added to the transportation 

system. Of this, 42 miles (12 miles Public use and 30 miles Administrative use) would be on 

landscapes that have a severe erosion hazard rating. 

Indirect Effects 

Off-site deposition of eroded material, soil erosion from roads and trails, and concentrated runoff 

would be reduced over time as more of the road and trail system is revegetated or is brought up to 

standard and BMPs are implemented. 

Alternative B Modified 

Direct Effects 

This alternative would add 71 miles of routes for administrative use and decrease by 74 miles the 

routes available for public motorized use on landforms with severe erosion hazard compared to the No 

Action Alternative. This includes adding routes to the system, changes in designation, and addressing 

the undetermined routes. 

This alternative would prohibit motorized travel on 161 miles of routes (107 miles on landscapes with 

severe erosion hazard, see above table), allowing vegetation to reestablish. This would reduce erosion 

and concentrated runoff from these sites. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-105

There are approximately 64 miles of non-system roads and trails being added to the transportation 

system. Of this, 47 miles (18 miles Public use and 29 miles Administrative use) would be on 

landscapes that have a severe erosion hazard rating. 

Indirect Effects 

Off-site deposition of eroded material, soil erosion from roads and trails, and concentrated runoff 

would be reduced over time as more of the road and trail system is revegetated or is brought up to 

standard and BMPs are implemented. 

No Action Alternative 

Direct Effects 

This alternative only includes those routes that are currently in the transportation system. There are 

672 miles of routes that would be available for public use. There are approximately 146 miles of nonsystem roads that would not be designated and would be available for rehabilitation and return of 

natural vegetation and eventually be returned to the productive land base. Concentrated runoff and 

erosion would be reduced from these sites. 

Existing low standard roads and trails would continue to erode and concentrate runoff and erosion at 

present rates. Existing sites where soil erosion is a concern will continue to erode and contribute 

sediment, especially where public use occurs. The area of soil productivity effects would continue to 

expand as new trail segments are developed to get around areas that are eroded. 

Indirect Effects 

Off-site deposition of eroded material, soil erosion from roads and trails, and concentrated runoff 

would be reduced over time as more of the road and trail system is revegetated or is brought up to 

standard and BMPs are implemented. 

Cumulative Effects 

Cumulative effects occur when past present or foreseeable activities overlap in both time and space 

with the proposed activities. Thus, cumulative effects are limited to the areas where the proposed 

activities would occur. In other words, cumulative effects would occur only where proposed activities 

would occur where previous management has affected soil conditions. Activities outside of the 

locations of proposed management are not subject to cumulative effects because they do not overlap 

spatially with the lands being proposed for management in the Ashland Ranger District Travel 

Management Project. Soil effects do not extend off of the piece of ground where they occur. 

Cumulative effects consist of the impacts from all past, present, future and proposed activities that 

overlap in time and space with the proposed project. 

Past, Present, and Reasonably Foreseeable Activities 

The current vegetative treatment and mining activities that do occur in the analysis area incorporate 

BMPs and produce relatively few soil impacts relating to roads and trails. There is a possibility that 

new roads will be constructed and added to the system in the future. These could be designated for 

public use or for administrative use only. If these roads were to be added to the transportation system, 

it would increase the compaction and potential runoff and erosion for the specific road. The location 

and analysis of the proposed roads would be determined based on site specific analysis to reduce the 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-106 Ashland Travel Management Final EIS – Chapter 3

potential impacts on soils. Timber sales are audited for compliance with BMPs and are monitored to 

see that design features that reduce soil effects are implemented. 

The continuation of livestock grazing activities will overlap with the proposed action in both time and 

space. They could potentially contribute to the effects. A possibility exists that new roads will be 

constructed and/or added to the transportation system in the future. This might occur if new range 

infrastructure is identified as a need for continued management. These could be designated for public 

use or for Administrative Use only. If these roads were to be added to the transportation system, it 

would increase the compaction and potential runoff and erosion for the specific road. The location 

and analysis of the proposed roads would be determined based on site specific analysis to reduce the 

potential impacts on soils. Another impact might occur if livestock grazing occurs where vegetation 

is beginning to reestablish, either naturally or through reclamation activities, on routes that are not 

designated. Continued grazing might reduce the vegetative cover, slowing reclamation. 

The decision made in this project will affect the amount of land committed to a dedicated use. By 

adding routes to the system or designating/not designating a route for specific use, this project might 

have an impact on other projects and that project’s ability to meet Regional policy regarding soil 

quality. 

3.4.2.3 Conclusion - Soils 

Roads and trails impact and disrupt the natural function of the soil resource, and are long-term 

commitments to that specific use. Routes not designated for public motorized use will begin to 

revegetate and improve soil productivity. 

Alternative A would provide the greatest number of miles of routes available for public use and the 

least number of miles of routes to return to productive capability over time. 

Alternative B and Alternative B Modified would provide an intermediate number of miles for public 

motorized use compared to Alternatives A and No Action. Alternative B and Alternative B Modified 

would have fewer miles of routes available to the public for motorized use on landforms with high 

erosion hazard compared to Alternative A and the No Action Alternative, though more miles of roads 

would be designated for administrative use. Alternative B Modified would decrease the miles of 

roads and trails, designated for public motorized use, on soils that have severe erosion rating by 73 

miles compared to the No Action Alternative and by 59 miles the miles of roads on soils rated as 

poorly suitable for Natural Surface Roads and Trails. Alternative B would decrease the miles of roads 

and trails, designated for Public use, on soils that have severe erosion rating by 90 miles compared to 

the No Action Alternative and by 76 miles the miles of roads on soils rated as poorly suitable for 

Natural Surface Roads and Trails. 

Alternative A would increase by 40 miles the roads and trails, for public motorized use, on soils 

having severe erosion hazard compared to the No Action Alternative. 

Soil crusts most likely do not occur on existing roads and trails due to type and level of existing 

disturbance. Generally, soil crusts will not be affected by designating roads and trails, since no new 

construction is being considered at this time. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-107

Consistency with Laws, Regulation, and Policy 

All Forest Plan management direction would be met by the proposed action. 

3.4.3 VEGETATION 

Overview of Changes from the Draft to the Final EIS 

 Minor editing changes and the addition of analysis for Alternative B Modified. 

Introduction 

Analysis of associated travel disturbances on vegetation, weed spread, and sensitive plants are 

addressed under the general heading of Vegetation. 

3.4.3.1 Affected Environment – Vegetation 

Introduction 

There is a concern that designation of travel routes allows for disturbance of native vegetation by 

vehicles, camping, hiking, mountain biking, and pack and saddle stock. Vegetation has various 

abilities to recover from disturbance depending upon frequency, duration, and timing of disturbance 

and species ability to resist disturbance. 

Regulatory Framework 

36 CFR 219.20 outlines direction regarding ecological sustainability. Plans should provide for 

maintenance or restoration of ecosystems at appropriate spatial and temporal scales determined by the 

responsible official. The spatial scale for this analysis is the project area and the temporal scale is the 

planning horizon of the decision resulting from this analysis, identified as ten years. 

Overview-Vegetation 

Vegetation of the Ashland Ranger District is floristically rich and diverse. The diversity is composed 

of many community types including ponderosa pine (5), aspen (1), green ash woodland (3), 

cottonwood (6), Rocky Mountain juniper (1), silver sage shrubland (1), big sage shrubland (4), 

skunkbush sumac shrubland (2), buffaloberry (1), western snowberry (1), horizontal juniper (1), 

grasslands (22), and herbaceous riparian (19). About half of the District is forested with ponderosa 

pine and half is grasslands/shrublands. About 30% of the District’s vegetation has been affected by 

wildfires. 

Factors Influencing Area Impacted and Severity of Impact 

The overall impact of a travel use on vegetation is a function of both the area impacted and the 

severity of impact within the disturbed area. Within the scope of this analysis, travel related impacts 

to vegetation include disturbances from camping and vehicle use. Factors that influence the severity 

of vegetation impact include duration and frequency of use, vegetation resistance and resilience, and 

season of use. 

Duration and Frequency of Use 

It is recognized that impacts might occur anywhere along designated travel routes. However, there is 

a higher probability of more severe vegetation impacts in areas where people tend to frequent 

repeatedly. These areas are typically near water, vistas, shade, and other areas on gentle terrain 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-108 Ashland Travel Management Final EIS – Chapter 3

suitable for camping (usually 0 to 4% slopes). Sites that are used infrequently and sites that are 

capable of resisting deterioration will usually be less impacted than those that are used frequently and 

those that are readily disturbed. For example, in long-established campsites, the magnitude of 

vegetation impact is determined as much by the ability of vegetation to recover from disturbance as by 

the ability to resist disturbance. 

Resistance and Resilience 

Aspects of vulnerability of vegetation having impacts and ability to recover include attributes of 

resistance and resilience. Resistance refers to the ability of vegetation to resist change when trampled. 

Resilience refers to the ability of vegetation to recover following the cessation of trampling and 

tolerate a cycle of disturbance and recovery. 

Resistant vegetation types, such as sedges, are able to absorb 25 to 30 times as much trampling as the 

least resistant type, such as ferns (Cole 1993b). Plant characteristics, notably the position of the 

plants’ perennating bud and physiological characteristics such as reproductive capacity and growth 

rates, also influence resilience (Cole 1995a,b,c). Morphological characteristics are primary factor 

influencing plant resistance to trampling. Grasses and sedges have flexible stems growing in mats or 

tufts. More fragile are woody plants and taller herbs. Complete loss of vegetation cover occurs quickly 

in shady forested areas, less quickly in open areas with resistant grassy vegetation (Leung & Marion, 

1996). The resilience of plants, their ability to recover following trampling disturbance, varies 

substantially by habitat, with higher recovery in the most productive environments such as those with 

higher soil fertility and moisture. For example, recovery rates are high in riparian and grassland areas. 

Recovery in forested systems is typically moderate to high. In contrast, trampling impacts in less 

resilient environments, such as arid environments, require a long time to recover (Leung & Marion, 

1996). 

Effects Analysis Methodology-Vegetation 

General potential effects to vegetation are based on literature reviews. Geographical Information 

System (GIS) methods were used to assess the magnitude of area potentially impacted and potential 

risk categories based on various elements of frequency and duration of trampling, and vegetation 

resistance and resilience. 

Duration and Frequency of Use 

Potential Infrequent Use Areas – Potential Use Corridors 

Impacts might occur within each Alternative’s potential impact corridor along designated travel 

routes. Sites that are used infrequently and sites that are capable of resisting deterioration will usually 

be less impacted than those that are used frequently and readily disturbed 

The following buffers from designated routes were used to describe the Potential Use Corridor by 

Alternative. For designated motorized routes with an allowance for dispersed vehicle camping access, 

a 300 foot buffer was applied all alternativesIt is recognized that not all estimated acreage will be 

affected and therefore results will be on the conservative side. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-109

Potential Frequent Use Areas – 0 to 4% Slopes 

There is a higher probability for more severe vegetation impacts in areas where people tend to visit 

repeatedly or with longer duration of use. These areas are typically near water, vistas, shade, and 

other areas on gentle terrain suitable for camping (usually 0 to 4% slopes). 

Zero to 4% slopes were used to represent potential frequent use areas, found within each Alternative’s 

potential use corridors, and are intersected with elements outlined in the resistance and resilience 

section below. The 0 to 4% slope class was used because people tend to concentrate for longer 

durations of use at campsites or areas in gentle terrain. It is recognized that not all estimated acreage 

will be affected and therefore results will be on the conservative side. 

Resistance and Resilience 

All vegetation cover types from satellite imagery (SILC3 post-large wildfires) are addressed within 

the following two risk groupings based on degree of vulnerability to resist impacts (resistance) and 

ability to recover (resiliency). The two groups are intersected with the frequent and infrequent use 

areas outlined above. 

Because grasslands, shrub/grass, and open woodland vegetation types tend to have higher resistance 

(lower vulnerability to trampling) and resilience (higher resiliency to recover) elements, these cover 

types are used to represent areas of low risk for impacts. 

Because forested vegetation types (greater that 65% canopy cover) tend to have lower resistance to 

impacts and moderate to high resiliency to recover, these cover types are used to represent areas of 

moderate risk for impacts. 

High risk category (alpine / subalpine and desert / semi-desert) is not considered in this analysis since 

these areas do not occur in the analysis area. 

Measurable Attributes 

Based on the above discussion, the magnitude of area potentially impacted is stratified by risk of 

impacts in low and moderate risk categories. Where vehicle access for dispersed camping is allowed, 

potential use within each Alternative’s corridor is projected to have less frequency of use (not all the 

area within the corridor will be traveled since one must use the most direct route to a campsite). 

These areas were identified through the intersection of cover type resistance / resilience groupings in 

each of the two risk categories with each of the Alternative’s use corridors. These areas were further 

intersected with the risk category cover type groups within a 0 to 4% slope class. The 0 to 4% slope 

class represents the area with higher probability for concentrated use and severity of impact such as 

camping. The measurement is in acres and percent of potentially impacted acres compared to total 

project area acres. It is recognized that not all estimated acreage will be affected and therefore results 

will be on the conservative side. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-110 Ashland Travel Management Final EIS – Chapter 3

3.4.3.2 Environmental Consequences – Vegetation 

Direct and Indirect Effects-Vegetation 

General Effects Common to All Alternatives 

Trampling 

Crushing or treading upon vegetation, either by foot, hoof, or tire, contributes to a wide range of 

vegetation impacts, including damage to plant leaves, stems, and roots, reduction in vegetation height, 

change in the composition of species, and loss of plants and vegetative cover. Trampling can quickly 

break down vegetation cover and create a visible route that attracts additional use. Complete loss of 

vegetation cover occurs quickly in shady forested areas, less quickly in open areas with resistant 

grassy vegetation. Regardless, studies have consistently revealed that impacts can occur with initial or 

low use, with a diminishing increase in impact associated with increasing levels of traffic (Hammit & 

Cole, 1998; Leung & Marion, 1996). Once trampling occurs, the rate of vegetative recovery can vary, 

depending on the site’s resistance and resilience to disturbance. 

Soil compaction from repeated trampling can affect plant growth by reducing moisture availability 

and precluding adequate taproot penetration to deeper soil horizons. In turn, the size and abundance of 

native plants may be reduced. Above-ground portions of plants also may be reduced through breakage 

or crushing, potentially leading to reductions in photosynthetic capacity, poor reproduction, and 

diminished litter cover. Likewise, blankets of fugitive dust raised by motorized traffic can disrupt 

photosynthetic processes, thereby suppressing plant growth and vigor, especially along motorized 

routes. In turn, reduced vegetation cover may permit invasive and/or non-native plants—particularly 

shallow-rooted annual grasses and early successional species capable of rapid establishment and 

growth—to spread and dominate the plant community, thus diminishing overall local biodiversity. 

Compositional changes in the vegetation along trail corridors can have both beneficial and adverse 

effects. Trampling-resistant plants provide a durable groundcover that reduces soil loss by wind and 

water runoff, and root systems that stabilize soils against displacement by heavy traffic. Many of 

introduced species are disturbance-associated and are naturally limited to areas where the vegetation is 

routinely trampled or cut back. However, a few invasive non-native species, once introduced to trail 

corridors, are able to out-compete native plants and spread away from the trail corridor in undisturbed 

habitats. Some of these species form dense cover that crowd out or displace native plants (see Weeds 

Section). 

Camping 

Vegetation composition of campsites is not changed by infrequent camping for short periods. 

However, aerial plant parts will be broken and flowering in the season of impact may be affected. 

Long-term or frequent camping, even for one season, results in the destruction of vegetation, leaving 

barren compacted areas. 

The creation of fire-rings impacts vegetation through burning, and the covering of vegetation with 

rocks. Revegetation is likely to be slow, because of changes in soil characteristics from such as loss of 

nitrogen, phosphorus, sulphur, and organic matter. The firewood used in campfires often comes from 

dead trees, but living trees have also been used, often to an extent which exceeds their capacity for 

regeneration. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-111

Minor impacts associated with camping include the death of vegetation covered with garbage, partlyburned wood, or rocks removed from campsites. Digging of pits for garbage disposal and the removal 

of rocks from campsites -result in the creation of small bare areas, which are often enlarged by 

erosional processes and trampling. 

Vehicles 

The overall impact of a vehicle on vegetation is a function of both the area impacted and the severity 

of impact within the disturbed area. The severity of vegetation impact within a disturbed area can be 

higher than hiking, mountain biking, and stock use based on weight (a dirt bike weighs 100-200 

pounds, whereas typical ATV can weigh up to 900 lbs, or up to several tons for 4x4 Off Road 

Vehicles), power, tire-surface area (tire footprint), and wheel slip that can cause greater compression 

on soils and vegetation as well as vegetation shearing. Vehicle impacts to vegetation can be 

exacerbated by rutting during wet periods due to low bearing capacity of soft soils (Affleck. 2005). 

Direct impacts of vehicle activities on vegetation include reduced vegetation cover and growth rates, 

and increased potential for non-native and pioneering species to become established, thus altering 

vegetation communities. In certain instances, however, the impervious nature of compacted routes 

could result in runoff that generates greater moisture availability immediately along motorized routes. 

In turn, this would promote increased vegetation cover and plant abundance farther away. Repeated 

off-route activity results in the crushing, breaking and overall reduction of vegetative cover. Detours 

around snowbanks or mud holes are sometimes made by vehicles, and parallel motorized routes can 

become widely spaced. 

Indirect effects of vehicle activities on vegetation are tied to soil properties altered by vehicle traffic, 

as soil properties typically influence vegetation growth. Motorized roads and trails also create edge 

habitats, which can generate conditions that promote the encroachment of non-native and invasive 

plant species. Other indirect effects include increased amounts of airborne dust raised by traffic. 

Fugitive dust on plant foliage can inhibit plant growth rate, size, and survivorship. Vehicle passes can 

also result in indirect effects including damaging germinating seeds, and weakening plants making 

them more susceptible to disease and insect predation. Vehicles can result in changes in plant species 

composition. 

Weeds 

An effect of travel and trampling can be the establishment and spread of weeds. These effects are 

further described in the Weed portion of the Vegetation section. 

Magnitude and Settings of Potential Effects on Vegetation 

The following table summarizes potential amount of vulnerability for vegetation impacts for each 

Alternative by risk categories based on various elements of frequency and duration of trampling, and 

vegetation resistance and resilience. It is recognized that not all estimated acreage will be affected 

and therefore results will be on the conservative side. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-112 Ashland Travel Management Final EIS – Chapter 3

Table 3-34. Potential Vegetation Impacts by Risk Category - Ashland

Attributes Alternative 

A 

Alternative 

B 

Alternative 

B Modified 

No Action 

Alternative 

Moderate Risk Areas

Acres Potential Frequent Use Areas F

17 (% of Project Area) 20 (Trace) 10 (Trace) 10 (Trace) 20 (Trace)

Acres Potential Infrequent Use Areas 18 (% of Project Area) 773 (Trace) 403 (Trace) 415 (Trace) 686 (Trace)

Miles in Moderate Risk Area 9 4 4 8 

Low Risk Areas

Acres Potential Frequent Use Areas F

19 (% of Project Area) 6530 (1%) 5088(1%) 5241(1%) 6036(1%) 

Acres Potential Infrequent Use Areas 20 (% of Project Area) 42759(10%) 31309 (7%) 32248(7%) 39153 (9%) 

Miles in Low Risk Area 711 514 530 640 

Cumulative Effects-Vegetation 

Fuels reduction, prescribed burning, livestock grazing, and timber management projects are currently 

planned and will continue to be planned for the District. These projects and any associated road use 

or construction have potential to impact vegetation. Projects are designed to minimize impacts to 

vegetation. 

Use of existing designated routes and associated 300 foot allowance for access to vehicle camping, in 

combination with the proposed actions, have potential to impact vegetation within the project area. 

Implementation of any of the alternatives considered in this analysis would not be expected to 

contribute to significant cumulative effects associated with vegetation. Anticipated future projects or 

activities are fewer in number and less disruptive from a resource extraction point of view than those 

projects or activities that have taken place in the past. 

3.4.3.3 Conclusion - Vegetation 

Because it is seldom possible to control or even document the past use or predict future use, estimates 

of the impacts caused by different use frequencies are imprecise. The ability to predict the effects of 

different intensities of various uses is low. However, the amounts of potentially affected area, 

projected within the context of moderate risk categories based on various elements of frequency, 

duration, timing, and vegetation resistance and resilience are displayed in the Potential Vegetation 

Impacts by Risk Category table above. It is recognized that not all estimated acreage will be affected 

and therefore results are on the conservative side. 

Under all alternatives, when compared against similar vegetation types, potential impacts from 

frequent use within the 0 to 4% slopes of the route’s corridor in moderate and low risk areas could 

occur in about one percent of the project area. Potential impacts from infrequent use within the 

 

17 Frequent Use Areas with Moderate Risk: Areas of 0-4% slopes within 300’ of motorized routes in Ponderosa pine types with greater 

than 65% canopy cover. 

18 Infrequent Use Areas with Moderate Risk: Areas of greater than 4% slopes within 300’ of motorized routes in Ponderosa pine types 

with greater than 65% canopy cover. 

19 Frequent Use Areas with Low Risk: Areas of 0-4% slopes within 300’ of motorized routes in community types with less than 65% 

canopy cover. 

20 Infrequent Use Areas with Low Risk: Areas of greater than 4% slopes within 300’ of motorized routes in Ponderosa pine types with 

less than 65% canopy cover. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-113

route’s corridor in moderate and low risk areas could occur in about 7% and 10% of the project area, 

respectively. 

Moderate risk category potential impact ranges from 413 (Alternative B) to 793 acres (Alternative A). 

This is less than one percent of the project area. Low risk category potential impact ranges from 

49,289 (Alternative B) to 36,397 acres (Alternative A). This is about 7 to 11% of the project area. 

Table 3-35. Potential Vegetation Impacts by Risk Category - Ashland

Attributes 

Alternate A 

Change from No 

Action 

Alternative B 

Change from No Action 

Alternative B Modified 

Change from No Action 

Moderate Risk Areas

Acres Potential Frequent Use Areas Increases by 0 Acres Decreases by 10 Acres Decreases by 10 Acres 

Acres Potential Infrequent Use Areas Increases by 87 Acres Decreases by 283 Acres Decreases by 271 Acres 

Miles in Moderate Risk Area Increases by 1 Mile Decreases by 4 Miles Decreases by 4 Miles 

Low Risk Areas

Acres Potential Frequent Use Areas Increases by 494 Acres Decreases by 948 Acres Decreases by 795 Acres 

Acres Potential Infrequent Use Areas Increases by 3606 Acres Decreases by 7844 Acres Decreases by 6905 Acres 

Miles in Low Risk Area Increases by 71 Miles Decreases by 126 Miles Decreases by 110 Miles 

While impacts resulting from camping and vehicles can be locally very significant, the total area of 

impact is small when compared to various ecosystems of the project area. The level of acceptable 

impact over a given area is within the discretion of the deciding official for this project as outlined in 

the regulatory framework for this section. Selection of any alternative would be consistent with the 

regulatory framework relative to vegetation sustainability at the level of this project’s scale. 

3.4.3.4 Affected Environment – Weeds 

Introduction 

There is concern that travel management can influence the spread of noxious weeds and invasive 

plants. Also, the Forest Service has identified invasive species as one of the top threats to the health 

of National Forests. In this document, the terms “weeds”, “noxious weeds’ and “invasive plants” are 

used synonymously. Invasive weeds are defined as any non-native plant, which when established is 

or may become destructive and difficult to control by ordinary means of cultivation or other control 

practices. “Noxious” weeds are those non-native plants that are legally listed as weeds by the state or 

county. 

Use of motorized routes contributes to the spread of weeds. Weeds can significantly alter the 

composition of native plant communities resulting in decreases in habitat quality for wildlife, reduced 

forage for livestock, increased erosion and increased sediment levels in streams, and decreases in 

aesthetic/recreational quality of wild lands (Sheley, R and J. Petroff. 1999). 

The District follows many strategies to reduce populations of weeds and to prevent further infestation. 

For instance: best management practices are followed (Forest Service Manual Section 2080 

(FSM2080)); standard and special provisions are included in timber sale contracts; a Forest-wide 

special order requiring weed-free hay and feed for stock has been implemented; weed-free gravel in 

road construction projects is required, and competitive seeding of disturbed sites is done with native 

vegetation. All districts on the Forest have implemented integrated weed management programs that 

include prevention through public education, along with biological, mechanical and chemical weed 

suppression. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-114 Ashland Travel Management Final EIS – Chapter 3

Regulatory Framework 

Nearly all users and interested parties desire complete prevention and eradication of noxious weeds on 

the Forest, but not necessarily at the expense of their use and enjoyment of the Forest. Neither are 

there sufficient resources or technology available to completely eradicate existing weed infestations 

within the planning horizon. The 1987 Custer National Forest Plan (Forest Plan - FP) directs control 

of noxious weeds as a priority item (FP Page II-3) where the goal is to implement an “integrated pest 

management program aimed at controlling new starts, priority areas of minor infestations. Holding 

actions will be implemented on areas of existing large infestations.” Additionally, the Forest Service 

Manual 2080 (1. b. (5)) requires a weed risk assessment be conducted for all projects that could spread 

weeds. Additional regulatory framework for integrated weed management is found in the 2006 Custer 

NF Weed Management FEIS (project file), which is incorporated by reference into this analysis. The 

overall goal of is to maintain or restore healthy plant communities that are relatively weed resistant, 

while meeting other land-use objectives such as forage production, wildlife habitat maintenance, or 

recreational land maintenance. 

Overview 

An extensive scientific literature review was recently conducted for the 2006 Custer NF Weed 

Management EIS (project file). Weeds have many vectors for dispersal, such as people, wind, water, 

and animals. Although wind and water contribute to weed dispersal, travel management does not 

influence these forms of seed dispersal; consequently, they are not addressed in this analysis. 

Research has shown that motorized vehicles tend to have a greater capacity for spreading weeds than 

non-motorized travel (Tyser and Worley, 1992). The current weed inventory for the Custer National 

Forest shows this same correlation; more weeds are present along motorized routes than along nonmotorized routes. The bulk of the remaining Ashland District infestations occur in areas that have 

been burned by wildfire. According to the Custer weed survey data as of 2006, of the infestations 

occurring near motorized routes, about 70 percent of the infestations occur within the first 100 feet of 

motorized routes. 

Current Weed Conditions 

Some weed species are extremely hardy, competitive, and have the ability to displace native plant 

species and permanently alter the structure, composition and function of native plant communities. 

These species are considered very invasive and are typically listed as noxious by States. Of the 2000 

plus vascular plant species that have been documented on the Custer National Forest, five are 

considered noxious weeds on the District. Currently there are approximately 4038 recorded acres 

infested with noxious weeds in the District boundary. Sites are generally small and widely scattered 

with many populations occurring along main National Forest System roads. Canopy density averages 

between 5-35 percent. Canada thistle, spotted knapweed, leafy spurge, and some houndstongue are 

the predominant noxious weed species on the District. 

Human Influence 

Human activities of grazing, timber harvest, road construction, recreation (camping, fishing, hunting, 

trail riding, back packing) and forest administration contribute, to various degrees, to the introduction 

and spread of weeds. Motorized vehicles and equipment contribute the most to introduction and 

spread of noxious weeds because of vehicle mobility and size, and/or distance of travel within a given 

time. Weed seeds become stuck in tire tread and in under carriage mud, pulled off and lodged in the 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-115

framework, drug out upon unloading from passenger and cargo compartments or deposited with 

contaminated cargo (e.g., gravel, hay, straw). 

Trend 

Nationally, National Forest System lands have an estimated six to seven million acres that are infested 

with noxious weeds. This figure is increasing at an exponential rate of 8-12 percent per year. An 

increase in inventoried infestations has occurred over the past 20 years due, in large part, to large scale 

wildfires and better inventory. In addition to annual appropriations, various grants and partnerships 

have been successful in adding resources to annual control measures. Treatment priority criteria are 

used because resources are generally not sufficient to treat all infestations (CNF Weed Management 

FEIS, 2006). Spread vector areas such as motorized routes are high in priority for treatment. The 

Custer National Forest could experience further invasion in the very near future, especially in light of 

some of the large scale wildfires that have occurred and will likely continue to occur. 

To counter the continuing spread, the Forest has had an active prevention and control program to 

reduce the impacts of invasive noxious weeds for over 25 years. Chemical weed control has 

historically been the primary tool for noxious weed control in the analysis area. 

Effects Analysis Methodology 

The degree of risk from some of the most threatening species can be evaluated when completing 

project weed risk assessments. The probability of exposure of each site to plant propagules affecting 

dispersal, the susceptibility of an area to species’ establishment, and the level of threat to susceptible 

areas can be evaluated. Overlaying weed inventories and designated public motorized routes, with 

this susceptibility assessment can further identify areas that are potentially at risk from invasion. A 

spatially explicit analytic model using a Geographic Information System (GIS) was used to map and 

calculate the acres at risk to invasive weeds (Project Record). 

Level of Risk 

Susceptibility, threat, and probability of exposure can be combined to model the degree of risk across 

a project area from some of the most threatening weed species. A risk assessment (Mantas, 2003) was 

completed for several weeds occurring in the USFS Northern Region, East of the Continental Divide 

(Hhttp://www.fs.fed.us/r1/cohesive_strategy/datafr.htm). This information was referenced in 

determining area susceptibility and threat levels. 

Weed Susceptibility 

Susceptibility is an estimate of the vulnerability of different habitats to colonization and establishment 

of a weed species. Even without any disturbance on the landscape, some areas are susceptible to the 

infestation by invasive plants. Because most of the weed species that occur on the District are 

considered aggressive in most non-forested and sparsely forested settings, these vegetation types are 

considered to be susceptible to weed invasion. Approximately 95% of the District is naturally 

susceptible to weed invasion. These areas are usually open areas with limited or no shade from tree 

overstory. 

A 400 foot buffer from each side of a motorized route was used for each alternative and helps assess 

indirect effects. This accounts for allowable dispersed camping within 300 feet of a route, along with 

a 100 foot addition for potential weed spread beyond the 300 foot dispersed camping allowance. 

These specific Alternative buffers were intersected with areas rated as susceptible to weed infestation. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-116 Ashland Travel Management Final EIS – Chapter 3

Weed Threat 

Threat refers to the estimated degree of change in structure, function or composition that a weed 

species would have on a potential natural vegetation type. Because the noxious weed species that 

occur on the District are considered aggressive, they all occur in the high threat class. 

Weed Exposure 

Exposure refers to the probability that an area would be exposed to seeds from noxious weeds. The 

exposure classes used in this analysis are high exposure (motorized routes designated for public use) 

and low to no exposure (motorized routes designated for administrative use only F

21 and non-motorized 

travel). An average of 70% of a road related infestations on the Forest occur within the first 100 feet 

of the buffer, about 82% occurs within the first 300 feet, and 95% occurs within the first 400 feet of 

motorized routes. 

Existing weed infestions within a 400 foot buffer from motorized routes was used to assess direct 

effects from exposure to weeds since most of the weed infestations, associated with motorized routes, 

are found within this distance. The effects analysis assumption used is that weed establishment in 

areas susceptible to weed infestation can spread within this 400 foot distance within the ten year 

planning horizon of the travel management decision if left untreated. However, road related 

infestations are given high priority for treatment since motorized routes are typically primary vectors 

for spread. Exposure to weed spread within 400 feet of a motorized route is less that that portrayed in 

the following table due to the likelihood of weed treatment and the fact that the bulk of road-related 

infestations occur within the first 100 feet. Therefore, the 400 foot buffer was used as a conservative 

approach for an analysis measurement. 

3.4.3.5 Environmental Consequences – Weeds 

Direct and Indirect Effects-Weeds 

The direct effect of motorized travel routes within susceptible areas for weed invasion is an increase in 

weed density and distribution. The following table is used to make Alternative comparisons. The 

corridor associated with the Alternative A has the most acres currently infested with weeds (1869 

acres), and Alternative B has the least (1646 acres). The motorized routes going through infested 

areas range from 41 - 46%. 

Table 3-36. Weed Infestations and Public Motorized Routes – Ashland 

Alternative A Alternative B Alternative B 

Modified 

No Action 

Alternative 

Total Infested Acres within 400’ Buffer 1869 1646 1650 1811 

Percent of Infested within 4038 Inventoried 

net Acres of Weeds F

22 46% 41% 41% 45% 

 

21 Motorized routes designated for administrative use fall within a controlled setting either through permit with associated terms and 

conditions or use by Forest Service employees where best management practices are required. Also, these routes tend to have less 

frequent travel and low duration of use which also lessen impacts compared to more frequent use by the general public who always are 

not aware of protective measures to take in preventing and combating noxious weeds. 

22 Most of the remaining acreage not occurring adjacent to motorized routes are a result of wildfire effects or animal vectors. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-117

Table 3-36. Weed Infestations and Public Motorized Routes – Ashland 

Alternative A Alternative B Alternative B 

Modified 

No Action 

Alternative 

Miles of Designated Routes bisecting Weed 

Infestations 90 77 77 86 

The following table summarizes indirect effects. Indirect effects include the risk of vegetation 

becoming infested from vehicles carrying and dropping weed seeds into areas susceptible to weed 

growth. Once aggressive weeds are introduced into the susceptible area, it would continue to spread 

and displace native plants, even if the area is not disturbed. 

The indirect effect for each alternative is based on the total number of acres susceptible to weeds that 

intersected the respective Alternative’s buffer of motorized routes. For each Alternative, about 95% 

of the buffered areas are susceptible to weed infestations. Alternative A has the greatest area at highrisk of weed invasion near motorized travel routes (62,717 acres), while Alternative B has the least 

(46,665 acres). The areas of high susceptibility are summarized in the following table: 

Table 3-37. Susceptibility to Weed Infestation by Alternative - Ashland 

Susceptible Area within Route Corridor F

23 Alternative 

A 

Alternative 

B 

Alternative B 

Modified 

No Action 

Alternative 

Susceptible Acres 62,717 46,665 48,138 57,606 

Percent of Area within Route Corridor infested with 

Weeds (Acres) 3 3 3 3 

Cumulative Effects-Weeds 

All of the activities identified as past and present activities in the beginning portion of this chapter, 

have influenced the spread of weeds. Future activities have the potential to spread weeds. 

The common elements associated with most weed infestations are ground disturbance, wildfire, and 

use of motorized vehicles. Once the weeds are introduced into an area they generally continue to 

spread into adjacent areas. Weeds will continue to be spread as a result of resource management and 

other human activities. The mitigation measures that are addressed in the Forest Service Manual 2080 

are being implemented and will help to slow the spread of weeds. 

If a disturbance (such as a fire or timber harvest) occurred in a high-risk area with an existing weed 

problem and the area has motorized routes, the cumulative impact will exasperate the problem. In this 

situation the weeds may spread quickly to new areas and may rapidly increase in density. Having 

motorized travel in these areas may carry the weeds to new locations. The best management practices 

outlined in Forest Service Manual 2080 will help to reduce the spread rate but may not prevent the 

spread altogether. 

Current on-going activities may have a cumulative negative effect by increasing the introduction and 

spread of noxious weeds. Livestock grazing may transport weed seed between private or other lands 

and the Forest, or from place to place on the Forest, by carrying seed in the hair or digestive tract. 

 

23 400 foot buffer from motorized route under all alternatives. See Methodology section. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-118 Ashland Travel Management Final EIS – Chapter 3

Livestock may also increase seed germination by reducing vegetation competition in areas of 

improper grazing and by ground disturbance in areas of excessive trailing. Wildlife and birds can 

similarly transport weed seed in hair, feathers and digestive tracts. Weed seeds are also transported by 

wind and water and wildfire provides improved germination. 

3.4.3.6 Conclusion - Weeds 

Since there is a high association with motorized routes and weed infestations, Alternatives A and No 

Action have a higher probability for weed spread than Alternatives B and B Modified. 

Table 3-38. Summary of Changes in Effects Compared to the No Action Alternative - Ashland

Change from the No Action 

Alternative Alternative A Alternative B Alternative B Modified 

Exposure to Current Weed Infestations

Change in motorized route 

corridor exposure to weed 

infestation acreage from No 

Action (% change from No 

Action)

Motorized route corridor 

exposure to 

weed infestations 

increased by 58 Acres 

(3%) 

Motorized route corridor 

exposure to 

weed infestations 

reduced by 165 Acres 

(9%) 

Motorized route corridor 

exposure to 

weed infestations 

reduced by 161 Acres 

(9%) 

Weed Susceptibility

Change in acreage of Weed 

Susceptible areas, within 

motorized route corridor, from No 

Action (% change from No 

Action)

Weed Susceptible Area 

increased by 

5,111 (9%) Acres 

Weed Susceptible Area 

reduced by 

10,941 Acres (19%) 

Weed Susceptible Area 

reduced by 

11,941 Acres (20%) 

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 defeat the purpose of the 

public lands, and is not public policy, and still would 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 more 

the public voluntarily accepts and implements weed prevention practices, less restrictions and 

expensive weed control will be required. 

Per existing policy, a noxious weed risk analysis will be done for each project and appropriate BMP 

measures (FSM 2080, R1 Supplement 2000-2001-1) included in each environmental analysis, permit, 

and contract and will help reduce cumulative effects. Each project and public use area will be 

monitored for noxious weeds and the implementation and effectiveness of BMP mitigation measures, 

prioritized by the degree of risk. The Forest Service will continue prevention, public education and 

appropriate weed treatment measures. 

All action alternatives are consistent with the Laws, Regulations, Policy, and Federal, Regional, State, 

and Custer Forest Plan. Of these regulatory directions, only the FSM 2080 addresses travel 

management with respect to weed management. A weed risk assessment is part of this analysis and 

meets this policy. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-119

3.4.3.7 Affected Environment – Sensitive Plants 

Introduction 

Forest Service sensitive species are defined as “Those plant and animal species identified by a 

Regional Forester for which population viability is a concern, as evidenced by: a) significant current 

or predicted downward trends in population numbers or density or b) significant current or predicted 

downward trends in habitat capability that would reduce a species’ existing distribution.” 

Regulatory Framework 

The 1987 Custer National Forest Land and Resource Management Plan (Forest Plan) and Forest 

Service Manual 2670.22 Sensitive Species provides for sensitive plants. Forest Service policy

regarding biological evaluations is summarized in Forest Service Manual (FSM) 2672.4. The intent 

of the biological evaluation process is to assess the potential impacts of proposed management 

activities, and ensure that such activities will not jeopardize the continued existence of species listed, 

or proposed to be listed, as Endangered or Threatened by the U. S. Fish and Wildlife Service and 

species designated as sensitive by the Regional Forester. 

Overview 

Only species with known locations or potential habitat on the District are addressed in the analysis 

and outlined in the following table. Three species are known to occupy habitat and have documented 

occurrences in the District. 

Table 3-39. R-1 Sensitive Plant Species - Ashland

Common & 

Scientific 

Name 

Type F

24 Global 

Rank F

25

State 

Rank

F

26

Habitat Closest known 

population 

Flowering 

Period 

Fruiting 

Period 

BADLANDS / SPARSE TO DRY HILLSLOPES

Barr’s 

milkvetch 

(Known) 

Astragalus 

barrii

2 G3 S2/S3 

Gullied knolls, 

buttes, and barren 

hilltops, often on 

calcareous soft shale 

and siltstone. 

Elev. 2940 - 4000 ft. 

Home Creek Area 

(1 populations); 

Lyon Creek Area 

(2 populations); 

Bloom Creek Area 

(2 populations); 

Otter Creek Area 

(9 populations); 

King Creek Area 

(1 populations); 

May-early 

June 

MayJune 

 

24 Scale of risk, per Region 1 Species at Risk Protocol: Type 1: Threatened, Endangered or Proposed (ESA); Type 2: Range-wide 

Imperilment; Type 3: Regional/State Imperilment 

25 and 25 The international network of Natural Heritage Programs employs a standardized ranking system to denote global (range-wide) 

and state status (Association for Biodiversity Information 2001). Species are assigned numeric ranks ranging from 1 (critically

imperiled) to 5 (demonstrably secure), reflecting the relative degree to which they are “at-risk”. 1 = Critically imperiled because of 

extreme rarity and/or other factors making it highly vulnerable to extinction; 2 = Imperiled because of rarity and/or other factors 

demonstrably making it vulnerable to extinction; 3 = Vulnerable because of rarity or restricted range and/or other factors, even though it 

may be abundant at some of its locations; 4 = Apparently secure, though it may be quite rare in parts of its range, especially at the 

periphery; 5 = Demonstrably secure, though it may be quite rare in parts of its range, especially at the periphery; T = Rank for 

subspecific taxon (subspecies, variety, or population); appended to the global rank for the full species, e.g. G4T3 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-120 Ashland Travel Management Final EIS – Chapter 3

Table 3-39. R-1 Sensitive Plant Species - Ashland

Common & 

Scientific 

Name 

Type F

24 Global 

Rank F

25

State 

Rank

F

26

Habitat Closest known 

population 

Flowering 

Period 

Fruiting 

Period 

Nuttall 

DesertParsley 

(Known) 

Lomatium 

nuttallii F

27

3 G3 S1 

Open, rocky, mid to 

lower hillslopes on 

sandstone, siltstone, 

or clayey shale. 

Elev. 3400-7200 ft. 

Poker Jim Creek June July 

MESIC CONDITIONS

Pregnant 

sedge 

(Known) 

Carex 

gravida 

var. gravida

3 G5 S1 

Open woods, often in 

ravines with 

deciduous trees, on 

the plains. 

Elev. 3,880 –4,000 ft. 

East Fork Otter Creek; 

Hay Creek July 

The following table outlines routes where potential impacts could occur. 

Table 3-40. Motorized Routes Adjacent to Sensitive Plant Populations - Ashland

Route Name Route ID# Sensitive Plant 

Picnic Area / Campground 4095a Pregnant sedge 

Stocker Branch 4021 Pregnant sedge 

Ft. Howes Comm. Site 44211 Barr’s milkvetch 

4503 4503 Barr’s milkvetch 

Effects Analysis Methodology-Sensitive Plants 

The analysis is based on known sensitive plant occurrences as provided by the Montana Natural 

Heritage Program (MNHP 2008), recent survey findings, and habitat potential or habitat/site 

characteristics (landtype, habitat type, aspect, and elevation). Information used came from data on file 

at the Custer National Forest, literature review (Heidel, et.al., 1995; Heidel, et.al, 1996; Heidel, et.al, 

2002; Heidel, 2004; Barton, et.al, 2003; Hansen, et.al, 1987; Mincemoyer. 2006; MNHP. 2008; 

NatureServe. 2007; Schmoller, 1993; Schmoller, 1995; USDA Forest Service. 2001; USDA, 2008; 

USDI, 2005; Vanderhorst, et.al, 1998; and WYNDD, 2008). 

The potential direct effects are direct mortality which may come from more frequent ground 

disturbing activities within or near sensitive plant populations, such as camping or infrequent 

disturbance from accessing dispersed campsites. To estimate frequent disturbance potential, a 0-4% 

slope was overlain in GIS within the motorized route access corridor for parking/vehicle access to 

dispersed camping (300 foot buffer for vehicle access to dispersed camping for each alternative). 

 

27 Lomatium nuttallii, although not listed in the Region 1 2004 sensitive plant list, has been added as a species of concern due to new information that 

there are known populations of this regional sensitive species on the Ashland District. Concurrence with this action made by Regional Botanist, June 

2005. 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-121

Indirect effects may come from frequency and duration of camping use resulting in more difficult 

recovery due to soil compaction and vegetation composition change (including weeds) which may 

out-compete sensitive plants. A 400 foot buffer was applied to each alternatives’ designated routes to 

address access to dispersed camping allowance (300 feet) and additional area for weed spread 

potential (an additional 100 feet). Weed spread assumptions are found in the Weed section of this 

chapter. 

Direct and indirect vulnerabilities and exposures are evaluated to make a biological assessment effects 

determination on each species. 

3.4.3.8 Environmental Consequences – Sensitive Plants 

Direct and Indirect Effects-Sensitive Plants 

Actions proposed in all Alternatives have the potential to affect populations of sensitive plants. The 

potential direct effects from motorized routes are direct mortality of plants which may come from 

ground disturbing activities within sensitive plant populations, such accessing dispersed camping sites 

and dispersed camping. 

Indirect effects may come from accessing dispersed camp areas and camping use. These uses can 

create more difficult plant recovery due to soil compaction and vegetation composition change 

(including weeds) which may out-compete sensitive plants. 

Some activities associated with the roads and trails do have the potential to negatively affect 

individual plants, but should not cause population viability losses. Vehicle or human travel outside the 

road or trail prism could negatively impact plants through direct removal or damage. Weed 

establishment along roads and trails could out-compete desired vegetation and negatively affect 

sensitive plant species. Most road and trail maintenance activities that stay within the existing prism 

would not pose a direct threat to those plant populations that are established along roads or trails. 

Vulnerability and Exposure 

Two known species’ populations are exposed (see table above) and moderately vulnerable to direct 

effects from travel management. All of the species habitats have potential for being susceptible to 

noxious weed spread as an indirect effect of travel management (see Weed section of this chapter). 

Population or habitat exposure and vulnerabilities to direct and indirect effects are displayed in the 

following table. 

Table 3-41. Sensitive Plant Vulnerability - Ashland 

Species Direct Effects – Populations / Habitats 

Vulnerable to Direct Disturbance 

Indirect Effects - Habitat Vulnerable to 

Weed Spread 

Barr’s milkvetch 

Astragalus barrii

Low; the habitat’s terrain is not typically 

amenable for dispersed vehicle camping. 

Known populations do not occur within access 

corridor under any alternative. 

Moderate vulnerability - habitat can be 

vulnerable to weed spread, but Low 

exposure - populations not within 400 foot 

indirect effects corridor.
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-122 Ashland Travel Management Final EIS – Chapter 3

Table 3-41. Sensitive Plant Vulnerability - Ashland 

Species Direct Effects – Populations / Habitats 

Vulnerable to Direct Disturbance 

Indirect Effects - Habitat Vulnerable to 

Weed Spread 

Nuttall Desert-Parsley 

Lomatium nuttallii 28

Low; legal access to known populations does 

not exist due to adjacent private land. 

Moderate vulnerability - habitat can be 

vulnerable to weed spread, but Low 

exposure - populations not within 400 foot 

indirect effects corridor.

Pregnant sedge 

Carex gravida 

var. gravida

Moderate; one route crosses through one known 

location – no known historic dispersed camping 

adjacent to the route. 

Moderate vulnerability - habitat can be 

vulnerable to weed spread. Moderate 

exposure – habitat within 400 feet of 

designated routes under any alternative. 

There are no direct or indirect effects to Barr’s milkvetch or Nuttal’s desert parsley. There could be 

direct or indirect effects to pregnant sedge populations. 

Direct and indirect vulnerabilities and exposures, outlined in previous tables, were given an adjective 

rating and evaluated to make a biological assessment effects determination for each species as 

displayed in the following table. Implementation of any alternative would not be anticipated to move 

any sensitive plant species within the project area toward federal listing. 

Table 3-42. Effects Determination - Ashland 

Species Effects Components Alternative 

A 

Alternative 

B 

Alternative B 

Modified 

No Action 

Alternative 

Vulnerability - Direct Low Low Low Low 

Exposure - Direct Low Low Low Low 

Vulnerability - Indirect Moderate Moderate Moderate Moderate 

Exposure - Indirect Low Low Low Low 

Barr’s milkvetch 

(Known) 

Astragalus barrii

Effects Determination NI F

29 NI NI NI 

Vulnerability - Direct Low Low Low Low 

Exposure - Direct Low Low Low Low 

Vulnerability - Indirect Moderate Moderate Moderate Moderate 

Exposure - Indirect Low Low Low Low 

Nuttall Desert-Parsley 

(Known) 

Lomatium nuttallii

Effects Determination NI NI NI NI 

Vulnerability - Direct Moderate Moderate Moderate Moderate 

Exposure - Direct Moderate Moderate Moderate Moderate 

Vulnerability - Indirect Moderate Moderate Moderate Moderate 

Exposure - Indirect Moderate Moderate Moderate Moderate 

Pregnant sedge 

(Known) 

Carex gravida 

var. gravida Effects Determination MIIHF

30 MIIH MIIH MIIH 

 

28 Lomatium nuttallii, although not listed in the Region 1 2004 sensitive plant list, has been added as a species of concern due to new 

information that there are known populations of this regional sensitive species on the Ashland District. Concurrence with this action 

made by Regional Botanist, June 2005. 

29 NI = No Impact 

30 MIIH: May Impact Individuals or Habitat but will not Likely Contribute to a trend towards Federal Listing or Loss of Viability to the 

Population or Species 
Chapter 3: Affected Environment and Environmental Consequences 

Ashland Travel Management Final EIS – Chapter 3 Page 3-123

Cumulative Effects-Sensitive Plants 

Fuels reduction and timber management projects are currently planned and will continue to be planned 

for the District. These projects and any associated road use or construction have the potential to 

detrimentally impact individual plants and/or populations through direct plant removal or damage, 

ground disturbance, forest vegetation successional shifts, or habitat alteration (e.g. shade reduction) 

within or adjacent to plant populations. Prescribed burning and/or wildfire (natural and humancaused) also have the potential to detrimentally impact sensitive plants. These actions, without 

mitigation, may kill individual plants or entire populations, modify habitat (understory and overstory 

vegetation) to an unsuitable condition, or remove the habitat entirely. Permitted grazing has potential 

to impact sensitive plants. However, prior to implementation of future management decisions, sitespecific analysis and field surveys, where appropriate, would be completed to identify sensitive plant 

populations, determine potential effects to the populations from the actions, and design alternatives 

and/or prescribe mitigation measures to minimize impacts. Typically, adverse actions to plant 

populations would be avoided. 

Roadside low density infestations of various noxious weeds are found adjacent to routes, but none are 

known to exist near known populations of sensitive plant species that occur within 400 feet of 

motorized route corridor under any alternative. 

Travel along these routes by Forest users increases the potential that weed seed will be spread to other 

portions of the motorized route system and may establish within or adjacent to sensitive plant 

populations. Invasive species pose a risk to sensitive plants through direct competition. Herbicide 

application to manage invasive species also has the potential to kill sensitive plants. To help protect 

sensitive species, the 2006 Custer Weed Management EIS and Record of Decision directs that 

periodic inspections of known populations for the presence of invasive weeds is done. Herbicide 

applications along roads and trails would comply with product label requirements and protection 

measures described in the 2006 Custer Weed Management EIS. 

Implementation of any of the alternatives considered in this analysis would not be expected to 

contribute to significant cumulative effects. Anticipated future projects or activities are fewer in 

number and less disruptive from a resource extraction point of view than those projects or activities 

that have taken place in the past. Past activities or projects have not precluded the establishment and 

existence of known sensitive plant populations throughout the project area where appropriate habitats 

are found. Therefore, continuation of less impactive projects or activities would not be anticipated to 

contribute significantly to cumulative effects. 

3.4.3.9 Conclusion - Sensitive Plants 

Under all alternatives, two of the three species assessed are anticipated to have no impact. Any 

alternative may impact individuals or habitat of one species but will not likely contribute to a trend 

towards Federal listing or loss of viability to the population or species. 
Chapter 3: Affected Environment and Environmental Consequences 

Page 3-124 Ashland Travel Management Final EIS – Chapter 3

Table 3-43. Effects Determination Summary - Ashland 

Species Alternative A Alternative B Alternative B 

Modified No Action Alternative 

Known Populations 

Barr’s milkvetch 

Astragalus barrii No Impact F

31 No Impact No Impact No Impact 

Nuttall Desert-Parsley 

Lomatium nuttallii No Impact No Impact No Impact No Impact 

Pregnant sedge 

Carex gravida var. gravida MIIHF

32 MIIH MIIH MIIH 

Table 3-44. Summary of Number of Species by Effects Determination - Ashland

Effects Determination Alternative A Alternative B Alternative B 

Modified 

No Action 

Alternative 

Number of Species with No Impact 2 2 2 2 

Number of Species with potential to effect 

individuals or Habitat but will not Likely 

Contribute to a trend towards Federal 

Listing or Loss of Viability to the 

Population or Species 

1 1 1 1 

All alternatives are consistent with the laws, regualations, policy, and Custer Forest Plan. Selection of 

any alternative would be consistent with the regulatory framework relative to sensitive plants. 

- End of Chapter 3 -

 

31 NI: No Impact 

32 MIIH: May Impact Individuals or Habitat but will not Likely Contribute to a trend towards Federal Listing or Loss of Viability to the 

Population or Species