Final 

General Management Plan / Environmental Impact Statement

DEVILS TOWER NATIONAL MONUMENT 

Crook County, Wyoming 

November 2001 

This General Management Plan / Environmental Impact Statement describes and analyzes five alternatives for managing 

Devils Tower National Monument. The approved plan will help managers make decisions about managing development, 

visitation, and natural and cultural resources for the next 15 to 20 years. Some issues to be addressed are vehicle congestion,

crowded facilities, limited orientation and interpretation, and protecting the rural character of land outside monument 

boundaries. 

Alternative 1, the no-action alternative, would continue the present management. It provides a baseline for understanding 

why certain changes may be advisable. There would be no new construction or major changes, and the monument would be 

operated and maintained as before. Summer congestion and noise in the Tower area would continue, and parking areas often 

would be full. Prairie dogs would be disturbed at pullouts along the main road. The four “action” alternatives prescribe various approaches to managing the monument’s resources and visitation. In alternative 2, registration would be necessary for 

visits in the peak season. In all the action alternatives, adjustments would be made in parking and in the use of monument 

roads and trails. A landscaped pedestrian plaza would be created near the Tower in alternatives 2, 3, and 4. A shuttle system 

would be established in alternatives 3 and 4, with a staging area where visitors could park, receive orientation and interpretation, and hike or bicycle to the Tower. In alternative 4 the staging area would be outside the monument boundary. Prairie 

dog viewing in alternatives 3 and 5 would be available from large pullouts on both sides of the road. In alternatives 2 and 

4, the current prairie dog pullouts would be removed and rehabilitated to natural conditions, but one loop of the Belle 

Fourche River campground would be converted to an area for parking and prairie dog viewing and interpretation. Alternative 2 would emphasize offering a natural setting. Some areas would be restored to native vegetation, and camping would be 

available only in one loop of the campground. In alternative 3, the preferred alternative, some areas would be restored to 

natural conditions, and all camping in the monument would be eliminated. In alternative 4 the headquarters and maintenance 

facilities would be relocated outside the boundaries, and their current locations would be restored to natural vegetation. Tour

buses would park in the offsite shuttle staging area, which also would accommodate restrooms, visitor orientation and interpretation, and other visitor facilities. Camping would be available in one loop of the campground, with the other loop converted to accommodate a shuttle stop, tour bus parking, a prairie dog trail, picnic sites, restrooms, and interpretation. 

Alternative 5 would offer experiences similar to those available now, but facilities would be added, and parking accommodations would be enlarged and redesigned. No shuttle system would be added, and the current camping facilities would 

remain. The headquarters building would be enlarged, and more restrooms would be added. 

This document includes discussion of the potential environmental consequences of each alternative. In the no-action alternative, as in all the action alternatives, the overall adverse or beneficial effects on vegetation, prairie dogs, habitat for other 

wildlife, and wetlands would be negligible to minor with appropriate mitigation. Moderate adverse impacts on air quality and 

floodplains would continue in alternative 1, and there would be adverse impacts on the ethnographic resources sacred to 

American Indian tribes, with minor to moderate adverse effects on other cultural resources. The visitor experience would be 

adversely affected by crowding and a lack of services but would benefit from retaining the campground and prairie dog viewing. Alternatives 1, 2, 4, and 5 would compromise natural and beneficial floodplain values, a major adverse impact on floodplains, and a minor to moderate risk of severe flooding in these alternatives could cause major adverse impacts on campers.

In alternative 3, removing the campground and rehabilitating the floodplain would restore natural and beneficial values, a 

major long-term beneficial effect, and removing the campground also would have a major beneficial effect on visitors who 

might have been at risk. Alternative 5 would cause long-term moderate adverse impacts on soils. Alternative 3 would result 

in moderate beneficial effects on historic resources. Alternative 5 would cause minor to moderate adverse impacts on historic 

resources, and mitigation might be required to comply with section 106 of the National Historic Preservation Act. The longterm beneficial effects on ethnographic resources from alternatives 2, 3, and 4 would be moderate, but alternative 5 would 

result in moderate long-term adverse impacts on ethnographic resources. Beneficial effects on the visitor experience from 

alternative 2 would be moderate to major; from alternative 3, major during peak use season; from alternative 4, minor to 

moderate. Alternative 5 would result in a long-term moderate adverse impact on the visitor experience. The short-term 

beneficial effect on employment opportunities and the local and regional economy, including indirect effects on local 

businesses and tax revenues from alternatives 2, 4, and 5 would be minor, and from alternative 3, moderate. 

The public review period on the Draft Environmental Impact Statement ended September 30, 2001. This final document 

includes the results of the public comment on the draft document. The no-action period on this final plan and environmental 

impact statement will end 30 days after the Environmental Protection Agency has accepted the document and published a 

notice of availability in the Federal Register. For further information, write to Superintendent, Devils Tower National Monument, P.O. Box 10, Devils Tower, Wyoming 82714, or telephone 307/467-5283, or e-mail deto_planning@nps.gov. 

______________________________________________________________________________

United States Department of the Interior ● National Park Service 
ii 
iii 

SUMMARY 

The purpose of this General Management Plan / 

Environmental Impact Statement is to define a 

direction for the management of Devils Tower 

National Monument for the next 15 to 20 years. 

The approved plan will provide a framework for 

making decisions about visitor use and the management of natural and cultural resources and 

development so that future opportunities and 

problems can be addressed effectively. The plan 

will prescribe the resource conditions and visitor 

experiences to be achieved over time according 

to law, policy, regulations, public expectations, 

and the monument’s purpose, significance, and 

special mandates. 

An updated plan is needed to address current 

issues related to increased visitation, the degradation of natural systems, changing regional 

land uses, and conflicts among various user 

groups. Some of those issues are vehicle 

congestion, crowded facilities, limited orientation and interpretation, and parking needs. 

ISSUES TO BE ADDRESSED 

The visitor center (built by the Civilian Conservation Corps in the 1930s) cannot accommodate 

the current level of visitation. Facilities used by 

the monument staff and the cooperating association are inadequate, as is storage space. However, despite the need for improved visitor and 

staff facilities, the small size of the monument 

and the importance of scenic views must be 

considered. 

Natural resource issues that must be addressed 

are the management of floodplains, the effects of 

fire suppression on native vegetative communities, and visitor interaction with prairie dogs. 

The effects of changing economics and development patterns on the setting and character of 

the surrounding area also need to be considered. 

Aboveground powerlines can obstruct scenic 

views, and night lighting affects views from the 

Tower area and the monument’s trails. 

Visitors’ use of the monument sometimes conflicts with the traditional cultural values of 

American Indians to whom Devils Tower has 

spiritual meaning. Visitors’ understanding of the 

significance of Devils Tower National Monument is limited by a lack of adequate orientation 

and interpretation. Additional interpretive emphasis is needed to foster awareness among 

visitors of the significance of the Tower to the 

indigenous nations of the northern plains. 

The National Park Service (NPS) at Devils 

Tower shares with many of its neighbors a 

concern for the long-term protection of the 

natural and rural character of the land outside 

monument boundaries. Actions taken by the 

Park Service or others could result in developments or land uses that would be inconsistent 

with local scenic values and would affect local 

residents’ quality of life. To help preserve scenic 

values, the National Park Service would seek 

expanded legislative authority to accept 

donations of lands and/or interests in lands (such 

as scenic easements), as well as land exchanges 

(with no net gain of government land). 

The National Park Service has worked with 

various landowners on agreements whereby the 

landowners would give the National Park 

Service scenic easements. Unfortunately, these 

efforts have not come to fruition. The National 

Park Service is willing to reexamine scenic 

easements if landowners are willing. 

ALTERNATIVES 

To achieve the desired conditions in Devils 

Tower National Monument, the planning team 

developed a “no-action” alternative (continuing 

present management) and four “action” alternatives for managing the resources and visitor uses 

of Devils Tower National Monument. Each 

action alternative would assign various areas of 

the monument to different management zones. 

The management zones identify how different 

areas could be managed to achieve a variety of 
SUMMARY

iv 

resource conditions and visitor experiences. In 

each alternative, the seven management 

zones — developed zone, pedestrian zone, 

natural trailed zone, developed camping zone, 

semiprimitive zone, special protection zone, and 

administrative zone — would each specify a 

particular combination of resource, social, and 

management conditions. 

Alternative 1, the no-action alternative,

represents the existing conditions at the monument. Under this alternative, the monument 

would continue to be managed as it has been in 

the past. This alternative is presented as a way of 

comparing current conditions to possible future 

conditions, as described in the other four alternatives. It provides a baseline for understanding 

why the National Park Service or the public may 

believe that certain future changes are necessary 

or advisable.

No new construction or major changes would 

take place under the no-action alternative, and 

the monument’s existing facilities would continue to be operated and maintained as before. 

The Tower area would continue to be congested 

and noisy in summer, and the available parking 

areas frequently would be full, causing visitors 

to wait for parking spaces. The parking lots 

could not accommodate oversize vehicles, and 

trailers and larger recreational vehicles would 

have to be left in a dropoff area. Idling tour 

buses would continue to contribute to noise and 

congestion. 

The initial section of the Tower trail still would 

be too steep for many visitors, especially those 

with impaired mobility. The prairie dog town 

pullouts along the main road would continue to 

contribute to traffic congestion and the disturbance of the animals and their habitat. The 

picnic area, the permit camping area for large 

groups, and the two-loop Belle Fourche River 

campground would be available for visitor use. 

Alternative 2 would emphasize offering a 

natural setting. Peak season visitation would be 

reduced through a reservation system. Overall 

development would be reduced and natural 

vegetation restored in some areas. The Tower 

parking area would be converted to a landscaped 

pedestrian plaza designed with sensitivity to the 

historic context. The graveled parking area 

would be paved and redesigned to accommodate 

nearly all types of vehicles. Tour bus passengers 

would be dropped off and picked up near the 

Tower, with a special bus parking area near the 

campground. Trailer dropoff areas would be 

restored to native vegetation. 

To maximize resource protection and opportunities for solitude in the northwest corner of 

the monument, tighter restrictions would be 

implemented, with parties of one to five selfregistering and parties of six or more registering 

with a ranger. Visitor use of the north road 

would be prohibited beyond the Joyner Ridge 

trailhead, where the road would be retained for 

administrative and private access use only. 

The beginning part of the Tower trail would be 

redesigned for easier access. Where two-track 

dirt roads make up part of a trail, one track 

would be restored to native vegetation, leaving 

the other track for a trail. The west road and the 

prairie dog viewing pullouts would be removed 

and revegetated to natural conditions. Trails 

around the prairie dog town would be graveled 

and widened, and loop B of the Belle Fourche 

River campground would be the only area open 

to camping. Prairie dog viewing and interpretation would be available in the present campground loop A. 

In alternative 3, the preferred alternative, a 

shuttle system would be established, and visitors 

would be required to park at a staging area during peak use times; from there, they could hike, 

bicycle, or ride the shuttle to the Tower. Restrooms, a bookstore, expanded picnic sites, and 

access to the prairie dog town would be available at the staging area, and orientation and 

interpretation would be offered there. Tour buses 

would be required to return to the staging area to 

park after dropping off passengers at the Tower. 

The paved parking area at the base of the Tower 

would be converted to a landscaped pedestrian 

plaza designed with sensitivity to the historic 

context. The focus of the current visitor center 
Summary 

v 

would be on interpretation rather than on orientation. The gravel-surfaced parking area would 

be paved for parking and a shuttle stop. The 

beginning expanse of the Tower trail would be 

redesigned for easier access. Trailer dropoff 

areas would be restored to native vegetation. 

The campground and other facilities in the Belle 

Fourche River floodplain would be eliminated 

and the area restored to natural conditions. The 

prairie dog town pullouts along the main road 

would be replaced with larger pullouts on both 

sides of the road. Where two-track dirt roads 

make up part of a trail, one track would be restored to native vegetation, leaving the other 

track for a trail. A spur trail would be built to 

link the Joyner Ridge and Red Beds trails. 

To maximize resource protection and opportunities for solitude, tighter restrictions would be 

implemented, in the northwest corner of the 

monument, with parties of one to five selfregistering and parties of six or more registering 

with a ranger. Visitor use of the north and west 

roads would be prohibited beyond the Joyner 

Ridge trailhead, where the road would be restricted to administrative and private use only. 

The headquarters building would be expanded to 

increase office and storage space. 

In alternative 4, a shuttle system would be established (as in alternative 3), but the shuttle 

staging area and the visitor orientation facilities 

would be placed outside the monument boundary. Visitors would be required to park at the 

staging area at peak visitation times and go to 

the Tower by shuttle, hiking, or bicycling; at offpeak times, private vehicles could enter the 

monument. 

The headquarters and maintenance facilities 

would be relocated outside the boundaries, and 

their current locations would be restored to 

natural vegetation. Tour buses would park in the 

staging area, which also would accommodate 

restrooms, visitor orientation, interpretation, a 

bookstore, an amphitheater, and picnic sites. The 

paved parking area near the Tower would be 

converted to a landscaped pedestrian plaza, as in 

alternative 3. The design and landscaping of this 

area would be sensitive to the historic context 

and would blend into the natural surroundings. 

The beginning expanse of the Tower trail would 

be redesigned for easier access. 

The campground and the Belle Fourche River 

sites would be accessible by shuttle during peak 

use times and by private vehicle during nonpeak times. Camping would be available in loop 

B of the Belle Fourche River campground, but 

no camping would be permitted in loop A, 

where a shuttle stop would be developed. Visitors could park there, and a trail would lead to 

the prairie dog town. Interpretation, restrooms, 

picnic sites, and an amphitheater would be available in this area. Tour buses would be required 

to park at this shuttle stop after dropping off 

passengers at the Tower. 

Where two-track dirt roads make up part of a 

trail, one track would be restored to native 

vegetation, leaving the other track for a trail. A 

spur trail would be built to link the Joyner Ridge 

and Red Beds trails. Trailer dropoff areas and 

the prairie dog town pullouts would be removed 

and restored to native vegetation. The main road 

near the administration building would be redesigned to allow for safe and efficient traffic flow 

into and out of the shuttle stop. 

To maximize resource protection and opportunities for solitude in the northwest corner of the 

monument, tighter restrictions would be implemented. Parties of one to five would selfregister, and parties of six or more would register with a ranger. Visitor use of the north and 

west roads would be prohibited beyond the 

Joyner Ridge trailhead, where the road would be 

restricted to administrative and private use only. 

Alternative 5 would offer experiences similar to 

those available now, but facilities would be 

added to reduce congestion. The paved and 

gravel-surfaced parking areas at the base of the 

Tower would be redesigned, enlarged, and consolidated for more efficient circulation, and all 

parking areas would be paved. To the extent 

possible within the available space, the approach 

to the Tower trail would be redesigned for easier 

access. No shuttle system would be added. 
SUMMARY

vi 

The Belle Fourche River campground would 

remain. Administrative headquarters would be 

enlarged to accommodate better visitor orientation and interpretive services. The visitor center 

parking lot and the overflow parking area would 

be enlarged, and all parking areas would be 

paved and redesigned to maximize safety and 

efficiency. The trailer dropoff area would be 

enlarged and paved to accommodate tour buses, 

which would be required to park there. The 

visitor center and ranger station would remain, 

but the exhibits would be minimal to reduce 

crowding. More restrooms would be added near 

the main parking lot. 

To accommodate more vehicles, the prairie dog 

town pullouts would be converted to parking 

lanes on both sides of the road. The prairie dog 

town trail would be surfaced to reduce maintenance costs. The entrance station area would be 

redesigned to better accommodate seasonal 

traffic flow. The road to the Joyner Ridge trail 

would be widened and paved, and the trailhead 

parking area would be enlarged. Tighter restrictions would be implemented in the northwest 

corner of the monument, with parties of one to 

five self-registering and parties of six or more 

registering with a ranger. 

ENVIRONMENTAL CONSEQUENCES 

The planning team evaluated the potential consequences that the actions of each alternative 

would have on natural resources, threatened, 

endangered, or candidate species, cultural resources, the visitor experience, and socioeconomic resources. The beneficial or adverse 

effects were categorized as either short term or 

long term, and their intensity was rated as negligible, minor, moderate, or major. The impacts 

of the alternatives are compared in table 2. 

For alternative 1, the no-action alternative,

the overall adverse or beneficial effects on such 

natural resources as soils, vegetation, wildlife, 

wetlands, and threatened or endangered species 

would be negligible to minor with appropriate 

mitigative measures. 

Air quality degradation — from vehicles waiting 

in line or circling to look for parking spaces and 

from tour buses idling — would continue. These 

adverse impacts would be moderate and long 

term at peak visitation times. Developments in 

the 100-year floodplain would continue to compromise the natural and beneficial values of 

floodplain areas. Developing an evacuation plan 

for the Belle Fourche River campground as 

mitigation would have a minor beneficial longterm effect on the floodplain. 

Visitor congestion and vehicular traffic during 

peak visitation periods would continue to degrade ethnographic resources sacred to American Indian tribes in the peak use season, a major 

long-term adverse impact. Privacy for American 

Indian religious activities could be compromised 

by the presence of visitors and traffic. These 

conflicts would be a minor recurring short-term 

adverse impact on ethnographic resources. Traffic, erosion, and highway construction would 

reduce the number and integrity of the roadway 

features made in the 1930s by the Civilian Conservation Corps. The effects on other cultural 

resources would be minor, and the overall 

adverse effects on historic resources from 

alternative 1 would be minor to moderate. 

The visitor experience would continue to be 

degraded by noise, vehicle smells, and the frustration of not being able to park at peak use 

times, a major adverse impact. Continuing the 

opportunity to observe prairie dogs would be a 

major beneficial effect for visitors. Retaining the 

administrative headquarters in the present location would continue a minor visual intrusion on 

the historic and natural scene in the long term, 

but continuing opportunities for a quiet, natural 

experience in the monument’s northwest corner 

would result in a long-term major benefit for 

visitors. 

Keeping the Tower trail as at present, with its 

difficult approach, would result in a major longterm adverse effect on visitors who could not 

experience the monument’s primary resource. 

Traffic congestion on the main road, together 

with the requirement that towed vehicles be 

dropped off, would inconvenience visitors, 
Summary 

vii 

resulting in moderate adverse impacts at peak 

times. Some visitors would continue to be 

frustrated by the inability to receive orientation 

and interpretation; this would constitute a longterm moderate to major adverse impact on the 

visitor experience. Retaining the campground 

would constitute a moderate long-term beneficial effect for visitors. 

The Devils Tower Trading Post and the KOA 

General Store would continue to have a competitive advantage over other commercial outlets, a moderate beneficial long-term effect for 

those businesses. Other socioeconomic impacts 

would be negligible to minor. 

Alternative 2 would result in overall negligible 

to minor adverse impacts on soils, vegetation, 

prairie dogs, and other wildlife (with appropriate 

mitigation). There would be negligible to minor 

beneficial effects on air quality and wetlands, 

and a major long-term adverse impact on floodplains and on campers if they experienced 

flooding. 

Traffic-related visual intrusions on culturally 

sensitive areas would be reduced, improving the 

ethnographic context of the area. This would be 

favorable to American Indian tribes. Decreased 

visitation and crowding would provide more 

opportunities for solitude and quiet for traditional uses, and visual and auditory intrusions 

would be reduced. On balance, the long-term 

beneficial effects on ethnographic resources 

from alternative 2 would be moderate. The adverse and beneficial effects on historic resources 

and the historic setting would be minor. 

Long-term major beneficial effects on the visitor 

experience would result from reduced waiting 

lines, improved traffic flow, and reduced traffic. 

Adding a pedestrian plaza and moving parking 

farther from the Tower would make the setting 

quieter and more contemplative, but placing 

parking farther from the facilities could affect 

visitors with impaired mobility. However, since 

design could minimize the grade, this long-term 

impact would be minor. Redesigning the Tower 

trail access would benefit a significant number 

of visitors, a moderate to major beneficial effect 

on the visitor experience. 

Short-term noise and visual intrusions from 

construction would cause moderate to major 

short-term adverse effects. Eliminating parking 

in pullouts along the main road would result in 

improved safety and a minor beneficial effect on 

the viewshed, and most visitors’ experience 

would be enhanced by being able to see prairie 

dogs in a quiet setting without traffic congestion. 

Establishing a reservation system would limit 

visitors’ ability to visit the monument spontaneously, a long-term major adverse impact because 

many visitors would be affected, and many place 

a high value on spontaneity. Having interpretation and information more effective and more 

readily available would be a major beneficial 

effect for most visitors. 

The Devils Tower Trading Post and the KOA 

General Store would continue to have a competitive advantage over other commercial outlets, a moderate beneficial long-term effect for 

those businesses. If campers displaced from 

Devils Tower chose to camp at the KOA or 

Tower View campgrounds, that could result in a 

minor beneficial long-term effect on revenues at 

those campgrounds. 

Construction work would result in about 16 new 

one-year jobs, and the expenditures of construction laborers would benefit local retailers, a 

minor short-term beneficial effect on the local 

and regional economy. Sales taxes collected on 

the expenditures of these workers would benefit 

local jurisdictions, as would the purchase of 

construction materials, a minor short-term beneficial effect on county sales tax revenues. 

Alternative 3, the preferred alternative, would 

cause minor long-term adverse impacts on soils, 

vegetation, and prairie dogs (with appropriate 

mitigation) and a minor beneficial effect on 

wildlife habitat in the long term. There would be 

a long-term negligible impact on wetlands and a 

major long-term beneficial effect on floodplain 

values. This alternative also could result in a 

major long-term beneficial effect on campers, 
SUMMARY

viii

who would not experience flooding if a flood 

occurred in the area of the current campground. 

Establishing a shuttle system would improve the 

air quality at the base of the Tower and degrade 

it at the shuttle staging area at peak times. Closing the campground would improve the air quality because wood smoke from campfires would 

be eliminated. Enlarging the headquarters building and moving the parking lot to the back of the 

building would result in a minor long-term adverse effect on wetlands. Removing the campground would end overnight use of the 100-year 

floodplain, a major long-term beneficial effect 

on the floodplain. 

A long-term moderate beneficial effect on ethnographic resources would result from converting the upper parking area to a pedestrian plaza, 

removing the prairie dog town pullouts, rehabilitating trails and disturbed areas, and limiting 

automobile access, all of which would improve 

the viewshed and reduce traffic noise. The 

ethnographic context would be improved by 

these actions, and more opportunities for 

solitude and quiet would be available for traditional uses. This would be favorable to American Indian tribes that might want to conduct 

religious activities at the Tower. 

The construction activities of alternative 3 

would cause some minor adverse impacts, as 

would adding a spur trail. Historic resources 

would benefit from removing the parking area at 

the base of the Tower, establishing a pedestrian 

plaza, operating a shuttle during peak visitation 

periods, and scheduling tour bus visits to the 

Tower. 

Managing monument use in the northwest 

corner to protect its quiet, contemplative character would benefit the visitor experience in the 

long term. Construction noise and visual intrusions would cause moderate to major short-term 

adverse impacts on the visitor experience, and 

removing a campground would be a negligible 

to minor long-term adverse impact. The shuttle 

system would result in a long-term major adverse impact on visitors who place high value on 

spontaneity, privacy, and independence. This 

impact would be mitigated somewhat because 

the shuttle would operate only during the peak 

use season, and even at peak times there would 

be hours in the morning and evening when visitors would not be required to use the shuttle. 

Crowding and noise in the Tower area would be 

reduced through managed visitation levels and 

the use of a shuttle system at peak times. Visitors would be free of the frustrations of searching for parking places, and many would enjoy 

the opportunity to experience the scenery without the pressures of driving. Adding restrooms 

also would benefit visitors. Redesigning the 

approach to the Tower trail would result in longterm moderate to major beneficial effects on the 

visitor experience. Adding a pedestrian plaza 

and moving parking farther from the Tower 

would make the setting quieter and more contemplative; however, having parking farther 

away could adversely affect visitors with impaired mobility. The design could minimize the 

grade; therefore, this long term impact would be 

minor. 

Visitors’ freedom of movement would be restricted by reducing road access in the northwest 

corner of the monument and by the requirement 

for use permits. The adverse effect of this would 

be minor for a small number of visitors, but it 

would be moderate for visitors with impaired 

mobility because of the loss of vehicle access to 

some parts of the monument. Safety would be 

improved by reducing traffic at the Tower area 

and providing pullouts on both sides of the road 

at the prairie dog town. Overall, alternative 3 

would have a major long-term beneficial effect 

on the visitor experience during the peak season. 

Moving the entrance station would allow more 

visitors to stop at businesses adjacent to the 

monument at peak times. This intermittent minor 

beneficial effect would be long term. Private 

campgrounds would gain new business, a moderate and intermittent beneficial effect on local 

businesses in the long term, and also a minor 

beneficial long-term effect on local taxing 

authorities. 
Summary 

ix 

The short-term construction projects of alternative 3 would result in about 61 one-year construction jobs, and the expenditures of construction workers would benefit local retailers, a 

minor short-term beneficial effect. The purchase 

of construction materials in the region would 

result in a minor short-term beneficial effect for 

regional suppliers and the regional economy. 

Sales taxes collected on the expenditures of construction workers would result in a minor shortterm benefit for local jurisdictions, as would the 

taxes collected on construction materials. 

Alternative 4 would have minor adverse effects 

on soils, vegetation, prairie dogs, and wildlife 

habitat (with appropriate mitigation). The air 

quality would be improved by adding a shuttle 

system and by the absence of wood smoke from 

campground loop A and the special permit 

camping area, but the air quality at the shuttle 

staging area outside the monument would be 

degraded. Removing the headquarters and maintenance facilities and the trailer dropoff and 

restoring the wetlands would have a moderate 

beneficial effect on wetlands in the long term. 

Adding a shuttle stop in the floodplain would 

decrease the absorption of water by the soil and 

would conflict with the NPS policy of protecting 

natural and beneficial floodplain values, resulting in a long-term major adverse impact on 

floodplains. Removing the maintenance complex 

from the 500-year floodplain would increase 

natural values in that area, a long-term minor 

beneficial effect on floodplains. Since one section of the campground would continue to occupy part of the 100-year floodplain, if a 100-year 

flood occurred on the Belle Fourche River, there 

would be a hazard to campground occupants; 

however, the expected 3-hour flood warning 

time and the evacuation plan to be developed 

would allow ample time for campers to get out 

of the floodplain. Severe flooding has been 

infrequent, and the risks are minor to moderate, 

but flooding could result in major adverse 

effects on the visitors involved. 

The viewshed would be improved and traffic 

noise and crowding would be reduced. This 

would improve the ethnographic context, offer 

more opportunities for solitude and quiet for 

traditional uses, and be favorable to American 

Indian tribes that might want to conduct 

religious activities at the Tower. This would be a 

long-term moderate beneficial effect on ethnographic resources. 

Reducing the concentrations of people in the 

northwest corner of the monument through 

permitting would protect culturally sensitive 

areas and increase the opportunity for solitude in 

a larger area, a negligible long-term beneficial 

effect on traditional cultural practices. Not 

allowing visitors on the north and west roads 

would reduce visual and auditory intrusions in 

this culturally sensitive area and increase the 

sense of solitude. This beneficial effect on ethnographic resources would be minor and long 

term. 

Visual and auditory intrusions from construction 

would result in short-term adverse impacts on 

historic resources, but beneficial effects would 

result from removing the parking area at the 

base of the Tower, establishing a pedestrian 

plaza, operating a shuttle at peak use times, and 

scheduling tour bus visits to the Tower. 

Alternative 4 would have major long-term beneficial effects on the visitor experience, especially 

in the peak season, because the shuttle system 

would reduce noise and crowding, visitors 

would not have to search for parking spaces, and 

added restrooms would decrease visitor discomfort. The setting would be quieter and more contemplative when the paved parking area was 

replaced by a more natural pedestrian plaza, 

with vehicles parked farther away. However, 

moving parking farther from the Tower could 

adversely affect some visitors, especially those 

with impaired mobility. The design could minimize the grade; therefore, this long term impact 

would be minor. Opportunities for interpretation 

and orientation would be improved by increased 

space in the pedestrian plaza and more in-depth 

orientation at the shuttle staging area. 

Redesigning the approach would improve access 

to the Tower trail, a long-term moderate to major beneficial effect. Views would be enhanced 
SUMMARY

x 

by the reduction of pavement near the Tower. 

Relocating the administrative headquarters and 

maintenance facilities would improve the viewshed. Rehabilitating the area from which those 

facilities were removed to a natural appearance 

would improve the scenery, a long-term major 

beneficial effect on most visitors. Safety would 

be improved by reducing traffic at the Tower 

area, removing the prairie dog town pullouts, 

and realigning the intersection between the main 

road and the access road to the shuttle staging 

area. 

The noise and visual intrusions from construction activities would have short-term moderate 

to major adverse effects on the visitor experience because they would occur in the monument’s prime resource areas. Construction 

activities would impair the viewshed and displace some animals and birds, reducing visitors’ 

opportunities for viewing wildlife. Visitors’ 

opportunities to see the prairie dogs would be 

enhanced through improved access and improved prairie dog town trails. People could 

watch the prairie dogs in a quieter setting free 

from traffic congestion and safety concerns. The 

overall effect on the visitor experience would be 

long term and beneficial. 

Eliminating 40% of the monument’s campsites 

would result in a minor short-term adverse impact on some campers. Managing monument use 

in the northwest corner to protect the quiet, contemplative character of the visitor experience 

would benefit the visitor experience in the long 

term. Visitors’ freedom of movement would be 

restricted by reduced road access in this area and 

by the requirement for use permits. Only a small 

number of visitors would be affected, so this 

long-term impact would be minor; however, for 

visitors with impaired mobility, the impact 

would be moderate because of the loss of vehicle access to some parts of the monument. 

Visitors could not move around at their own 

pace during peak times, and using the shuttle 

might increase the cost of visiting the monument. Overall, the shuttle system would result in 

a long-term major adverse impact on visitors 

who place high value on spontaneity, privacy, 

and independence. This impact would be mitigated somewhat because the shuttle would 

operate only during the peak use season, and 

even at peak times there would be morning and 

evening hours when shuttle use would not be 

required. The shuttle system would reduce waiting lines at the entrance station, resulting in a 

long-term minor to moderate beneficial effect on 

the visitor experience. 

Alternative 4 would result in a minor beneficial 

long-term effect on local taxing authorities from 

increased taxable revenues, and a minor longterm beneficial effect on the local and regional 

economy. Operating a shuttle service would 

have a minor beneficial long-term effect on 

employment opportunities, on the local and 

regional economy, and on local businesses and 

tax revenues. Between 8 and 29 jobs could be 

created. Overall, the shuttle service would 

contribute only a small percentage of the 

regional economy’s jobs and earnings. 

The addition of about 61 one-year construction 

jobs would be a minor short-term beneficial 

effect on the region’s overall employment. The 

purchase of construction materials in the region 

would result in a minor short-term beneficial 

effect for regional suppliers and the regional 

economy. Sales taxes collected on the expenditures of construction workers would result in a 

minor short-term benefit on local jurisdictions, 

as would the taxes collected on construction 

materials. 

In Alternative 5 about 1 acre of natural soil profile would be lost, and despite efforts to prevent 

erosion, some soil probably would be eroded on 

about 5 acres disturbed by construction. About 2 

more acres of soil would be covered with hardened surface, and none would be rehabilitated. 

Implementing alternative 5 would result in longterm moderate adverse impacts on soils. 

The adverse impacts on vegetation, prairie dogs, 

wetlands, wildlife habitat, and air quality would 

be negligible to minor. There would be major 

long-term adverse impacts on floodplain values 

and on campers if they experienced flooding. 
Summary 

xi 

The solitude needed for religious ceremonies 

would be lessened by developments and increased visitor access. This alternative, which 

calls for the highest level of development and 

for paving the current trailer dropoff area and 

parking tour buses there, would compromise the 

ethnographic resources of the Tower area and 

degrade the viewshed. This would be a moderate 

long-term adverse impact on ethnographic resources. Adverse impacts on other ethnographic 

resources would be negligible to minor. 

The effects on historic resources from visitor 

activity and traffic congestion would be minor. 

Adding parking lanes on both sides at the prairie 

dog town, redesigning the entrance station area, 

and increasing the size of the headquarters 

would modify the historic road corridor, a moderate long-term adverse impact. Redesigning the 

entrance station area would change the setting of 

the national register-listed entrance station, and 

widening the road through the prairie dog town 

could alter CCC elements of the historic road, 

such as culverts. The impacts that these actions 

would have cannot be known without more information on the details of design. One or both 

of these actions could require mitigation to 

comply with section 106 of the National Historic 

Preservation Act. 

Improving the approach to the Tower trail would 

have a major beneficial effect on visitors who 

otherwise might be unable to have a close experience of the Tower. Added parking in the 

Tower area would reduce visitor frustration over 

the inability to find a parking space, and better 

design would foster safer traffic flow. However, 

alternative 5 would have long-term moderate to 

major adverse impacts on the visitor experience 

at peak use times because noise, traffic, and vehicle odors would continue to degrade the experience of the monument’s prime resources. 

Interpretive opportunities would be limited by 

the small size of the visitor center and by 

crowding at the Tower area. This would constitute a long term moderate to major adverse impact on visitors. For visitors to whom spontaneity is important, the freedom to come and go 

at their own pace would be perceived as a long 

term major beneficial effect. Continuing the 

availability of the campground and picnic area 

would have a long term moderate beneficial 

effect on visitors. 

The Devils Tower Trading Post and the KOA 

General Store would continue to have a competitive advantage over other commercial outlets, a moderate beneficial long-term effect for 

those businesses. Adding parking along both 

sides of the road through the prairie dog town 

would improve traffic safety, a minor long-term 

beneficial effect. The creation of about 37 oneyear construction jobs would have a minor longterm beneficial effect on employment opportunities and the local and regional economy, 

including indirect effects on local businesses and 

tax revenues. 
SUMMARY

xii 

(blank) 
xiii 

CONTENTS 

Purpose of and Need for the Plan 

Purpose, Need, and Scoping 1 

Brief Description 1 

Purpose of the Plan 1 

Need for the Plan 1 

Congestion 1 

Inadequate Staff Facilities 2 

Interpretation and Visitor Orientation 2 

Natural Resource Management 2 

Boundary and Cross-Boundary Concerns 2 

Cultural Resource Management 3 

Aesthetics 3 

Development 3 

The Scoping Process 3 

Notices, Newsletters, and Meetings 3 

Visitor Use Study 3 

Laws, Policies, and Mandates 4 

Mission and Goals 4 

Monument Purpose 4 

Monument Significance 4 

Mission Goals 4 

Special Mandates and Administrative Commitments 4 

Climbing Management 4 

Livestock Management 4 

Servicewide Laws and Policies 5 

Natural Resource Management Requirements 5 

Cultural Resource Management Requirements 9 

Visitor Experience and Park Use Requirements 12 

Sustainable Design/Development 13 

Rights-of-way and Telecommunication Infrastructure 13 

Alternatives, Including the Proposed Action 

What Might Be Achieved 19 

Decision Points 19 

Issue Not Addressed in This Plan 19 

Resources and Values at Stake in the Planning Process 19 

Topics Dismissed from Further Consideration 20 

Threatened, Endangered, and Proposed Species 20 

Prime and Unique Farmland 21 

Water Resources 21 

Archeological Resources 21 

Cultural Landscapes 21 

Collections 22 

Traffic 22 

Environmental Justice 22 

Relationships to Plans of Other Agencies 22 
CONTENTS

xiv

Indian Trust Resources 22 

Potential Management Prescriptions 24 

Developed Zone 24 

Pedestrian Zone 24 

Natural Trailed Zone 25 

Developed Camping Zone 25 

Semiprimitive Zone 25 

Special Protection Zone 26 

Administrative Zone 26 

Alternative 1 (No Action) 27 

Alternative 2 31 

Overall Concept 31 

Detailed Descriptions 31 

Estimated Costs 32 

Alternative 3 (Preferred Alternative) 35 

Overall Concept 35 

Detailed Descriptions 35 

Estimated Costs 39 

Alternative 4 40 

Overall Concept 40 

Detailed Descriptions 40 

Estimated Costs 43 

Alternative 5 44 

Overall Concept 44 

Detailed Descriptions 44 

Estimated Costs 47 

Alternatives Eliminated, Environmentally Preferable Alternative, and Mitigation 48 

Alternatives Eliminated from Further Consideration 48 

Develop a Visitor Parking Area North of the Tower 48 

Develop Tent Campsites at the Special Permit Camping Area 48 

Prohibit Vehicle Use in the Monument 48 

Construct the Shuttle Staging Area at the Belle Fourche River Campground Site 48 

The Environmentally Preferable Alternative 48 

Mitigation and Additional Studies 49 

Water Resources 49 

Cultural Resources 49 

Affected Environment 

Natural Resources 63 

Setting 63 

Soils 63 

Vegetation 63 

Wildlife 63 

Air Quality 64 

Threatened, Endangered, and Candidate Species 64 

Wetlands 64 

Floodplains 64 

Cultural Resources 66 

Ethnographic Resources 66 

Historic Resources 66 
Contents 

xv 

Visitor Experience 68 

Experiencing the Resources 68 

Freedom to Go at One’s Own Pace 68 

Orientation and Interpretation 69 

Safety 69 

Socioeconomic Resources 71 

Businesses and Monument Neighbors 71 

Local and Regional Economy 71 

Environmental Consequences 

Methodology for Analyzing Impacts 75 

Projects That Make Up the Cumulative Impact Scenario 75 

Impairment of Resources 77 

Natural Resources 77 

Cultural Resources 78 

Visitor Experience 80 

Socioeconomic Resources 80 

Effects of Alternative 1 (No Action) 84 

Natural Resources 84 

Soils 84 

Vegetation 84 

Wildlife 85 

Air Quality 85 

Threatened, Endangered, and Candidate Species 86 

Wetlands 86 

Floodplains 87 

Cultural Resources 89 

Ethnographic Resources 89 

Historic Resources 89 

Visitor Experience 91 

Visitors’ Experience of Monument Resources 91 

Access and Freedom to Go at One’s Own Pace 91 

Access to Orientation and Interpretation 92 

Visitor Safety 92 

Socioeconomic Resources 93 

Businesses and Neighbors 93 

Local and Regional Economy 94 

Unavoidable Adverse Impacts 94 

Irreversible and Irretrievable Commitments of Resources 95 

Relationships of Short-term Uses of the Environment and Long-term Productivity 95 

Impairment 96 

Effects of Alternative 2 97 

Natural Resources 97 

Soils 97 

Vegetation 98 

Wildlife 98 

Air Quality 99 

Threatened, Endangered, and Candidate Species 99 

Wetlands 100 

Floodplains 100 
CONTENTS

xvi

Cultural Resources 102 

Ethnographic Resources 102 

Historic Resources 103 

Visitor Experience 105 

Visitors’ Experience of Monument Resources 105 

Access and Freedom to Go at One’s Own Pace 106 

Access to Orientation and Interpretation 106 

Visitor Safety 107 

Socioeconomic Resources 107 

Businesses and Neighbors 107 

Local and Regional Economy 108 

Unavoidable Adverse Impacts 110 

Irreversible and Irretrievable Commitments of Resources 110 

Relationship of Short-term Uses of the Environment and Long-term Productivity 110 

Impairment 111 

Effects of Alternative 3 (Preferred Alternative) 112 

Natural Resources 112 

Soils 112 

Vegetation 113 

Wildlife 114 

Air Quality 114 

Threatened, Endangered, and Candidate Species 115 

Wetlands 115 

Floodplains 115 

Cultural Resources 117 

Ethnographic Resources 117 

Historic Resources 119 

Visitor Experience 120 

Visitors’ Experience of Monument Resources 120 

Access and Freedom to Go at One’s Own Pace 121 

Access to Orientation and Interpretation 122 

Visitor Safety 122 

Socioeconomic Resources 123 

Businesses and Neighbors 123 

Local and Regional Economy 124 

Unavoidable Adverse Impacts 126 

rreversible and Irretrievable Commitments of Resources 127 

Relationship of Short-term Uses of the Environment and Long-term Productivity 127 

Impairment 127 

Effects of Alternative 4 128 

Natural Resources 128 

Soils 128 

Vegetation 129 

Wildlife 130 

Air Quality 131 

Threatened, Endangered, and Candidate Species 131 

Wetlands 132 

Floodplains 132 

Cultural Resources 134 

Ethnographic Resources 134 
Contents 

xvii 

Historic Resources 135 

Visitor Experience 137 

Visitors’ Experience of Monument Resources 137 

Access and Freedom to Go at One’s Own Pace 138 

Access to Orientation and Interpretation 139 

Visitor Safety 139 

Socioeconomic Resources 140 

Businesses and Neighbors 140 

Local and Regional Economy 141 

Unavoidable Adverse Impacts 144 

Irreversible and Irretrievable Commitments of Resources 145 

Relationship of Short-term Uses of the Environment and Long-term Productivity 145 

Impairment 146 

Effects of Alternative 5 147 

Natural Resources 147 

Soils 147 

Vegetation 148 

Wildlife 148 

Air Quality 149 

Threatened, Endangered, and Candidate Species 149 

Wetlands 149 

Floodplains 150 

Cultural Resources 152 

Ethnographic Resources 152 

Historic Resources 153 

Visitor Experience 154 

Visitors’ Experience of Monument Resources 154 

Access and Freedom to Go at One’s Own Pace 155 

Access to Orientation and Interpretation 156 

Visitor Safety 156 

Socioeconomic Resources 157 

Businesses and Neighbors 157 

Local and Regional Economy 157 

Unavoidable Adverse Impacts 159 

Irreversible and Irretrievable Commitments of Resources 160 

Relationship of Short-term Uses of the Environment and Long-term Productivity 160 

Impairment 161 

Consultation and Coordination with Others 

Public Involvement 165 

Agencies and Organizations to Which This Document Was Sent 166 

Public Review of the Draft Document 168 

Record of Public Comments 168 

Written Comments 168 
CONTENTS

xviii

Appendixes, Bibliography, Preparers, and Index 

Appendix A: Developing the Preferred Alternative 187 

Appendix B: Summary of 1995 Climbing Management Plan 189 

Appendix C: Legislation 190 

Appendix D: Letter from U.S. Fish and Wildlife Service 193 

Appendix E: Statement of Findings for Wetlands 196 

Appendix F: Memorandum of Understanding Regarding Prairie Dogs 203 

Bibliography 209 

Preparers of Document 212 

Index Error! Bookmark not defined.

Maps 

Alternative 1 29 

Alternative 2 33 

Alternative 3 37 

Alternative 4 41 

Alternative 5 45 

Figure 

Figure 1: Total Visitation at Devils Tower 70 

Tables 

1. Comparison of Alternatives 51 

2. Comparison of Impacts 53 

3. Overnight Stays at Devils Tower National Monument 81 

4. Camping Costs at KOA Near Devils Tower 82 

5. Camping Costs at Devils Tower National Monument 82 

6. Criteria for Rating Severity of Impacts 83 
PURPOSE OF AND NEED FOR THE 

PLAN 
PURPOSE OF AND NEED FOR THE PLAN

xx 

(blank back of divider) 
1 

PURPOSE, NEED, AND SCOPING 

BRIEF DESCRIPTION 

Devils Tower National Monument comprises 

1,347 acres in northeastern Wyoming on the 

northwest edge of the Black Hills. The monument’s flora and fauna are typical of the Black 

Hills region of South Dakota and surrounding 

areas in Wyoming (NPS 1992). The Belle 

Fourche River, which flows through the eastern 

side of the monument, is part of the Cheyenne 

River Basin. Devils Tower, one of the most 

conspicuous geologic features of the Black Hills 

region, is made of igneous rock. 

PURPOSE OF THE PLAN 

The purpose of this General Management Plan / 

Environmental Impact Statement is to clearly 

define a direction for resource preservation and 

visitor experience at Devils Tower National 

Monument. 

The approved plan will provide a framework for 

proactive decision-making, including decisions 

on visitor use and on managing natural and 

cultural resources and development. This will 

allow managers to address future opportunities 

and problems effectively. 

This plan will prescribe the resource conditions 

and visitor experiences that are to be achieved 

and maintained in the national monument over 

time. What must be achieved according to law 

and policy will be clarified on the basis of 

review of the monument’s purpose, significance, 

special mandates, and the body of laws and 

policies directing management. Management 

decisions that must be made where law, policy, 

or regulations do not provide clear guidance or 

limits will be based on the monument’s purposes, the range of public expectations and 

concerns, resource analysis, evaluation of the 

natural, cultural, and social impacts of alternative courses of action, and consideration of longterm economic costs. This document will not 

propose specific actions or describe how particular programs or projects will be implemented or 

prioritized. Those decisions will be deferred to 

more detailed implementation planning, which 

will follow the broad, comprehensive decisionmaking presented in this document. 

NEED FOR THE PLAN 

The previous General Management Plan for 

Devils Tower was approved in 1986. The plan 

focused primarily on the construction of facilities, none of which have been built because of 

funding limitations. That plan did not address 

current issues related to greatly increased 

visitation, the degradation of natural systems, 

changing regional land uses, and conflicts 

among various user groups. 

The major issues to be addressed in the plan are 

outlined in the following paragraphs. 

Congestion 

The national monument is subject to visitor 

congestion, including vehicular circulation and 

parking, crowded visitor facilities, and visitor 

carrying capacity. 

Since the earliest years of Devils Tower 

National Monument, private automobiles have 

been the preferred means of access. For decades 

the National Park Service tried to satisfy increasing demands in traffic volume and vehicle size. 

Vehicular traffic during the peak visitor season 

now exceeds the monument’s capacity. A 

dramatic increase in overall visitation has 

resulted in overcrowding, congestion, impacts 

on natural sound, and trampling of vegetation. 

Since 1985 visitation increased from 224,994 

visitors per year to about 450,000 in 1990. 

Visitation is concentrated into the prime 

resource areas of the Tower, the visitor center 

area, the Tower trail, and the prairie dog town. 

During times of heavy use, visitors must wait in 

long lines to use the facilities at the Tower area. 

Staff members frequently have to wait for more 

than 15 minutes to enter the monument grounds 
PURPOSE OF AND NEED FOR THE PLAN

2 

when visitation is high. Not enough restrooms 

are available; this lack is among the most 

frequent complaints received from visitors. 

Inadequate Staff Facilities 

Offices for the monument staff are in four 

buildings located throughout the monument. 

Only two of these buildings were designed for 

office space; the other two are historic log 

cabins that have been modified for office space. 

None of the buildings has adequate space for 

today’s staff and office requirements. In addition, storage space is inadequate, and there are 

no facilities for staff meetings or breaks. The 

space available for the cooperating association’s 

offices and bookstore also is inadequate. 

Interpretation and Visitor Orientation 

Congestion and inadequate facilities limit the 

staff’s ability to offer orientation and interpretation that would ensure visitor understanding of 

the monument’s significance and allow visitors 

to make the best use of their time. The existing 

interpretive efforts concentrate on exploration by 

early settlers, recreational rock climbing, geologic theory of the Tower’s origin, and wildlife. 

However, with growing awareness of the significance of the Tower to the indigenous nations of 

the northern plains, additional interpretive 

emphasis is needed. 

A visitor center built by the Civilian Conservation Corps (CCC) in the 1930s to accommodate 

20,000 visitors per year now must accommodate 

approximately 400,000 visitors a year. A 1995 

visitor study showed that 80% of visitors who 

came to the monument used the visitor center, 

yet visitors ranked its quality among the poorest 

of the services and facilities. 

Natural Resource Management 

Flood control structures on the Belle Fourche 

River inside and outside the monument have 

severely damaged the riparian woodland system. 

The problem affects all the low elevation flatlands that make up the monument’s southeast 

corner. Dying trees and a lack of natural regeneration are evidence of this impact. Floodplain 

values are further compromised by the presence 

of some development in the 100-year floodplain. 

Virtually every square meter of the monument 

with soil has at least one of 56 exotic species. 

Herbicide applications to leafy spurge for the 

last 40 years have had a detrimental effect on 

riparian vegetation. 

Fire suppression is affecting native vegetative 

communities and wildlife habitat throughout the 

national monument. Nearly a century of fire 

suppression has left the monument’s pine forests 

more dense and vulnerable to catastrophic fires 

than in historic times. The lack of fire also has 

led to a failure to reproduce among deciduous 

woodland trees and shrubs. 

Large numbers of visitors stop along the entry 

road to watch prairie dogs. Many people walk 

out into the prairie dog town, which impacts the 

vegetation and alters the animals’ behavior. 

Visitors’ feeding the prairie dogs alters the animals’ behavior and poses a risk their health and 

safety. Occasionally the animals are lured to the 

road for handouts and are killed by automobiles. 

Boundary and Cross-Boundary Concerns 

Changing economics and development patterns 

threaten the traditional ranching lifestyle of 

monument neighbors and increase the potential 

for imminent development on adjacent lands. 

Such development could change the setting and 

rural character of the surrounding area. 

A proposed new airport 8 miles from the monument (near Hulett ) could negatively affect the 

monument’s natural quiet and viewshed. Airport 

planners predict nearly 10,000 takeoffs and 

landings per year, concentrated during the summer months. Computer analysis of the viewshed 

indicates that night lighting at the airport could 

be visible from inside the national monument. 
Purpose, Need, and Scoping 

3 

Cultural Resource Management 

Modern recreational use, developments, and 

climbing on the Tower are sometimes in conflict 

with American Indian traditional cultural values. 

High levels of development, visitor use, and 

crowding at the base of the Tower are not consistent with the spiritual nature of the area. 

Aesthetics 

Aboveground powerlines obstruct scenic views 

in Devils Tower. Monument developments and 

night lighting affect views from key resource 

areas such as the Tower area and the trails. 

Development 

Despite the need for improved visitor and staff 

facilities, additional development is of concern 

because of the small size of the monument and 

the importance of scenic views. 

THE SCOPING PROCESS 

Notices, Newsletters, and Meetings 

The notice of intent to prepare an environmental 

impact statement was published in the Federal 

Register on August 19, 1999. A newsletter was 

distributed in summer 1999 to inform the general public of the beginning of the planning 

process. The newsletter summarized the planning process and schedule, presented monument 

purpose and significance statements and mission 

goals, and included a brief listing of issues and 

concerns to be addressed in the plan. A response 

form included with the newsletter invited public 

comment on the purpose and significance statements and asked for any additional issues or 

concerns. Comments were received in the general areas of congestion, natural and cultural 

resource protection, interpretation and orientation, the monument boundary, aesthetics, and 

development. 

A second newsletter released in fall 1999 summarized public response to the first newsletter, 

organized planning issues into three major 

decision points, and presented three possible 

concepts around which alternatives could be 

developed. Another mail-back comment form 

was included for public response. 

A third newsletter issued in spring 2000 described possible management zones and introduced preliminary alternatives. Four open house 

meetings shortly after the release of the newsletter were attended by a total of 21 people. 

A fourth newsletter issued in fall 2000 presented 

the proposed preferred alternative and asked for 

comments. Four subsequent open houses were 

attended by a total of 14 people. 

American Indians were consulted throughout the 

planning process. Members of the planning team 

visited three tribal offices in October 1999 and 

October 2000, where 60 and 15 people attended, 

respectively. A consultation meeting took place 

in the spring of 2000 at Sundance, Wyoming, 

with 23 people in attendance. 

Visitor Use Study 

In summer 1999 the University of Minnesota 

Cooperative Park Studies Unit (CPSU) gathered 

information about visitors at Devils Tower 

National Monument (Univ. of Minn. 2000). Survey participants were representative of visitors 

who come throughout the summer season, not 

only during peak use times. The purpose of the 

study was to better understand experiences that 

monument visitors sought and attained. Information was gathered about visitors’ background 

characteristics, activities that visitors engaged in, 

their attitudes concerning the quality and adequacy of available facilities, and their opinions 

about management strategies to address problems (such as alternative transportation to 

relieve congestion).Also see appendix A, 

“Development of the Preferred Alternative.” 
4 

LAWS, POLICIES, AND MANDATES 

Each unit in the national park system is guided 

by agencywide and park-specific laws, regulations, and policies. Understanding this guidance 

and how it affects each unit’s mission is fundamental to planning for the future. This section 

highlights the missions (expressed as purpose, 

significance, and mission goals) and legal and 

policy mandates that guide the management of 

Devils Tower National Monument. These 

mission and mandate statements define the 

parameters within which all management actions 

must fall. All alternatives to be considered in the 

general management planning effort must be 

consistent with and contribute to fulfilling these 

missions and mandates. 

MISSION AND GOALS 

Monument Purpose 

Devils Tower, the nation’s first national monument, was established in 1906 under the 

Antiquities Act as “an extraordinary example of 

the effects of erosion in the higher mountains as 

to be a natural wonder and an object of historic 

and great scientific interest . . .” 

Monument Significance 

• Devils Tower, a monolith made of igneous 

rock, commands attention due to many 

symmetrical joint columns. At 867 feet high, 

it is the dominant landmark in the northern 

Great Plains. 

• The Tower is sacred to many peoples. It 

figures prominently in the belief systems 

and narratives of northern Plains Indians. 

• The Tower is one of the premiere areas for 

“crack climbing” (traditional climbing using 

natural cracks, crevices, and ledges) in 

North America and boasts a colorful 100-

year climbing history. 

• At Devils Tower, mountain and northern 

plains species meet in the ecological mix 

distinctive to the Black Hills. 

Mission Goals 

• Restore and maintain the health and 

diversity of the monument’s natural systems. 

• Preserve archeological, historic, and 

ethnographic values at Devils Tower. 

• Interpret the significant and varied themes of 

Devils Tower. 

• Balance educational, spiritual, and 

recreational uses of Devils Tower and its 

surrounding landscape to provide 

meaningful visitor experiences. 

SPECIAL MANDATES AND 

ADMINISTRATIVE COMMITMENTS 

Climbing Management 

The Final Climbing Management Plan / Finding 

of No Significant Impact was published in 

February 1995. This General Management Plan

reaffirms the climbing plan. No alternative of 

this plan suggests any revisions. The Climbing 

Management Plan (NPS 1995) is summarized in 

appendix B. 

Livestock Management 

The monument contains no legal right-of-way 

for livestock. However, at this time it is an 

acceptable practice to allow a right-of-way and 

water gap for livestock on the south boundary of 

the monument. This is not a guaranteed use for 

the future. 
Laws, Policies, and Mandates 

5 

SERVICEWIDE LAWS AND POLICIES

As with all units of the national park system, the 

management of Devils Tower National Monument is guided by the 1916 Organic Act (which 

created the National Park Service), the General 

Authorities Act of 1970, the act of March 27, 

1978, relating to the management of the national 

park system, and other applicable federal laws 

and regulations, such as the Endangered Species 

Act and the National Historic Preservation Act. 

Actions are also guided by the National Park 

Service Management Policies 2001 (NPS 

2001a). Also see appendix C, “Legislation.” 

Many resource conditions and some aspects of 

visitor experience are prescribed by these legal 

mandates and NPS policies. Although attaining 

some of these conditions has been deferred in 

the monument because of funding or staffing 

limitations, the National Park Service (NPS) will 

continue to strive to implement these requirements with or without a new General Management Plan. This plan is not needed to decide, for 

instance, whether or not it is appropriate to 

protect endangered species, control exotic 

species, improve water quality, protect archeological sites, provide access for visitors with 

disabilities, or conserve artifacts. 

The conditions prescribed by laws, regulations, 

and policies most pertinent to the planning and 

management of the monument are summarized 

in this chapter. 

Natural Resource Management Requirements 

Air Quality. The monument is a class II air 

quality area. Current laws and policies require 

that the following desired conditions be 

achieved in the monument: 

• Air quality in the monument meets national 

ambient air quality standards (NAAQS) for 

specified pollutants. Healthful indoor air 

quality at NPS facilities will be ensured. 

• Monument activities will not contribute to 

deterioration in the air quality. 

(SOURCES: Clean Air Act, NPS Management 

Policies)

Although the National Park Service has very 

little direct control over air quality in the airshed 

encompassing the monument, monument managers cooperate with the Wyoming Department 

of Environmental Quality and the U.S. Environmental Protection Agency to monitor air quality 

and ensure that air quality is not impaired. 

The National Park Service will take the 

following kinds of actions to meet legal and 

policy requirements related to air quality: 

• Participate in regional air pollution control 

plans and regulations and review of permit 

applications for major new air pollution 

sources 

• Conduct operations in compliance with 

federal, state, and local air quality 

regulations 

Water Resources, Floodplains, and Wetlands.

Current laws and policies require that the desired 

conditions delineated below be achieved in the 

monument: 

• Surface water and groundwater will be 

restored or enhanced. 

• NPS and NPS-permitted programs and 

facilities will be maintained and operated to 

avoid pollution of surface water and 

groundwater. 

• Natural floodplain values will be preserved 

or restored. 

• The natural and beneficial values of 

wetlands will be preserved and enhanced. 
PURPOSE OF AND NEED FOR THE PLAN

6 

• Long-term and short-term environmental 

effects associated with the occupancy and 

modification of floodplains will be avoided. 

• When it is not practicable to locate or 

relocate development or inappropriate 

human activities to a site outside the floodplain or where the floodplain will not be 

affected, the National Park Service will do 

the following: 

3⁄4 prepare and approve a statement of 

findings in accordance with DO 77-2 

3⁄4 use nonstructural measures as much as 

practicable to reduce hazards to human 

life and property while minimizing 

impacts on the natural resources of 

floodplains 

3⁄4 ensure that structures and facilities are 

designed to be consistent with the intent 

of the standards and criteria of the 

National Flood Insurance Program (44 

CFR 60) 

3⁄4 avoid direct or indirect support of new 

construction in wetlands unless there are 

no reasonable alternatives and the 

proposed action includes all practicable 

measures to minimize harm to wetlands 

3⁄4 compensate for remaining unavoidable 

adverse impacts on wetlands by restoring 

wetlands that have been previously 

destroyed or degraded 

• The National Park Service will implement a 

“no net loss of wetlands” policy and strive to 

achieve a longer-term goal of net gain of 

wetlands across the national park system 

through the restoration of previously 

degraded or destroyed wetlands. 

(SOURCES: Clean Water Act; Executive Order 

(EO) 11514, NPS Management Policies, EO 

12088, EO 11988, Rivers and Harbors Act, 

Special Directive 93-4, EO 11990, Special 

Directive 77-1; Director’s Order (DO) 77-2, 

“Floodplain Management”; DO 77-1, “Wetland 

Protection,” National Flood Insurance Program 

(44 CFR 60.)) 

The National Park Service will take the 

following kinds of actions to meet legal and 

policy requirements related to water resources, 

floodplains, and wetlands: 

• Apply best management practices to all 

pollution-generating activities and facilities 

in the monument, such as NPS maintenance 

and storage facilities and parking areas; 

minimize the use of pesticides, fertilizers, 

and other chemicals and manage them in 

keeping with NPS policy and federal 

regulations. 

• Remove from the floodplain the diesel, 

gasoline, and propane storage tanks that are 

marginally within the 500-year floodplain, 

or protect them as required by NPS policy. 

• Remove any human made objects placed in 

the floodplain for erosion control that are no 

longer effective for the intended purpose. 

Species of Special Concern. Current laws and 

policies require that the following desired 

conditions be achieved in the monument: 

• Federally listed and state-listed threatened 

and endangered species and their habitats 

will be sustained. 

• Native species populations that have been 

severely reduced in or extirpated from the 

monument will be restored where feasible 

and sustainable. 

• The management of populations of exotic 

plant and animal species, up to and 

including eradication, will be undertaken 

wherever such species threaten monument 

resources or public health and when control 

is prudent and feasible. 

(SOURCES: Endangered Species Act; NPS 

Management Policies, EO 13112, “Invasive 

Species.”)

Many species of invasive exotic plants have 

become established throughout much of the 

monument and threaten native species. Given 

time, these aggressive exotic plants can greatly 
Laws, Policies, and Mandates 

7 

expand their populations, alter forest and wildlife habitats, and change scenery by smothering 

and displacing native species. These effects, 

which clearly are already occurring in some 

areas of the monument, will worsen substantially 

if left untreated. A sustained effort is needed to 

control these internal threats to the native 

species and their natural habitats. 

The National Park Service will take the following kinds of actions to comply with legal and 

policy requirements related to native species and 

to manage the monument “in as natural 

condition as possible”: 

• Complete an inventory of plants and animals 

in the monument and regularly monitor the 

distribution and condition (e.g., health, disease) of selected species that are (a) indicators of ecosystem condition and diversity, 

(b) rare or protected species, (c) invasive 

exotics, (d) native species capable of 

creating resource problems (e.g., habitat 

decline due to overpopulation). 

• Support research that will contribute 

knowledge for the management of native 

species. 

• Take mitigating actions to restore native 

species and their habitats where warranted. 

• Control or eliminate exotic plants where 

there is a reasonable expectation of success 

and sustainability. 

Wildland Fire. Current laws and policies require that the following desired conditions be 

achieved in the monument: 

• Monument fire management programs will 

be designed to meet resource management 

objectives prescribed for the various areas of 

the monument and to ensure that the safety 

of firefighters and the public are not compromised. Until a fire management plan is 

approved, all wildland fires will be aggressively suppressed, taking into account the 

• resources to be protected and the safety of 

firefighters and the public. 

(SOURCES: NPS Management Policies, DO 41, 

“Wilderness Preservation and Management.”)

All fires burning in natural or landscaped vegetation will be classified as either wildland fires 

or prescribed fires. All wildland fires will be 

effectively managed, considering resource 

values to be protected and firefighter and public 

safety, using the full range of strategic and 

tactical operations as described in an approved 

fire management plan. Prescribed fires are those 

fires ignited by managers to achieve resource 

objectives. 

To provide information on whether specified 

objectives are met, monitoring programs will be 

instituted for such fires to record fire behavior, 

smoke behavior, fire decisions, and fire effects. 

The monument has an approved fire management plan and is in the process of drafting a new 

plan that follows an updated format. 

Night Sky. The monument’s night sky is a 

feature that contributes to visitors’ experiences. 

The following is a desired condition for the 

night sky: 

• The National Park Service will cooperate 

with monument neighbors and local 

government agencies to seek ways to 

minimize the intrusion of artificial light into 

the night scene in the monument. In natural 

areas, artificial outdoor lighting will be 

limited to basic safety requirements and will 

be shielded when possible. 

(SOURCES: NPS Management Policies)

The National Park Service will take the 

following kinds of actions to comply with the 

policy mentioned above:

• The monument staff will work with local 

communities and other agencies to encourage the protection of the night sky. 

• The monument staff will evaluate the impacts on the night sky caused by monument 
PURPOSE OF AND NEED FOR THE PLAN

8 

facilities. If light sources in the monument 

are determined to be affecting night skies, 

the staff will study alternatives such as 

shielding lights, changing lamp types, or 

eliminating unnecessary sources. 

• The monument staff has signed a memorandum of agreement with the town of Hulett 

and the Hulett Airport Advisory Board to 

shield, to the extent possible, the beacon 

associated with the Hulett Municipal Airport 

from view of all parts of Devils Tower 

National Monument and to install radio 

frequency-controlled runway and taxi lights 

that can be turned on and off from an 

aircraft. 

Natural Sounds. An important part of the NPS 

mission is to preserve or restore the natural 

soundscapes associated with national parks. The 

sounds of nature are among the intrinsic elements that combine to form the environment of 

our national parks. The following are desired 

conditions regarding natural sounds. 

• The National Park Service will preserve the 

natural ambient soundscapes, restore degraded soundscapes to the natural ambient 

condition wherever possible, and protect 

natural soundscapes from degradation due to 

human-caused noise. Disruptions from 

recreational uses will be managed to provide 

a high quality visitor experience in an effort 

to preserve or restore the natural quiet and 

natural sounds. 

• Noise sources will be managed to preserve 

or restore the natural soundscape. 

(SOURCES: NPS Management Policies,

Executive memorandum signed by President 

Clinton on April 22, 1996.)

The National Park Service will take the following kinds of actions to comply with the policies 

mentioned above. 

• Actions will be taken to prevent or minimize 

unnatural sounds adversely affect monument 

resources or values or visitors’ enjoyment of 

them. 

• The National Park Service will work with 

the Federal Aviation Administration (FAA), 

tour operators, commercial businesses, and 

general aviation interests to encourage aircraft to fly outside the monument, especially 

for flights where the presence of the monument is incidental to the purpose of the flight 

(i.e., transit between two points). Actions 

that might be considered to encourage pilots 

to fly outside the monument include identifying the monument on route maps as a 

noise-sensitive area, educating pilots about 

the reasons for keeping a distance from the 

monument, and encouraging pilots to 

comply with FAA regulations and advisory 

guidance, in a manner that will minimize 

noise and other impacts. 

• The monument staff will continue to require 

tour bus companies to comply with 

regulations designed to reduce noise levels 

(for example, turning off engines when 

buses are parked). 

• Noise generated by NPS management activities will be minimized by strictly regulating 

administrative functions such as the use of 

motorized equipment. Noise will be a 

consideration in the procurement and use of 

equipment by the monument staff. 

• The monument staff has signed a memorandum of agreement with the town of Hulett 

and the Hulett Airport Advisory Board to 

establish a voluntary no-fly advisory zone of 

2 miles centered on Devils Tower National 

Monument. (Up to a 3-mile zone may be 

considered during June out of respect for 

American Indian values) This no-fly advisory zone does not include lands adjacent 

to the monument, aircraft operations associated with law enforcement, search and rescue and medical emergency activities, firefighting, agricultural practices, and utility 

rights-of-way surveys. 
Laws, Policies, and Mandates 

9 

Cultural Resource Management 

Requirements 

Archeological Resources. Current laws and 

policies require that the following desired 

conditions be achieved in the parks: 

• Archeological sites will be identified and 

inventoried and their significance determined and documented. Archeological sites 

will be protected in an undisturbed condition 

unless it is determined through formal processes that disturbance or natural deterioration is unavoidable. When disturbance or 

deterioration is unavoidable, the site will be 

professionally documented and salvaged in 

consultation with the state historic preservation officer and American Indian tribes. 

(SOURCES: NPS Management Policies,

National Historic Preservation Act; EO 11593; 

Archeological Resources Protection Act; the 

Secretary of the Interior’s Standards and 

Guidelines for Archeology and Historic Preservation; programmatic memorandum of 

agreement among the National Park Service, 

the Advisory Council on Historic Preservation, 

and the National Council of State Historic 

Preservation Officers (1995.)

The Archeology Laboratory of the University of 

South Dakota conducted an intensive survey of 

Devils Tower National Monument from July to 

September 1997 and July to August 1998. The 

purpose of The Archeological 1997–1998 Survey 

and National Register Evaluation of Devils 

Tower National Monument, Crook County, 

Wyoming (Univ. of SD Archeol. Lab. 1998) was 

to locate and interpret all historic and prehistoric 

sites in the monument and evaluate their significance within the guidelines of the National 

Register of Historic Places. Of the 25 sites found 

eligible for the national register, 8 are historic: 

homestead, administrative district, Tower ladder, 

entrance station, entrance road, cabin/motel site, 

historic road, and graffiti. Of these, the administrative district, the entrance station, and the 

entrance road have been listed on the National 

Register of Historic Places. Seventeen earlier 

sites were found eligible: Devils Tower, a cave, 

two prehistoric rock paintings, and 13 lithic 

scatter sites. Among the 17 sites were artifacts 

dating from the Late Paleoindian period to the 

Late Prehistoric. Indications of heavy occupation were found for the Late Plains Archaic and 

Late Prehistoric periods. 

The National Park Service will take the 

following kinds of actions to meet legal and 

policy requirements related to archeological 

sites: 

• Treat all archeological resources as eligible 

for listing on the National Register of 

Historic Places pending a formal determination by the National Park Service and the 

Wyoming state historic preservation office 

as to their significance 

• Protect all archeological resources eligible 

for listing or listed on the national register; if 

disturbance to such resources is unavoidable, conduct formal consultation with the 

Advisory Council on Historic Preservation, 

as appropriate, and the state historic 

preservation officer in accordance with the 

National Historic Preservation Act and 

implementing regulations. 

Ethnographic Resources. Certain contemporary American Indian and other communities are permitted by law, regulation, or 

policy to pursue customary religious, subsistence, and other cultural uses of NPS resources 

with which they are traditionally associated. 

Consistent with the establishment clause of the 

Constitution, the National Park Service wishes 

to accommodate tribal religious activities. To the 

extent permitted by law, the National Park 

Service will take care to protect resources in a 

way that will accommodate their religious value. 

The following are the desired conditions for 

ethnographic resources. 

• Appropriate cultural anthropological 

research will be conducted in cooperation 

with groups associated with the monument. 

• All agencies, including the National Park 

Service, are required to accommodate access 

to and ceremonial use of Indian sacred sites 

by Indian religious practitioners and avoid 
PURPOSE OF AND NEED FOR THE PLAN

10 

adversely affecting the physical integrity of 

these sacred sites. 

• NPS general regulations on access to and 

use of natural and cultural resources in parks 

will be applied in an informed and balanced 

manner consistent with monument purposes, 

and the Park Service will not unreasonably 

interfere with any American Indian use of 

traditional areas or sacred resources that 

does not result in the degradation of 

resources. 

• Other federal agencies, state and local governments, potentially affected American 

Indian and other communities, interested 

groups, the State Historic Preservation Officer, and the Advisory Council on Historic 

Preservation will be given opportunities to 

become informed about and comment on 

anticipated NPS actions at the earliest 

practicable time. 

• All agencies are required to consult with 

tribal governments before taking actions that 

affect federally recognized tribal governments. These consultations are to be open 

and candid so that all interested parties may 

evaluate for themselves the potential impact 

of relevant proposals. Parks (including 

Devils Tower National Monument) must 

regularly consult with traditionally associated American Indians regarding planning, 

management, and operational decisions that 

affect subsistence activities, sacred materials 

or places, or other ethnographic resources 

with which they are historically associated. 

• The identities of community consultants and 

information about sacred and other culturally sensitive places and practices will be 

kept confidential when research agreements 

of other circumstances warrant. 

• American Indians and other individuals and 

groups linked by ties of kinship or culture to 

ethnically identifiable human remains, 

sacred objects, objects of cultural patrimony 

and associated funerary objects will be consulted when such items may be disturbed or 

are encountered on monument lands. 

(SOURCES: NPS Management Policies,

National Historic Preservation Act, EO 11593, 

Advisory Council on Historic Preservation 

implementing regulations, EO 13007 on 

American Indian Sacred Sites, American Indian 

Religious Freedom Act, programmatic memorandum of agreement among the National Park 

Service, the Advisory Council on Historic 

Preservation, and the National Council of State 

Historic Preservation Officers (1995), Native 

American Graves Protection and Repatriation 

Act, Presidential memorandum of April 29, 

1994, on government-to-government relations 

with tribal governments.)

To accomplish the above goals, the National 

Park Service will do the following: 

• Continue to provide access to sacred sites 

and monument resources by American 

Indians when the use is consistent with 

monument purposes and the protection of 

resources. 

• Survey and inventory ethnographic resources and document their significance. 

• Treat all ethnographic resources as eligible 

for listing on the National Register of 

Historic Places pending a formal determination by the National Park Service and the 

Wyoming state historic preservation officer 

as to their significance. 

• Protect all ethnographic resources determined eligible for listing or listed on the 

national register. If disturbing such resources is unavoidable, conduct formal consultation with the Advisory Council for Historic 

Preservation, as appropriate, with the state 

historic preservation officer, and with 

American Indian tribes. This consultation 

will be in accordance with the National 

Historic Preservation Act and the Advisory 

Council for Historic Preservation implementing regulations and programmatic 

agreement. 

• Conduct regular consultations with affiliated 

tribes to continue to improve communica-
Laws, Policies, and Mandates 

11 

tions and resolve any problems or misunderstandings that occur. 

• Continue to encourage the employment of 

American Indians on the monument staff to 

improve communications and working 

relationships and encourage cultural 

diversity in the workplace. 

Historic Resources. Current laws and policies 

require that the following desired conditions be 

achieved for historic properties (e.g. buildings, 

structures, roads, trails, or cultural landscapes): 

• Historic resources will be inventoried and 

their significance and integrity evaluated 

under national register criteria. The qualities 

that contribute to the listing or eligibility for 

listing of historic properties on the National 

Register of Historic Places will be protected 

in accordance with the Secretary of the 

Interior’s Standards (unless it is determined 

through a formal process that disturbance or 

natural deterioration is unavoidable). 

(SOURCES: NPS Management Policies, National Historic Preservation Act, EO 11593, 

Archeological and Historic Preservation Act; 

the Secretary of the Interior’s Standards and 

Guidelines for Archeology and Historic Preservation; Secretary of the Interior’s Standards 

for the Treatment of Historic Properties, with 

Guidelines for the Treatment of Cultural Landscapes;, NPS-28: “Cultural Resource Management Guidelines” (1994) programmatic memorandum of agreement among the National Park 

Service, the Advisory Council on Historic 

Preservation, and the National Council of State 

Historic Preservation Officers (1995).)

The National Park Service will take the following kinds of actions to meet legal and policy 

requirements related to historic properties: 

• Determine the appropriate level of preservation for each historic property formally 

determined to be eligible for listing or listed 

on the national register (subject to the 

Secretary of the Interior’s Standards). 

• Implement and maintain the appropriate 

level of preservation for such properties. 

• Analyze the design elements (e.g., materials, 

colors, shape, massing, scale, architectural 

details, and site details) of historic structures 

intersections, curbing, signs, picnic tables, 

and cultural landscapes in the monument 

(e.g., intersections, curbing, signs, and roads 

and trails) to guide the rehabilitation and 

maintenance of sites and structures. 

• Before modifying any historic properties on 

the National Register of Historic Places, 

such as the main road, the log entrance 

station, or the Old Headquarters Historic 

District, the Park Service will consult with 

the Wyoming state historic preservation 

officer and the Advisory Council for 

Historic Preservation, as appropriate. 

Collections. Current laws and policies require 

that the following desired conditions be 

achieved in the monument for museum 

collections: 

• All museum objects and manuscripts will be 

identified and inventoried, and their significance determined and documented. 

• The qualities that contribute to the significance of collections will be protected in 

accordance with established standards. 

(SOURCES: NPS Management Policies,

National Historic Preservation Act, American 

Religious Freedom Act, Archeological and 

Historic Preservation Act, Archeological 

Resources Protection Act, Native American 

Graves Protection and Repatriation Act.)

To accomplish the above goals, the National 

Park Service will do the following: 

• Inventory and catalog all monument 

museum collections in accordance with 

standards in the NPS Museum Handbook.

• Develop and implement a collection management program according to NPS 

standards to guide the protection, conservation, and use of museum objects. 
PURPOSE OF AND NEED FOR THE PLAN

12 

Visitor Experience and 

Park Use Requirements 

Current laws and policies require that the 

following desired conditions be achieved in the 

parks: 

• Visitor and employee safety and health will 

be protected. 

• Visitors will understand and appreciate park 

values and resources and have the information necessary to adapt to the monument’s 

environments; visitors will have opportunities to enjoy the national monument in ways 

that leave the resources unimpaired for 

future generations. 

• Recreational uses will be promoted and 

regulated, and basic visitor needs will be 

met in keeping with the monument’s 

purposes. 

• To the extent feasible, facilities, programs, 

and services in the national monument will 

be accessible to and usable by all people, 

including those with disabilities. 

• Visitors who use federal facilities and 

services for outdoor recreation may be required to pay a greater share of the cost of 

providing those opportunities than the 

population as a whole. 

• The national monument will identify 

implementation commitments for visitor 

carrying capacities for all areas of the unit. 

(SOURCES: NPS Management Policies,

National Historic Preservation Act, NPS 

Organic Act, DO 22, “Fee Collection,” Title 36 

of the Code of Federal Regulations (CFR), 

Americans with Disabilities Act, Architectural 

Barriers Act; Rehabilitation Act, 1998 Executive Summary to Congress; Recreational Fee 

Demonstration Program, Progress Report to 

Congress, vol. 1: Overview and Summary (U.S. 

Department of the Interior, National Park 

Service, U.S. Fish and Wildlife Service, Bureau 

of Land Management; U.S. Department of 

Agriculture, Forest Service), PL 95-625, 1978 

National Parks and Recreation Act.)

The laws, regulations, and policies leave considerable room for judgment about the best mix 

of types and levels of visitor use activities, programs, and facilities. For this reason, most decisions related to visitor experience and use are 

addressed in the section “What Might Be 

Achieved,” below, and in the alternatives. However, the authority to charge fees is dictated by 

law and is therefore the same for all alternatives. 

The National Park Service will take the following kinds of actions to meet legal and policy 

requirements related to visitor experience and 

use of the national monument: 

• Give visitors the opportunity to understand, 

appreciate, and enjoy the monument 

(management directions within this broad 

policy are discussed in the alternatives.) 

• Continue to enforce the regulations governing visitor use and behavior in Title 36 of 

the Code of Federal Regulations (36 CFR). 

• Ensure that all programs and facilities in the 

monument are accessible to the extent 

feasible. 

• Following approval of the Final General 

Management Plan, the National Park Service will undertake detailed planning to 

establish visitor carrying capacity strategies 

and monitoring programs. If a shuttle system 

is to be established, the carrying capacity 

planning will be undertaken as part of the 

planning and design of the system. Studies 

will determine what levels of visitation will 

be consistent with the experiences that 

Tower visitors desire. Shuttle schedules and 

capacities will be used to manage the 

numbers of visitors dropped off at the base 

of the Tower. 

• Regardless of whether or not a shuttle 

system is planned, the national monument 

will initiate a scheduling system for tour 

buses to manage the number of buses and 

tour groups at the Tower. 
Laws, Policies, and Mandates 

13 

Sustainable Design/Development 

Sustainability can be described as the result 

achieved by managing units of the national park 

system in ways that do not compromise the 

environment or its capacity to provide for present and future generations. Sustainable practices 

minimize the short-term and long-term environmental impacts of developments and other activities through resource conservation, recycling, 

waste minimization, and the use of energyefficient and ecologically responsible materials 

and techniques. The following are the desired 

conditions for sustainable design. 

• NPS and concessioner visitor management 

facilities will be harmonious with monument 

resources, compatible with natural processes, aesthetically pleasing, functional, as 

accessible as possible to all segments of the 

population, energy-efficient, and costeffective. 

(SOURCES: NPS Management Policies, EO 

13123, “Greening the Government through 

Efficient Energy Management”; EO 13101, 

“Greening the Government through Waste 

Prevention, Recycling, and Federal Acquisition”; NPS Guiding Principles of Sustainable 

Design; DO 13, “Environmental Leadership”; 

DO 90, “Value Analysis.”)

The NPS Guiding Principles of Sustainable 

Design (1993b) directs NPS management 

philosophy. It provides a basis for achieving 

sustainability in facility planning and design, 

emphasizes the importance of biodiversity, and 

encourages responsible decisions. The guidebook articulates principles to be used in the 

design and management of tourist facilities that 

emphasize environmental sensitivity in construction, the use of nontoxic materials, resource 

conservation, recycling, and integrating visitors 

with natural and cultural settings. 

Sustainability principles have been developed 

and are followed for interpretation, natural 

resources, cultural resources, site design, 

building design, energy management, water 

supply, waste prevention, and facility maintenance and operations. The National Park 

Service also reduces energy costs, eliminates 

waste, and conserves energy resources by using 

energy-efficient and cost-effective technology. 

Energy efficiency is incorporated into the decision-making process during the design and 

acquisition of buildings, facilities, and transportation systems emphasizing the use of 

renewable energy sources. 

In addition to following these principles, the 

following also will be accomplished: 

• The staff of the national monument will 

work with appropriate experts to make the 

monument’s facilities and programs sustainable. Value analysis and value engineering, including life cycle cost analysis, will 

be performed to examine the energy, environmental, and economic implications of 

proposed developments. 

• The monument staff will support and encourage suppliers, permittees, and contractors to follow sustainable practices. 

• Interpretive programs at the national monument will address sustainable practices 

within and outside of the national monument. 

Rights-of-way and Telecommunication 

Infrastructure 

Current laws and policies require that the 

following desired conditions be achieved in the 

national monument. 

• Monument resources or public 

enjoyment of the monument will not 

be denigrated by nonconforming uses. 

Telecommunication structures will be 

permitted in the monument to the 

extent that they do not jeopardize the 

monument’s mission and resources. 

No new nonconforming use or rightsof-way will be permitted through the 

monument without specific statutory 

authority and approval by the director 

of the National Park Service or his 

representative, and such use will be 
PURPOSE OF AND NEED FOR THE PLAN

14 

permitted only if there is no 

practicable alternative to such use of 

NPS lands. 

(SOURCES: Telecommunications Act; 16 USC 

79; 23 USC 317; 36 CFR 14; NPS 

Management Policies; DO 53A, “Wireless 

Telecommunications”; Reference Manual 53, 

“Special Park Uses.”) 

The Telecommunications Act of 1996 directs all 

federal agencies to assist in the national goal of 

achieving a seamless telecommunications 

system throughout the United States by accommodating requests by telecommunication 

companies for the use of property, rights-ofway, and easements to the extent allowable 

under each agency’s mission. The National Park 

Service is legally obligated to permit telecommunication infrastructure in the parks if such 

facilities can be structured to avoid interference 

with monument purposes. 

The management of Devils Tower National 

Monument has determined that because of the 

monument’s small size and the scenic and 

ethnographic significance of its resources, there 

are no appropriate locations for telecommunication infrastructure in Devils Tower 

National Monument. 
Laws, Policies, and Mandates 

15 

Map: Location 
PURPOSE OF AND NEED FOR THE PLAN

16 

Blank back of map 
Laws, Policies, and Mandates 

17 

ALTERNATIVES, INCLUDING THE 

PROPOSED ACTION 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

18 

(blank back of divider) 
19 

WHAT MIGHT BE ACHIEVED 

DECISION POINTS 

Decisions must be made in this General Management Plan about several major points, based 

on public comments and NPS concerns. Alternatives have been developed to explore these 

decision points. Issue categories are included; 

they are addressed by each decision point 

statement. 

• Should the monument accommodate visitation as it comes, or should visitation be 

managed to reduce congestion? 

Related issue categories: (a) congestion, 

(b) managing natural and cultural 

resources, (c) interpretation and visitor 

orientation, (d) development 

• Is land within the monument boundary adequate to protect the values, or should the 

National Park Service preserve the scenic 

and rural nature of the surrounding 

viewshed? 

Related issue categories: (a) boundary, 

(b) esthetics, (c) development

• In order to support and accommodate visitor 

experiences and resource conditions, what 

types and levels of development and 

management are needed? 

Related issue categories: (a) congestion, 

(b) interpretation and visitor orientation, 

(c) natural and cultural resource management, (d) development 

ISSUE NOT ADDRESSED IN THIS PLAN 

There is considerable controversy over the name 

of Devils Tower National Monument. Some 

local communities would like to have the current 

name retained, but affiliated American Indian 

tribes are offended by the association of the 

word “devil” with an area that is sacred to them. 

The tribes have signed a resolution that states a 

preferred name; they would like to have the 

name of Devils Tower changed to Bear Lodge. 

The naming of a national monument or park is 

not within the purview of the National Park 

Service, nor is the naming of a geologic feature. 

Changing the name of the geologic feature 

would involve an administrative process through 

the United States Board of Geographic names, 

and changing the name of the national monument would involve an act of Congress. Neither 

of these processes is possible at present. The 

national monument has decided to continue 

educating the public about the name issue with 

the hope that over time the two sides can come 

together to resolve the controversy. Therefore, 

the resolution of the naming controversy is 

outside the scope of this General Management 

Plan.

RESOURCES AND VALUES AT STAKE 

IN THE PLANNING PROCESS 

Specific impact topics were developed for discussion focus and to allow comparison of the environmental consequences of each alternative. 

These impact topics were identified on the basis of 

federal laws, regulations, and executive orders; the 

NPS Management Policies 2001; and NPS knowledge of limited or easily impacted resources. A 

brief rationale for the selection of each impact 

topic is given below. 

Natural Resource Topics 

The planning team selected seven natural resource 

impact topics. The selection was based on the major values or issues the team identified early in the 

planning process, as well as on applicable laws 

and executive orders (for example, the Endangered Species Act of 1973, as amended, Executive 

Order 11988, “Floodplain Management,” and Executive Order 11990, “Protection of Wetlands”). 

Natural resource topics are soils, vegetation, 

wildlife, air quality, threatened, endangered, and 

candidate species (such as the black-tailed prairie 

dog), wetlands, and floodplains. 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

20 

Cultural Resource Topics 

Cultural resource impact topics were selected on 

the basis of major values identified in the monument’s enabling legislation, values identified in 

the scoping process, and applicable laws and executive orders pertaining to cultural resources (the 

1966 National Historic Preservation Act, the 

National Environmental Policy Act). The topics 

are ethnographic resources and historic resources. 

Visitor Experience Topics 

The planning team identified visitor experience as 

an important issue that could be appreciably affected under the alternatives. Impact topics in this 

category are visitors’ experience of the monument 

resources, visitor access and freedom to 

experience the monument at one’s own pace, 

visitors’ access to orientation and interpretive 

information, and visitor safety. 

Socioeconomic Resource Topics 

Analyzing the local economic impacts provides 

the context for evaluating the possible impacts on 

the local area that could result from the alternatives. In addition, the national monument has 

neighbors that could be affected by the alternatives. The topics discussed are businesses, access 

to private property, and the local and regional 

economy. 

TOPICS DISMISSED FROM 

FURTHER CONSIDERATION 

Threatened, Endangered, and 

Proposed Species 

The following species have been dismissed from 

consideration. However, the black-tailed prairie 

dog is analyzed as an impact topic. 

Black Footed Ferrets. The black-footed ferret, 

an endangered species, has not been sighted at 

the national monument. Normally, a prairie dog 

town of about 5,000 acres or more is required to 

support a ferret. The size of the town at Devil’s 

Tower is approximately 40 acres. The Atlas of 

Birds, Mammals, Reptiles and Amphibians in 

Wyoming, by the Wyoming Game and Fish Department, Wildlife Division (1997), states that 

there are “no recent data to suggest occurrence” 

of ferrets in the part of the state where Devils 

Tower is located. Therefore, actions of any of 

the alternatives of this plan would not affect any 

ferrets. 

Bald Eagles. The bald eagle, a threatened 

species, does not nest at Devils Tower. It does 

occupy the monument all winter. Any construction activity to implement any alternative of the 

General Management Plan would be unlikely to 

occur in winter; therefore, the alternatives of this 

plan would not impact the bald eagle. However, 

a site has not been selected for out-of-monument 

staging in alternative 4. If that alternative was 

selected, the potential staging site would be 

surveyed for bald eagles. 

Mountain Plover. According to the U.S. Fish 

and Wildlife Service, mountain plover, a species 

proposed for listing, is associated with shortgrass prairie, plains, alkali flats, agricultural 

lands, cultivated lands, sod farms, prairie dog 

towns, and shrub-stepped landscapes at both 

breeding and wintering locales. There are areas 

in the monument that might be expected to 

support mountain plover, but none of the birds 

has been sighted at the monument. The Atlas of 

Birds, Mammals, Reptiles and Amphibians in 

Wyoming, by the Wyoming Game and Fish 

Department, Wildlife Division (1997), indicates 

that the mountain plover has been observed in 

the monument’s area of the state, but there is no 

evidence of nesting. The Wyoming Natural 

Diversity Data Base lists no occurrences in 

Crook County. 

According to a representative of the U.S. Fish 

and Wildlife Service, the only suitable habitat in 

the Devils Tower area may be the prairie dog 

town. However, mountain plovers tend to avoid 

people on foot. The prairie dog town contains a 

bisecting road and a footpath around the perimeter; therefore, the prairie dog town at Devils 

Tower is not likely to be used by mountain 

plover. The Fish and Wildlife Service has no 
What Might Be Achieved 

21 

requirements for the conservation of proposed 

species such as the mountain plover. 

Ute Ladies’ Tresses. The Ute ladies’ tresses, a 

threatened perennial, terrestrial orchid, has not 

been reported at Devils’ Tower. However, the 

monument is in a drainage where the Fish and 

Wildlife Service recommends that surveys for 

the plant be conducted. The Wyoming Natural 

Diversity Database shows no reports of the plant 

in Crook County. The closest sighting is from 

Converse County, about 80 miles southwest of 

the monument. The plant was not found in either 

a floristic study of the national monument 

(Marriott 1982) or a vegetation mapping program (USGS 2000). There is an abundance of 

leafy spurge, an exotic plant, in areas where the 

orchid might be found. Given the level of reconnaissance that has been done and the condition 

of the habitat, the Park Service has concluded 

that there are no Ute ladies’ tresses in the 

monument; therefore, these plants could not be 

affected by any action of this plan. 

Prime and Unique Farmland 

In August 1980, the Council on Environmental 

Quality (CEQ) directed that federal agencies must 

assess the effects of their actions on farmland soils 

classified as prime or unique by the Natural Resource Conservation Service, U.S. Department of 

Agriculture. Prime or unique farmland is defined 

as soil that produces general crops such as common foods, forage, fiber, and oil seed. Unique 

farmland produces specialty crops such as fruits, 

vegetables, and nuts. According to the Natural 

Resource Conservation Service, there are no 

prime or unique farmlands in Devils Tower 

National Monument; therefore, the topic of prime 

and unique farmland has been dismissed as an 

impact topic in this document. 

Water Resources 

In all alternatives of this plan, the quality and 

quantity of water for personal consumption 

meets all standards and is abundant. In each 

alternative, the water source is from a deep 

aquifer that requires minimal treatment before 

consumption. In each alternative, there is adequate land base to develop needed sewage treatment facilities, or there is a facility currently in 

use that would handle the needed treatment. In 

the preferred alternative, the location for the 

staging area has been evaluated for utilities in a 

“Visitor Center Location and Feasibility Study” 

completed in January 1993. That study found the 

access to primary utilities (water, electricity, 

sewer, and telephone) adequate for the use level 

expected. 

Archeological Resources 

The Archeology Laboratory of the University of 

South Dakota conducted an intensive survey of 

Devils Tower National Monument from July to 

September 1997 and July to August 1998. The 

purpose of The Archeological 1997–1998 Survey 

and National Register Evaluation of Devils 

Tower National Monument, Crook County, Wyoming (Univ. of SD, Archeol. Lab. 1998) was to 

locate and interpret all historic and prehistoric 

sites in the monument and to evaluate their significance within the guidelines of the National 

Register of Historic Places. No known archeological sites lie within the area of potential effect 

in the monument for any alternative in this plan. 

However, a site has not been selected for out-ofmonument staging in alternative 4. If that alternative was selected, the potential staging site 

would be surveyed for archeological resources 

and the other steps described in “Cultural Resource Management Requirements” would be 

followed. 

Cultural Landscapes 

Although several historic structures adjacent to 

the visitor parking lot are included as part of the 

Old Headquarters Area Historic District, modern 

changes to the area’s landscaping have reduced 

landscape integrity, and according to the form 

nominating the district to the National Register 

of Historic Places, it no longer qualifies as a 

cultural landscape. 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

22 

Collections 

None of the alternatives in this plan would affect 

the monument’s collections; therefore, the topic 

of collections will not be discussed. 

Traffic 

The current visitation to the monument impacts 

traffic only on the road linking Wyoming 

Highway 24 to the main monument road (Wyoming Highway 110). None of the alternatives 

described would appreciably alter traffic on WY 

24, so there would be no impact on state roads. 

Therefore, the topic of traffic has been considered and dismissed. 

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 missions by identifying 

and addressing disproportionately high and 

adverse human health or environmental effects of 

their programs and policies on minorities and lowincome populations and communities. No alternative would have health or environmental effects 

on minorities (including American Indian tribes) 

or low-income populations or communities as 

defined in the Environmental Protection Agency’s 

Environmental Justice Guidance (1998). Environmental Justice has been dismissed as an impact 

topic in this document. 

Relationships to Plans 

of Other Agencies 

Possible conflicts between the alternatives and 

county, state, tribal, or federal land use plans and 

policies must be considered. Devils Tower is in 

the center of Crook County, Wyoming. Properties surrounding the monument are primarily 

privately owned residential and agricultural 

lands, and there are a few commercial and stateowned parcels. There are no tribal lands nearby. 

The county’s most recent land use plan was 

completed in 1998. The purpose of the plan is 

“to establish a process for Crook County to 

coordinate with federal and state agencies on 

their proposed actions that may potentially affect 

the management of private and public land and 

natural resource use.” 

Crook County has been informed and involved 

in the development of this plan through informal 

and formal discussions with monument staff 

(more details are available in the “Public 

Involvement” chapter). The “Environmental 

Consequences” chapter contains analyses of the 

impacts of concern to the county. This ongoing 

consultation and the analysis of topics of 

concern are in accordance with the Crook 

County land use plan, which establishes a 

process for coordination with federal agencies 

on their proposed actions that might affect the 

management of private and public land and 

natural resources. 

No actions of this plan would be inconsistent 

with the Black Hills National Forest Land and 

Resource Management Plan (USFS 1996) or the 

Wyoming SCORP: State Comprehensive Outdoor Recreation Plan (WY Dept. of Commerce 

1995). 

Any changes brought about by any of the 

alternatives would not conflict with any of the 

approved plans of other jurisdictions; therefore, 

this topic has been dismissed from further 

consideration. 

Indian Trust Resources 

President Clinton’s April 29, 1994, “Memorandum for the Heads of Executive Departments 

and Agencies” directs that: “Each executive 

department and agency shall assess the impact of 

federal government plans, projects, programs, 

and activities on tribal trust resources and assure 

that tribal government rights and concerns are 

considered during the development of such 

plans, projects, programs, and activities.” 

In addition, order 3175 (Secretary of the Interior, 

November 8, 1993) states the following: 
What Might Be Achieved 

23 

The heads of bureaus and offices are responsible for being aware of the impact of 

their plans, projects, programs or activities 

on Indian trust resources. Bureaus and 

offices when engaged in the planning of 

any proposed project or action will ensure 

that any anticipated effects on Indian trust 

resources are explicitly addressed in the 

planning, decision and operational documents. These documents should clearly 

state the rationale for the recommended 

decision and explain how the decision will 

be consistent with the Department’s trust 

responsibilities. 

One definition of tribal trust resources is “those 

natural resources, either on or off Indian lands, 

retained by, or reserved by or for Indian tribes 

through treaties, statutes, judicial decisions, and 

executive orders, which are protected by a 

fiduciary [trust] obligation on the part of the 

United States” (subsection B, section 3, 

Secretarial Order 3206, Babbitt 6/5/1997). None 

of the lands in Devils Tower are trust resources 

according to this definition. Therefore, this topic 

has not been analyzed. 
24 

POTENTIAL MANAGEMENT PRESCRIPTIONS 

(MANAGEMENT ZONES) 

An important tool in planning and management 

is the establishment of management prescriptions for various areas in the monument. Different management prescriptions are termed 

“management zones.” Management zones 

identify how different areas could be managed to 

achieve a variety of resource conditions and 

visitor experiences. Each zone specifies a particular combination of resource, social, and 

management conditions. The National Park 

Service would take different actions in different 

zones with regard to the types and levels of uses 

and facilities. The following seven management 

zones have been described for Devils Tower. 

Alternatives for future conditions and management have been developed by placing these 

zones in different configurations. 

DEVELOPED ZONE 

Resource Condition or Character 

In the developed zone, tolerance for resource 

degradation would be high where necessary for 

development. Maintaining scenic quality would 

be important. Natural sounds might be compromised because of the presence of vehicles and 

high levels of visitor use. 

Visitor Experience 

Visitors would use the paved roadways and 

associated developments in this zone for touring 

the monument, enjoying scenic overlooks, 

reading interpretive media, and gaining access to 

other zones. Visitor services in the developed 

zone would be convenient and easily accessible. 

Many areas would offer opportunities for social 

experiences, and the probability of encountering 

other visitors and NPS staff would be high. 

Appropriate Kinds of Facilities 

Facilities appropriate to the developed zone 

would be monument roads and parking areas, 

visitor facilities, staging area support facilities, 

entrance stations, scenic and interpretive 

pullouts, signs, interpretive media, and short 

trails. Also appropriate would be picnic tables 

benches, campgrounds, amphitheaters, restroom 

facilities, and other small structures. All structures and development would blend with the 

natural and cultural environment. Facilities and 

services would be fully accessible. 

PEDESTRIAN ZONE 

Resource Condition or Character 

In the pedestrian zone, resources might be 

modified for essential visitor and monument 

operation needs, but they would be changed in 

ways that would harmonize with the natural 

environment, natural processes, and scenic 

quality of the adjacent zones. Because of these 

possible changes, the National Park Service’s 

tolerance for resource degradation would be 

moderate. 

Visitor Experience 

High use areas and trail corridors in this zone 

would provide access to prime monument 

features. Visitors would be able to see, touch, 

smell, and hear the resources as they moved 

along well-defined trails and walkways. To use 

this area, visitors would need to make a short 

time commitment and physically exert themselves to some degree. The experience would be 

highly social and interpretive, with consideration 

for the natural appearance of the area. Visitor 

uses, sites, and trails might be intensively 

managed to ensure resource protection and 

public safety. 

Appropriate Kinds of Facilities 

Appropriate facilities in the pedestrian zone 

would be trails and walkways with pavement or 

other resilient surfaces, interpretive media, and 
Potential Management Prescriptions 

25 

small visitor support structures such as 

restrooms, benches, or picnic tables. To the 

extent feasible, facilities and services would be 

accessible to people with disabilities. 

NATURAL TRAILED ZONE 

Resource Condition or Character 

Resources in the natural trailed zone might be 

modified for essential visitor needs, but they 

would be changed in ways consistent with the 

natural environment, natural processes, and 

scenic quality of the adjacent zones. The tolerance for resource degradation would be low. 

Visitor Experience 

Trail corridors in this zone would be somewhat 

more primitive than those in the pedestrian zone. 

This area would give visitors a sense of being 

immersed in a natural landscape, and it would 

feel somewhat distant from most comforts and 

conveniences. Scenic quality and natural sounds 

would be essential. Visitors would have to commit a block of time and some physical exertion 

to use the area. The probability of encountering 

other visitors and NPS staff would be low. There 

might be some opportunities for interpretation, 

but any onsite media would be kept unobtrusive. 

Appropriate Kinds of Facilities 

Appropriate facilities in the natural trailed zone 

would be maintained but unsurfaced trails, 

trailhead parking, and access roads. Orientation 

signs and subtle interpretive media also would 

be appropriate. Other structures (such as fences, 

bridges, or boardwalks) would be appropriate 

only if required for resource protection. 

DEVELOPED CAMPING ZONE 

Resource Condition or Character 

In the developed camping zone, some resource 

modification for visitor use would be appropriate, but the overall appearance would be 

natural or rural. The tolerance for the disruption 

of natural processes would be low. 

Visitor Experience 

Visitors would be permitted to stay overnight in 

a small established camping area with limited 

services. Camping would be possible in an 

uncongested natural setting, with options for 

social interaction or moderate privacy. Scenic 

quality and natural sounds would be important 

but might be somewhat compromised because of 

the presence of vehicles and visitor use. 

Appropriate Kinds of Facilities 

Access roads and parking areas would be 

appropriate for the developed camping zone, as 

would signs and interpretive media, campsites, 

restrooms, short trails, and benches and picnic 

tables. Other small structures might also be 

appropriate. The area would be highly managed 

for resource protection and visitor safety. 

SEMIPRIMITIVE ZONE 

Resource Condition or Character 

The semiprimitive zone would be managed for 

resource protection, and no accommodations 

would be made for visitor use. Tolerance for 

resource degradation would be low, and the 

overall resource character would be pristine. The 

emphasis would be on restoring and perpetuating natural systems and processes. 

Visitor Experience 

Visitors would be permitted, but not encouraged, 

to enter the semiprimitive zone, which would 

not be equipped with any facilities. Any visitor 

who did venture into these areas might experience solitude, natural sounds, some sense of 

discovery and adventure, and pristine surroundings. 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

26 

Appropriate Kinds of Facilities 

It would be appropriate for the semiprimitive 

zone to have no visitor facilities, but. structures 

or devices used for research or resource 

management might be permitted. 

SPECIAL PROTECTION ZONE 

Resource Condition or Character 

Areas with resource or ethnographic sensitivity 

or fragility requiring special management would 

be included in the special protection zone. Tolerance for degradation of resources would be low. 

Requests for visitor use or other access to this 

zone would be evaluated individually to ensure 

compatibility with resource management and 

protection. 

Visitor Experience 

Visitor uses and activities in the special protection zone would vary widely but would be 

limited to low impact activities compatible with 

the natural setting and ethnographic character. 

Registration or permits would be required. Uses 

would be managed intensively, and many 

restrictions might apply. 

Appropriate Kinds of Facilities 

The only facilities appropriate to the special 

protection zone would be those required for 

resource management or visitor safety, and they 

would be consistent with resource protection 

objectives. 

ADMINISTRATIVE ZONE 

Resource Condition or Character 

The primary purpose of the administrative zone 

would be to contain administrative services and 

operational support. Natural character would be 

maintained to the highest degree possible consistent with this purpose. Resource degradation 

would be acceptable where necessary for 

development. 

Visitor Experience 

Under most circumstances there would be no 

visitor access to the administrative zone. 

Appropriate Kinds of Facilities 

Facilities needed for administration and operations would be included in this zone. These 

might include housing, buildings for maintenance and administration, utilities, access roads, 

and leachfields. All structures and development 

would blend with the natural and cultural environment. Facility design would emphasize 

operational efficiency, safety, and accessibility 

requirements. 
27 

ALTERNATIVE 1 (NO ACTION) 

OVERALL CONCEPT 

The no-action alternative represents the existing 

conditions at the monument. This alternative is 

presented as a way of comparing current conditions to possible future conditions, as described 

in the other four alternatives. Examining the noaction alternative is often useful in understanding why the National Park Service or the public 

may believe that certain future changes are 

necessary or advisable. The primary concerns 

about existing conditions are crowding and 

congestion during the heavy use season and the 

condition of some natural and ethnographic 

resources. The four “action” alternatives present 

different possible ways of addressing these 

concerns. 

EXISTING CONDITIONS 

Most visitor activity at the monument is centered 

on the developed and trailed areas at the base of 

the Tower, generally referred to as the Tower 

area. That area is congested and noisy during 

peak visitation times (June, July, and August, 

especially from 9 A.M. to 3 P.M.). A 75-space 

paved parking area and a 62-space graveled 

parking area are frequently full, and visitors 

often have to wait up to 15 minutes for a parking 

space. Neither parking lot can accommodate 

vehicles longer than the standard parking space 

will allow. The only way a longer vehicle can 

park is to parallel park over several parking 

spaces, and during peak visitation longer vehicles must park in a specially designated area 

(with limited space) alongside the very busy 

main road. Parking in this area puts visitor safety 

at risk. No walkways are associated with this 

specially designated parking area (see the 

Alternative 1 map). 

Visitors pulling trailers are asked to disconnect 

their trailers and park them in a lot 2 miles from 

the Tower area. Recreational vehicles with 

passenger vehicles in tow are asked to disconnect and drive the smaller vehicles to the Tower 

area parking lot. 

In summer some visitors come to the monument 

on tour buses. Bus operators drop passengers off 

in the Tower area and frequently remain in the 

area idling their buses. The overall noise, activity, and congestion in the Tower area has been 

described by some people as inconsistent with 

the beauty and grandeur of the Tower, interfering with the experience visitors are seeking. 

A visitor center and a ranger station in the 

Tower area are listed on the National Register of 

Historic Places. Visitor orientation and interpretation are available in these historic buildings, as are a bookstore, employee office space, 

and restrooms. These structures were built to 

accommodate a small administrative staff and an 

expected visitation of 20,000 per year. The 

monument’s current administrative staff is larger 

and has outgrown the facilities, and annual 

visitation is now about 400,000. These buildings 

are showing wear from excessive use and 

stopgap maintenance. 

A surfaced trail (the Tower trail) with interpretive signs leads up to and around the base of 

the Tower. The initial section of the trail, which 

leads visitors to an unobstructed view of the 

Tower, is too steep for many visitors, especially 

anyone with impaired mobility or health conditions that limit their level of strenuous activity. 

In addition to the Tower trail, two longer loop 

trails are available for hiking. The Joyner Ridge 

trail leads off a gravel spur road off the main 

monument road, and the trailhead for the Red 

Beds trail is near the base of the Tower. Spur 

trails connect the Red Beds trail with the prairie 

dog town. 

Approximately 5,000 people climb the Tower 

each year, using about 220 identified climbing 

routes. Most climbers abide by a voluntary 

climbing ban during June out of respect for 

American Indian spiritual activities. Climbing is 

managed according to a climbing management 

plan that was approved in 1995. 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

28 

A prairie dog town along the main monument 

road is another location of primary visitor 

activity. Several traffic pullouts with interpretive 

signs enable visitors to stop and look at the 

prairie dogs. Some visitors use informal trails to 

walk around the general area. The pullouts cause 

traffic congestion and create hazardous conditions during high-use periods. Traffic and 

pedestrian congestion disturb the prairie dogs 

and their habitat and may affect visitors’ 

enjoyment of the monument. 

In the southeast part of the monument are a 

developed picnic area and the Belle Fourche 

River campground, a two-loop developed campground. Evening interpretive programs are 

offered at a nearby amphitheater. 

The northwest corner of the monument is 

undeveloped, but it is accessible from two 

gravel- surfaced spur roads off the main 

monument road. These roads lead to neighboring 

private lands and offer scenic views. Some 

American Indian ceremonial activities also are 

accommodated in this area. 

Just inside the monument from the entrance 

station, a small area between the road and the 

river is available by permit for group camping. 

There are no facilities, and campers must bring 

their own water and portable toilets. The area is 

used sporadically and infrequently. 

The administrative headquarters, including staff 

offices, maintenance facilities, and housing, is 

near the picnic area and campground. Office 

space and storage for administrative and 

maintenance functions are too small to serve the 

current operation. 
29 

Alternative 1 map 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

30 

blank back of map 
31 

ALTERNATIVE 2 

OVERALL CONCEPT 

In alternative 2, offering a more rural, natural 

setting would be emphasized. This would be 

accomplished by reducing visitation to the 

Tower area during the peak season, reducing 

overall development, and restoring natural 

vegetation in some areas. Reservations would be 

necessary for visits during the peak season. 

DETAILED DESCRIPTIONS 

In all four action alternatives, the descriptions 

are organized by management zones. The 

various kinds of management zones are 

described at the beginning of this chapter. Also 

see the Alternative 2 map.

Developed Zone 

The developed zone in alternative 2 would 

consist of campground loop A, the main monument roadway, and a parking area at the base of 

the Tower. To reduce congestion in the Tower 

area and to make it possible to see the Tower 

with fewer human-made intrusions, the existing 

paved parking area would be converted to a 

landscaped pedestrian plaza. The gravelsurfaced parking area would be paved and 

redesigned to accommodate nearly all types of 

vehicles and would become the only parking at 

the base of the Tower. Approximately 25% 

fewer visitors could be accommodated at the 

Tower than at present. An area would be incorporated in this design to allow for the dropoff 

and pickup of tour bus passengers. Tour buses 

would be required to park near the campground 

after dropping off passengers. Every effort 

would be made to keep the bus parking area as 

natural in appearance as possible, in keeping 

with the goals of this alternative. 

Parking and trail access for prairie dog viewing 

and interpretation would be developed in loop A 

of the existing Belle Fourche River campground. 

No camping would be permitted in loop A, but 

people still could camp in loop B. 

Visitors towing trailers or those with recreational vehicles towing passenger vehicles 

would be required to leave the trailers or large 

vehicles in the prairie dog town parking area 

before driving to the Tower. The current picnic 

area, amphitheater, and entrance areas would 

remain. To improve traffic safety and relieve 

congestion, The vehicle pullouts by the prairie 

dog town would be removed and rehabilitated to 

natural conditions. 

Pedestrian Zone 

The pedestrian zone would include the current 

paved parking area, the Tower trail, and the 

prairie dog town trail. As was mentioned above, 

the paved parking area in front of the visitor 

center would be converted to a pedestrian plaza. 

This area would be designed and landscaped to 

be sensitive to the historic context of the visitor 

center and ranger station and to blend into the 

natural surroundings of the Tower. Overall there 

would be fewer paved areas than at present. 

Vehicles would no longer be able to drive in 

front of the visitor center or the Tower trail trailhead. A view of the Tower would be available, 

and there would be less traffic noise and congestion. Facilities in this area could include interpretive exhibits, benches, an interpretive area, 

and walkways. 

The beginning expanse of the Tower trail would 

be redesigned for easier access. Trails around 

the prairie dog town would be graveled and 

widened to encourage circulation on the trail 

only. Interpretation would be available along the 

trail. 

Natural Trailed Zone 

The natural trailed zone would consist of the 

Joyner Ridge, Red Beds, and South Side trail 

systems. Where abandoned two-track dirt roads 

form part of trail system, one of the tracks would 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

32 

be restored to native vegetation, leaving the 

other track for the trail. 

Developed Camping Zone 

The developed camping zone would consist of 

loop B of the campground, the only place where 

camping would be permitted. 

Semiprimitive Zone 

The semiprimitive zone would comprise all parts 

of the monument not included in any other zone. 

As in all alternatives, this management zone 

would cover the largest areas of the monument. 

Group camping would not be available in the 

current special permit camping area near the 

entrance, and the area would be allowed to 

return to natural conditions. Trailer drop areas 

would no longer be needed; they would be 

restored to native vegetation. 

Special Protection Zone. 

The special protection zone would comprise the 

Tower and a large area in the northwest corner 

of the monument. To maximize resource protection and opportunities for solitude, tighter 

restrictions would be implemented. Parties of 1–

5 would self-register, parties of 6 or more would 

be required to register with a ranger, and activities would be restricted to those that would 

result in minimal or no resource impact. 

Vehicles would be prohibited on the west road, 

which would be rehabilitated to natural conditions. Climbing would be managed according to 

the monument’s Climbing Management Plan.

Administrative Zone 

To reduce impacts on resources, the north road 

beyond the Joyner Ridge trailhead would be 

retained for administrative and private access 

use only. Visitor use on this route would no 

longer be permitted. 

ESTIMATED COSTS 

The costs of the construction and rehabilitation 

actions of alternative 2 have been estimated at 

$1.8 million. This estimate is general and should 

be used only for comparing the alternatives. 
33 

Alternative 2 map 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

34 

blank back of map 
35 

ALTERNATIVE 3 (PREFERRED ALTERNATIVE) 

OVERALL CONCEPT 

In alternative 3, shuttle service to the Tower 

would be instituted to decrease the number of 

vehicles and the need for parking and to make it 

possible for visitors to have a quieter, more relaxed experience. In peak visitation times visitors would be required to park at a staging area 

near the entrance, where orientation and interpretation would be offered. Here visitors could 

learn about all available options so that they 

could make best use of their time. From here, 

those who wanted to go to the Tower could use 

the shuttle or hike or bicycle to Tower. To 

alleviate congestion, the number of people at the 

Tower area would be adjusted by shuttle 

schedules or capacities. In non-peak times 

visitors could drive to the Tower (see the 

Alternative 3 map).

The existing paved parking area at the base of 

the Tower would be converted to a landscaped 

pedestrian plaza. The current gravel-surfaced 

parking area would be paved for parking and a 

shuttle stop. The campground and other facilities 

in the Belle Fourche River floodplain would be 

eliminated and the area restored to natural conditions. A shuttle system would be necessary to 

achieve the objectives of this alternative, and it 

would be an appropriate commercial use in the 

monument. A commercial shuttle operation 

would be economically feasible, and a concessioner could make a reasonable profit by 

industry standards (NPS 2001b). 

DETAILED DESCRIPTIONS 

Developed Zone 

The developed zone in alternative 3 would 

consist of the area behind the entrance station 

and adjacent to the monument boundary, the 

main road, and a graveled parking area at the 

base of the Tower. A staging area for a shuttle 

system would be developed adjacent to the 

boundary, behind the entrance station. During 

peak visitation times, visitors would be required 

to park at the staging area and ride the shuttle, 

hike, or bicycle to reach the Tower. The staging 

area would accommodate visitor parking and 

tour bus parking. Restrooms, visitor orientation 

and interpretation, and a bookstore would be 

available here, as would interpretive program 

spaces, expanded picnic sites, and access to the 

prairie dog town and the monument trails. 

A shuttle stop would be established, and tour 

buses could drop off and pick up passengers at 

the staging area. Tour buses would be required 

to park in the staging area after dropping off 

passengers. When the shuttle was not operating 

(in off-peak times) visitors would be directed 

into the staging area before continuing up the 

main road to the Tower. As a part of the staging 

area design, the current fee collection kiosk 

would be removed, and a new one would be 

placed at the staging area entrance to improve 

traffic circulation and reduce the queues of 

vehicles at the monument entrance. 

At off-peak times, parking would be permitted 

in the current gravel-surfaced parking area, 

which would be paved and redesigned to 

accommodate most types of vehicles. 

The vehicle pullouts along the main road at the 

prairie dog town would be replaced with larger 

pullouts on both sides of the road. 

If funding for a shuttle system was not available 

or would be delayed for some time, traffic to the 

Tower would be managed from the staging area. 

For example, when parking at the Tower was 

full, visitors might be asked to wait at the 

staging area until parking became available. 

Visitors would always have the option of hiking 

or bicycling to the Tower. 

To better accommodate incoming traffic and 

relieve congestion in front of the private 

businesses near the monument, the entrance 

station would be relocated closer to the shuttle 

staging area and the orientation center. 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

36 

Pedestrian Zone 

The pedestrian zone would consist of the area at 

the base of the Tower, the Tower trail, and the 

prairie dog town trail. The paved parking area in 

front of the visitor center would be redesigned to 

create a pedestrian plaza. This area would be 

designed and landscaped with sensitivity to the 

historic context of the visitor center and ranger 

station and to blend into the natural surroundings 

of the Tower. Overall there would be fewer 

paved areas than at present. Vehicles would no 

longer be able to drive in front of the visitor 

center or the Tower trail trailhead. A view of the 

Tower would be available, and there would be 

less traffic noise and congestion. The current 

visitor center would remain. Its focus would be 

on interpretation, rather than orientation. Facilities in this area could include interpretive 

exhibits, benches, an interpretive area, and 

walkways. 

The beginning expanse of the Tower trail would 

be redesigned for easier access. Trails around 

the prairie dog town would be resurfaced to 

better accommodate visitor use and reduce 

maintenance costs. 

Natural Trailed Zone 

In the natural trailed zone would be the Joyner 

Ridge, Red Beds, and South Side trail systems. 

Where abandoned two-track dirt roads form part 

of trail system, one of the tracks would be restored to native vegetation, leaving the other 

track for the trail. When the shuttle was operating, access to the Joyner Ridge trailhead might 

not be available (specific shuttle stops have not 

been determined). For this reason, a new spur 

trail would be established to link the Joyner 

Ridge and Red Beds trails. 

Semiprimitive Zone 

The semiprimitive zone would comprise all parts 

of the monument not included in any other zone. 

The 50-space developed campground would be 

removed, and the picnic area and amphitheater 

would be relocated to a site in the staging area. 

Trailer dropoff areas would no longer be needed; 

they would be restored to native vegetation and 

enhanced floodplain values. 

Special Protection Zone 

The special protection zone would comprise the 

Tower and a large area in the northwest corner 

of the monument. To maximize resource protection and opportunities for solitude, tighter 

restrictions would be implemented. Parties of 1–

5 would self-register; parties of 6 or more would 

be required to register with a ranger, and activities would be restricted to those that would 

result in minimal or no resource impact. Climbing would be managed according to the monument’s Climbing Management Plan.

Administrative Zone 

The administrative zone would consist of the 

north and west roads and the administrative/ 

housing area in the southern part of the monument. To reduce impacts on resources, access to 

the north and west roads beyond the Joyner 

Ridge trailhead would be restricted to administrative and private use only. The headquarters 

building would be expanded to increase office 

and storage space. 

Viewshed Protection Outside 

the Monument Boundary 

The National Park Service at Devils Tower 

shares with many of its neighbors a concern for 

the long-term protection of the natural and rural 

character of the land outside monument boundaries. Actions taken by the Park Service or others 

could result in developments or land uses that 

would be inconsistent with local scenic values 

and would affect the quality of life for area 

residents and for the monument. To help preserve scenic values around the monument, the 

National Park Service would seek expanded 

legislative authority to accept donations of lands 

and/or interests in lands (such as scenic easements), as well as land exchanges (with no net 

gain of government land). This authority would 
Alternative 3 (Preferred Alternative) 

37 

Alternative 3 map 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

38 

blank back of map 
Alternative 3 (Preferred Alternative) 

39 

allow the Park Service to enter into land protection agreements with neighboring landowners 

who might choose to participate and who might 

benefit from such agreements. 

The National Park Service has worked with 

various landowners on agreements whereby the 

landowners would give the National Park 

Service scenic easements. Unfortunately, these 

efforts have not come to fruition. The National 

Park Service is willing to reexamine scenic 

easements if landowners are willing. 

ESTIMATED COSTS 

The costs of the construction and rehabilitation 

actions of alternative 3 have been estimated at 

$4.7 million. This estimate is general and should 

be used only for comparing the alternatives. 
40 

ALTERNATIVE 4 

OVERALL CONCEPT 

Alternative 4 is similar to alternative 3, the preferred alternative, in that shuttle service to the 

Tower would be offered during peak visitation 

times. However, in alternative 4 the staging area 

for the shuttle and the visitor orientation facilities would be placed outside the monument 

boundary. Using lands outside the current 

boundary could involve federal acquisition or 

leasing of land or participation in a partnership 

with a private party or another government 

entity. Visitors would stop first at the staging 

area to learn about all available options, so that 

they could make best use of their time. Then, if 

they chose, they could take a shuttle to the 

Tower. 

Headquarters and maintenance facilities would 

be relocated outside the boundaries, and their 

current locations would be restored to natural 

vegetation. 

As in alternatives 2 and 3, the paved parking 

area near the Tower would be converted to a 

landscaped pedestrian plaza. However, in alternative 4 the campground and other monument 

facilities near the Belle Fourche River would 

remain. These areas would be accessible by 

shuttle during peak use times and by private vehicle during non-peak times. A shuttle system 

would be necessary to achieve the objectives of 

this alternative, and it would be an appropriate 

commercial use in the monument. A commercial 

shuttle operation would be economically feasible, and a concessioner could make a reasonable profit by industry standards (NPS 2001b). 

DETAILED DESCRIPTIONS 

Developed Zone 

The developed zone in alternative 4 would consist of campground loop A, the main monument 

roadway, and a parking area at the base of the 

Tower. With the staging area for the shuttle 

system outside the current boundary, visitors 

would be required to park at the staging area at 

peak visitation times and ride the shuttle, hike, 

or bicycle to reach the Tower. At off-peak times, 

private vehicles could enter the monument. 

Headquarters and maintenance facilities would 

also be relocated to an area outside the boundary 

(see the Alternative 4 map). 

The staging area would accommodate visitor 

parking and tour bus parking. Restrooms, visitor 

orientation, interpretation, and a bookstore 

would be available there, as would an amphitheater and picnic sites. When the shuttle was 

not operating (off-peak times) visitors would be 

directed into the staging area before entering the 

monument. At off-peak times, parking would be 

permitted in the current gravel-surfaced parking 

area, which would be paved and redesigned to 

accommodate most types of vehicles. 

No camping would be permitted in loop A of the 

existing Belle Fourche River campground, but 

people still could camp in loop B. A shuttle stop 

would be developed in the area that is now 

campground loop A. At this stop, visitors could 

park, and there would be trail access so that they 

could see the prairie dog town. Also included at 

this stop would be related interpretation, restrooms, picnic sites, and the amphitheater. Tour 

buses would be required to park at this shuttle 

stop after dropping off passengers at the Tower. 

Campers would be permitted to drive to the 

campground at all times. 

To enhance traffic safety and relieve congestion, 

the vehicle pullouts by the prairie dog town 

would be removed and rehabilitated to natural 

conditions. To allow for a safe and efficient 

traffic flow into and out of the prairie dog town 

shuttle stop, the main road near the administration building would be redesigned. 
41 

Alternative 4 map 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

42 

blank back of map 
Alternative 4 

43 

Pedestrian Zone 

The pedestrian zone would consist of the parking area at the base of the Tower, the Tower 

trail, and the prairie dog town trail. The paved 

parking area in front of the visitor center would 

be redesigned to create a pedestrian plaza. The 

design and landscaping of this area would be 

sensitive to the historic context of the visitor 

center and ranger station and would blend into 

the natural surroundings of the Tower. Overall 

there would be fewer paved areas than at present. Vehicles would no longer be able to drive in 

front of the visitor center or the Tower trail trailhead. A view of the tower would be available, 

and there would be less traffic noise and congestion. The function of the visitor center would 

be shifted from a primary orientation center to 

an interpretive center. Facilities in this area 

could include interpretive exhibits, benches, an 

interpretive area, and walkways. 

The beginning expanse of the Tower trail would 

be redesigned for easier access. The trails 

around the prairie dog town would be resurfaced 

to better accommodate visitor use and reduce 

maintenance costs. 

Natural Trailed Zone 

The Joyner Ridge, Red Beds, and South Side 

trail systems would make up the natural trailed 

zone in alternative 4. Where abandoned twotrack dirt roads form part of trail system, one of 

the tracks would be restored to native vegetation, leaving the other track for a trail. When the 

shuttle was operating access to the Joyner Ridge 

trailhead might not be available (specific shuttle 

stops have not been determined). For this reason, 

a new spur trail would be established to link the 

Joyner Ridge and Red Beds trails. 

Developed Camping Zone 

The developed camping zone would consist of 

loop B of the campground, the only place where 

camping would be permitted. 

Semiprimitive Zone 

The semiprimitive zone would comprise all parts 

of the monument not included in any other zone. 

Group camping would not be available in the 

current special permit camping area near the entrance The picnic area and amphitheater would 

be relocated to a site in the staging area. The 

trailer dropoff areas would no longer be needed; 

they would be restored to native vegetation. A 

new headquarters and maintenance area would 

be constructed outside the monument boundary, 

and their present locations would be restored to 

natural conditions. 

Special Protection Zone 

The special protection zone would comprise the 

Tower and a large area in the northwest corner 

of the monument. To maximize resource protection and opportunities for solitude, tighter 

restrictions would be implemented. Parties of 1–

5 would self-register; parties of 6 or more would 

be required to register with a ranger, and activities would be restricted to those that would result in minimal or no resource impact. Climbing 

would be managed according to the monument’s 

Climbing Management Plan.

Administrative Zone 

The administrative zone would consist of the 

north and west roads and the housing area in the 

southern part of the monument. To reduce impacts on resources, access to the north and west 

roads beyond the Joyner Ridge trailhead would 

be restricted to administrative and private use 

only. 

ESTIMATED COSTS 

The costs of the construction and rehabilitation 

actions of alternative 4 have been estimated at 

$6.7 million. This estimate is general and should 

be used only for comparing the alternatives. 
44 

ALTERNATIVE 5 

OVERALL CONCEPT 

In alternative 5, visitor experiences similar to 

those available now would be offered, but facilities would be added to reduce congestion. The 

paved and gravel-surfaced parking areas at the 

base of the Tower would be redesigned, 

enlarged, and consolidated for more efficient 

circulation, and all parking areas would be 

paved. There would be no shuttle system; 

visitors would hike or drive to all monument 

facilities and features. The existing level of 

visitation would be accommodated, but if visitation increased in the future, some management 

of visitor numbers could be required (see the 

Alternative 5 map). 

The campground and other facilities near the 

Belle Fourche River would remain. The 

administrative headquarters would be enlarged 

to accommodate better visitor orientation and 

interpretive services. 

DETAILED DESCRIPTIONS 

Developed Zone 

The developed zone in alternative 5 would 

consist of the main monument road, the prairie 

dog town pullouts, a tour bus parking area, a picnic area, and the amphitheater, as well as Joyner 

Ridge road, the west road, the north road, and 

the Tower area parking lot. To make as much 

parking as possible available at the base of the 

Tower, the size of the existing visitor center 

parking lot and the overflow parking area would 

be increased as much as reasonable. The entire 

parking area would be paved and redesigned to 

maximize safety and efficiency. 

The current trailer dropoff area would be enlarged, redesigned, and paved to accommodate 

tour buses so that bus parking would not infringe 

on parking for personal vehicles at the Tower. 

After dropping off passengers at the Tower, tour 

bus operators would be required to drive back to 

the new bus parking area. 

The visitor center and ranger station would 

continue to serve visitors and monument staff, 

but to reduce crowding, visitor center exhibits 

would be minimal. The historic buildings would 

be maintained to established standards. Additional restroom facilities would be developed 

near the main parking lot. 

The road to the Joyner Ridge trailhead parking 

lot would be widened and paved for easier 

access. The existing vehicle pullouts at the 

prairie dog town would be converted to parking 

lanes on both sides of the road to accommodate 

more vehicles and reduce traffic congestion. The 

entrance station area would be redesigned to 

better accommodate seasonal traffic flow. 

Pedestrian Zone 

The pedestrian zone would consist of the Tower 

trail and the prairie dog town trail. The latter 

trail would be surfaced to better accommodate 

increased use and reduce maintenance costs. To 

the extent possible within the available space, 

the approach to the Tower trail would be 

redesigned for easier access. 

Natural Trailed Zone 

The natural trailed zone would consist of the 

Joyner Ridge, Red Beds, and South Side trail 

systems. The road to the Joyner Ridge trail 

would be widened and paved for easier visitor 

access. The trailhead parking area would be 

enlarged to accommodate approximately 10 

vehicles. The trails would not be modified in any 

way. 

Developed Camping Zone 

Loops A and B of the Belle Fourche River 

campground would compose the developed 

camping zone. An area just inside the entrance 

would continue to be used for groups of more 

than 20 people to camp by permit.
45 

Alternative 5 map 
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

46 

blank back of map 
Alternative 5 

47 

Semiprimitive Zone 

As in all the other alternatives, the semiprimitive 

zone would comprise most of the monument. 

There would be no changes from the existing 

conditions in this zone. 

Special Protection Zone 

The special protection zone would comprise the 

Tower, a relatively small area in the northwest 

corner of the monument, and the area behind the 

entrance station. 

Tighter restrictions would be implemented: 

Parties of 1–5 would self-register; parties of 6 or 

more would be required to register with a ranger, 

and activities would be restricted to those that 

would result in minimal or no resource impact. 

Climbing would be managed according to the 

monument’s Climbing Management Plan. 

Administrative Zone 

This zone would consist of the 

administrative/housing area in the southern part 

of the monument. The headquarters building 

would be enlarged to increase office and storage 

space and to accommodate visitor orientation 

and interpretation. 

ESTIMATED COSTS 

The costs of the construction and rehabilitation 

actions of alternative 5 have been estimated at 

$2.7 million. This estimate is general should be 

used only for comparing the alternatives. 
48 

ALTERNATIVES ELIMINATED, ENVIRONMENTALLY 

PREFERABLE ALTERNATIVE, AND MITIGATION 

ALTERNATIVES ELIMINATED FROM 

FURTHER CONSIDERATION 

During the planning process, the public suggested several ideas that were dropped from 

further consideration because they would have 

resulted in unacceptable impacts on resources or 

visitors. These ideas are discussed below. 

Develop a Visitor Parking Area 

North of the Tower 

Adding a visitor parking area north of the tower 

was considered; however, significant topographic modification would have been required. This 

would have resulted in unacceptable resource 

impacts, particularly since the construction 

would have taken place in a previously 

undisturbed area. 

Develop Tent Campsites at the 

Special Permit Camping Area 

The idea of developing tent camping sites at the 

current special permit camping area was considered, but it was rejected for several reasons. The 

existing campground is rarely fully occupied, so 

additional camping facilities are not needed. In 

addition, tent camping is readily available in 

nearby private and U.S. Forest Service camping 

areas. 

Prohibit Vehicle Use in the Monument 

Several members of the public suggested that 

vehicle traffic be halted at the entrance, allowing 

only trail access to the Tower. This idea was 

eliminated from further consideration because it 

would have resulted in severe impacts on visitors unable to hike to the Tower, who therefore 

would have been unable to experience the monument’s primary resource. The alternatives, including the preferred alternative, would make 

substantial improvements to the natural setting 

of the Tower and would significantly reduce 

traffic noise, odors, and congestion, while still 

allowing most visitors to access the immediate 

Tower area. Access to the Tower by trail is 

currently available and would be improved in 

several of the alternatives. 

Construct the Shuttle Staging Area at the 

Belle Fourche River Campground Site 

A preliminary alternative prepared by the 

planning team called for constructing a shuttle 

staging area and associated facilities at the 

current Belle Fourche River campground. 

Visitor overnight use of the Belle Fourche River 

floodplain would have been eliminated, but the 

structures and other facilities in the floodplain 

would have remained. Subsequent public input 

suggested an alternative shuttle staging site just 

inside the entrance. This site was found to be 

outside the 100-year floodplain, and it has been 

included in the preferred alternative. 

THE ENVIRONMENTALLY 

PREFERABLE ALTERNATIVE 

The environmentally preferable alternative is the 

alternative that will promote the national environmental policy as expressed in section 101 of 

the National Environmental Policy Act. 

Ordinarily, this means the alternative that would 

cause the least damage to the biological and 

physical environment; it also means the alternative that would best protect, preserve, and 

enhance historic, cultural, and natural resources. 

Alternative 3, which has been selected as the 

preferred alternative, is also the environmentally 

preferable alternative. Three of the six criteria 

listed in NEPA are particularly relevant: 

(a) Fulfill the responsibilities of each generation 

as trustee of the environment for succeeding 

generations. 
Alternatives Eliminated, Environmentally Preferable Alternative, and Mitigation 

49 

(b) Assure for all Americans safe, healthful, 

productive, and esthetically and culturally 

pleasing surroundings. 

(c) Preserve important historic, cultural, and 

natural aspects of our national heritage, and, 

wherever possible, maintain an environment 

that supports diversity and variety of 

individual choice. 

In the process used to select the preferred alternative, alternative 3 was found overall to have 

the best potential for safeguarding the resource 

and scenic values of Devils Tower National 

Monument while making those resources easily 

accessible to visitors. The spiritual character and 

cultural heritage values of the Tower would be 

protected under this alternative, and the visitor 

experience would be enhanced. Removing 

developments from the floodplain of the Belle 

Fourche River would represent the highest level 

of natural resource protection and restoration of 

any of the alternatives. 

MITIGATION AND 

ADDITIONAL STUDIES

Water Resources

A statement of findings for floodplains would be 

prepared if the selected alternative included 

retaining the campground in the 100-year 

floodplain. The statement of findings would 

include an emergency preparedness plan for 

evacuating campers in the event of a flood. More 

detail is available in the “Affected Environment” 

chapter, under “Natural Resources.” 

Any new facilities proposed for location in the 

floodplain (except trails, roads, and picnic 

facilities) would be designed to manage flood 

conditions, and a statement of findings for 

floodplains would be prepared. 

For critical actions in the 500-year floodplain 

(existing fuel storage at the maintenance area 

and storing propane tanks at headquarters), 

mitigating actions would be undertaken, such as 

moving the fuel storage to a location out of the 

500-year floodplain or constructing a protective 

embankment. Constructing an embankment 

would require the approval of a statement of 

findings for floodplains. 

All facilities would be located to avoid wetlands 

if feasible. If avoiding wetlands was not feasible, 

other actions would be taken to comply with 

Executive Order 11990 (“Protection of 

Wetlands”), the Clean Water Act, and Director’s 

Order 77-1 (“Wetland Protection”). 

A statement of findings for wetlands has been 

prepared because the preferred alternative would 

result in long-term negligible adverse impacts on 

wetlands (see appendix E). The statement of 

findings includes an analysis of the alternatives, 

delineation of the wetland, a wetland restoration 

plan to identify mitigation, and a wetland functional analysis of the impact site and the 

restoration site. 

Increased caution would be exercised to protect 

wetlands from damage caused by construction 

equipment, erosion, siltation, and other activities 

with the potential to affect wetlands. Construction materials would be kept in work areas, 

especially if the construction took place near 

streams or natural drainages. 

Wetlands would be delineated by qualified 

National Park Service staff or certified wetland 

specialists, and they would be marked before 

construction. 

Cultural Resources 

Whenever possible, monument staff would 

continue to educate visitors about American 

Indian concerns regarding the displacement of 

offerings or the disturbance of religious 

activities. 

In accordance with NPS policies and procedures, 

the protection of cultural resources would continue as much as would be allowable under 

present funding and staffing levels. The disturbance of significant resources would be avoided 

wherever possible. Where avoidance or preser-
ALTERNATIVES, INCLUDING THE PROPOSED ACTION

50 

vation could not be achieved, appropriate mitigation would be carried out according to the 

procedures of the Advisory Council on Historic 

Preservation (36 CFR 800). 

“Stop work” provisions and other protective 

measures would be included in project documents implementing the preferred alternative. 

Construction would be restricted to the immediate vicinity of the projects, and new disturbance 

would not be permitted outside the designated 

project area. 

If previously unknown and significant archeological resources were unearthed during construction or if human remains were discovered, 

work in the discovery area would be stopped 

immediately, and the monument superintendent 

and the contracting officer would be notified 

immediately. Measures would be instituted to 

protect the remains, sacred objects, associated 

funerary objects, and objects of cultural patrimony. The superintendent would notify the state 

historic preservation officer. Any artifacts found 

in association with the remains, funerary objects, 

sacred objects, and objects of cultural patrimony 

would be left in place. If the remains were 

determined to be of American Indian origin, the 

monument superintendent would notify 

associated tribes according to NAGPRA and its 

implementing regulations. 
51 

TABLE 1: COMPARISON OF ALTERNATIVES

Alternative 2 Alternative 3 (Preferred) Alternative 4 Al

Developed Zone

Graveled parking area redesigned and paved for primary Tower parking 

Graveled parking area redesigned and paved for off-peak Tower parking and shuttle stop 

Same as alternative 3 Graveled and o

combined and sible to maximTower 

Pullouts for prairie dog town removed and returned to natural conditions 

Prairie dog town pullouts replaced with larger ones on both sides of road 

Same as alternative 2 Parking lanes a

No shuttle system Shuttle staging area developed inside

boundary; would include parking, restrooms, orientation, interpretation, amphitheater, and picnic sites 

Shuttle staging area developed outsidecurrent boundary; would include parking, restrooms, orientation, interpretation, amphitheater, and picnic sites 

No shuttle syst

Loop A of Belle Fourche River campground converted to use for trailer drop, tour bus parking, prairie dog viewing, and interpretation 

Trailer drop not needed; no camping in monument 

Campground loop A converted to use for shuttle stop, prairie dog viewing. interpretation, restrooms, and off-peak trailer drop; intersection of main road realigned near campground 

Trailer drop arparking; Belle ground unchan

Pedestrian Zone

Paved Tower parking area converted to landscaped pedestrian plaza 

Same as alternative 2 Same as alternative 2 Pedestrian zon

of only trails; pdeveloped zon

Visitor orientation at Tower visitor center 

Visitor orientation moved to shuttle staging area 

Same as alternative 3 Same as altern

Natural Trailed Zone

Natural character of Joyner Ridge, Red Beds, and South Side trails improved 

Same as alternative 2 Same as alternative 2 No changes in 

No spur trail added Spur trail established between Red Beds 

and Joyner Ridge 

Same as alternative 3 No spur trail a

and trailhead paccommodate 

Developed Camping Zone

Camping permitted in loop B of campground; (loop A converted to prairie dog viewing and interpretation); no large group camping 

Camping in the monument eliminated Camping permitted in loop B of Belle 

Fourche River campground; (loop A converted to shuttle staging area); no large group camping 

Camping permBelle Fourche groups could cinside entrance 
Alternative 2 Alternative 3 (Preferred) Alternative 4 Al

Semiprimitive Zone

Special permit camping area, trailer drop area, and prairie dog town pullouts returned to natural condition; native vegetation restored 

Special permit camping area and campground/picnic area complex restored to native vegetation 

Special permit camping area, prairie dog town pullouts, picnic area, amphitheater site, trailer dropoff area, and headquarters and maintenance sites restored to native vegetation 

No sites vacateconditions 

Special Protection Zone

Zone would cover Tower and large area in NW part of monument; west road rehabilitated to natural conditions; tighter restrictions and registration to protect resources 

Zone would cover Tower and large area in NW part of monument; tighter restrictions and registration to protect resources 

Zone would cover Tower and small area in NW part of monument; tighter restrictions and registration to protect resources 

Zone would coarea in NW parestrictions and resources; speccontinue as at p

Administrative Zone

No visitor use of north road beyond Joyner Ridge trailhead 

No visitor use of west and north roads beyond Joyner Ridge trailhead 

Same as alternative 3 No change in u

No changes in headquarters Headquarters building enlarged for 

more office and storage space 

Headquarters and maintenance relocated outside boundary 

Headquarters boffice and stormodate orienta
53 

TABLE 2: COMPARISON OF IMPACTS

Alternative 1 (No Action) Alternative 2 Alternative 3 (Preferred) Alternative 4 

Soils

Soil erosion a short-term minor adverse impact; compaction, reduced permeability, less moisture, and erosion from ongoing visitor use would be longterm, negligible, and adverse. 

Some natural soil profile lost from regrading at lower parking area, a minor short-term adverse impact; construction would disturb about 4 acres of soil, increasing erosion, a minor shortterm adverse impact; erosion, soil nutrient transport, and vegetation composition increased by adding 0.5 acre more of paved surfaces (including gravel), a long-term minor adverse impact; overall adverse impacts on soils minor and long term. 

A small part of natural soil profile lost on less than 1 acre; some soil erosion on 15 acres from construction and rehabilitation despite preventive efforts; 4 more acres covered with hardened surfaces; 9 acres rehabilitated; overall adverse impacts on soils minor and long term. 

Natural soil profile lost on up to 8 acres; some soil erosion on about 10 acres from construction and revegetation despite preventive efforts; 4 more acres covered with hardened surfaces; 2 acres rehabilitated; overall adverse impacts on soils minor and long term. 

Natural acre; soacres frtation dmore acsurfaceadverse and lon

Vegetation

Maintenance and visitor use would change relative abundance of species, cause death of some plants from trampling and exposure of root systems; resulting changes in species composition adverse, negligible to minor, and long term. 

Although there would be a net gain of 2.6 acres of vegetation and improved preservation of vegetation in the northwest area, 1.3 acres of already- disturbed vegetation lost, a minor longterm adverse impact. 

About 6 acres of disturbed vegetation lost, 9 acres revegetated; clearing some vegetation during construction could increase relative abundance of invasive plants; more erosion at cleared areas could expose root systems, causing death of mesic plants; preservation of a prairie remnant in northwest corner of monument enhanced; overall adverse effects on vegetation minor and long term. 

About 2 acres of disturbed vegetation lost inside monument and up to 5 acres outside; clearing some vegetation during construction could increase relative abundance of invasive plants; more erosion at cleared areas could expose root systems, causing death of mesic plants; overall adverse impacts on vegetation minor and long term. 

About 3 tion lossome vcould ininvasivcleared systemsplants; vegetat

Wildlife

Wildlife would suffer collisions with vehicles, habitat interruption, alteration of movement, resulting in minor adverse impacts in the long term. 

Wildlife habitat increased by about 2.6 acres; smallness of area and care to avoid cottonwood trees in campground would result in a minor beneficial effect in the long term. 

About 6 acres of habitat lost, 9 acres rehabilitated; invertebrates destroyed and small vertebrates displaced, small mammals and birds disrupted by construction; overall effects on wildlife minor, beneficial, and long term. 

About 8 acres of habitat lost, 2 acres rehabilitated; invertebrates destroyed and small vertebrates displaced, small mammals and birds disrupted by construction; overall adverse effects on wildlife minor and long term. 

About 3 brates dvertebramammaconstruon wild
Alternative 1 (No Action) Alternative 2 Alternative 3 (Preferred) Alternative 4 

Air Quality

Overall adverse impacts on air quality generally minor and long term. 

Overall long-term effects on air quality in peak season minor and beneficial because of reservation system. 

Air quality at base of Tower improved through shuttle system, degraded at staging area in peak times; wood smoke eliminated by removal of campgrounds, improving air quality; overall, minor adverse changes in air quality. 

Air quality at base of Tower and shuttle staging area (former campground) improved through shuttle system, degraded at staging area outside monument in peak times; wood smoke reduced by removing campground loop A and special permit area; overall adverse impacts on air quality minor and short term at peak use times. 

More eternativvehicleTower; air qual

Threatened, Endangered, and Candidate Species

Size of black-tailed prairie dog town limited by preventing its spread into other suitable habitat; a minor long-term adverse impact; benefits of retaining prairie dog colony partially offset by preventing expansion, an adverse regional effect. 

About 0.1 acre of prairie dog habitat lost, a minor long-term adverse impact. 

About 0.8 acre of prairie dog habitat lost, a minor long-term adverse impact. 

Same as alternative 3. About 1 

lost, a mimpact. 

Wetlands

Retaining administrative building and employee residence in wetlands and diverting runoff away from wetlands would continue a minor long-term adverse effect; long-term adverse effects from trampling of wetland near special permit campground once or twice a year would be negligible. 

Removing special permit campground might benefit wetlands in the long term, a negligible effect. 

Enlarging headquarters and moving parking lot to behind building would encroach on 0.04 acre of wetland, causing long-term loss of natural and beneficial values on less than 0.1 acre; building additions would disturb less than 0.5 acre in the short term, a minor adverse impact on wetlands. 

Removing development and restoring natural and beneficial wetland values would result in a long-term moderate impact on wetlands. 

Enlargiwould cwetlandeffect; bdisturb term, a wetland
Alternative 1 (No Action) Alternative 2 Alternative 3 (Preferred) Alternative 4 

Floodplains

Presence of campground would continue to compromise natural and beneficial floodplain values, a major long-term adverse impact; minor to moderate risk of severe flooding could cause major adverse impacts on visitors involved. 

Development in floodplains would compromise natural and beneficial floodplain values, a major long-term adverse impact; minor to moderate risk of severe flooding could cause major adverse impacts on visitors involved. 

Removing campground and related structures and rehabilitating the 100-year floodplain would restore natural and beneficial values, a major long-term beneficial effect; removing campground also would have a major beneficial effect on visitors who might have been at risk. 

Keeping 30 campsites in floodplain and replacing others with shuttle staging area would have major long-term adverse impacts on natural processes, partly offset by long-term minor beneficial effect of removing maintenance complex; minor to moderate risk of severe flooding could cause major adverse impacts on visitors involved. 

Same a

Cultural Resources — Ethnographic Resources 

Ongoing long-term major adverse impacts would continue at the Tower, the entrance station, and other administrative and visitor use areas. 

Ethnographic impacts mixed: removing upper parking lot to create pedestrian plaza, removing prairie dog pullouts, rehabilitating trails and disturbed areas, and allowing fewer people in special permit zone would cause long-term beneficial effects, as would rehabilitating west and closing north roads; requiring groups to register and reducing access to traditional areas (but not impeding traditional access) would have negligible long-term adverse effects; restoring special permit campground to natural conditions would result in minor long-term adverse impacts; construction and rehabilitation would cause short-term minor adverse impacts. On balance, alternative 2 would have longterm beneficial effects on ethnographic resources. 

Construction would adversely affect ethnographic resources, a minor short-term impact; adding visitor use areas would cause some adverse impacts, as would adding a spur trail between the Red Beds and Joyner Ridge trails; however, a moderate long-term beneficial effect would result from removing the paved upper parking area, creating a pedestrian plaza, moving the main parking area farther away from Tower, decreasing prairie dog pullouts, rehabilitating trails, disturbed areas, and the developed campground, allowing fewer people at the base of the Tower at one time, reducing concentrations of people, establishing a shuttle system, and eliminating visitor access to the north and west roads. 

Construction would adversely affect ethnographic resources, a short-term minor impact; adding visitor use areas and adding a spur trail between the Red Beds and Joyner Ridge trails would cause some adverse impacts; however, moderate long-term beneficial effects would result from removing paved upper parking area to create a pedestrian plaza, moving main parking area farther away from Tower, eliminating prairie dog pullouts, rehabilitating trails, disturbed areas, and 20 sites of developed campground, allowing fewer people at base of Tower at one time, reducing concentrations of people, establishing a shuttle system, eliminating visitor access to north road and eliminating west road. 

More vdevelopdetract ligious which cdevelopethnograrea anincreasitraffic aRidge aethnogrcomprodropoff tour bueffects would b
Alternative 1 (No Action) Alternative 2 Alternative 3 (Preferred) Alternative 4 

Cultural Resources — Historic Resources

Visitor use and traffic congestion in the historic district and the modification of buildings for accessibility would continue longterm minor adverse impacts on historic resources. 

The overall long-term impacts on historic resources from this alternative would be beneficial and minor to major.

Visual and auditory intrusions from construction would cause minor short-term adverse impacts on historic resources; removing paved parking area, establishing a pedestrian plaza, operating a shuttle at peak visitation times, and scheduling tour bus visits to the Tower would have moderate long-term beneficial effects on historic resources. 

Visual and auditory intrusions from construction would cause minor short-term adverse impacts on historic resources; removing paved parking area, establishing a pedestrian plaza, operating a shuttle at peak visitation times, and scheduling tour bus visits to the Tower would have moderate long-term beneficial effects on historic resources; moving headquarters and maintenance to outside boundary would result in a moderate long-term beneficial effect on historic road corridor. 

Visitor tion wotrict and adverse peak timnear praentrancquarters corridoverse imarea wonationation, andog towments onot be kdesign could reand comNationa

Visitor Experience — Visitors’ Experience of Monument Resources

Noise, vehicle smells, and inability to find a parking space would continue to degrade visitors’ experience of the monument’s prime resource; continuing these conditions would result in a major long-term adverse impact on visitors at peak use times; retaining campground would result in a moderate beneficial effect for visitors, many of whom value the peaceful experience of this pleasant, shady area 

Reducing crowding and traffic would cause a major beneficial effect for most visitors in peak use season; converting one campground loop to parking for towed vehicles would reduce the number of available campsites; however, the adverse effect would be minor because seldom are all sites in use, and camping in other loop still would be available. 

Managing visitation levels and using shuttle system at peak times would decrease crowding, noise, and disruption in Tower area and let visitors experience scenery without the pressures of driving; an opportunity many would enjoy and a major beneficial effect on visitor experience, especially in the peak season; removing campground would cause some visitors to lose the opportunity for an overnight experience in the monument, a long-term minor to moderate adverse impact because only a small percentage of visitors use the campground. 

Managing visitation levels and using shuttle system at peak times would decrease crowding and noise in Tower area, lower use at peak times and increase it somewhat in off-peak times, let visitors experience scenery without driving pressures, which many would enjoy; adding a shuttle staging area outside monument would let visitors transition from highway driving to entering monument; reduced traffic and crowding would be a major benefit for visitor experience, especially in peak season; retaining one campground loop, long-term favorable effect, would be minor because few people affected. 

Adding reduce it easier design whelp tracongesttinue; bbut noisstill woprime rmoderavisitors Tower tmajor bwise coretaininarea wobeneficties are 
Alternative 1 (No Action) Alternative 2 Alternative 3 (Preferred) Alternative 4 

Visitor Experience — Access and Freedom to Go at One’s Own Pace V

The Tower trail would continue to be inaccessible for some visitors, who could not have a close experience of the Tower, a major long term adverse impact for those visitors; visitors are free to come and go at their own pace in the monument, depending on availability of parking; many visitors to whom spontaneity is an important value perceive this freedom of movement as a long-term major beneficial effect. 

Redesigning Tower trail approach would improve access for a significant number of visitors, a moderate to major beneficial effect; visitors could not come to the monument spontaneously at peak times, and some would be inconvenienced by not being able to come when they would prefer; some might be unable to visit at all if they could not get reservations to fit their schedules; public response to the concept of a reservation system indicates that such a system would result in a major adverse impact on visitors because many value spontaneity highly. 

Redesigning Tower trail approach would improve access for a significant number of visitors, a moderate to major beneficial effect; visitors could not move around monument at own pace when shuttle system operating, and having a shuttle might increase cost of visiting Devils Tower; some people who prefer not to use shuttle might choose not to come; shuttle system would have a long-term major adverse impact on people who value spontaneity, privacy, and independence; impact mitigated somewhat because shuttle would operate only in peak use season, and shuttle use not required in mornings and evenings. 

Same as alternative 3. Redesig

would icant nuto majonative wand go own paof parkitaneity of movbenefic

Visitor Experience — Access to Orientation and Interpretation

Facility limitations and crowded conditions would continue, and visitors would continue to be frustrated by inability to receive orientation and interpretive information. 

Modifications at Tower area, reduced crowding, and improvements in prairie dog viewing area would enhance opportunities for ranger contact and more effective interpretation and dissemination of information. 

Modifications at Tower area, reduced crowding, and improvements in prairie dog viewing area would enhance opportunities for ranger contact and more effective interpretation and dissemination of information; new programs and more in-depth treatment of some themes at shuttle staging area and on the shuttle itself would result in major long-term beneficial effects. 

Same as alternative 3. Tower v

orientatcould bmore reavailabbuilding limitaticontinuinability orientaton interterm moimpact 
Alternative 1 (No Action) Alternative 2 Alternative 3 (Preferred) Alternative 4 

Visitor Experience — Visitor Safety

Vehicle accidents in monument have been infrequent, and risks are considered minor to moderate, but any accident would result in major adverse impact on the people involved. 

Less traffic at Tower area and eliminating prairie dog pullouts would reduce potential for vehicle-pedestrian accidents; reducing risks would have a long term beneficial effect because any accident would have a major adverse impact on the people involved. 

Less traffic in Tower area and added pullouts on both sides of prairie dog town would reduce potential for vehicle and vehicle-pedestrian accidents; reducing risks would have a moderate long-term beneficial effect because any accident would have a major adverse impact on the people involved. 

Less traffic in Tower area and along main road and eliminating prairie dog pullouts would reduce potential for accidents; realigning intersection of main road and new shuttle staging area access road would improve shuttle and visitor car safety; reducing risks would have a moderate long-term beneficial effect because any accident would have a major adverse impact on the people involved. 

Some vfrom trato manismall sptrian accould jeconsideever, anadverse involve

Socioeconomic Resources — Businesses and Neighbors

Devils Tower Trading Post and KOA General Store would continue to have a competitive advantage over other outlets farther from entrance, a moderate longterm beneficial effect on those businesses; owners of adjacent property who travel through monument might be inconvenienced by entrance station traffic at peak times, a minor adverse effect. 

Devils Tower Trading Post and KOA General Store still would have a competitive advantage over outlets farther from entrance, a moderate long-term beneficial effect on those businesses; KOA and Tower view campgrounds could gain more revenue from campers displaced from monument, a minor beneficial long-term effect on those businesses; closing west road would eliminate one access/ egress route for one landowner, but adverse effect would be negligible because at least one alternate route exists. 

Moving entrance station would allow more visitors (now prevented from stopping by peak-time traffic) to stop at adjacent businesses, a minor intermittent beneficial effect on adjacent businesses in the long term; private regional campgrounds might gain up to $102,500 per year in new business, a moderate long-term beneficial effect on local businesses. 

Adding an entrance at shuttle staging area would allow more visitors (now prevented from stopping by peak-time traffic) to stop at adjacent businesses, a minor beneficial effect on adjacent businesses in the long term; private regional campgrounds might gain up to $12,500 per year in new business, a minor, longterm beneficial effect on local businesses. 

Redesigprove trvisitors ping by adjacenmittent businesof adjacfrom adroad at beneficJoyner make adifficuladverse effect obe bene
Alternative 1 (No Action) Alternative 2 Alternative 3 (Preferred) Alternative 4 

Socioeconomic Resources — Local and Regional Economy

Monument employment and expenditures are small compared to overall county economy, so effects of monument employment and expenditures would be negligible, long-term, and beneficial. 

Negligible short-term beneficial effect on employment and minor short-term benefit for local and regional economy, including indirect effects on local businesses and tax revenues from construction; about 16 one-year jobs would add a payroll of about $500,000; total impact on Wyoming economy from construction up to $1,730,000; overall effect on region’s employment from construction would be negligible. 

Eliminating monument campground would increase area camping revenues by about $102,500 per year, a minor beneficial longterm effect on regional economy; annual taxable revenues from camping outside monument would increase about $102,500, a minor long-term beneficial effect for local taxing authorities; shuttle service would benefit local and regional employment opportunities, adding 8–29 jobs ($60,000–220,000), with indirect beneficial effects on local businesses and tax revenues; overall, shuttle service would add only a small percentage to regional jobs and earnings; construction effects on employment and local and regional economy would be beneficial, including indirect effects on local businesses and taxes; about 61 one-year construction jobs would be added, total payroll about $1.9 million; total effect on Wyoming economy from construction up to $6,574,000, adding only a small percentage to regional jobs and earnings; overall Devils Tower construction effects on regional employment, local businesses, and local and regional economy minor, beneficial, and short term; about $3.8 million circulated throughout regional economy would generate $2.090–2.774 million, a minor long-term beneficial effect. 

Converting 20 campsites to other uses would increase area camping revenues by about $2,500 per year, a minor beneficial longterm effect on regional economy; annual taxable revenues from camping outside monument would increase about $12,500, a minor long-term beneficial effect for local taxing authorities; shuttle service would benefit local and regional employment opportunities, adding 8–29 jobs ($60,000–220,000), with indirect beneficial effects on local businesses and tax revenues; shuttle service would add only a small percentage to regional jobs and earnings; construction effects on employment and local and regional economy would be beneficial, including indirect effects on local businesses and taxes; about 61 one-year construction jobs would be added, total payroll about $1.9 million; total effect on Wyoming economy from construction up to $6,574,000, adding only a small percentage to regional jobs and earnings; overall Devils Tower construction effects on regional employment, local business, and local and regional economy minor, beneficial, and short term; about $3.8 million circulated throughout regional economy would generate $2.090–2.774 million, a minor long-term beneficial effect. 

Construand locwould bindirect and tax jobs woabout $Wyomiconstruadding regionaDevils Tregionabusineseconomterm. 
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61 

AFFECTED ENVIRONMENT 
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63 

NATURAL RESOURCES 

SETTING 

Devils Tower National Monument comprises 

1,347 acres in northeastern Wyoming on the 

northwestern edge of the Black Hills. The flora 

and fauna of the monument are typical of the 

Black Hills region of South Dakota and surrounding areas in Wyoming (NPS 1992). The 

Belle Fourche River, which flows through the 

eastern side of the monument, is part of the 

Cheyenne River Basin. Devils Tower, one of the 

most conspicuous geologic features of the Black 

Hills region, is made up of igneous rock 

surrounded by sedimentary rock of the Spearfish, 

Gypsum Spring, and Sundance formations. 

SOILS 

Two general soil units found in the monument 

are (a) the floodplain/terrace soils, which consist 

primarily of very deep and nearly level loamy 

soils formed in alluvium, and (b) soils derived 

from sedimentary rock such as siltstone, sandstone, and shale that are loamy and primarily 

deep to very deep, on 6%–30% slopes. The soil 

survey for Crook County describes none of the 

soils as unusual or suitable for development. 

Most of the soils are described as having high 

erosion hazard, and some are susceptible to 

landslide. 

VEGETATION 

Ponderosa pine forests and woodlands grow in 

about 62% of the monument. Other species 

common to the pine forest are common juniper, 

Oregon grape, poverty oatgrass, needle-andthread grass, western wheatgrass, porcupine 

grass, big bluestem, green needlegrass, and 

Kentucky bluegrass. Prairie grasslands of six 

different types cover about 29% of the monument; they occur in small pockets and patches 

within the ponderosa pine community. 

About 5% of the monument supports deciduous 

woodlands. The deep, shady drainage trending 

southwest to northeast along the south leg of the 

Joyner Ridge trail is composed of pine forest 

above, grading into deciduous woodland. Species found in the deciduous woodland are bur 

oak, green ash, chokecherry, hawthorn, American plum, serviceberry, stickseed, treacle 

mustard, and others. Large cottonwoods in the 

area of the Belle Fourche River campground 

create shade and provide habitat for wildlife, 

including many birds. 

The monument is plagued by many invasive 

exotic plants, some of which the state of Wyoming has designated noxious. The National Park 

Service has developed strategies to control some 

of these species. The monument has three main 

noxious weed species of concern: Canada thistle, 

leafy spurge, and houndstongue are common 

understory species in deciduous woodlands and 

prairie edges. 

WILDLIFE 

The most common animals using or inhabiting 

Devils Tower are porcupine, white-tailed deer, 

red squirrel, least chipmunk, deer mouse, 

yellow-bellied racer, and bullsnake. Common 

breeding birds are wild turkey, mourning dove, 

hairy woodpecker, northern flicker, western 

wood-pewee, violet-green swallow, bluejay, 

black-capped chickadee, white-breasted nuthatch, red-breasted nuthatch, brown creeper, 

American robin, mountain bluebird, Townsend’s 

solitaire, solitary vireo, yellow-rumped warbler, 

ovenbird, western tanager, chipping sparrow, 

dark-eyed junco, red crossbill, and pine siskin. 

Fences along the monument boundary, development in the monument, and the presence of 

visitors and employees interrupt wildlife habitat 

and alter wildlife movement. Of these factors, 

the fences used by private landowners to restrict 

movement of their cattle probably cause the 

greatest impact on wildlife by restricting their 

movement. 
AFFECTED ENVIRONMENT

AIR QUALITY 

Devils Tower National Monument is classified 

as a class II area under the National Clean Air 

Act of 1977. In a class II area, moderate degradation of air quality is allowed. The Department 

of the Interior has identified the monument as 

possessing air quality-related values. Air quality 

is excellent in the area except during the fire 

season in the western United States, when 

smoke from distant fires contributes to regional 

haze. 

THREATENED, ENDANGERED, 

AND CANDIDATE SPECIES 

The state of Wyoming maintains no list of 

endangered, threatened, or other special species. 

Although the U.S. Fish and Wildlife Service has 

listed them as potentially occurring in the monument, black-footed ferret, mountain plover, and 

Ute ladies’ tresses have not been found in Devils 

Tower. Bald eagles do not nest at Devils Tower 

(see “Impacts Considered But Dismissed”). The 

black-tailed prairie dog is the only special species that might be affected by actions discussed 

in this document (see appendix D). 

The U.S. Fish and Wildlife Service has identified the black-tailed prairie dog (Cynomys 

ludovicianus) as proposed for listing as threatened. Devils Tower contains a black-tailed 

prairie dog town of about 34 acres along both 

sides of the main road to the Tower, and it is a 

primary visitor attraction. An interpretive trail 

goes around the prairie dog town, part of which 

is outside the trail. The primary resource management issues associated with prairie dogs are 

that they burrow into visitor use areas such as 

the campground, and visitors feed them human 

food. Some prairie dogs are killed by vehicles. 

This occurs more often during times of lower 

vehicle traffic, perhaps because a more constant 

flow of traffic keeps prairie dogs from trying to 

cross the roads. 

The colony of black-tailed prairie dogs at Devils 

Tower has never been found to carry bubonic 

plague; therefore, they could not transmit plague 

to visitors. 

WETLANDS 

The National Wetlands Inventory and map show 

two wetlands in Devils Tower National Monument. One is just south of the entrance road; the 

other is the old sewage lagoon north of the 

Tower. Other areas in the monument contain 

wetland indicator species. NPS employees surveyed these areas in June 2000 to locate wetlands. Wetland areas were found on the first 

river terrace near the primitive campground, at 

the south side of the bridge within the old river 

channel (perhaps the same as one identified in 

the national wetlands inventory), at the administrative building and nearest residence, and behind and to the west of the maintenance facility. 

See appendix E, “Statement of Findings for 

Wetlands.” 

FLOODPLAINS 

The monument’s Resources Management Plan

(NPS 1992) indicates that the Wyoming Department of Environmental Quality has classified the 

Belle Fourche River as a class II river, which 

means that the river can support game fish. The 

Wyoming Game and Fish Department classified 

the river as a warm water fishery and determined 

that the supply of aquatic food is poor (NPS 

1992). 

The Keyhole Dam and reservoir on the Belle 

Fourche River are 17.8 miles upstream from the 

monument. Belle Fourche River flows have been 

regulated since the dam’s completion in 1952. 

Water is released from Keyhole Reservoir in 

response to irrigation and flood control needs. 

River regulation has affected riparian habitats and 

geomorphological processes in the monument. 

The National Park Service does not possess water 

rights for maintaining minimum flows in the river 

(NPS 1992). 

The Army Corps of Engineers completed a flood 

analysis of the Belle Fourche River through the 

monument in 1985. In July 2000 the Water 
Natural Resources 

65 

Resources Division of the National Park Service 

performed further analysis to identify the flood 

hazard associated with specific sites. The difference in elevation between specific locations 

and the river channel was measured and compared to the estimated flood depths from the 

Corps study. The NPS analysis found that the 

maintenance facility, including fuel storage, is 

within the 500-year floodplain. The propane 

tank field near headquarters is within the 100- 

and 500-year floodplain. The Belle Fourche 

River campground is in the 100-year floodplain. 

If a 100-year flood occurred in the campground, 

the depth of water would be 2 to 4 feet and of 

moderate velocity. These conditions would be 

hazardous to campground occupants; however, 

there is a convenient escape route to higher 

ground toward the northwest. 

The Crook County Emergency Plan, part of the 

Wyoming Hazard Identification and Risk Assessment Survey of 1996, evaluates the likelihood of 

risk to people and property for many types of 

hazards. Keyhole Dam is a type 1, “high hazard” 

dam. Because it would contain floodwaters, the 

dam makes it unlikely that a flood of 100-year 

magnitude would reach Devils Tower National 

Monument. Should the dam fail, a “significant 

loss of life” and “excessive economic loss” 

would be possible, according to the definition of 

a “high hazard dam.” The emergency plan indicates that “In the event of a dam breach at Keyhole, it will be approximately three hours before 

floodwaters reach Devils Tower National 

Monument and four hours before floodwaters 

reach Hulett.” This amount of warning would 

allow visitors ample time to vacate the campground and reach nearby higher ground. 

Several potential occurrences could put campers 

in the floodplain in danger even though safety 

precautions might have been taken. If the Keyhole Dam was at capacity and rain occurred, 

causing a flood event on one or more tributaries 

of the Belle Fourche River between the dam and 

Devils Tower, the dam would not contain the 

floodwaters, and there could be flooding in the 

campground. Communications might not always 

be fully comprehended or acted upon, and miscommunications or misunderstandings could put 

visitors at risk. 

The 1987 Safety Evaluation of Existing Dams 

(SEED): Keyhole Dam report (Bureau of 

Reclamation 1987) presents a comprehensive 

assessment of the past performance and current 

condition of Keyhole Dam, including analysis of 

downstream flooding. The Emergency Preparedness Plan says the following: 

Failure or misoperation of the dam could 

result in large losses of life and property. 

The Villages of Hulett, Wyoming (population 429), and Belle Fourche, South 

Dakota (population 4,200), are located 

approximately 20 and 80 miles downstream, respectively, and would be inundated by a failure flood. Several smaller 

communities and private residences 

located in proximity to the river would 

also be included in the anticipated 

inundation zone. 
66 

CULTURAL RESOURCES 

ETHNOGRAPHIC RESOURCES 

American Indians revered the Tower during the 

historic period, and many continue to value it as 

an important sacred place. In addition, evidence 

exists that during both the historic and contemporary periods, successive generations of 

American Indian groups have returned to the 

Tower and its surrounding landscape to carry out 

traditional rituals and ceremonies. 

Devils Tower has been found eligible for listing 

as a traditional cultural property because it is 

significant for its association with the ideology, 

beliefs, rituals, and sacred narratives of several 

American Indian tribes, including the Lakota, 

Crow, Cheyenne, Arapaho, Kiowa, and Eastern 

Shoshone. Ethnohistorical data and ethnographic 

research have directly linked the site with the 

traditional beliefs of several Northern Plains 

tribes. Several versions of creation stories exist 

explaining the origins of the Cheyenne, Kiowa, 

and Arapaho. To the Lakota, the Tower is a 

sacred place of renewal and continues to be the 

subject of the Sun Dance, which is performed 

during the summer solstice. Individuals and 

groups of several tribes have conducted traditional ritual activities at the Tower, which include vision quests, sweat lodge rites, fasting, 

and praying by the Crow and Lakota; possible 

burials by the Arapaho and Cheyenne; and group 

rituals such as the Sun Dance of the Lakota. 

The Tower is also significant for its association 

with gods and demigods who figure importantly 

in tribal traditions and are central to tribal 

creation narratives. These gods and demigods 

include Mato, the Great Bear, the Lakota god 

symbolizing wisdom, who imparted the sacred 

language and ceremonies of healing to Lakota 

shamans at Devils Tower, thus making it the 

birthplace of wisdom and an important connection between the tribe and the cosmos. To the 

Kiowa, Crow, and Arapaho, the Tower is similarly associated with legends involving the Great 

Spirit, the transformation of a human to a bear, 

and the creation of the Tower itself or of 

constellations. 

Although the Tower trail, which encircles the 

base of the Tower, marks the extent of the 

current traditional cultural property determination of eligibility, it is likely that other sites 

related to the traditional cultural use of the 

Tower exist outside this boundary and will be 

the subject of further ethnographic study and 

evaluation. 

It has been determined that June is the most 

sensitive month for American Indian traditional 

religious activities at the Tower. Acknowledging 

the American Indian cultural values attached to 

Devils Tower, the National Park Service implemented a climbing management plan in 1995 

that requested that climbers voluntarily refrain 

from climbing in June each year out of respect 

for Indian traditional activities and beliefs. The 

plan also called for an expanded interpretive 

program at the monument to explain to the 

public the monument’s cultural significance to 

numerous tribes. 

The Ethnographic Overview and Assessment of 

Devils Tower National Monument, Wyoming 

(Hanson and Chirinos 1997, 33) recommends 

that, subject to consideration and approval by 

the Lakota, the National Park Service consider 

nominating the Sun Dance grounds to the 

National Register of Historic Places. Inclusion 

on the register could help ensure the protection 

of the area for the continuation of this sacred 

Lakota ceremony. 

Tribes usually bring plants and other materials 

for ceremonial use into the monument from outside. They harvest materials in the monument 

only occasionally. 

HISTORIC RESOURCES 

The visitor center area contains several historic 

resources dating back to 1917, when the original 

grade was cut for the national monument road. 
Cultural Resources 

67 

Development of monument facilities gained 

momentum during the 1930s with establishment 

of a Civilian Conservation Corps (CCC) camp at 

the monument. Between 1933 and 1938 the corps 

built a number of visitor and monument facilities, 

including the present entrance road. The visitor 

center (also known as old administration building, HS-3, and the museum) was completed in 

1935. The ranger office (also known as the 

custodian’s residence) a few hundred feet north 

of the visitor center, was initially completed in 

1931. In 1996 the garage of this former staff 

residence was converted into fully accessible 

public restrooms. The CCC-constructed firehose house is between these two buildings, and 

on July 24, 2000, the three log and stone structures collectively were listed on the National 

Register of Historic Places as the Old Headquarters Area Historic District. The CCC-era 

water delivery system and sewage disposal 

system of the visitor center area were judged 

ineligible for listing, as was the monument’s 

trail system. 

A multiple property nomination for a number of 

the monument’s cultural resources was prepared 

for listing on the National Register of Historic 

Places on July 24, 2000. These properties are the 

entrance road, the entrance station (a log structure), the Old Headquarters Area Historic 

District, and the Tower ladder. 
68 

VISITOR EXPERIENCE 

EXPERIENCING THE RESOURCES 

Since the CCC days, when the monument’s 

facilities were constructed, visitation has 

increased twentyfold (see figure 1). Annual 

visitation over the past ten years has neared or 

exceeded 400,000. Nearly three fourths of the 

year’s visitation occurs during June, July, and 

August. 

Most visitors to Devils Tower enjoy photographing the Tower, hiking area trails, camping, 

picnicking, and wildlife viewing. Approximately 

5,000 technical rock climbers scale the Tower 

each year. A large proportion of visitors walk 

the Tower trail, the main access route to view 

the Tower. Only a very small number of visitors 

hike the other trails, including the Joyner Ridge 

trail and the Red Beds trail. 

Camping is available in the monument from 

April through October. The staff reports that the 

campground is rarely filled to capacity. This 

anecdotal evidence is consistent with NPS 

statistics, which show the five-year average 

annual use of the Devils Tower campground at 

2,300 tents and 1,800 recreational vehicles, or a 

total of 4,100 occupied campsites per year. The 

capacity of the campground through the entire 

camping season is approximately 10,500 

campsites. 

In the summer of 1999 the University of Minnesota Cooperative Park Studies Unit (CPSU) 

gathered information about monument visitors. 

Survey participants represented visitors who 

come throughout the summer, not only during 

peak use times. The purpose of the study was to 

better understand the experiences that visitors 

sought and attained. Information was gathered 

on what activities visitors engaged in, their 

opinions about the quality and adequacy of 

available facilities, their ideas about strategies to 

address problems associated with management 

(such as alternative transportation systems), and 

their background characteristics. 

Participants were asked about the importance of 

various experiences. Respondents rated enjoying 

area scenery the most important experience. 

Slightly more than 80% of the respondents reported that they had met their goal of enjoying 

the scenery. About 70% of the respondents said 

that “experiencing natural quiet” was “important” or “very important.” Approximately 40% 

reported this goal fully attained; approximately 

55% reported it as “somewhat” or “moderately” 

attained. Nearly 70% of the respondents listed 

“getting away from the usual demands of life” as 

important or very important. Approximately 

60% reported that goal fully attained; about 40% 

indicated that they had “somewhat” or 

“moderately” achieved that goal. 

Existing parking and visitor facilities at the 

Tower area are too small to accommodate 

visitation during the peak season. As a result, the 

area is congested and noisy. Parking is particularly difficult for visitors with large or towed 

vehicles. Sounds and smells from autos and 

buses mask natural sounds and smells. The 

overall experience at peak use times is crowded 

and frustrating and, for many visitors, inconsistent with the significance and meaning of the 

Tower. Because there are not enough restrooms, 

some visitors spend long periods waiting in line 

to use them. 

FREEDOM TO GO AT ONE’S OWN PACE 

Visitors were surveyed about the problems that 

they encountered during their visit. About 30% 

of those questioned identified the congestion in 

the parking area at the base of the Tower and the 

visitor center as a moderate to very serious problem. Similarly, about 30% of the respondents 

listed congestion at the prairie dog town and the 

entrance station as a problem. About 60% listed 

“recreating in a safe area” as important or very 

important. About 30% reported this goal only 

somewhat or moderately attained, and about 

70% fully attained this goal. 
Visitor Experience 

69 

Most visitors come to Devils Tower as a part of 

a larger regional travel itinerary. Many are en 

route between Mount Rushmore National Monument and Yellowstone National Park. This 

leaves them with limited time to spend at Devils 

Tower, and many value the ability to keep their 

time spent at the monument very flexible. 

ORIENTATION AND INTERPRETATION 

In the 1999 visitor study results, visitors highly 

valued the interpretation of monument resources. Between 70% and 85% of respondents 

indicated that learning about geology, natural 

history, and cultural history were important or 

very important to their visit. Responses that 

these goals were only somewhat to moderately 

attained ranged from about 50% to about 65% of 

the respondents. Between 30% and 50% of the 

respondents rated these goals as fully attained. 

Interpretive media at the visitor center are outdated and ineffective. The facility is too small to 

accommodate orientation and interpretive functions. Outside the visitor center, in the Tower 

area, interpretive programs are hampered by 

inadequate space and disruption from crowding, 

noise, and traffic. Wayside exhibits and 

brochures at the prairie dog town provide interpretive information, and sometimes roving interpreters are stationed in the area. The staff also 

offers interpretive programs at the amphitheater 

near the Belle Fourche River campground. In 

summer visitors are contacted at the entrance 

station and at the visitor center. Some stop at the 

administrative headquarters to ask questions. In 

winter, when the visitor center is closed and the 

entrance station is not staffed, headquarters 

serves as the only visitor contact point. 

SAFETY 

Traffic congestion in the monument presents the 

potential for vehicle accidents, which could 

occur in the roadway and parking areas at the 

base of the Tower and along the road in the 

prairie dog town. Although accidents have been 

infrequent, if traffic congestion continues to 

worsen, the likelihood of accidents could 

increase. 

71 

SOCIOECONOMIC RESOURCES 

BUSINESSES AND MONUMENT 

NEIGHBORS 

There are several private businesses at or near the 

monument entrance, including gift shops and a 

privately operated campground. A bed and 

breakfast establishment is on private land just 

outside the northwest corner of the monument. 

Most other adjacent lands are ranches. 

Two private landowners cross the monument to 

reach their property. One of them passes through 

as many as three or four times a day. 

LOCAL AND REGIONAL ECONOMY 

The economy in the Devils Tower National 

Monument area is based mainly on agriculture, 

sheep and cattle ranching, cut timber processing 

and tourism. The nearest town, Hulett, 10 miles 

northeast of the monument, has a population of 

429 (NPS 1992). Other Wyoming towns in the 

vicinity are Sundance (28 miles southeast) and 

Moorcroft, (37 miles southwest). 

The main local attractions are Devils Tower 

National Monument, the Bear Lodge District of 

the Black Hills National Forest, and the 

November deer hunting season. Goods, services, 

and accommodations are available at several of 

the local towns. 

March 2000 unemployment rates in the Devils 

Tower region were higher than the statewide 

unemployment rate of 4.0% (4.4% in Campbell 

County, 6.8% in Crook County, and 5.4% in 

Weston County). This is not considered 

abnormal for the region. It is also important to 

note that regional unemployment rates typically 

decline with seasonal employment in spring and 

summer, when most construction takes place. 
72 

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73 

ENVIRONMENTAL CONSEQUENCES 
74 

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75 

METHODOLOGY FOR ANALYZING IMPACTS 

The planning team based this impact analysis 

and the conclusions in this part largely on the 

review of existing literature and studies, information provided by experts in the National Park 

Service and other agencies, and Devils Tower 

staff insights and professional judgment. The 

team’s method of analyzing impacts is further 

explained below. It is important to remember 

that all the alternatives include mitigating measures to minimize or avoid impacts. If mitigating 

measures described in the alternatives chapter 

were not applied, the potential for resource 

impacts and the magnitude of those impacts 

would increase. 

Effects can be direct, indirect, or cumulative. 

Direct effects are caused by an action and occur 

at the same time and place as the action. Indirect 

effects are caused by the action and occur later 

or farther away, but are still reasonably foreseeable. Cumulative effects are the impacts on the 

environment that result from the incremental 

impact of the action when added to other past, 

present, and reasonably foreseeable future 

actions, regardless of what agency (federal or 

nonfederal) or person undertakes such other 

action. Cumulative effects can result from 

individually minor, but collectively significant, 

actions taking place over a period of time. 

Impact intensity is the degree to which a resource would be is positively or negatively 

affected. The criteria that were used to rate the 

intensity of the impacts for each resource topic 

are presented below under each topic heading. 

They are also shown in table 6, at the end of the 

“Methodology” section. 

Impact duration refers to how long an impact 

topic would last. For the purposes of this 

document, the planning team used the following 

terms to describe the duration of the impacts: 

Short-term: The impact would last less than 

one year, normally during construction and 

recovery. 

Long-term: The impact would last more 

than one year, normally from operations. 

The normal life of a general management plan is 

assumed to be 15 to 20 years. 

PROJECTS THAT MAKE UP THE 

CUMULATIVE IMPACT SCENARIO 

A cumulative impact is described in regulation 

1508.7 of the Council on Environmental Quality 

(CEQ), as follows: 

A “cumulative impact” is the impact on 

the environment which results from the 

incremental impact of the action when 

added to other past, present, and reasonably foreseeable future actions regardless 

of what agency (Federal or non-Federal) or 

person undertakes such other actions. 

Cumulative impacts can result from 

individually minor but collectively 

significant actions taking place over a 

period of time. 

To determine potential cumulative impacts, 

projects in the area surrounding Devils Tower 

were identified. The area included Crook 

County, Wyoming, and nearby lands administered by the state, the Bureau of Land Management, and the U.S. Forest Service. Projects were 

determined by meetings and phone calls with 

county and town governments and federal land 

managers. Potential projects identified as 

cumulative actions included any planning or 

development activity that was currently being 

implemented or would be implemented in the 

reasonably foreseeable future. 

These cumulative actions are evaluated in the 

cumulative impact analysis in conjunction with 

the impacts of each alternative to determine if 

they would have any additive effects on a particular natural, cultural, visitor use, or social 

resource. Because most of these cumulative 

actions are in the early planning stages, the 

evaluation of cumulative effects was based on a 

general description of the project. 
ENVIRONMENTAL CONSEQUENCES

Past Actions 

The following past actions could contribute to 

cumulative effects. 

Agriculture and ranching outside the monument, mostly ranching, have greatly reduced 

native prairie plants and animals in favor of 

cattle and sheep and the vegetation they prefer 

for food. This in turn has led to the alteration of 

soil and the loss of soil through erosion. Fences 

have been built near the monument boundaries 

and elsewhere to limit the movement of animals, 

principally cattle and sheep. Along with ranching has come the use of herbicides to kill unwanted plant species and the introduction of 

exotic species of plants. The monument’s use of 

herbicides to control exotics contributes to 

overall herbicide use in the area 

Between October 1999 and February 2000, 9 of 

11 state fish and wildlife agencies within blacktailed prairie dog range signed a memorandum 

of understanding on the conservation and management of black-tailed prairie dogs in North 

America. The memorandum text includes this 

statement: 

“The affected State Fish and Wildlife 

Agencies agree that cooperative efforts are 

necessary to collect and analyze data on 

black-tailed prairie dogs and their habitats 

so that comprehensive state plans may be 

formulated and implemented to maintain 

the broadest distribution and greatest 

abundance possible within the fiscal 

realities of the state agencies and cooperating partners.

Among the actions for carrying out the program 

is the “development of cooperative partnerships 

with interested individuals, and private, state, 

tribal, and federal land managers.” These efforts 

could lead to incentives that might induce ranchers to have prairie dog colonies on their lands 

(see appendix F). 

The Keyhole Dam and reservoir are 17.8 miles 

upstream from the monument. Belle Fourche 

River flows have been regulated since the dam’s 

completion in 1952. Water is released from Keyhole Reservoir in response to irrigation and flood 

control needs. River regulation has affected 

riparian habitats and geomorphological processes 

in the monument. The National Park Service does 

not possess water rights for maintaining minimum 

flows in the river (NPS 1992). 

Current and Future Actions 

Current actions and those projected for the 

future also could contribute to cumulative 

effects. 

The Black Hills National Forest, the monument’s largest land managing neighbor, has the

Land and Resource Management Plan for the 

Black Hills National Forest. The forest encompasses 1.23 million acres, including the 

Bearlodge Mountains in northeastern Wyoming 

and most of the Black Hills in western South 

Dakota. In 1996 the Final Environmental Impact 

Statement for the Land and Resource Management Plan for the forest was completed. The 

purpose of this plan is to direct all natural resource management activities in the forest. 

Land around Devils Tower National Monument 

could be developed for residential, business, or 

other use. No plans to do so are known at this 

time. 

A National scenic byway was proposed by the 

U.S. Forest Service to be established in the vicinity of the national monument. The proposal 

has been withdrawn because of opposition from 

local citizens. 

Repaving the main monument road is being 

considered. The National Park Service is preparing an environmental assessment about 

repaving 2.8 miles of Wyoming Highway 110 

between the monument boundary and the visitor 

center at the Tower. The road would be widened 

1 foot on each side, to a width of 22 feet, from 

the eastern edge of the prairie dog town to the 

Tower. The roadway would remain on its existing previously disturbed bench, and the centerline would remain in its current position along 

most of the road’s length. However, in several 

areas the road would be shifted slightly to avoid 
Methodology for Analyzing Impacts 

77 

construction impacts on historic culvert headwalls. One historic culvert would be buried in 

place, and drains would be added to correct 

erosion problems adjacent to the culvert. The 

visitor center parking area at the end of WY 110 

would be resurfaced, and the oversize-vehicle 

parking area immediately north of the visitor 

center would be widened and paved. Parking lot 

curbs would be modified to provide access for 

people with disabilities. 

IMPAIRMENT OF RESOURCES 

In addition to determining the environmental 

consequences of the preferred alternative and 

other alternatives, section 1.4 of NPS Management Policies 2001 (NPS 2001a) requires that 

potential effects be analyzed to determine 

whether or not proposed actions would impair 

the resources of the unit. 

The fundamental purpose of the national park 

system, established by the Organic Act and 

reaffirmed by the General Authorities Act, as 

amended, begins with a mandate to conserve 

resources and values. National Park managers 

must always seek ways to avoid or minimize, to 

the greatest degree practicable, adverse impacts 

on the resources and values. However, the laws 

do give the National Park Service the management discretion to allow impacts on the resources and values when necessary and appropriate 

to fulfill the purposes of a park, as long as the 

impact does not constitute impairment of the 

affected resources and values. Although Congress has given the National Park Service this 

management discretion, that discretion is limited 

by the statutory requirement that the National 

Park Service must leave the resources and values 

unimpaired unless a particular law directly and 

specifically provides otherwise. 

The prohibited impairment is an impact that, in 

the professional judgment of the responsible 

NPS manager, would harm the integrity of the 

resources and values, including the opportunities 

that otherwise would be present for the enjoyment of those resources or values. An impact on 

any resource or value may constitute an impairment. An impact would be most likely to constitute an impairment if it affected a resource or 

value whose conservation would be (a) necessary to fulfill specific purposes identified in the 

establishing legislation or proclamation of the 

park, (b) key to the natural or cultural integrity 

of the park or to opportunities to enjoy it, or (c) 

identified as a goal in the park’s general management plan or other relevant NPS planning 

documents. Impairment might result from NPS 

activities in managing a park, visitor activities, 

or activities undertaken by concessioners, contractors, and others operating in the park. In this 

document, a determination on impairment is 

made in the conclusion section for each impact 

topic in the “Environmental Consequences” 

chapter. 

Natural Resources 

The impact topic of natural resources includes 

discussions of the effects on the integrity of 

natural systems, including soils, vegetation, 

wildlife, air quality, and natural sound; threatened, endangered, and sensitive species; and 

wetlands and floodplains. Threatened, endangered and sensitive species are those listed 

by the U. S. Fish and Wildlife Service as threatened, endangered, or proposed for listing under 

the Endangered Species Act. Sensitive species 

also include state-listed plants and animals; 

however, Wyoming does not maintain a list of 

sensitive species. Wetlands are “ . . . lands where 

saturation with water is the dominant factor determining the nature of soil development and the 

types of plant and animal communities living in 

the soil and on its surface” (USFWS 1979). 

Floodplains are defined by the NPS Floodplain 

Management Guideline (1993a) as “the lowland 

and relatively flat areas adjoining inland and 

coastal waters, including flood-prone areas of 

offshore islands, and including, at a minimum, 

that area subject to temporary inundation by a 

regulatory flood.” 

Information on known resources was compiled. 

Where possible, map locations of sensitive 

resources were compared with the locations of 

proposed developments and modifications. Pre-
ENVIRONMENTAL CONSEQUENCES

dictions about short-term and long-term site impacts were based on previous studies of visitor 

and facilities development impacts on natural 

resources. Sociological studies comparing the 

deterrent effects of signs versus ranger presence 

on sites were also considered in this analysis. 

The definitions presented below assume that 

mitigation would be implemented. For this 

document, the planning team qualitatively 

evaluated the impact intensity for natural 

resources, except threatened and endangered 

species, as follows: 

Negligible: The impact would be localized 

and not detectable, or would be at the 

lowest levels of detection. 

Minor: The impact would be localized and 

slightly detectable but would not affect 

overall structure of any natural community. 

Moderate: The impact would be clearly 

detectable and could have an appreciable 

effect on individual species, communities, 

and/or natural processes. 

Major: The impact would be highly noticeable and would have a substantial influence 

on natural resources, including impacts on 

individuals or groups of species, communities, and/or natural processes. 

The following categories were used to evaluate 

the potential impacts on threatened, endangered, 

or proposed species: 

Negligible: The action would result in a 

change to a population or individuals of a 

species that would be so small that it would 

not be of any measurable or perceptible 

consequence to the population or other 

changes that would be so small that they 

would not be measurable or perceptible. 

Minor: The action would result in a change 

to a population or individuals of a species 

that, if measurable, would be small and 

localized, or other changes that would be 

slight but detectable. 

Moderate: The action would result in a 

change to a population or individuals of a 

species that would be measurable but 

localized. 

Major: The action would result in a change 

to a population or individuals of a species 

that would be measurable and have a 

permanent consequence to the population. 

Cultural Resources 

In this impact analysis, cultural resources consist 

of two property types, ethnographic and historic 

resources. The topics of archeological resources 

and cultural landscapes were dismissed (see 

“Topics Dismissed from Further Consideration” 

in the “Alternatives” chapter. 

Section 106 of the National Historic Preservation Act requires that federal agencies take into 

account the effects of their undertakings on 

properties included on or eligible for inclusion 

on the National Register of Historic Places. 

Agencies also must give the Advisory Council 

on Historic Preservation a reasonable opportunity to comment. This also applies to properties not formally determined eligible, but 

which are considered to meet eligibility criteria. 

All NPS undertakings affecting historic properties are subject to the provisions of the 1995 

programmatic agreement among the National 

Park Service, the Advisory Council on Historic 

Preservation, and the National Conference of 

State Historic Preservation Officers. Applicable 

legislation and regulations and specific management procedures regarding cultural resources are 

detailed in the National Park Service’s Cultural 

Resource Management Guideline (Director’s 

Order No. 28, 1998). 

The assessment of impacts on cultural resources 

is based on the regulations of the Advisory 

Council on Historic Preservation (36 CFR 800). 

These include: (1) identifying the areas that 

could be affected, (2) comparing that location 

with the location of resources listed, eligible, or 

potentially eligible for listing on the National 

Register of Historic Places, (3) identifying the 
Methodology for Analyzing Impacts 

79 

extent and type of effect, (4) assessing those 

effects according to procedures established in 

the Advisory Council’s regulations, and (5) 

considering ways to avoid, reduce, or mitigate 

adverse effects. 

In this document, effects on cultural resources 

are described in terms consistent with the 

regulations of the Council on Environmental 

Quality (CEQ) for implementing the National 

Environmental Policy Act (NEPA). The National Park Service intends to comply with 

requirements of NEPA and section 106 of the 

National Historic Preservation Act. 

CEQ regulations require that the impacts of 

alternatives and their component actions be 

disclosed. Consistent with those regulations, the 

analysis of individual actions includes identification (for example, the degradation or disturbance of ethnographic resources caused by visitor 

activities) and characterization of impacts. Characterization includes a discussion of the type 

(beneficial or adverse), duration (short-term, 

long-term, or permanent), and intensity of 

impact. The intensity of impacts in the cultural 

resource analysis is rated by the following terms. 

Negligible: The impact would be barely 

perceptible and not measurable; it would be 

confined to small areas or would affect a 

single contributing element of a larger 

national register district with low data 

potential. 

Minor: The impact would be perceptible 

and measurable, would remain localized 

and confined to a single contributing element of a larger national register district 

with low to moderate data potential, or 

would not affect the character-defining 

features of a national register eligible or 

listed property. 

Moderate: The impact would be sufficient 

to cause a change in a character-defining 

feature but would not diminish the integrity 

of the resource to the extent that its national 

register eligibility would be jeopardized, or 

it generally would involve a single or small 

group of contributing elements with 

moderate to high data potential. 

Major: the impact would result in substantial and highly noticeable change in 

character-defining features, which would 

diminish the integrity of the resource to the 

extent that it would no longer be eligible for 

listing on the National Register of Historic 

Places, or it would involve a large group of 

contributing elements and/or individually 

significant property with exceptional data 

potential. 

Moreover, CEQ calls for a discussion of the 

“appropriateness” of mitigation. DO-12, the 

National Park Service’s NEPA guideline, 

requires an analysis of the effect of mitigation. 

The resultant reduction in intensity from mitigation is an estimate of the effectiveness of 

mitigation under NEPA. 

For NEPA purposes, the mitigation discussed in 

this document includes avoiding, minimizing, 

rectifying, or compensating for the impact. 

Every effort would be made to avoid adversely 

affecting cultural resources through avoidance. 

When avoidance would not be feasible or prudent and the undertaking might result in adverse 

impacts, a number of other mitigative measures 

could be employed. 

Mitigative measures might include applying the 

Secretary of the Interior’s Standards, developing and implementing design standards to 

ensure compatibility, using design methods such 

as screening with vegetation when placing new 

facilities in a historic district, and documenting 

according to standards of the Historic American 

Buildings Survey/Historic American Engineering Record (HABS/HAER) as defined in the 

October 1, 1997, Reengineering Proposal. For 

archeological resources, mitigation would include recovering information that would make 

sites eligible for inclusion on the National 

Register of Historic Places. When demolishing a 

historic structure was proposed, the architectural 

elements and objects might be salvaged for reuse 

in rehabilitating similar structures, or the elements and objects might be added to the monu-
ENVIRONMENTAL CONSEQUENCES

ment’s museum collection. In addition, the 

National Park Service could prepare the story of 

the history of the alteration of the human environment and the reasons for that alteration, and 

that story could be used in interpretation. 

Under section 106 of the National Historic 

Preservation Act, an impact on historic properties is either adverse or not adverse. Adverse 

effects under section 106 may also be partially 

or completely mitigated; however, unlike NEPA 

analysis, the effect cannot be reduced and 

remains an adverse effect. To comply with this 

difference in terminology for section 106, an 

additional “Section 106 Summary” discussion 

has been added for each subheading under the 

impacts on cultural resources for each alternative. The require determination of effect for the 

undertaking (implementation of the alternative) 

is included in the “Section 106 Summary” 

sections for each alternative. 

Effects under both the National Environmental 

Policy Act and the National Historic Preservation Act are considered adverse when they 

diminish the significant characteristics of a 

historic property. 

The National Park Service will continue to 

consult with affiliated Indian tribes to develop 

appropriate mitigation strategies for effects on 

ethnographic resources. Such strategies could 

include continuing to provide access to traditional use or spiritual areas and screening new 

development from traditional use areas. 

Visitor Experience 

The discussions of the visitor experience in this 

document cover the effects on: visitors’ ability 

to experience the monument’s primary resources 

and their natural setting (including vistas, natural 

sounds and smells, and wildlife); overall visitor 

access to the monument, and the freedom to 

experience the resources at one’s own pace. 

Also discussed are visitors’ access to appropriate 

orientation and interpretive information and the 

effects of proposed actions on visitors’ safety. 

Information gathered in the survey discussed 

under “Visitor Experience” earlier in this 

chapter was used, along with public input during 

the planning process, to evaluate the potential 

impacts of each alternative on visitors. 

Public responses to newsletters have supported 

the findings of the University of the University 

of Minnesota survey. Visitors have expressed 

concern about crowding and scenic quality. 

Freedom to experience the monument on their 

own schedules and at their own pace has 

frequently been mentioned as an important 

factor in their visit. 

Consultation with American Indian groups has 

revealed that these groups are concerned about 

crowding and noise near the Tower, and that 

they want to participate in traditional cultural 

activities with a minimum of visual and auditory 

intrusions. 

For analysis purposes, impact intensities for 

visitor experience impact topics have been 

defined as follows: 

Negligible: The impact would be barely 

detectable, would not occur in primary 

resource areas, or would affect few visitors. 

Minor: The impact would be slight but 

detectable, would not occur in primary 

resource areas, or would affect few visitors. 

Moderate: The impact would be readily 

apparent, would occur in primary resource 

areas, or would affect many visitors. 

Major: The effect would be severely adverse or exceptionally beneficial, would 

occur in primary resource areas, or would 

affect the majority of visitors. 

Socioeconomic Resources 

The discussion of socioeconomic effects consists 

of the effects of each alternative on: businesses, 

access to private property, and the local and 

regional economy. The following information 
Methodology for Analyzing Impacts 

81 

and assumptions were used to analyze impacts 

on local businesses. 

First, an estimate was made of the amount of 

revenue the monument would receive in one 

year from camping. Next, an estimate was made 

of the revenue that the KOA campground near 

Devils Tower would receive in one year for the 

same number of stays. 

Camping at Devils Tower. NPS data show the 

use rates for the Devils Tower National Monument campgrounds from 1994 to 1999 (see table 

3). Using this information, the following estimate was made: 4,100 occupied sites (2,300 

tents and 1,800 recreational vehicles) per year. 

The estimated number of occupied tent and recreational vehicle (RV) sites was used with the 

estimate of camping costs at Devils Tower and 

KOA to determine the amount of revenue the 

monument would lose from removing campsites, 

the amount of revenue other campgrounds might 

receive if campers who were displaced from the 

monument chose to camp near Devils Tower, 

and the amount of revenue on which local 

authorities would collect tax (tables 4 and 5, 

below). 

Camping Costs at Devils Tower and KOA. 

According to data on the KOA web site 

(www.koa.com), camping rates at the Devils 

Tower KOA are as shown in table 4. 

The cost of camping at Devils Tower National 

Monument, including entry fees (according to 

data on the National Park Service web site — 

www.nps.gov), is shown in table 5. 

According to these data, the estimated nightly 

camping fees are $25 at KOA and $20 at Devils 

Tower National Monument. This analysis also 

relies on anecdotal evidence provided in public 

comment and by the monument staff. 

The campground at Devils Tower has revenues 

of roughly $82,000 per year (4,100 occupied 

sites per year multiplied by $20 per site). 

If all the campers who camp at Devils Tower 

National Monument camped at KOA, that 

campground’s revenues would increase by 

$102,500 per year (4,100 x $25 per site).

Effects on Local and Regional Economy. The 

following information and assumptions were 

used to analyze impacts on the local and 

regional economy: 

These facts were used to translate construction 

spending into number of jobs created and to 

change jobs into changes in income and dollar 

input into the local and regional economy.

TABLE 3: OVERNIGHT STAYS AT DEVILS TOWER NATIONAL MONUMENT

 Number of Tents 

Number of 

Recreational Vehicles 

Number of 

Tent Campers 

Number of 

RV Campers 

1995 4,900 5,583 16,468 19,010 

1996 2,811 2,116 9,368 6,951 

1997 2,425 1,892 7,982 6,201 

1998 1,960 1,669 6,516 5,505 

1999 2,442 1,838 8,056 5,999 

 

Range 1,960–4,900 1,669–5,583 6,516 – 16,468 5,505 – 19,010 

Median 2,442 1,892 8,056 6,201 

Mean (1995–1999) 2,908 2,620 9,678 8,733 

Mean (1997–1999) 2,276 1,800 7,518 5,902 

Impact Analysis 

Estimate 2,300 1,800 7,500 6,000 
ENVIRONMENTAL CONSEQUENCES

TABLE 4: CAMPING COSTS

 AT KOA NEAR DEVILS TOWER

Tent site (2 adults) $20.00 

RV site $23.00–28.00 

Kamping Kabin $35.00 

Extra people: Child (17 and under) 

 Adult (18 and over) 

$ 2.50 each 

$ 3.50 each 

TABLE 5: CAMPING COSTS

AT DEVILS TOWER NATIONAL MONUMENT

Entry fee (automobile) $ 8.00 

Entry fee (per person)e $ 3.00 

Camping fee (tent or RV) $12.00 

Construction Jobs per $1 Million in 

Construction Spending. According to the 

Wyoming Department of Employment, 

construction jobs pay approximately $13 per 

hour ($12.41 per hour). 

• Working 50 weeks at 40 hours per week 

results in 2,000 annual hours. 

• Two thousand hours at $13 per hour equals 

$26,000 per year. 

• Assuming benefits equal to 25% of annual 

wages would add $6,500 to the cost of each 

laborer, resulting in a total salary and 

benefits package of $32,500 per construction 

job. 

• Based on industry standards, 50% of 

construction spending is for labor; therefore, 

for $1 million in construction spending, 

$500,000 would go to labor. 

• At $32,500 per job, $500,000 in labor 

spending (or $1 million in total construction 

spending) would result in 15.4 jobs. 

• This study uses 16 jobs per $1 million in 

construction spending to account for 

rounding up to $13 per hour in construction 

wages. 

For analysis purposes, the intensities for impacts 

on businesses, access to private property, and the 

local and regional economy will be defined as 

follows: 

Negligible: The impact would not be 

detectable and would have no discernible 

effect on the socioeconomic environment. 

Minor: The impact would be slightly 

detectable but would not affect the overall 

socioeconomic environment. 

Moderate: The impact would be clearly 

detectable and could have an appreciable 

effect on the socioeconomic environment. 

Major: The impact would have a 

substantial, highly noticeable, potentially 

permanent influence on the socioeconomic 

environment. 

The criteria that were used to rate the intensity 

of the impacts for each resource topic are 

presented in table 6. 
TABLE 6: CRITERIA FOR RATING SEVERITY OF IMPACTS

 Natural Resources 

Threatened, Endangered, or 

Candidate Species Cultural Resources Visitor Experience 

Short-term = Less than one year, normally during construction and recovery. Long-term = Longer than one year, normally from operations. 

Cumulative impact = Incremental impact of an action added to past, present, and reasonably foreseeable future actions, regardless of what agency oother actions. Can result from individually minor but collectively significant actions taking place over a period of time. 

Negligible 

Impact localized and not detectable, or at lowest levels of detection 

Change in a population or individuals of a species; consequences to population not measurable or perceptible, or other changes not measurable or perceptible 

Impact barely perceptible and not measurable; confined to small areas or affecting a single contributing element of a larger national register district with low data potential 

Impact barely detectable, not in primary resource areas or would affect few visitors 

Minor 

Impact localized and slightly detectable but would not affect overall structure of any natural community 

Change in a population or individuals of a species, if measurable, would be small and localized, or other changes would be slight but detectable 

Impact perceptible and measurable, but would remain localized; affecting a single contributing element of a larger national register district with low to moderate data potential, or would not affect characterdefining features of a national register eligible or listed property 

Impact slight but detectable, not in primary resource areas or would affect few visitors

Moderate 

Impact clearly detectable; could affect individual species, communities, or natural processes appreciably 

Change in a population or individuals of a species measurable but localized 

Impact sufficient to change a characterdefining feature but would not diminish resource’s integrity enough to jeopardize its national register eligibility, or it generally would involve a single or small group of contributing elements with moderate to high data potential 

Impact readily apparent, in primary resource areas or would affect many visitors 

Major 

Impact highly noticeable and would substantially influence natural resources, e.g. individuals or groups of species, communities, or natural processes 

Change in a population or individuals of a species measurable and would result in permanent consequence to the population 

Substantial, highly noticeable change in character-defining features would diminish resource’s integrity so much that it would no longer be eligible for national register listing, or it would involve a large group of contributing elements or individually significant properties with exceptional data potential 

Effect severely adverse or exceptionally beneficial, in primary resource areas, or would affect most of visitors 
84 

EFFECTS OF ALTERNATIVE 1 (NO ACTION) 

NATURAL RESOURCES 

Soils 

Alternative 1 would not result in any soil disturbance except that caused by ongoing maintenance such as road grading and revegetation. 

All the areas that would be affected have been 

previously disturbed. Sites with soil disturbance 

would undergo accelerated erosion, at least 

temporarily, until drainage structures were fully 

operational and vegetation had recovered in 

cleared areas. 

Maintenance activity would be restricted to the 

minimum area required for rehabilitation. To 

conserve available organic matter, topsoil would 

be retained and replaced where possible. To 

minimize the soil erosion created by foot traffic, 

most visitor developments have been constructed where the slopes are less than 15%. Where 

heavy foot traffic was expected, trails have been 

paved , and visitors are encouraged to stay on 

maintained trails. Trail rehabilitation would include special design methods in areas where the 

slope is high and soils are easily eroded. Because a relatively small area would be affected 

and mitigative measures such as prompt revegetation and silt fences would be employed, these 

adverse impacts would be minor and short term. 

The soil survey for Crook County does not list 

soils in the monument as suitable for development. Most have a high erosion hazard, and 

some are susceptible to landslide. Under the noaction alternative, 36 acres of the 1,347 in the 

monument would continue to be occupied by 

development (less than 3%). Development has 

wholly or partially eliminated the direct inflow 

of water and diverted precipitation from natural 

drainages. Foot traffic would continue to compact soils, decrease permeability, alter soil 

moisture, and diminish water storage capacity, 

increasing erosion. Prolonged trampling would 

decrease vegetation and expose the soil to the 

erosive effects of rainfall. Runoff not collected 

and diverted to natural drainages would overflow on adjacent areas, increasing the local soil 

moisture regime. Increased runoff in these areas 

would result in localized increases in erosion, 

changes in soil nutrient transport and changes in 

the natural composition of vegetation. Altered 

vegetative composition would create changes in 

soil chemistry. These impacts have already 

occurred to some degree because all the areas 

involved have been disturbed; consequently, soil 

erosion, soil nutrient transport, and vegetation 

composition from hardened surfaces would be 

negligible, long-term adverse impacts. 

Conclusion: Soil disturbance from ongoing 

maintenance would be restricted to the minimum 

required for rehabilitation. Short-term impacts 

on soil erosion would be minor and adverse. The 

adverse impacts on soils from ongoing visitor 

use (compaction, decreased permeability, 

decreased moisture, erosion) would be long-term 

and negligible. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Vegetation 

Alternative 1 would not result in any disturbance 

of vegetation except that caused by ongoing 

maintenance such as road grading and revegetation. Because most of these maintenance 

activities would occur over small areas that have 

been previously disturbed, this would be a 

negligible long-term adverse impact. 

Clearing some vegetation during maintenance 

could increase the relative abundance of plant 

species that invade disturbed areas. Increased 
Effects of Alternative 1 (No Action) 

85 

erosion at these areas could expose root systems, 

subsequently leading to the death of more mesic 

plants (those needing a moderate amount of 

water). 

The preservation of a remnant of a prairie remnant in the northwest corner of the monument 

would continue. This would be a minor beneficial long-term effect on the prairie remnant. 

Conclusion: Maintenance and ongoing 

visitor use would affect vegetation by leading to 

changes in the relative abundance of species, the 

death of some plants from the exposure of root 

systems, the trampling and death of some plants, 

and the resultant changes in species composition. These would be negligible to minor longterm adverse effects. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wildlife 

There would be no change in the amount of 

wildlife habitat in the monument under alternative 1. Development would continue to 

occupy 36 acres. 

Wildlife habitat would continue to be fragmented by roads, trails, and facilities. Wildlife 

habits and movement would continue to be 

altered by employees and visitors. People still 

would concentrate at the base of the Tower, at 

the picnic, campground, trailer dropoff, and 

amphitheater, and in the administrative area. 

This would disturb wildlife and degrade habitat. 

These intermittent adverse impacts would be 

minor and long term. 

Visitors using the northwest area or the special 

permit camping area a few times a year would 

continue to cause an intermittent minor disruption of wildlife. This intermittent adverse impact 

would be negligible and long term. 

Vehicle traffic would still proceed at low speeds 

so that the incidence of collisions with wildlife 

would continue to be relatively low. 

Conclusion: Overall, the interruption of 

wildlife habitat, the alteration of wildlife movement, and vehicular collisions with wildlife from 

this alternative would be a long-term minor 

adverse impact. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National Monument, (2) key to the natural or cultural integrity 

of the monument or to opportunities for visitor 

enjoyment, or (3) identified as a goal in the 

monument’s General Management Plan or other 

relevant NPS planning documents.

Air Quality 

Air quality at the entrance station is degraded 

during peak visitation periods when visitor 

vehicles must wait in line. Air quality degradation also occurs at the base of the Tower when 

visitor vehicles circle the parking area repeatedly, searching for a place to park. These situations would continue under alternative 1. Tour 

buses idling while parked also degrade the air 

quality. Continuing this situation would result in 

a long-term moderate adverse impact during 

peak times. Because visitors would notice the air 

degradation, the effect would be moderate and 

adverse, occurring from approximately 9 A.M. 

until 7 P.M. from Memorial Day through the 

third week in September. 

Visitor vehicles would continue to degrade the 

air quality at the picnic, campground, trailer 

dropoff, and amphitheater areas. This impact 
ENVIRONMENTAL CONSEQUENCES

would be minor because it would be localized 

and intermittent, as vehicles would come and go. 

The effect would be long term, occurring primarily from 9 A.M. to 7 P.M. from Memorial Day 

through the third week in September. 

When the special permit camping area was in 

use, the air quality would continue to be degraded by some group activities and campfires. 

This infrequent adverse effect would last only 

for several days about three times a year. 

Visitor vehicles and employee activities, including maintenance, would continue to degrade the 

air quality at the administrative area. This negligible to minor impact would continue to occur 

sporadically throughout the year. 

Conclusion: The adverse impacts on air 

quality and natural sound generally would be 

minor and long term. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Threatened, Endangered, and 

Candidate Species 

Many natural resource experts consider prairie 

dogs a keystone species in the grassland ecosystem. Their presence indicates how healthy 

that ecosystem is. However, ranchers often view 

them as pests. The closeness of the picnic, 

campground, trailer dropoff, and amphitheater 

might limit the expansion of the prairie dog 

town. It is not known whether the visitor use 

area would be intermittently or perennially 

suitable habitat for prairie dogs. A high water 

table might make that area unsuitable in wet 

years. At present, prairie dogs moving into the 

visitor use area are moved out again because of 

concerns about visitor safety (bites). This would 

be a long-term minor adverse impact on the 

prairie dog town at Devils Tower. It is especially 

important to retain the population in the monument because this is the only prairie dog town 

within 7 miles. 

At the prairie dog town, the habituation of wildlife to unnatural foods would continue. The 

monument staff would continue to try to reduce 

the feeding of human food to prairie dogs by 

educating visitors. This would be a long-term 

minor beneficial effect on prairie dogs. 

Conclusion: Overall, limiting the size of 

the prairie dog town by preventing it from 

spreading into other suitable habitat in the 

monument would be a minor long-term adverse 

impact on prairie dogs. The beneficial effect of 

retaining the prairie dog town in the monument 

would be partially offset by the negative regional effect of preventing the prairie dog colony 

from expanding. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wetlands 

In the no-action alternative the administrative 

building and nearest residence would continue to 

occupy a wetland area. Maintaining the monument road also would continue to modify a wetland area. Thus, the natural functioning of these 

wetlands would continue to be compromised. 

Because the area involved would be less than 1 

acre, this continuing adverse impact on wetlands 

would be long term and minor. 
Effects of Alternative 1 (No Action) 

87 

The wetland on the first river terrace near the 

special permit campground might be trampled 

by campers trying to reach the river. However, 

since such special permit camping takes place 

only once or twice a year, this continuing 

adverse impact on wetlands would be negligible, 

intermittent, and long-term. 

Conclusion: Maintaining the administration building and employee residence in wetlands and diverting runoff away from these 

wetlands would continue a minor long-term 

adverse effect on wetlands. Trampling of a 

wetland near the special permit campground 

would be a negligible long-term adverse impact 

that might occur up to twice a year. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Floodplains 

Natural and Beneficial Floodplain Values. 

The natural and beneficial values of floodplains 

would continue to be compromised by the 

presence of the 50-site campground. This continuing adverse impact on natural processes 

would be major and long term. 

Flooding. Under the no-action alternative the 

50-site campground would continue to occupy 

part of the 100-year floodplain. If a 100-year 

flood occurred on the Belle Fourche River, 

water in the campground would be 2 to 4 feet 

deep and of moderate velocity. In the past 40 

years, two flood events from spring runoff and 

heavy rain covered the campground with 5 feet 

of water. Such an occurrence could be caused by 

heavy rain when the dam is already full or by 

flooding on one or more tributaries of the Belle 

Fourche. A breach of the Keyhole Dam would 

potentially cause a level of flooding that would 

endanger campers. These conditions would be 

hazardous to campground occupants; however, 

there is a convenient escape route to higher 

ground toward the northwest, and an evacuation 

plan would be developed in accordance with 

NPS policy. 

The Crook County Emergency Plan indicates 

that, “In the event of a dam breach at Keyhole, it 

will be approximately 3 hours before floodwaters reach Devils Tower National Monument.” 

However, even though an evacuation plan would 

be prepared and potential warning from operators of the Keyhole Dam would reduce the risk 

to campers, some danger to these visitors would 

remain. Communications might not always be 

fully comprehended or acted upon. Miscommunications could leave campers at risk in the 

event of a 100-year flood or breach of the Keyhole Dam. Severe flooding has been infrequent, 

and the risks are minor to moderate, but the 

results of flooding could cause major adverse 

impacts on the visitors involved.

Conclusion: The natural and beneficial values of floodplain areas would continue to be 

compromised by the presence of the 50-site 

campground. This continuing long-term adverse 

effect on natural processes would be major. Although severe flooding has been infrequent and 

the risks are minor to moderate, flooding could 

result in major adverse impacts on the visitors 

involved. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Agriculture (including 

dryland farming) and ranching have greatly 
ENVIRONMENTAL CONSEQUENCES

reduced native prairie plants and animals and led 

to the alteration and erosion of soils. Wildlife 

have been affected by being displaced, and 

habitat has been lost through agricultural uses, 

animals, and plants. Probably the greatest impact 

on wildlife at the monument has been the restriction of movement caused by fencing much of the 

perimeter along the south and west boundaries. 

Wildlife are also disrupted by development, 

employees, and visitors. 

If the repaving and widening of the road, as described in the cumulative effect scenario, was 

approved, approximately 0.68 acre of previously 

disturbed herbaceous vegetation along the road 

would be lost. Placing riprap in several locations 

to reduce the erosion of drainage ditches would 

result in the loss of 0.01 acre of grassland. Removing and revegetating at least four existing 

pullouts would result in the establishment of 

approximately 0.2 acre of additional grassland 

habitat dominated by native grasses and wildflowers. Small mammals would be displaced and 

native vegetation would be removed by these 

actions. 

The development of some private or state lands 

for tourist-related activities or for residential or 

other uses could increase runoff and soil compaction and could alter soil regimes and vegetative communities, as well as causing the loss 

of plants in some areas. Increased development 

outside the monument would further fragment 

wildlife habitat and interrupt wildlife habits and 

movement. Less land would be available for 

prairie dog habitation. Road kills of rodents, 

larger mammals, and birds would increase because more development probably would increase traffic. If visitation increased, bringing 

more traffic, the air quality would be degraded 

further 

“The black-tailed prairie dog has undergone 

severe reduction in occupied range and population in Wyoming since settlement and the 

advent of farming and ranching. Occupied range 

has been reduced by over 80% from presettlement” (Campbell and Clark 1981). “Similar to other parts of the historical range, the 

major reduction in prairie dog populations 

probably occurred in the early 1900s when 

poisoning programs began in earnest”( AZ 

Game and Fish Dept. 1999).

The implementation of a “Memorandum of 

Understanding among State Fish and Wildlife 

Agencies within Black-tailed Prairie Dog Range: 

Conservation and Management of Black-tailed 

Prairie Dog in North America” (9 of 11 states) 

might lead to the development and implementation of comprehensive state plans. These plans 

would be designed to maintain the broadest distribution and greatest abundance possible within 

the fiscal realities of the state agencies and 

cooperating partners. 

Cooperative partnerships might be developed 

with interested individuals and private, state, 

tribal, and federal land managers. However, 

implementing such plans would take several 

years. For the time being, it is not expected that 

landowners outside the monument would allow 

prairie dogs to move onto their land. Therefore, 

the prairie dog colony at Devils Tower would be 

unlikely to grow large enough to support ferrets 

and mountain plover. The population in the 

monument probably would continue to be small 

and isolated. 

As part of road repaving, wooden posts would 

be replaced along the road and at pullouts adjacent to the prairie dog colony. This could temporarily displace individual animals but would 

not be not likely to result in mortality. In areas 

occupied by prairie dogs, the centerline of WY 

110 would be shifted north to avoid impacts on 

numerous burrows adjacent to the southern edge 

of the road (NPS 2000a.) 

The construction of the Keyhole Dam has 

greatly reduced the extent of the floodplain, 

associated wetlands, and the natural and beneficial values of floodplains and wetlands. At 

least some wetlands in the area probably have 

been filled to make more land available for 

growing crops. Cattle and sheep probably have 

been allowed to use some wetland and riparian 

areas in the vicinity of the monument. These 

practices decrease the wetland areas and degrade 

natural and beneficial floodplain values in ex-
Effects of Alternative 1 (No Action) 

89 

change for benefits to agricultural uses. NPS 

structures and visitor uses in wetland and floodplain areas contribute to the loss of natural and 

beneficial values. This alternative would not 

involve removing activities and structures from 

floodplains and wetlands or restoring natural and 

beneficial values inside or outside the monument. The presence of the dam would result in 

major long-term reductions in area and in beneficial values in floodplains and wetlands downstream of the dam on the Belle Fourche River. 

Repaving the main monument road would not 

result in any impact on any floodplain or 

wetland. 

Further developments in floodplains and wetlands for residential, agricultural, or commercial 

uses would decrease the area in which natural 

and beneficial wetland and floodplain values 

would be preserved. 

Overall, the above past, present, and future 

actions, in conjunction with the impacts of 

alternative 1, would result in major long-term 

adverse impacts on natural resources, including 

soils, vegetation, wildlife, prairie dogs, wetlands, and floodplains. Most of the impacts 

would result from previous actions, including 

agriculture, ranching, and dam construction. The 

actions of alternative 1 would contribute a very 

small increment to the overall cumulative 

impact. 

CULTURAL RESOURCES 

Ethnographic Resources 

Ethnographic resources sacred to tribes, 

including the viewshed, would continue to be 

degraded by high visitor congestion and vehicular traffic at the base of the Tower, at the entrance station, and at the picnic area, the campground and special permit camping area, and the 

administrative area. The congestion and traffic 

are readily apparent. The Tower has been found 

eligible for listing on the National Register of 

Historic Places as a traditional cultural property, 

and it also is a center of religious ceremony, a 

sacred place, and a place of healing. The Tower 

is critical to the tribal existence of a people. 

Therefore, the adverse impacts on ethnographic 

resources that would occur during the peak use 

season each year under alternative 1 would 

continue to be major and long term. 

American Indians wanting privacy for religious 

activities would continue to be disrupted 

occasionally by such things as the presence of 

other visitors or traffic congestion. These 

conflicts, which would be slight but detectable, 

would constitute a minor recurring short-term 

adverse impact. 

Continuing the existing requirement for large 

groups of campers to obtain a permit would have 

a negligible long-term adverse effect on 

ethnographic resources. 

Conclusion: Ongoing major long-term 

adverse impacts on ethnographic resources at the 

Tower, the entrance station, and other visitor use 

and administrative areas would continue under 

alternative 1. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Although past actions 

have affected ethnographic resources, no ongoing or future actions such as the repaving of the 

main monument road would have a perceptible 

impact on them. Actions in alternative 1 would 

not add appreciably to the cumulative impacts. 

Historic Resources 

Historic fabric could be lost or new visual and 

nonhistoric elements could be introduced 

through actions taken to make historic buildings 
ENVIRONMENTAL CONSEQUENCES

and structures accessible to people with impaired mobility to comply with the Architectural 

Barriers Act of 1968 and the Rehabilitation Act 

of 1973. The monument would develop design 

solutions using the Secretary of the Interior’s 

Standards to meet accessibility requirements 

while minimizing impacts on cultural resources. 

When specific proposals were evaluated, 

impacts would be assessed. Any actions then 

would have no more than a minor effect on 

historic buildings and structures. 

Visitor activity and traffic congestion would 

continue in the historic district at the base of the 

Tower and the viewshed from the Tower. The 

buildings were intended to facilitate visitor use 

of the area, but the degree of congestion has 

increased so much over the years that there is a 

minor adverse impact on the historic setting 

during peak times each year, and this impact 

would continue under alternative 1. 

The historic road and historic entrance station 

would continue to be intruded upon by nonhistoric buildings such as the kiosk and the 

administrative area. This slight but detectable 

continuing adverse impact would be minor and 

long term. 

Some maintenance activities would result in 

visual and auditory intrusions; however, such 

intermittent adverse impacts would be short term 

and minor. 

Conclusion: Long-term minor adverse 

impacts from visitor and traffic congestion in the 

historic district and from the modification of 

buildings for accessibility would continue. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: The number and 

integrity of CCC-made roadway features (such 

as rock walls and culvert headwalls) would 

continue to be gradually reduced by traffic, erosion, natural processes, and highway construction. With continuing aging of these 1930s 

structures, there is the potential for accelerated 

deterioration from natural causes, which could 

result in the loss of structural integrity and 

original materials. 

Repaving the main monument road would not 

affect the historic buildings. Burying the culvert 

headwall would have a minor long-term adverse 

effect on one roadway contributing feature. A 

moderate long-term beneficial effect would result from rehabilitating the roadway. Long-term 

moderate adverse cumulative effects would 

result from traffic, natural processes, and new 

construction, which would damage or destroy 

CCC roadway structures. 

Overall, the above past, present, and future 

actions, in conjunction with the actions of this 

alternative, would result in long-term minor to 

moderate adverse impacts on historic resources. 

Most of these impacts would have been caused 

by past actions and processes, including traffic, 

erosion, natural processes, and highway construction. The actions of this alternative would 

contribute a very small increment to the overall 

cumulative effect. 

Section 106 Summary: This summary was 

prepared with the use of the definitions of section 106 of the National Historic Preservation 

Act.

Under the regulations of the Advisory Council 

on Historic Preservation (36 CFR 800.9) 

addressing the criteria of effect and adverse 

effect, the National Park Service finds that 

continuing management policies under this 

alternative (visitor and vehicular congestion at 

the base of the Tower and in other areas) would 

result in continued adverse effects on ethnographic resources. 

The effect on ethnographic resources from the 

continued requirement that permits be obtained 
Effects of Alternative 1 (No Action) 

91 

for the use of the northwest and special permit 

camping area would not be adverse. 

The continued degradation of the setting of the 

historic district would not constitute an adverse 

effect (see “Cultural Resources” under “Methodology for Analyzing Impacts,” above).

VISITOR EXPERIENCE 

Visitors’ Experience of Monument Resources 

Under this alternative, visitors’ experience of the 

Tower area would continue to be degraded by 

noise, vehicle smells, and the frustration of not 

finding parking places. The continuation of these 

existing conditions would be a long-term major 

adverse impact on visitors during peak use 

times. The impact would be major because most 

visitors would be affected and because the 

Tower area is a primary resource area. Fewer 

visitors would be affected in non-peak times, so 

at those times the impact would be moderate. 

Monument visitors can stop at three vehicle pullouts along the road near the prairie dog town, 

get out of their cars, and watch prairie dogs up 

close. They can walk along short trails, and 

some simply wander around the prairie dog 

town. This opportunity for close interaction with 

wildlife is considered an important element of 

most visitors’ experience; therefore, continuing 

this opportunity would result in a continued 

major beneficial effect for most visitors. 

Although only a small number of visitors use it, 

the campground offers a pleasant, shady, peaceful camping experience that its users value 

highly. Visitors also enjoy the picnic area, as do 

local residents on family outings. Although these 

two facilities are important to some visitors, the 

visitor experiences they offer are not fundamental to the monument’s significance. Nevertheless, public input has indicated that these 

assets would continue to have a long-term 

moderate beneficial effect for visitors. 

The location of the monument’s administrative 

headquarters along the main road between the 

entrance and the Tower area would continue a 

minor inconvenience to a small number of visitors. For all visitors, the headquarters building 

would continue to be a long-term minor visual 

intrusion on the historic and natural scenic 

corridor of the road.

Parked vehicles, lights at night, and developments associated with the campground, picnic 

area, trailer dropoff, and administrative headquarters are visible from the Tower area and 

from the trails. These visual intrusions degrade 

the natural setting. However, under existing 

conditions, these long-term adverse visual impacts would be minor because the developments 

are low-key and screened somewhat by vegetation. Nevertheless, lights at night would continue to disrupt the view for small numbers of visitors who might be at or on the Tower at night. 

The best opportunities for quiet and a natural 

experience are in the northwest corner of the 

monument. Views of the Tower are outstanding, 

and the viewshed is virtually pristine. Although 

this area is not heavily visited, these kinds of 

experiences are important to the visitors who go 

there. Responses to visitor surveys have indicated a high interest in quiet, natural scenery, 

and getting away from life’s pressures. Continuing to have these opportunities available 

would result in a long-term major benefit for 

visitors seeking these kinds of experiences. 

Although the large group permit camping area is 

not heavily or frequently used and not fundamental to the monument’s mission, this area 

offers expanded opportunities for group recreation. However, it also results in a minor impact 

on the viewshed from the Tower and the trails. 

Continuing the availability of permit camping in 

this area would result in a long-term minor benefit for the few visitors served. 

Access and Freedom to 

Go at One’s Own Pace 

Under current conditions, visitors are free to 

come and go within the monument at their own 

pace, depending on the availability of parking. 
ENVIRONMENTAL CONSEQUENCES

This freedom of movement is perceived as a 

long-term major beneficial effect by visitors to 

whom such spontaneity is an important value. 

During peak use times, this benefit is reduced to 

a moderate level by the constraints of traffic and 

parking congestion. 

Access to the Tower trail is congested at peak 

times, and the steep trail approach is difficult or 

impossible for some visitors to negotiate. The 

inaccessibility of the approach to the Tower trail 

would continue to have a major long-term adverse effect on visitors who would be excluded 

from a close experience of the monument’s 

primary resource. 

Traffic congestion on the main road through the 

prairie dog town would cause frustration for 

visitors who wanted to go on to the Tower. This 

would be a minor adverse impact on most 

visitors during periods of low visitation. However, during peak use times, the impact would be 

moderate, particularly if a visitor’s time in the 

monument was limited. 

Continuing the requirement that towed vehicles 

be dropped off at the mowed area along the 

campground access road before proceeding to 

the Tower area would continue to result in 

inconvenience for those visitors under existing 

conditions. This would be a minor impact because of the small number of visitors affected; 

however, moderate adverse impacts would result 

during peak visitation. 

When waiting lines at the entrance station are up 

to 0.5 mile long at peak use times, visitors may 

be frustrated. On a few days a year the lines may 

up be up to 1.5 miles long. In this alternative, 

delays at the entrance station would continue to 

be a negligible to minor adverse impact on most 

visitors, but the frustration could continue to 

have a moderate effect on visitors at peak use 

times, particularly for those on a tight schedule. 

Access to Orientation and Interpretation 

Facility limitations and crowded conditions at 

the Tower area and visitor center would continue 

to lead to visitor frustration over being unable to 

get the important orientation and interpretation 

that they would like to have. Almost all visitors 

would be affected, and because of the high value 

they place on interpretation, continuing the 

current limitations on interpretive opportunities 

would constitute a long-term moderate to major 

adverse impact. 

Visitor Safety 

Some vehicle accidents in the Tower area could 

result from traffic congestion and the need to 

manipulate large vehicles in a small space. The 

parking pullouts and pedestrian activity at the 

prairie dog town also could result in some traffic 

congestion, threatening vehicle and pedestrian 

safety. Vehicle accidents have been infrequent in 

the monument, and risks are considered minor to 

moderate, but the results of an accident could be 

a major adverse impact on the visitors involved. 

Cumulative Effects: Although past actions 

have affected visitor experience, no ongoing or 

future actions such as the repaving of the main 

monument road would have a perceptible impact 

on it. The actions of this alternative would not 

add appreciably to cumulative effects. 

Conclusion: Alternative 1 would result in 

continuing degradation of the prime monument 

resource by noise, vehicle smells, and visitor 

frustration at not finding parking places. 

Continuing these existing conditions would 

result in a long-term major adverse impact on 

visitors coming at peak use times. The inaccessibility of the approach to the Tower trail 

would continue to exclude some visitors from a 

close experience with the Tower, a major, longterm adverse impact for those visitors. Overall, 

because of the facility limitations and crowded 

conditions at the Tower area and the visitor 

center, visitors would continue to be frustrated 

by the inability to receive orientation and 

interpretation. 

Visitors would be free to come and go around 

the monument at their own pace, depending on 

the availability of parking. This freedom of 
Effects of Alternative 1 (No Action) 

93 

movement would be a long-term major benefit 

for visitors to whom such spontaneity is an 

important value. 

The campground offers a pleasant, shady, peaceful camping experience that its users value 

highly. Public input indicates that retaining the 

campground would constitute a moderate longterm beneficial effect for visitors. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

SOCIOECONOMIC RESOURCES

Businesses and Neighbors 

The entrance station would remain in its current 

location in the middle of the entrance road under 

alternative 1, at the point where the monument 

abuts the Devils Tower Trading Post and the 

KOA General Store. With the entrance station in 

this location, the Trading Post and KOA have a 

distinct competitive advantage over commercial 

outlets farther from the entrance. This would be 

a moderate long-term beneficial effect on the 

nearby businesses. A transportation study prepared by Robert Peccia & Associates (October 

1999) indicates that 34% of the vehicles entering 

Devils Tower National Monument first enter the 

retail area immediately outside the entrance. The 

same study reports that 41% of vehicles leaving 

the monument enter the retail area immediately 

outside the entrance. However, Anecdotal reports from these businesses indicate that monument visitors are discouraged from entering the 

business establishments during peak visitation 

times because there can be a the line of traffic 

blocking the entrances. 

Without data on how many vehicles contain 

visitors who want to stop at the retail area, and 

assuming that the same vehicles are not stopping 

upon entrance and exit, it appears that about 

75% of vehicles manage to stop at the retail 

area. Assuming that all the vehicles that do not 

stop do not do so because the visitors in them do 

not want to stop, this is a negligible short-term 

adverse impact that occurs during peak use 

periods. Assuming that all 25% of vehicles that 

do not stop contain visitors who want to stop but 

cannot do so because of the traffic, this adverse 

impact would be minor, intermittent, and long 

term, occurring at peak times. Consequently, the 

loss of revenue to these businesses from the 

traffic congestion during peak use periods would 

vary from negligible to moderate, depending on 

visitor preference. 

The monument would continue to make available tent and RV campsites. To the extent that 

visitors chose to stay in the NPS campground, 

that business would be lost to competing private 

and public campgrounds. The NPS campground 

is relatively small; therefore, this would be a 

continuing negligible long-term adverse impact 

on competing campgrounds. 

The owners of property adjacent to the monument who use the entrance road for access to and 

egress from their properties might continue to 

experience minor inconvenience due to visitor 

traffic at the entrance station during peak use 

periods. This would be a long-term adverse impact that would not affect the property owners’ 

quality of life because there are alternative 

accesses, and the impact would occur only 

during peak use periods. 

The traffic flow through the northwest corner of 

the monument would not change under this 

alternative, and there would be no change in 

access for owners of adjacent property who 

currently have unrestricted access to their 

properties through this part of the monument. 

Conclusion: The Devils Tower Trading 

Post and the KOA General Store have a competitive advantage over commercial outlets 

farther from the monument entrance. This is a 
ENVIRONMENTAL CONSEQUENCES

moderate beneficial long-term effect for those 

businesses.

Owners of property adjacent to the monument 

who use the entrance road to come and go from 

their properties might experience minor inconvenience from visitor traffic at the entrance 

station during peak times. 

Local and Regional Economy 

Devils Tower National Monument employs 10 

permanent employees and as many as 18 seasonal employees. The affiliated natural history 

association has one permanent and up to 5 seasonal employees. The total employment in 

Crook County in 1997 was 3,302. Therefore, the 

effect of employment at the monument on the 

county economy is negligible, long-term, and 

beneficial. 

The monument’s operating budget for 2001 is 

$753,000. Total industry earnings in Crook 

County in 1997 were $62.2 million. Therefore, 

the impact of the monument on the Crook 

County economy is negligible, long term, and 

beneficial. 

Conclusion: Because employment and 

expenditures of the monument are very small 

compared to the county economy as a whole, the 

impacts of monument employment and 

expenditures are negligible, long term, and 

beneficial. 

Cumulative Effects: Although past actions 

have affected socioeconomic resources, no 

ongoing or future actions such as the repaving of 

the main road would have a perceptible socioeconomic impact. The actions of alternative 1, 

together with those in the cumulative effect 

scenario, would not add appreciably to 

cumulative effects. 

UNAVOIDABLE ADVERSE IMPACTS 

The following paragraphs describe the more 

important (moderate and major intensity) 

adverse impacts that would result from 

alternative 1. These are residual impacts that 

would remain after mitigation was implemented. 

The negligible and minor impacts are described 

in the foregoing analysis. 

Natural Resources 

Wildlife habitat would continue to be interrupted, and wildlife habits and movement would 

be altered by the presence of development, employees, visitors, and fences along the monument boundary. Long-term adverse impacts on 

wildlife would continue to be negligible to 

moderate. 

The natural and beneficial values of floodplain 

areas would continue to be compromised by the 

presence of the 50-site campground. This 

continuing long-term adverse impact on natural 

processes would be major. Although severe 

flooding has been infrequent and risks are minor 

to moderate, flooding could result in major 

adverse impacts on the visitors involved. 

Cultural Resources 

Ethnographic resources sacred to tribes, including the viewshed, are degraded by high visitor 

congestion and vehicular traffic at the base of 

the Tower, the entrance station, the picnic and 

campground areas, the administrative area, and 

the special permit camping area. The congestion 

and traffic are readily apparent. The Tower has 

been found eligible for listing on the National 

Register of Historic Places as a traditional cultural property. It is also a center of religious 

ceremony, a sacred place, and a place of healing, 

and it is critical to tribal existence as a people. 

Therefore, a major long-term adverse impact on 

ethnographic resources would continue during 

the peak use season each year. 

American Indians wanting privacy for religious 

activities would continue to be disrupted occasionally by such things as the presence of other 

visitors or traffic congestion. These conflicts, 

which would be slight but detectable, would 

constitute a minor recurring short-term adverse 

impact. If visitor intrusions caused tribes to 
Effects of Alternative 1 (No Action) 

95 

change their religious activities, the adverse 

impact would become major and long term. 

Visitor Experience 

Visitors’ experience of the Tower area would 

continue to be degraded by noise, vehicle smells, 

and the frustration of not finding parking places. 

Continuing these existing conditions would be a 

long-term major adverse impact on visitors at 

peak use times. The impact would be major 

because most visitors would be affected and 

because the Tower area is a primary resource 

area. Fewer visitors would be affected in nonpeak times, so at those times the impact would 

be moderate 

Access to the Tower trail is congested during 

peak times, and the steep trail approach is difficult or impossible for some visitors to negotiate. 

The inaccessibility of the approach to the Tower 

trail would continue to have a major long-term 

adverse effect on visitors who would be 

excluded from a close experience of the 

monument’s primary resource. 

Traffic congestion on the main road through the 

prairie dog town would cause frustration for 

visitors who wanted to go on to the Tower. 

During peak use times, the impact would be 

moderate, particularly if a visitor had limited 

time to spend in the monument. 

Continuing the requirement that towed vehicles 

be dropped off at the mowed area along the 

campground access road before proceeding to 

the Tower area would continue to result in an 

inconvenience for those visitors under existing 

conditions. This would result in a moderate 

adverse impact on those visitors during peak 

visitation. 

When waiting lines at the entrance station became up to 0.5 mile long at peak use times, 

some visitors might be frustrated On a few days 

a year, the lines might reach 1.5 miles long 

Delays at the entrance station would continue to 

have a moderate long term effect on visitors 

during peak use times, and the frustration could 

continue, particularly for those on a tight 

schedule. 

Facility limitations and crowded conditions at 

the Tower area and visitor center would continue 

to lead to visitor frustration over being unable to 

get the important orientation and interpretation 

that they would like to have. Almost all visitors 

would be affected, and because of the high value 

they place on interpretation, continuing the current limitations on interpretive opportunities 

would constitute a long-term moderate to major 

adverse impact. 

Some vehicle accidents in the Tower area could 

result from traffic congestion and the need to 

manipulate large vehicles in a small space. The 

parking pullouts and pedestrian activity at the 

prairie dog town also could result in some traffic 

congestion, threatening vehicle and pedestrian 

safety. Vehicle accidents have been infrequent, 

and risks are considered minor to moderate, but 

an accident could result in a major long-term 

adverse impact on the people involved. 

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

Severe flooding has been infrequent, and the 

risks are minor to moderate; however, flooding 

could result in major adverse impacts on the 

visitors involved. Any loss of life would be 

irreversible. 

RELATIONSHIPS OF SHORT-TERM 

USES OF THE ENVIRONMENT AND 

LONG-TERM PRODUCTIVITY 

Continuing visitor activities would reduce the 

long-term productivity of the environment. 

Noise, artificial lighting, and human activities 

associated with ongoing visitor and administrative use of the monument would prevent 

wildlife populations, including prairie dogs, 

from reaching their full potential in size and 

population density. Visitation at peak times and 

associated congestion at the Tower would 

continue to diminish the area’s long-term value 

for American Indian religious practices. 
ENVIRONMENTAL CONSEQUENCES

IMPAIRMENT 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. Should 

ongoing adverse impacts on ethnographic 

resources at the Tower continue unchecked, this 

critical system might be impaired at some point 

in the future. 
97 

EFFECTS OF ALTERNATIVE 2 

NATURAL RESOURCES 

Soils 

In the lower parking area at the base of the 

tower, some regrading and possible construction 

of retaining walls would be necessary under 

alternative 2 before the area was paved. A small 

part of the natural soil profile could be lost, a 

minor long-term adverse impact. 

Several impacts would result from the alternative 2 actions of converting the upper parking 

area at the Tower to a pedestrian plaza, enlarging and paving the lower parking area, 

rehabilitating the west road and one track of 

Joyner Ridge trail, removing vehicle pulloffs 

from the prairie dog town, converting loop A of 

the campground to a trailer dropoff area and tour 

bus parking, and restoring vegetation in the 

special permit camping area. Approximately 4 

acres of soils would be disturbed in the short 

term. All the areas that would be affected have 

been previously disturbed. Sites with soil disturbance would undergo accelerated erosion, at 

least temporarily, until drainage structures were 

fully operational and vegetation had recovered. 

Construction activity would be restricted to the 

minimum area required for building or rehabilitating. Topsoil would be retained and replaced 

where possible to conserve available organic 

matter. Most visitor developments would be 

built on areas with slopes of less than 15% to 

minimize the soil erosion created by foot traffic. 

Trails where heavy foot traffic could be expected would be paved, and visitors would be 

encouraged to stay on maintained trails. Special 

designs would be used for trail construction in 

areas with high slope and easily eroded soils. 

The area that would be affected has been disturbed previously, and mitigating measures 

would be implemented; therefore, the adverse 

impacts on soils from increased erosion would 

be minor and short term. 

The net increase in paved surfaces (including 

gravel) would be less than 0.5 acre. In areas with 

hardened surfaces, the direct inflow of water to 

soil would be partially or totally eliminated, and 

precipitation would be collected and diverted to 

natural drainages. Runoff not collected and diverted to natural drainages would pour out onto 

adjacent areas, increasing the local soil moisture 

regime. Increased runoff in these areas would 

result in localized increases in erosion, changes 

in soil nutrient transport, and changes in the 

natural composition of vegetation. Altered vegetative composition would create slight changes 

in soil chemistry. These impacts have already 

occurred to some degree because all the areas 

involved have already been disturbed. Because 

the area that would be impacted is very small 

and already disturbed, the impact would be 

minor. Increased erosion, soil nutrient transport, 

and vegetation composition from hardened 

surfaces would result in long-term adverse 

impacts on soils. 

Conclusion: Potential regrading of the 

lower parking area could cause the loss of a 

small part of the natural soil profile, a minor 

adverse short-term impact. Disturbing about 4 

acres of soil during construction would increase 

soil erosion, which would be a minor adverse 

short-term impact on soils. Increasing paved 

surfaces (including gravel) by less than 0.5 acre 

would increase erosion, soil nutrient transport, 

and vegetation composition, a minor long-term 

adverse impact. The overall adverse impacts on 

soils would be minor and long term. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 
ENVIRONMENTAL CONSEQUENCES

Vegetation 

Enlarging the overflow parking at the Tower, 

widening the trail in the prairie dog town, and 

converting campground loop A to accommodate 

trailer dropoff and tour bus parking would result 

in the loss of about 1.3 acres of already disturbed vegetation. Because the area is already 

disturbed and mitigating measures would be 

implemented (as described under “soils”), this 

long-term adverse impact would be minor. 

Clearing some vegetation during construction 

could increase the relative abundance of plants 

that invade disturbed areas. Increased erosion at 

these areas could expose root systems and lead 

to the subsequent death of more mesic plants 

(those needing a moderate amount of water). 

Every effort would be made to preserve the large 

cottonwood trees in the campground. Topsoil 

would be scraped off and set aside before construction began. To allow more rapid recovery 

of native vegetation and to minimize the encroachment of invading species, the soil would 

subsequently be replaced and reseeded with 

seeds of native species gathered in the monument or seeds gathered in the monument and 

propagated elsewhere. During the recovery 

period, the artificially seeded or replanted native 

vegetation would not be identical in composition 

to vegetation in adjacent areas. A reduction in 

the organic content of the soil would cause a 

slight change in species composition for several 

years. Because the affected area is already disturbed and the described mitigating measures 

would be taken, this adverse impact on previously disturbed vegetation would be minor and 

long term. 

Some vegetation would be trampled or destroyed by the use of the northwest corner of the 

monument a few times a year. The permit system and associated management of visitor use 

under alternative 2 would reduce this impact by 

spreading the use over a larger area. This 

intermittent adverse impact would be negligible 

and long term. 

The preservation of a prairie remnant in the 

northwest corner of the monument would be 

enhanced by closing the north road to all but 

administrative use and by obliterating and 

reseeding the west road and one track of Joyner 

Ridge trail with native species. This beneficial 

effect on the prairie remnant would be minor 

and long term. 

Revegetating about 4 acres at the pedestrian 

plaza, the west road, the Joyner Ridge trail, and 

the prairie dog pullouts would result in a minor 

long-term beneficial effect on vegetation. The 

revegetation would benefit about three times the 

acreage than the amount that would be lost in 

this alternative(about 1.3 acres). 

Conclusion: Although there would be a net 

gain of 2.6 acres of vegetation and improved 

preservation of vegetation in the northwest area, 

1.3 acres of already-disturbed vegetation would 

be lost. This adverse effect would be minor and 

long term. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wildlife 

Approximately 1.3 acres of wildlife habitat 

would be lost through enlarging the lower parking area at the Tower, widening the trail through 

the prairie dog town, and converting loop A of 

the campground to accommodate trailer dropoff 

and tour bus parking. Every effort would be 

made to avoid harm to the large cottonwood 

trees in the campground area, which provide 

habitat for wildlife. This adverse impact on 

already disturbed wildlife habitat would be 

minor and long term. 
Effects of Alternative 2 

99 

A long-term increase of about 3.9 acres of 

wildlife habitat would be brought about by 

closing and revegetating the west road, restoring 

one lane of the two-track Joyner Ridge trail, 

restoring the prairie dog town pulloffs, and 

restoring the special permit campground to 

natural conditions. Restoring the latter campground would have a very small effect, if any, 

because it is used so little; even so, there would 

be a minor long-term beneficial effect on 

wildlife habitat. 

Invertebrates and small vertebrates can be destroyed by construction or displaced by changes 

in vegetation that result from construction. Small 

mammals and birds usually are displaced and 

disrupted by the development of an area. The 

areas that would be developed in alternative 2 

are already disturbed, and it is possible that 

creating a pedestrian plaza, with its increased 

vegetation, might increase habitat for invertebrates, small vertebrates, mammals, and birds by 

about 0.5 acre. Paving the trailer dropoff area 

might decrease habitat for these animals by 0.4 

acre. Thus, the adverse effect on invertebrates 

and small vertebrates would be negligible and 

short term. 

Conclusion: Alternative 2 would result in a 

net increase in wildlife habitat of about 2.6 

acres. Because of the relatively small area of 

impact and because care would be taken to avoid 

the large cottonwood trees in the campground 

area, the long-term beneficial effect on wildlife 

would be minor. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Air Quality 

Admitting fewer visitors during peak times 

would improve air quality because fewer 

vehicles would be in the monument at any one 

time. The air quality also would be improved 

because circling the parking lot at the Tower to 

find a parking space would become unnecessary. 

This minor beneficial effect during peak times 

would be long term and intermittent. 

Construction would cause only temporary 

localized impacts on air quality, such as dust and 

diesel fumes from heavy equipment. This 

negligible short-term effect would be adverse. 

Conclusion: The overall effect of alternative 2 on air quality in the peak season would be 

minor and beneficial in the long term because of 

the potential reservation system. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Threatened, Endangered, and 

Candidate Species 

Removing automobile pulloffs (0.2 acre) from 

the prairie dog town and restoring these areas to 

more natural conditions would reduce interactions between visitors and prairie dogs. It also 

would reduce stress on the prairie dogs, eliminate their chance of being run over in the pulloffs, and make it more difficult for visitors to 

feed them human food. Eliminating a place 

where humans interact with prairie dogs would 

result in a minor long-term beneficial effect on 

the prairie dogs. 
ENVIRONMENTAL CONSEQUENCES

Widening the trail around the prairie dog town 

and covering it with gravel would reduce the 

habitat slightly (by 0.3 acre) and could lead to 

stress on individual prairie dogs along the trail 

edge. This would be a minor long-term adverse 

impact on prairie dogs. However, the prairie 

dogs would benefit from the trail widening 

because it would discourage visitors from 

wandering off the trail. Because the trail is already in place and would only be widened, this 

long-term effect on prairie dogs would be negligible. A net loss of 0.1 acre in prairie dog habitat 

would be a minor long-term adverse impact. 

Conclusion: Alternative 2 would result in 

an overall minor long-term adverse impact on 

black-tailed prairie dogs from a net loss of 0.1 

acre of habitat. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wetlands 

The only new effect on wetlands under alternative 2 would be caused by discontinuing the use 

of the special permit campground, which has 

been used only once or twice a year, with the 

possibility that campers might walk through the 

wetland on their way to the river. Removing this 

use might result in a negligible beneficial longterm effect on wetlands. 

Conclusion: Removing the special permit 

campground might have a negligible beneficial 

long-term effect on wetlands. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Floodplains 

Natural and Beneficial Floodplain Values. 

With the structures in floodplains left as at 

present and with campground loop A converted 

to accommodate trailer dropoff, bus parking, and 

trail access for prairie dog viewing and interpretation, the development footprint in the floodplain would remain the same. There probably 

would be a small net increase in paved area. 

Natural and beneficial floodplain values would 

continue to be compromised. This continuing 

long-term adverse impact on natural processes 

would be major. 

Flooding. Reducing the potential overnight 

occupancy from 50 sites to 30 (in campground 

loop B, which would be unchanged) would 

mean that campers still would be subject to the 

potential hazard of a 100-year flood. If a 100-

year flood occurred on the Belle Fourche River, 

water in the campground would be 2 to 4 feet 

deep and of moderate velocity. In the past 40 

years, two flood events from spring runoff and 

heavy rain covered the campground with 5 feet 

of water. Such an occurrence could be caused by 

heavy rain when the dam is already full or by 

flooding on one or more tributaries of the Belle 

Fourche. A breach of the Keyhole Dam would 

potentially cause a level of flooding that would 

endanger campers. These conditions would be 

hazardous to campground occupants; however, 

there is a convenient escape route to higher 

ground toward the northwest, and an evacuation 

plan would be developed in accordance with 

NPS policy. 

The Crook County Emergency Plan indicates 

that, “In the event of a dam breach at Keyhole, it 

will be approximately 3 hours before floodwa-
Effects of Alternative 2 

101 

ters reach Devils Tower National Monument.” 

However, even though an evacuation plan would 

be prepared and potential warning from operators of the Keyhole Dam would reduce the risk 

to campers, these visitors would remain in some 

danger. Communications might not always be 

fully comprehended or acted upon. Miscommunications could leave campers at risk in the 

event of a 100-year flood or breach of the Keyhole Dam. Severe flooding has been infrequent, 

and risks are minor to moderate, but flooding 

could result in major adverse impacts on the 

visitors involved.

A 100-year flood, as described in the “Affected 

Environment” chapter, would be hazardous to 

campground occupants. If Keyhole Dam failed, 

the expected 3-hour flood warning time would 

allow campers ample time to get themselves and 

their equipment out of the floodplain. Therefore, 

developing an evacuation plan for the campground would result in a negligible beneficial 

effect in the long term. 

Conclusion: The natural and beneficial 

values of floodplain areas would continue to be 

compromised by the development within them. 

This continuing long-term adverse impact on 

natural processes would be major. Although 

severe flooding has been infrequent and risks are 

minor to moderate, flooding could result in 

major adverse impacts on the visitors involved. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Agriculture (including 

dryland farming) and ranching uses have greatly 

reduced native prairie plants and animals and led 

to the alteration and erosion of soils. Wildlife 

have been affected by being displaced, and 

habitat has been lost through agricultural uses, 

animals, and plants. Probably the greatest impact 

on wildlife at the monument has been the restriction of movement caused by fencing much of the 

perimeter along the south, east and west boundaries. Wildlife are also disrupted by development, 

employees, and visitors. 

If the repaving and widening of the road, as 

described in the cumulative impact scenario, was 

approved, approximately 0.68 acre of previously 

disturbed herbaceous vegetation along the road 

would be lost. Placing riprap in several locations 

to reduce the erosion of drainage ditches would 

result in the loss of 0.01 acre of grassland. Removing and revegetating at least four existing 

pullouts would result in the establishment of 

approximately 0.2 acre of additional grassland 

habitat dominated by native grasses and wildflowers. Small mammals would be displaced and 

native vegetation would be removed by these 

actions. 

The development of some private or state lands 

for tourist-related activities or for residential or 

other uses could increase runoff and soil compaction and alter soil regimes and vegetative 

communities, as well as causing the loss of 

plants in some areas. Increased development 

outside the monument would further fragment 

wildlife habitat and interrupt wildlife habits and 

movement. Less land would be available for 

prairie dog habitation. Road kills of rodents, 

larger mammals, and birds would increase 

because more development probably would 

increase traffic. If visitation (and traffic) increased, the air quality would be degraded 

further. 

“The black-tailed prairie dog has undergone 

severe reduction in occupied range and population in Wyoming since settlement and the advent 

of farming and ranching. Occupied range has 

been reduced by over 80% from pre-settlement” 

(Campbell and Clark 1981). “Similar to other 

parts of the historical range, the major reduction 

in prairie dog populations probably occurred in 

the early 1900s when poisoning programs began 

in earnest”( AZ Game and Fish Dept. 1999). 
ENVIRONMENTAL CONSEQUENCES

The implementation of the “Memorandum of 

Understanding among State Fish and Wildlife 

Agencies within Black-tailed Prairie Dog Range: 

Conservation and Management of Black-tailed 

Prairie Dog in North America” (9 of 11 states) 

might lead to the development and implementation of comprehensive state plans. These plans 

would be designed to maintain the broadest distribution and greatest abundance possible within 

the fiscal realities of the state agencies and 

cooperating partners. 

Cooperative partnerships might be developed 

with interested individuals and with private, 

state, tribal, and federal land managers. However, implementing such plans would take 

several years. For the time being, it is not 

expected that landowners outside the monument 

would allow prairie dogs to move onto their 

land. Therefore, the prairie dog colony at Devils 

Tower would be unlikely to grow large enough 

to support ferrets and mountain plover. The 

population in the monument probably would 

continue to be small and isolated. 

As part of road repaving, wooden posts would 

be replaced along the road and at pullouts 

adjacent to the prairie dog colony. This could 

temporarily displace individual animals but 

would not be likely to result in mortality. In 

areas occupied by prairie dogs, the centerline of 

WY 110 would be shifted north to avoid impacts 

on numerous burrows adjacent to the southern 

edge of the road (NPS 2000a). 

The construction of the Keyhole Dam has 

greatly reduced the extent of the floodplain, 

associated wetlands, and the natural and beneficial values of floodplains and wetlands. At 

least some wetlands in the area probably have 

been filled to make more land available for 

growing crops. Cattle and sheep probably have 

been allowed to use some wetland and riparian 

areas in the vicinity of the monument. These 

practices decrease the area of wetlands and 

degrade natural and beneficial floodplain values 

in exchange for benefits to agricultural uses. 

NPS structures and visitor uses in wetland and 

floodplain areas contribute to the loss of natural 

and beneficial values. This alternative would not 

involve removing activities and structures from 

floodplains and wetlands or restoring natural and 

beneficial values inside or outside the monument. The presence of the dam would result in 

major long-term reductions in area and in beneficial values in floodplains and wetlands downstream of the dam on the Belle Fourche River. 

Repaving the main monument road would not 

result in any effect on any floodplain, wetland, 

or other water resources. 

Further developments in floodplains and 

wetlands for residential, agricultural, or 

commercial uses would decrease the area in 

which natural and beneficial wetland and 

floodplain values would be preserved. 

Overall, the above past, present, and future 

actions, in conjunction with the impacts of this 

alternative, would result in major long-term 

adverse impacts on natural resources, including 

soils, vegetation, wildlife, prairie dogs, wetlands, and floodplains. Most of the impacts 

would result from previous actions, including 

agriculture, ranching, and dam construction. The 

actions of alternative 2 would contribute a very 

small increment to the overall cumulative 

impact. 

CULTURAL RESOURCES 

Ethnographic Resources 

Removing the paved upper parking area at the 

Tower to create a pedestrian plaza, removing the 

prairie dog town pullouts, and rehabilitating 

trails and disturbed areas would improve the 

viewshed in the Tower area, leaving fewer 

traffic-related visual intrusions on culturally 

sensitive areas. These actions would improve the 

ethnographic context of the area and would be 

favorable to American Indian tribes. Reducing 

the carrying capacity of the monument would 

decrease visitation and crowding, thereby providing more opportunities for solitude and quiet 

for traditional uses. This long-term beneficial 

effect on ethnographic resources would be 

moderate. 
Effects of Alternative 2 

103 

Reducing the concentrations of people and returning areas in the special permit zone (northwest corner of the monument) to natural conditions would give more protection to culturally 

sensitive areas and increase the opportunities for 

solitude in a larger area than in alternative 1. 

This beneficial effect on traditional cultural 

practices would be negligible and long term. 

Continuing the present practice of requiring 

large groups to obtain a permit and requiring 

groups of six or more to register with a ranger 

would have a negligible long-term adverse effect 

on ethnographic resources. 

Removing and rehabilitating the west road and 

closing the north road to visitors would reduce 

visual and auditory intrusions in this culturally 

sensitive area. This readily apparent change 

would be a moderate beneficial long-term effect. 

Removing the west road and closing the north 

road to visitors would not impede access to 

traditional areas because access would continue 

to be available via the main road. This negligible 

adverse impact would be long term. 

Upgrading and formalizing the lower parking 

area at the Tower would move the intrusion on 

the ethnographically sensitive area at the Tower 

farther away. This long-term beneficial effect 

would be moderate. 

Returning the special permit camping area to 

natural conditions could inconvenience up to 

two parties of American Indians per year. No 

one has used the campground since 1999. This 

would be a minor long-term adverse impact on 

American Indians who might wanted to camp 

there. 

Visual and auditory intrusions would occur in 

the vicinity of all construction and rehabilitation 

activities. This minor adverse impact would be 

short term. 

Conclusion: The impacts on ethnographic 

resources would be mixed. Removing the paved 

upper parking area at the Tower and creating a 

pedestrian plaza would be a moderate long-term 

benefit, as would removing the prairie dog town 

pullouts, rehabilitating trails and disturbed areas, 

and reducing the concentrations of people in the 

special permit zone. Removing and rehabilitating the west road and closing the north road to 

visitors also would result in moderate long-term 

beneficial effects. 

Requiring groups of six or more to register with 

a ranger would result in negligible long-term 

adverse impacts, as would removing a little-used 

road and closing another to visitor use; however, 

these actions would not impede access to traditional areas. There would be minor long-term 

adverse impacts from returning the special permit campground to natural conditions and a 

short-term minor adverse impact from construction and rehabilitation. 

On balance, the long-term effects on ethnographic resources from alternative 2 would be 

moderate and beneficial. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Although past actions 

have affected ethnographic resources, no ongoing or future actions such as the repaving of the 

main road would have a perceptible impact on 

them. The actions of alternative 2 would not add 

appreciably to the cumulative impacts. 

Historic Resources 

Removing the paved upper parking lot at the 

base of the Tower and establishing a pedestrian 

plaza would partially restore the setting of the 

historic district (which is listed on the national 

register) and improve its integrity. Upgrading 

the lower Tower parking lot for use as the prin-
ENVIRONMENTAL CONSEQUENCES

cipal parking area would move primary parking 

farther from the historic district. This beneficial 

effect would be major and long term. 

Historic fabric could be lost and new visual 

nonhistoric elements could be introduced as a 

result of making historic buildings and structures 

accessible to people with impaired mobility to 

comply with the Architectural Barriers Act of 

1968 and the Rehabilitation Act of 1973. The 

monument would develop design solutions using 

the Secretary of the Interior’s Standards to meet 

accessibility requirements while minimizing 

impacts on cultural resources. Impacts would be 

assessed when specific proposals were evaluated. Any actions would be expected to have no 

more than a minor effect on historic buildings 

and structures. 

Visitor activity and traffic congestion would 

continue in the historic district at the base of the 

Tower and in the viewshed from the Tower. The 

buildings were intended to facilitate visitor use 

of the area, but the degree of congestion has increased so much over the years that there is a 

minor adverse impact on the historic setting 

during peak times each year, and this impact 

would continue under alternative 2. 

Removing the prairie dog town pullouts would 

restore the original alignment of the national 

register-listed main road in that area. This would 

be a minor long-term benefit for historic 

resources. 

The construction activities of alternative 2 

would result in visual and auditory intrusions; 

however, such adverse impacts would be short 

term and minor. 

Conclusion: Overall, the long-term effects 

on historic resources from alternative 2 would be 

minor to major and beneficial. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: The number and 

integrity of CCC-made roadway features (such 

as rock walls and culvert headwalls) would 

continue to be gradually reduced by traffic, 

erosion, natural processes, and highway construction. With continuing aging of these 1930s 

structures, there would be a potential for accelerated deterioration from natural causes, which 

could result in the loss of structural integrity and 

original materials. 

Repaving the main monument road would not 

affect the historic buildings. Burying the culvert 

headwall would have a minor long-term adverse 

effect on one roadway contributing feature A 

moderate long-term beneficial effect would 

result from rehabilitating the roadway. Traffic, 

natural processes, and new construction could 

damage or destroy CCC roadway structures, 

resulting in moderate adverse cumulative impacts in the long term. 

Overall, the above past, present, and future 

actions, in conjunction with the actions of this 

alternative, would result in long-term minor to 

moderate adverse impacts on historic resources. 

Most of these impacts would result from past 

actions and processes, including traffic, erosion, 

natural processes, and highway construction. 

The actions of this alternative would contribute a 

very small increment to the overall cumulative 

impact. 

Section 106 Summary: This summary was 

prepared with the use of the definitions of section 106 of the National Historic Preservation 

Act. 

Under the regulations of the Advisory Council 

on Historic Preservation (36 CFR 800.9) addressing the criteria of effect and adverse effect, 

the National Park Service finds that converting 

the upper Tower parking area to a pedestrian 

plaza and moving the principal parking farther 
Effects of Alternative 2 

105 

away to the lower parking area would have an 

effect that would not be adverse. 

Continuing the requirement for permits to use 

the northwest and special permit camping areas 

would have an effect on ethnographic resources 

that would not be adverse. 

The actions of this alternative, taken together, 

would have an effect on cultural resources that 

would not be adverse.

VISITOR EXPERIENCE 

Visitors’ Experience of Monument Resources 

Reduced visitation levels in this alternative 

would decrease crowding, noise, and disruption 

in the Tower area. The peak use levels would be 

lowered from the current rate, but use during 

off-peak times might increase somewhat. Over 

time, most visitors would benefit from the overall reduction in crowding and traffic, which 

would offer some relief from the associated frustration and distraction. This would be a long 

term major beneficial effect for visitors during 

the peak season. 

Replacing the existing paved parking area with a 

pedestrian plaza and parking vehicles in the existing overflow parking area (farther from the 

base of the Tower) would make the setting for 

the Tower quieter and more contemplative. For 

many visitors, this setting would be much more 

commensurate with the Tower’s meaning and 

significance. Views from the Tower and areas at 

its base would be enhanced by the reduction of 

pavement near the Tower and vegetative screening of parked vehicles; however, paving the existing overflow parking area could have a minor 

adverse effect on the view. Overall, because 

most visitors would benefit from an improved 

experience of the monument’s prime resources, 

these changes would result in major long term 

beneficial effects, particularly for visitors 

arriving during peak use times. 

Construction activities to modify Tower area 

facilities and remove the parking pullouts at the 

prairie dog town would result in short-term 

adverse impacts. The visitor experience would 

be affected by noise from construction vehicles 

and equipment, visual intrusions from ground 

and vegetation disturbance, more traffic, the 

presence of large construction vehicles, and the 

general disruption of circulation and activities. 

These effects, although short term, could be 

moderate to major because they would occur in 

the prime resource areas of the monument. 

These effects would be particularly severe for 

visitors who might have only one opportunity to 

visit Devils Tower and whose experiences were 

degraded by construction activities. 

Providing new access to the prairie dog town 

and improving the area trails would enhance 

most visitors’ experience because they would be 

able to watch prairie dogs in a quieter setting, 

without the traffic congestion and safety concerns that are present at the current pullouts 

along the main road. Some visitors might want 

to stop along the road when the prairie dogs 

could first be seen, but overall these changes 

would result in a long term moderate beneficial 

effect for visitors. Eliminating parked vehicles 

from pullouts along the main road would result 

in a minor beneficial effect on the viewshed 

from the Tower and the trails. 

Converting campground loop A to parking for 

towed vehicles would reduce the availability of 

campsites. This effect, although long term, 

would be minor because the existing sites are 

rarely fully used, and people could still camp in 

loop B. Noise from vehicles in the parking area 

could mask natural sounds, but this impact 

would be minor because most vehicle dropoff 

and pickup would occur earlier in the day than 

most visitors would be in the campground. 

Views from the Tower and the monument trails 

could be affected by increased pavement in the 

parking area and the presence of vehicles parked 

there. This minor impact would be long term, 

although the area would be screened somewhat 

by vegetation. Some of this impact would also 

be balanced by removing the existing informal 

dropoff area. Short-term effects from construction activities would occur as described above, 
ENVIRONMENTAL CONSEQUENCES

but they would be minor because of the small 

scale of the construction and the small number 

of visitors affected, and because the construction 

would not be in prime resource areas. 

Removing one road segment and closing another 

to visitor use in the northwest corner of the 

monument would result in long-term beneficial 

effects, as would managing use in a large area to 

protect the quiet, contemplative character of that 

experience. The viewshed would be improved, 

and vehicle traffic would disrupt natural sounds 

infrequently. A small number of visitors would 

be affected directly by these changes, and continuing to provide opportunities for solitude and 

quieter experiences would be a major benefit for 

visitors seeking quieter experiences. Reducing 

roads in the area could make access more difficult for some visitors, but this would be a minor 

impact because of the relatively short distances 

from the remaining road and the small number 

of people that would be affected. 

Converting two-track administrative roads to 

single-track trail segments would have a long 

term minor beneficial effect on the natural 

character of the trail experience. The special 

permit camping area, although not heavily used 

and not fundamental to the monument’s mission, 

offers expanded opportunities for group recreation. However, eliminating that area and 

rehabilitating its soils and vegetation would increase the overall natural setting. This would be 

a long-term minor effect because the disruption 

caused by the existing use and condition of the 

area is minor. Because the number of visitors 

affected would be small, this would be a minor 

adverse impact. 

Because this alternative would involve no 

changes to administrative headquarters, the 

impacts there would be the same as in the noaction alternative. 

Access and Freedom to 

Go at One’s Own Pace 

In this alternative the levels of visitor use 

probably would be managed by a reservation 

system, at least during peak use times. Visitors 

could not come to the monument spontaneously 

during peak times, and some would be inconvenienced by being unable to come whenever 

they would like. Some people might be unable to 

come at all if they could not get reservations to 

fit their schedules. Based on public responses to 

the concept of a reservation system, this would 

be a long-term major adverse effect on visitors 

because many would be affected, and many 

place a high value on spontaneity. 

Removing visitor parking from the existing 

paved area would slightly increase the walking 

distance to visitor facilities and the Tower’s 

base. This could particularly affect visitors with 

impaired mobility. Because the distance would 

not be great and design could minimize the 

grade, this long-term impact would be minor. 

Redesigning the approach would make access to 

the Tower trail easier. Because the current approach is steep, redesign could improve access 

to the base of the Tower for a significant number 

of visitors, resulting in a long-term moderate to 

major beneficial effect. 

Reducing visitor numbers at peak times would 

shorten the entrance station waiting lines, reducing the chance of visitor frustration. Improved traffic flow at the entrance station would 

be a negligible to minor beneficial effect on 

most visitors, but the effect could be moderate at 

peak times because then more people would be 

affected. 

Visitors’ freedom of movement would be 

restricted by reducing road access in the northwest corner of the monument and requiring use 

permits. This long-term impact would be minor 

because of the small number of visitors affected. 

However, the effect on visitors with impaired 

mobility could be moderate because vehicle 

access to parts of the area would be lost. 

Access to Orientation and Interpretation 

Opportunities for ranger contact and for more 

effective dissemination of interpretation and 
Effects of Alternative 2 

107 

information would be greatly enhanced by the 

modifications in the Tower area, the reduced 

crowding, and the improvements in the prairie 

dog viewing area. Visitors would be less distracted in the visitor center, and the increased 

space in the pedestrian plaza and at the prairie 

dog town would allow for better, quieter, less 

disrupted interpretive programs. More effective 

interpretation would result in greater visitor 

understanding of the monument’s significance. 

Better orientation information would help visitors make the best use of their time. Long-term 

improvements over the current information and 

interpretation programs (which are hampered by 

general crowding) would benefit most visitors; 

this would be a major beneficial effect. 

Visitor Safety 

Reducing traffic at the Tower area and removing 

the parking pullouts at the prairie dog town 

would decrease the potential for vehicle and 

vehicle-pedestrian accidents. Although vehicle 

accidents have been infrequent, reducing the 

risks would be a long term moderate beneficial 

effect because the results of an accident could be 

major to the visitors involved. 

Cumulative Effects: Although past actions 

have affected the visitor experience, no ongoing 

or future actions such as the repaving of the 

main monument road would have a perceptible 

impact on it. The actions of alternative 2 would 

not add appreciably to cumulative impacts. 

Conclusion: Over the long term, most visitors would benefit from the overall reduction in 

crowding and traffic brought about by alternative 2; and this would be a major beneficial effect on visitors’ experiences during the peak 

season. Redesigning the access to the Tower 

trail could improve access to the base of the 

Tower for a significant number of visitors; 

therefore, this would be a moderate to major 

beneficial effect. Opportunities for ranger contact and for more effective dissemination of 

interpretation and information would be greatly 

enhanced by the modifications in the Tower 

area, the reduced crowding, and the improvements to the prairie dog viewing area. 

Some visitors would be inconvenienced by 

being unable to visit the monument spontaneously during peak times. Some people might not 

be able to visit at all if they could not get reservations to fit their schedules. Public responses to 

the concept of a reservation system have indicated that this would be a major adverse impact 

on visitors, many of whom place a high value on 

spontaneity. 

Converting campground loop A to parking for 

towed vehicles would reduce the availability of 

campsites. This adverse effect would be minor 

because the existing sites are rarely fully used, 

and people could still camp in loop B. 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

SOCIOECONOMIC RESOURCES 

Businesses and Neighbors 

With the entrance station left in its current location in the middle of the entrance road, at the 

point where the monument abuts the Devils 

Tower Trading Post and the KOA General Store, 

those businesses would continue to have a distinct competitive advantage over commercial 

outlets farther from the monument entrance. 

This would be a moderate beneficial long-term 

effect for the Trading Post and KOA. 

As described before, a transportation study 

(Robert Peccia & Associates 1999) indicated 

that 34% of the vehicles entering Devils Tower 

National Monument first enter the retail area 
ENVIRONMENTAL CONSEQUENCES

immediately outside the entrance; 41% of the 

vehicles leaving enter the retail area immediately outside the entrance. Anecdotal reports 

from these businesses indicate that lines of traffic block monument visitors from entering the 

businesses. Without data on how many visitors 

want to stop at the retail area, and assuming that 

the same vehicles are not stopping upon entrance 

and exit, it appears that about 75% of vehicles 

manage to stop at the retail area. Assuming that 

all the vehicles that do not stop have not stopped 

because the people in them do not want to stop, 

this would be a negligible long-term adverse 

impact occurring at peak times. Assuming that 

all 25% of the vehicles that do not stop contain 

visitors who would like to stop but are prevented 

from doing so by the traffic, this intermittent adverse impact would be minor, occurring during 

peak use periods. 

Converting campground loop A to a trailer dropoff area and a bus parking space (roughly 20 

campsites) would eliminate about 40% of the 

monument’s campsites. This would not impact 

access to camping at Devils Tower throughout 

most of the camping season. 

In peak use periods, the remaining 30 campsites 

in loop B might not be sufficient to accommodate all visitors interested in camping there. 

There are a number of other camping options in 

the surrounding area, and neighboring campgrounds have enough capacity to absorb the 

campers who otherwise would have stayed at 

Devils Tower. For campers interested in being 

as close to the monument as possible, the KOA 

campground immediately outside the entrance to 

Devils Tower would be the most likely beneficiary of the new business. For people looking for 

the least expensive camping option, free camping is available at Tower View and on nearby 

National Forest property. 

The overall number of people camping in the 

Devils Tower area would not decrease from 

reducing the number of campsites in the 

monument. Consequently, overall visitor 

spending in the region would not decline. If, 

over the course of the camping season, 500 

fewer Devils Tower campsites were occupied, 

and these campers went to other campgrounds 

instead, the revenues from camping at these 

private campgrounds would increase by $12,500 

per year, a minor beneficial long-term effect on 

local businesses. 

Removing the west road and revegetating the 

area would eliminate one access/egress route 

currently used by one neighboring landowner, 

causing him to change travel routes. The monument staff says that at least one other route is 

available; therefore, this long-term adverse 

impact on one landowner would be negligible. 

Conclusion: The Devils Tower Trading 

Post and the KOA General Store would continue 

to have a competitive advantage over commercial outlets farther from the monument entrance. This would be a moderate beneficial 

long-term effect for those businesses. If campers 

displaced from Devils Tower chose to camp at 

the KOA or Tower View campgrounds, that 

could result in a minor beneficial long-term 

effect on revenues ($12,500) at those campgrounds. 

Eliminating an access/egress route for one 

landowner by closing the west road would result 

in a long-term adverse impact that would be 

negligible because there is at least one 

alternative route. 

Local and Regional Economy 

Revenue from camping in the monument is not 

taxable to local authorities, as is camping outside the monument; therefore, this alternative 

would result in a $12,500 increase in taxable 

revenues. This would be a minor beneficial long 

term effect on local taxing authorities. 

The National Park Service’s cost estimate for the 

construction work of alternative 2 is roughly $1 

million, of which approximately 50% would go 

toward labor, with the rest going for materials 

and services, according to rule-of-thumb 

estimates for the construction industry. This 

translates into the equivalent of 16 one-year construction jobs over the duration of the various 
Effects of Alternative 2 

109 

construction periods. (The construction projects 

of this alternative, which could last from a week 

to more than a year, could include widening or 

narrowing monument roads, converting roads to 

hiking trails, converting the upper parking lot to 

a pedestrian plaza, and preparing new exhibits 

and orientation space. The Devils Tower staff 

might complete some projects, but private contractors would be hired for most of the work.) 

Because 16 jobs is a very small portion of 2,100, 

this would be a minor short-term beneficial 

effect on the local and regional economy. 

Short-term construction also would have certain 

spinoff effects. Data in the 1998 Occupational 

Employment Statistics Wage Survey (Wyo. Dept. 

of Employment 1998) show that construction 

jobs in the Devils Tower region pay a mean 

hourly wage of $12.41. The 16 one-year jobs 

would have a payroll of about $500,000. Construction laborers would add to the food, fuel, 

and possibly lodging expenditures made in the 

region for the duration of the construction 

period. This would directly benefit retailers 

immediately outside the Devils Tower National 

Monument entrance and in the nearest towns. 

This would be a minor short-term beneficial 

effect on the local and regional economy. 

Sales taxes collected on the expenditures of 

additional workers would benefit local jurisdictions. According to the Crook County 

Treasurer’s Office, Crook County’s sales tax 

rate is 5%. Thus, sales taxes resulting from 

alternative 2 would be a minor short-term beneficial effect on Crook County revenues. 

Assuming that construction materials purchased 

by contractors would not be subject to the 

National Park Service’s tax exempt status, local 

jurisdictions would have tax revenues on 

$500,000 in purchases of construction materials. 

The collection of about $25,000 in tax revenues 

would be a minor short-term beneficial effect on 

county sales tax revenues. 

Construction impacts would be felt primarily 

while construction was taking place, which 

would vary by project. Multiple projects could 

occur simultaneously. Over roughly three years, 

dollars spent on construction would be circulated throughout the regional economy from 

alternative 2. According to data from the U.S. 

Bureau of Economic Analysis (BEA), the estimated amount of spinoff income generated by 

$1 million of new construction would be an 

additional total of $550,000 to $730,000 

throughout the state economy (above and beyond the $1 million in construction). The range 

of spinoff income reflects the different BEA 

multipliers for new construction (1.5532) or 

maintenance and repair construction (1.7318) in 

Wyoming. This would be a minor short-term 

beneficial effect on the local and regional 

economy. 

March 2000 unemployment rates in the Devils 

Tower region were higher than the statewide 

unemployment rate of 4.0% (4.4% in Campbell 

County, 6.8% in Crook County, and 5.4% in 

Weston County). This is not considered abnormal for the region. It is also important to note 

that regional unemployment rates typically 

decline with seasonal employment in spring and 

summer, when most construction takes place.

The short-term construction projects of alternative 2 would contribute only a small percentage 

of the regional economy’s jobs and earnings. 

According to the Wyoming Department of Employment, approximately 2,100 of the 26,500-

person labor force in Crook, Campbell, and 

Weston Counties were employed in the construction industry during the third quarter of 

1999 (1,900 of them in Campbell County). 

Consequently, the construction at Devils Tower 

National Monument under alternative 2 would 

have a negligible effect on overall employment 

in the region. 

 Conclusion: The short-term construction 

projects of alternative 2 would have a small 

beneficial effect on employment opportunities 

and on the local and regional economy, including indirect effects on local businesses and tax 

revenues. The equivalent of about 16 one-year 

jobs would be created during the construction 

period, with a total payroll of roughly $500,000. 

The total impact that the proposed construction 

would have on Wyoming’s economy would be 
ENVIRONMENTAL CONSEQUENCES

up to $1,730,000. Construction at Devils Tower 

National Monument proposed under alternative 

2 would have a negligible impact on overall 

employment in the region. 

Cumulative Effects: Although past actions 

have affected socioeconomic resources, no ongoing or future actions, such as the paving of the 

main monument road, would have a perceptible 

socioeconomic impact. The actions of alternative 2, together with those in the cumulative 

impact scenario, would not appreciably add to 

cumulative impacts. 

UNAVOIDABLE ADVERSE IMPACTS 

The following paragraphs describe the more 

important (moderate and major intensity) adverse impacts that would result from alternative 

2. These are residual impacts that would remain 

after mitigation was implemented. The negligible and minor impacts are described in the 

previous analysis. 

Natural Resources 

The natural and beneficial values of floodplain 

areas would continue to be compromised by the 

development within them. This continuing longterm adverse impact on natural processes would 

be major. Although severe flooding has been 

infrequent and risks are minor to moderate, 

flooding could result in major adverse impacts 

on the visitors involved. 

Visitor Experience 

Modifying the Tower facilities and removing the 

parking pullouts at the prairie dog town would 

result in short-term impacts from construction 

activities. The visitor experience would be 

affected by noise from construction vehicles and 

equipment, visual intrusions from ground and 

vegetation disturbance, more traffic, the presence of large construction vehicles, and general 

disruption of circulation and activities. These 

effects, although short term (less than one year) 

could be moderate to major because they would 

take place in the monument’s prime resource 

areas. These effects would be particularly severe 

for visitors who might have only one opportunity to visit the monument and whose experiences were degraded by construction activities. 

In this alternative the levels of visitor use probably would be managed by a reservation system, 

at least at peak use times. Visitors could not 

come to the monument spontaneously during 

peak times, and some would be inconvenienced 

by being unable to come whenever they would 

like. Some people might be unable to come at all 

if they could not get reservations to fit their 

schedules. Based on public responses to the 

concept of a reservation system, this would be a 

major adverse effect on visitors because many 

place a high value on spontaneity. 

Reducing road access in the monument’s northwest corner and requiring use permits would 

increase restrictions on visitor freedom of 

movement. Because of the small number of 

visitors affected, this long-term impact would be 

minor. However, for visitors with impaired 

mobility, the long-term effect would be moderate because of the loss of vehicle access to 

parts of the area. 

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

Some regrading at the lower Tower parking area 

could result in the loss of a small part of the 

natural soil profile on less than 1 acre. This loss 

would be permanent and irreversible. 

Severe flooding has been infrequent, and the 

risks are minor to moderate, but flooding could 

result in major adverse impacts on the visitors 

involved. Any loss of life would be irreversible. 

RELATIONSHIP OF SHORT-TERM USES 

OF THE ENVIRONMENT AND LONGTERM PRODUCTIVITY 

In alternative 2, the short-term disturbance of 

soils, vegetation, and wildlife habitat from constructing facilities and rehabilitating disturbed 

areas and the long-term loss of vegetation and 
Effects of Alternative 2 

111 

wildlife habitat from added paving would be 

more than offset by the long-term restoration of 

vegetation and wildlife habitat. 

Reducing the number of monument visitors 

during peak times would decrease crowding and 

traffic and lead to a major long-term improvement in the visitor experience. The monument’s 

air quality and natural sound would be improved 

at peak times over the long term. If visitors who 

could not get into the monument at peak times 

shifted their visits to off-peak times, there might 

be minor long-term degradation of air quality 

and natural sound at those times. The visitor 

experience would not be diminished at peak 

times because visitor facilities and programs 

could handle the peak visitation level. 

For American Indians and other visitors, the 

short-term visual intrusions from demolition, 

construction, and rehabilitation would give way 

to long-term improvements in the historic setting 

of the national register-listed historic district at 

the Tower, the ethnographic values at the Tower, 

and the views from the Tower. 

IMPAIRMENT 

The monument’s resources and values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 
112 

EFFECTS OF ALTERNATIVE 3 (PREFERRED ALTERNATIVE) 

NATURAL RESOURCES 

Soils 

In the gravel-surfaced lower parking area at the 

base of the tower, some regrading and possible 

construction of retaining walls would be necessary under alternative 3 before the area was 

paved. A small part of the natural soil profile 

could be lost on less than 1 acre. This would be 

a minor long-term adverse impact. 

Several impacts would result from the alternative 3 actions of converting the upper parking 

area at the Tower to a pedestrian plaza, paving 

the graveled parking area at the base of the 

Tower, rehabilitating one track of the Joyner 

Ridge trail, building a spur connecting the Joyner Ridge and Red Beds trails, widening the trail 

around the prairie dog town (gravel), developing 

a shuttle staging area, building a new intersection off the main road leading to the shuttle 

staging area, relocating the entrance station 

farther inside the monument, removing the 

campground, enlarging the headquarters building, and replacing the current prairie dog town 

pullouts with two enlarged pullouts. 

These actions would subject about 15 acres of 

soils to short-term disturbance. Most of the areas 

that would be affected have been disturbed 

previously. Erosion on those sites would be 

accelerated at least temporarily, until drainage 

structures were fully operational and vegetation 

had recovered. 

To mitigate adverse impacts, construction activity would be restricted to the minimum area required for building or rehabilitating, topsoil 

would be retained and replaced where possible 

to conserve the available organic matter, and 

most visitor developments would be built on 

slopes of less than 15% to minimize the soil erosion from foot traffic. Trails where heavy foot 

traffic was expected would be paved, visitors 

would be encouraged to stay on maintained 

trails, and special designs would be used for trail 

construction in areas with high slope and easily 

eroded soils. The adverse impacts on soils from 

increased erosion would be minor and short 

term. 

The net increase in paved surfaces (including 

gravel) in this alternative would be about 4 

acres. This would result from the actions described above for soil disturbance. In areas with 

hardened surfaces, the direct inflow of water to 

soil would be partially or totally eliminated, and 

precipitation would be collected and diverted to 

natural drainages. Runoff not collected and diverted to natural drainages would pour out onto 

adjacent areas, increasing the local soil moisture 

regime. Increased runoff in these areas would 

result in localized increases in erosion, changes 

in soil nutrient transport, and changes in the 

natural composition of vegetation. 

In addition to conserving and replacing topsoil 

from disturbed areas to minimize the loss of organic material, the National Park Service would 

reseed these areas with native species to speed 

the rate of recovery and to minimize the encroachment of invading species. Altered vegetative composition would create slight changes in 

the soil chemistry. These impacts have already 

occurred to some degree because all the areas 

involved have been previously disturbed. The 

adverse impacts on soil erosion, soil nutrient 

transport, and vegetative composition from an 

increase in hardened surfaces would be minor 

and long term. 

A total of 9 acres of soil would be rehabilitated 

by creating the pedestrian plaza, removing the 

old pullouts from the prairie dog town, rehabilitating one track of the Joyner Ridge trail, and 

restoring the developed camping area. This 

beneficial effect would be minor and long term. 

Conclusion: A small part of the natural soil 

profile would be lost on less than 1 acre. Despite 

efforts to prevent soil erosion, some soil probably would be eroded on 15 acres where construction and rehabilitation would be carried out. 

Additional hardened surfaces would cover 4 
Effects of Alternative 3 (Preferred Alternative) 

113 

acres of soil, and 9 acres would be rehabilitated. 

Therefore, the adverse impacts on soils from the 

preferred alternative would be minor and long 

term. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Vegetation 

Approximately 6 acres of disturbed vegetation 

would be lost from modifying the graveled parking area at the base of the Tower, widening the 

prairie dog town trail, developing a shuttle 

staging area, relocating the entrance station, 

enlarging headquarters, and creating a trail spur. 

This adverse impact would be minor and long 

term. 

Clearing some vegetation during construction 

could increase the relative abundance of species 

that invade disturbed areas. Increased erosion at 

these areas could expose root systems and lead 

to the subsequent death of more mesic plants 

(those needing a moderate amount of water). 

This adverse impact on previously disturbed 

vegetation would be minor and long term. 

Topsoil would be scraped off and set aside before construction began. To allow more rapid 

recovery of native vegetation and to minimize 

the encroachment of invading species, the topsoil subsequently would be replaced and reseeded with native species gathered in the monument 

or seeds gathered in the monument and propagated elsewhere. During the recovery period, the 

artificially seeded or replanted native vegetation 

would not be identical in composition to vegetation in adjacent areas. A reduction in the organic 

content of the soil would cause a slight change 

in species composition for several years. Because the affected area is already disturbed and 

the described mitigating measures would be 

taken, this adverse impact on previously disturbed vegetation would be minor and long term. 

The preservation of a prairie remnant in the 

northwest corner of the monument would be 

enhanced by closing the west and north roads to 

all but administrative and private use and reseeding one track of Joyner Ridge trail with 

native species. This beneficial effect on the 

prairie remnant would be minor and long term.

Approximately 9 acres would be revegetated at 

Joyner Ridge trail, the old prairie dog pullouts, 

the picnic area, the amphitheater, the trailer 

dropoff area, and the developed campground. 

Reseeding these areas with native species would 

speed the rate of recovery and minimize the 

encroachment of invading species. This beneficial effect on vegetation would be minor and 

long term. 

Conclusion: About 6 acres of disturbed 

vegetation would be lost, and 9 acres would be 

revegetated under this alternative. The relative 

abundance of invasive species could be increased by clearing some vegetation during construction. Increased erosion at cleared areas 

could expose root systems and lead to the death 

of more mesic plants. The preservation of a 

prairie remnant in the northwest corner of the 

monument would be enhanced. Overall, implementing the preferred alternative would result in 

minor long-term adverse impacts on vegetation. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 
ENVIRONMENTAL CONSEQUENCES

Wildlife 

Approximately 6 acres of wildlife habitat would 

be lost through enlarging the graveled parking 

area at the base of the Tower, building a trail 

spur, widening the trail through the prairie dog 

town, building a new intersection, relocating the 

entrance station, developing a shuttle staging 

area, and enlarging the headquarters building. 

Every effort would be made to avoid harm to the 

large cottonwood trees in the campground area, 

which provide habitat for wildlife. This adverse 

impact on already disturbed wildlife habitat 

would be minor and long term. 

A long-term increase of about 9 acres of wildlife 

habitat would be brought about by restoring to 

natural conditions one lane of the two-track Joyner Ridge trail, the former pullouts at the prairie 

dog town, and the developed campground. This 

beneficial effect on wildlife would be minor and 

long term. 

This alternative would result in a net gain of 

about 3 acres of wildlife habitat, which would be 

a minor beneficial effect in the long term. 

Invertebrates and small vertebrates can be destroyed by construction or displaced by changes 

in vegetation that result from construction. Small 

animals and birds usually are displaced and disrupted by the development of an area. Most 

areas that would be developed under alternative 

3 are already disturbed. The adverse impact on 

invertebrates and small vertebrates would be 

negligible and short term. 

Conclusion: Alternative 3 would result in 

the loss of approximately 6 acres of wildlife 

habitat, and 9 acres would be rehabilitated, so 

the net gain would be about 3 acres. Construction would destroy invertebrates and small vertebrates and probably displace and disrupt small 

mammals and birds. Overall, implementing the 

preferred alternative would result in minor longterm beneficial effects on wildlife. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Air Quality 

The air quality at the base of the Tower would 

improve because visitors’ vehicles would not go 

there during peak times. The air quality also 

would be improved because circling the parking 

lot to find a parking space would become unnecessary. There would be increased bus traffic, 

but drivers would not be allowed to idle bus engines, and buses would not be queuing because 

they would be on a schedule. This minor beneficial effect would last approximately four hours 

per day for 17 weeks each year. 

Requiring visitors to use the shuttle bus to get to 

the base of the Tower at peak times could result 

in the degradation of air quality because the 

level of bus activity in the monument could be 

high. Air quality would be most compromised at 

the shuttle staging area because automobile traffic, parking, and shuttle activity would be added. 

Shuttles would use the best available practical, 

low emission technology. The adverse effects on 

air quality from the shuttle system would be 

minor and short term. 

Removing the campground would improve the 

air quality because the associated wood smoke 

would be eliminated. This would be a minor 

beneficial long-term effect on air quality. 

Construction would cause only temporary, 

localized impacts on air quality, such as dust and 

diesel fumes from heavy equipment. This minor 

adverse effect would be short term. 

Conclusion: Establishing a shuttle system 

probably would improve the air quality at the 

base of the Tower and degrade it at the shuttle 

staging during peak times. The monument’s air 
Effects of Alternative 3 (Preferred Alternative) 

115 

quality would be improved by the absence of 

wood smoke when the campground was closed. 

The overall effect of alternative 3 on air quality 

in the peak season would be adverse minor 

short-term changes in air quality at the shuttle 

staging area 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Threatened, Endangered, and 

Candidate Species 

The habituation of prairie dogs to unnatural 

foods would continue. The monument staff 

would continue to educate visitors not to feed 

human food to prairie dogs. This would result in 

a minor beneficial long-term effect on prairie 

dogs. 

Widening the trail around the prairie dog town 

and covering it with gravel would reduce the 

habitat slightly (0.3 acre) and could lead to stress 

on individual prairie dogs along the trail edge. 

Widening probably would discourage visitors 

from wandering off the trail and therefore benefit the prairie dogs. Any displaced prairie dogs 

would move their burrows outside the new trail 

perimeter. The adverse impact on prairie dogs 

would be negligible and long term. 

Conclusion: A net loss of 0.8 acre in 

prairie dog habitat would be a minor long-term 

adverse impact on prairie dogs. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wetlands 

Enlarging the headquarters building and moving 

the parking lot to the back of the building would 

further encroach on 0.04 acre of wetland and 

result in the long-term loss of natural and beneficial values on less than 0.1 acre. This would be 

a long-term negligible impact on wetlands. Constructing the additions to the headquarters building would result in short-term disturbance of less 

than 0.5 acre of the wetland. This would be a 

minor long-term adverse impact on wetlands. 

Appendix E contains a statement of findings for 

wetlands. 

Conclusion: Enlarging the headquarters 

building and moving the parking lot to the back 

of the building would result in a long-term loss 

of about 0.04 acre of wetland, a long-term 

negligible adverse impact. The effect of a shortterm disturbance of 0.5 acre of wetland by construction would be minor. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Floodplains 

Natural and Beneficial Floodplain Values. 

The natural and beneficial values of floodplain 

areas would be restored in the area from which 

the campground, amphitheater, picnic area, and 

trailer dropoff would be removed. Removing the 
ENVIRONMENTAL CONSEQUENCES

campground would eliminate the possibility that 

campground fixtures and visitor camping equipment would enter floodwaters and clog the 

floodway. This major beneficial effect on natural 

processes would be long term. 

Flooding. Removing the 50-site campground 

and related structures and rehabilitating that part 

of the 100-year floodplain would eliminate the 

hazard to campers from flooding of the Belle 

Fourche River. Severe flooding has been infrequent, and the risks are minor to moderate, but 

the removal of the risk of flooding would be a 

major beneficial long-term effect on the visitors 

who might have been at risk. 

Conclusion: Removing the 50-site campground and related structures and rehabilitating 

the 100-year floodplain would restore natural 

and beneficial values of that area, a major longterm beneficial effect on the floodplain. Removing the campground from the floodplain 

also would result in a major beneficial effect on 

the visitors who might have been at risk. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Agriculture (including 

dryland farming) and ranching uses have greatly 

reduced native prairie plants and animals and led 

to the alteration and erosion of soils. Wildlife 

have been affected by being displaced, and 

habitat has been lost through agricultural uses, 

animals, and plants. Probably the greatest impact 

on wildlife at the monument has been the restriction of movement caused by fencing much of the 

perimeter along the south, east, and west boundaries. Wildlife are also disrupted by development, employees, and visitors. 

If the repaving and widening of the road was 

approved, approximately 0.5 acre of previously 

disturbed herbaceous vegetation along the road 

would be lost. Placing riprap in several locations 

to reduce the erosion of drainage ditches would 

result in the loss of 0.01 acre of grassland. Removing and revegetating at least four existing 

pullouts would result in the establishment of 

approximately 0.2 acre of additional grassland 

habitat dominated by native grasses and wildflowers. Small mammals would be displaced and 

native vegetation would be removed by these 

actions. 

The development of some private or state lands 

for tourist-related activities or for residential or 

other uses could increase runoff and soil compaction and could alter soil regimes and vegetative communities, as well as causing the loss 

of plants in some areas. Increased development 

outside the monument would further fragment 

wildlife habitat and interrupt wildlife habits and 

movement. Less land would be available for 

prairie dog habitation. Road kills of rodents, 

larger mammals, and birds would increase 

because added development probably would 

increase traffic. If visitation increased, bringing 

more traffic, the air quality would be degraded 

further. 

“The black-tailed prairie dog has undergone 

severe reduction in occupied range and population in Wyoming since settlement and the 

advent of farming and ranching. Occupied range 

has been reduced by over 80% from presettlement” (Campbell and Clark 1981). “Similar to other parts of the historical range, the 

major reduction in prairie dog populations 

probably occurred in the early 1900s when 

poisoning programs began in earnest”( AZ 

Game and Fish Dept. 1999). 

The implementation of the “Memorandum of 

Understanding among State Fish and Wildlife 

Agencies within Black-tailed Prairie Dog Range: 

Conservation and Management of Black-tailed 

Prairie Dog in North America” (9 of 11 states) 

might lead to the development and implementation of comprehensive state plans These plans 

would be designed to maintain the broadest dis-
Effects of Alternative 3 (Preferred Alternative) 

117 

tribution and greatest abundance possible within 

the fiscal realities of the state agencies and 

cooperating partners. 

Cooperative partnerships might be developed 

with interested individuals and with private, 

state, tribal, and federal land managers. However, implementing such plans would take 

several years. For the time being, it is not 

expected that landowners outside the monument 

would allow prairie dogs to move onto their 

land. Therefore, the prairie dog colony at Devils 

Tower would be unlikely to grow large enough 

to support ferrets and mountain plover. The 

population in the monument probably would 

continue to be small and isolated. 

As part of road repaving, wooden posts would 

be replaced along the road and at pullouts adjacent to the prairie dog colony. This could temporarily displace individual animals but would 

not be likely to result in mortality. In areas 

occupied by prairie dogs, the centerline of WY 

110 would be shifted north to avoid impacts on 

numerous burrows adjacent to the southern edge 

of the road (NPS 2000a). 

The construction of the Keyhole Dam has 

greatly reduced the extent of the floodplain, 

associated wetlands, and the natural and beneficial values of floodplains and wetlands. At 

least some wetlands in the area probably have 

been filled to make more land available for 

growing crops. Cattle and sheep probably have 

been allowed to use some wetland and riparian 

areas in the vicinity of the monument. These 

practices decrease the area of wetlands and degrade natural and beneficial floodplain values in 

exchange for benefits to agricultural uses. 

NPS structures and visitor uses in wetland and 

floodplain areas contribute to the loss of natural 

and beneficial values. Removing the campground, amphitheater, and picnic area from the 

100-year floodplain and restoring that area 

would result in a moderate long-term beneficial 

effect on floodplain values. Enlarging the headquarters building and moving the parking area to 

the back of the building would result in the longterm loss of 0.04 acre of wetland and a shortterm disturbance of 0.5 acre. To compensate for 

the 0.04 acre of wetland lost, a new wetland 

would be constructed as described in the “Statement of Findings” in appendix E. The presence 

of the dam would result in major long-term 

reductions in area and in beneficial values in 

floodplains and wetlands downstream of the 

dam on the Belle Fourche River. Repaving the 

main monument road would not result in any 

effect on any floodplain, wetland, or other water 

resources. 

Overall, the above past, present, and future 

actions, in conjunction with the impacts of this 

alternative, would result in major long-term 

adverse impacts on natural resources, including 

soils, vegetation, wildlife, prairie dogs, wetlands, and floodplains. Most impacts would result from previous actions, including agriculture, 

ranching, and dam construction. The impacts of 

alternative 3 would contribute a very small 

increment to the overall cumulative impact. 

CULTURAL RESOURCES 

Ethnographic Resources 

The viewshed in the Tower area would be improved through converting the paved upper 

parking area to a pedestrian plaza, removing the 

prairie dog town pullouts, and rehabilitating 

trails and disturbed areas. This would leave 

fewer traffic-related visual intrusions on culturally sensitive areas. Although the shuttles might 

be noisier than automobiles, the traffic noise 

would be of shorter duration with the shuttle 

system operating at peak times, and there would 

be fewer cars at the base of the Tower. Requiring visitors to use the shuttle or other nonmotorized means to reach the base of the Tower in 

peak times would reduce crowding at the base of 

the Tower. These actions would improve the 

ethnographic context of the area, provide more 

opportunities for solitude and quiet for traditional uses, and benefit American Indian tribes 

that might want to conduct religious activities at 

the Tower. This long-term beneficial effect on 

ethnographic resources would be moderate. 
ENVIRONMENTAL CONSEQUENCES

Reducing the concentrations of people in the 

monument’s northwest corner would give more 

protection to culturally sensitive areas and increase the opportunities for solitude in a larger 

area than in alternative 1. This beneficial effect 

on traditional cultural practices would be minor 

and long term. 

Because most American Indian religious practitioners come as individuals or in very small 

groups, the permitting requirements would result 

in a negligible long-term adverse impact on their 

traditional cultural practices. 

Adding high visibility visitor use areas would 

result in the perception of greater human presence in the viewshed and would potentially 

disturb traditional religious cultural practices. 

This adverse impact would be moderate and 

long term. 

Adding a spur trail between the Red Beds trail 

and the Joyner Ridge trail could bring more visitors into an area now little used, which offers 

great solitude for religious ceremonies. Funneling more visitors into that area could change the 

perception of solitude. This adverse impact 

would be minor and long term. 

Not allowing visitors on the north and west 

roads would reduce visual and auditory intrusions in this culturally sensitive area and increase the sense of solitude. This beneficial 

effect would be minor and long term. Reducing 

road access to traditional areas would not impede access. This long-term adverse impact 

would be negligible. 

Upgrading and formalizing the gravel-surfaced 

parking area at the base of the Tower would 

move the intrusion on the ethnographically 

sensitive area farther away. This long-term 

beneficial effect would be moderate. 

Discontinuing the use of the special permit 

camping area could inconvenience up to two 

parties of American Indians per year. No one has 

used the campground since 1999. This would be 

a minor long-term adverse impact on American 

Indians who might want to camp there. 

Visual and auditory intrusions would occur in 

the vicinity of all construction and rehabilitation 

activities. This minor adverse impact would be 

short term. 

Conclusion: Construction would have a 

minor short-term adverse impact on ethnographic resources. Some adverse impacts also 

would result from adding high visibility visitor 

use areas and from adding a spur trail between 

the Red Beds and Joyner Ridge trails. However, 

on balance, alternative 3 would result in a minor 

beneficial effect on ethnographic resources in 

the long term. This is because ethnographic resources would benefit from removing the paved 

upper parking area at the base of the Tower, 

creating a pedestrian plaza, moving the main 

parking area farther away from the base of the 

Tower, decreasing the number of prairie dog 

town pullouts, and rehabilitating trails and disturbed areas. Rehabilitating the developed campground, potentially allowing fewer visitors at 

one time at the base of the Tower, reducing the 

concentrations of people, establishing a shuttle 

system, and eliminating visitor access to the 

north and west roads also would benefit 

ethnographic resources. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Although past actions 

have affected ethnographic resources, no ongoing or future actions such as repaving the main 

road would have a perceptible impact on them. 

The actions of alternative 3 would not add 

appreciably to cumulative impacts. 
Effects of Alternative 3 (Preferred Alternative) 

119 

Historic Resources 

Removing the paved parking area at the base of 

the Tower and establishing a pedestrian plaza 

would partially restore the setting of the historic 

district listed on the national register, improve 

its integrity, and remove some visitor intrusions. 

Upgrading the graveled parking area at the base 

of the Tower for use as the principal parking 

area would move primary parking farther from 

the historic district. This beneficial effect on 

historic resources would be a moderate and long 

term.

Operating a shuttle during peak visitation 

periods and scheduling tour bus visits to the 

Tower would result in fewer traffic-related 

visual intrusions on culturally sensitive areas. 

This moderate long-term beneficial effect would 

occur during peak use periods. 

Construction activities would cause visual and 

auditory intrusions. These short-term adverse 

impacts would be minor. 

Conclusion: Visual and auditory intrusions 

from construction would result in short-term 

adverse impacts on historic resources. Beneficial 

effects on historic resources would result from 

removing the paved parking at the base of the 

Tower, establishing a pedestrian plaza, operating 

a shuttle during peak visitation periods, and 

scheduling tour bus visits to the Tower. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: The number and 

integrity of CCC-made roadway features (such 

as rock walls and culvert headwalls) would 

continue to be gradually reduced by traffic, 

erosion, natural processes, and highway 

construction. With continuing aging of these 

1930s structures, there is the potential for 

accelerated deterioration from natural causes, 

which could result in the loss of structural 

integrity and original materials. 

Repaving the main monument road would not 

affect the historic buildings. Burying the culvert 

headwall would have a minor long-term adverse 

impact on one roadway-contributing feature. A 

moderate long-term beneficial effect would result from rehabilitating the roadway. Traffic, 

natural processes, and new construction could 

damage or destroy CCC roadway structures, 

resulting in moderate adverse cumulative 

impacts in the long term. 

Overall, the above past, present, and future 

actions, in conjunction with the actions of this 

alternative, would result in long-term minor to 

moderate adverse impacts on historic resources. 

Most of these impacts would result from past 

actions and processes, including traffic, erosion, 

natural processes, and highway construction. 

The actions of alternative 3 would contribute a 

very small increment to the overall cumulative 

impact. 

Section 106 Summary: This summary was 

prepared with the use of the definitions of section 106 of the National Historic Preservation 

Act. 

Under the regulations of the Advisory Council 

on Historic Preservation (36 CFR 800.9) addressing the criteria of effect and adverse effect, 

the National Park Service finds that converting 

upper Tower parking area to a pedestrian plaza 

and moving the principal parking area farther 

away would have an effect that would not be 

adverse. 

Continuing the requirement for permits to use 

the northwest corner of the monument would 

have an effect on ethnographic resources that 

would not be adverse. 
ENVIRONMENTAL CONSEQUENCES

The actions of alternative 3, taken together, 

would have an effect on cultural resources that 

would not be adverse. 

VISITOR EXPERIENCE 

Visitors’ Experience of Monument Resources 

Managed visitation levels and the use of a 

shuttle system during peak times would decrease 

crowding, noise, and disruption in the Tower 

area. When the shuttle was operating, there 

would be a change from constant traffic noise to 

louder but less frequent noise events. Visitors 

would be free of the frustrations of searching for 

parking places and competing with large vehicles for parking and circulation space. Many 

would enjoy the opportunity to experience the 

scenery without the pressures of driving. Adding 

restrooms at the shuttle staging area would decrease visitor discomfort and frustration at the 

inadequacy of these facilities in the Tower area. 

Over time, most visitors would benefit from the 

overall reduction in crowding and traffic. This 

would be a major long-term beneficial effect on 

the visitor experience during the peak season. 

Replacing the existing paved parking area with a 

more natural pedestrian plaza and parking vehicles in the existing overflow parking area (farther from the base of the Tower) would make the 

setting for the Tower quieter and more contemplative. For many visitors, this setting would be 

much more commensurate with the Tower’s 

meaning and significance. Views from the 

Tower and areas at its base would be enhanced 

by the reduction of pavement near the Tower 

and by the vegetative screening of parked vehicles; however, paving the existing overflow 

parking area could have a minor adverse effect 

on the view. Overall, these changes would result 

in major long term beneficial effects, particularly for visitors arriving during peak use times. 

Modifying the Tower area facilities, constructing a shuttle staging area, and relocating the fee 

collection kiosk and the prairie dog town pullouts would result in short-term adverse impacts. 

The visitor experience would be affected by 

noise from construction vehicles and equipment, 

visual intrusions from ground and vegetation 

disturbance, more traffic, the presence of large 

construction vehicles, and general disruption of 

circulation. These impacts, although short term, 

could be moderate to major because they would 

occur in the monument’s prime resource areas. 

These impacts would be particularly severe for 

visitors who might have only one opportunity to 

visit Devils Tower and whose experiences were 

degraded by construction activities. 

New development and parking at the shuttle 

staging area would be visible from the Tower 

and the trails. The impacts on the viewshed from 

this development would be major because of its 

size. Using design and materials that would 

blend with the scene and maximizing vegetative 

screening could mitigate some of this impact. 

Noise would increase in the general area, and 

some animals and birds would be displaced, 

reducing visitors’ opportunities for viewing 

wildlife. Because these impacts would not occur 

in prime resource areas, the long-term impacts 

would be considered moderate. 

Removing the campground would result in the 

loss of overnight experiences for some visitors. 

Only a small percentage of visitors use the 

campground, but those who do value the quiet, 

shady character of the area. Camping is not 

fundamental to the mission of the monument, 

and other campgrounds are readily available 

outside the monument. For these reasons, and 

because a relatively small number of visitors 

would be affected, the loss of the campground 

would be a negligible to minor long-term 

adverse impact. 

Some long-term major beneficial effects would 

result from managing monument use in the 

northwest corner to protect the quiet, contemplative character of the visitor experience and from 

closing two road segments to visitor use. The 

viewshed would be improved, and vehicle traffic 

would disrupt natural sounds infrequently. Although only a small percentage of visitors would 

be affected directly by these changes, continuing 

to offer opportunities for solitude and quieter 

experiences would be a major benefit. Reducing 
Effects of Alternative 3 (Preferred Alternative) 

121 

road access could make access more difficult for 

some visitors, but this would be a minor impact 

because of the relatively short distances from the 

remaining road and the small number of visitors 

that would be affected. 

Adding a new trail spur to connect the Joyner 

Ridge and Red Beds trails would enhance visitor 

opportunities for solitude and wildlife viewing. 

Because only a small number of visitors would 

be affected, this long-term beneficial effect 

would be minor. 

Eliminating the special permit camping area 

would increase the overall natural setting. Since 

the disruption caused by the existing use and 

condition of the area is minor, this change would 

result in a minor effect. The special permit 

camping area, although rarely used, offers expanded opportunities for group recreation. However, because this activity is not fundamental to 

the monument’s mission and the number of visitors affected would be very small, this would be 

a negligible long-term adverse impact on groups. 

Redesigning the administrative headquarters 

could include relocating the parking area behind 

the building. This would allow better vegetative 

screening of the parking area from the main 

road; however, the viewshed from the Tower 

and trails would be adversely affected because 

of the increased size of the development. The 

overall effects, although long term, would be 

minor, considering the mixed beneficial and 

adverse results and the fact that there is 

development on the site now. 

Access and Freedom to 

Go at One’s Own Pace 

Visitors would not have the freedom to move 

around the monument at their own pace when 

the shuttle system was operating, and the shuttle 

might increase the cost of visiting the monument. Some visitors might choose not to visit 

Devils Tower because they would prefer not to 

use the shuttle. The shuttle would also change 

visitors’ experience from one of family or peer 

group to sharing at least part of the experience 

with groups of people unknown to them. Overall, the shuttle system would result in a longterm major adverse impact on visitors who place 

high value on spontaneity, privacy, and independence. This impact would be mitigated somewhat because the shuttle would operate only 

during the peak use season, and even at peak 

times there would be hours in the morning and 

evening when visitors would not be required to 

use the shuttle. 

The shuttle system would increase some visitor 

options for different experiences. For example, 

trails could be hiked one-way, since visitors 

could ride the shuttle to trailheads or use the 

shuttle to return to their cars after hiking. Based 

on current use patterns, it appears that a small 

percentage of visitors would be likely to take 

advantage of these opportunities; therefore, the 

long-term beneficial effect would be minor to 

moderate. 

Removing visitor parking from the existing 

paved area would slightly increase the walking 

distance to visitor facilities and the Tower’s 

base. This could particularly affect visitors with 

impaired mobility. Because the distance would 

not be great and design could minimize the 

grade, this long term impact would be minor. 

During times when the shuttle was operating, 

visitors might be dropped off closer to the base 

of the Tower than the parking spaces many are 

able to find at present. 

Redesigning the approach would make access to 

the Tower trail easier. Because the current approach is steep, redesign could improve access 

to the base of the Tower for a significant number 

of visitors, resulting in a long-term moderate to 

major beneficial effect. 

Using the shuttle system during peak use times 

would reduce or eliminate the waiting lines at 

the entrance station, thereby reducing visitor 

frustration. This long term improvement would 

result in a minor beneficial effect on most visitors, but the effect could be moderate during 

peak use times. 
ENVIRONMENTAL CONSEQUENCES

Reducing road access in the northwest corner of 

the monument and requiring use permits would 

further restrict visitors’ freedom of movement. 

Because only a small number of visitors would 

be affected, this long-term impact would be 

minor. However, for visitors with impaired mobility, the impact would be moderate because of 

the loss of vehicle access to some parts of the 

monument. 

Visitors would no longer be inconvenienced by 

the need to drop off towed vehicles before 

continuing along the road to the Tower area. 

Because only a small number of people would 

be affected, this long-term beneficial effect 

would be minor. 

Access to Orientation and Interpretation 

Opportunities for ranger contact and for more 

effective dissemination of interpretation and 

information would be greatly enhanced by the 

modifications in the Tower area and the reduced 

crowding. Visitors would be less distracted in 

the interpretive center, and the increased space 

in the pedestrian plaza would allow for better, 

quieter, less disrupted interpretive programs. 

There would be opportunities for new programs, 

and more in-depth orientation to resources 

would be available at the shuttle staging area. 

Visitors would have time to absorb more information while waiting for the shuttle, and more 

interpretation could be offered on the shuttle 

itself. 

More effective interpretation would result in 

greater visitor understanding of the monument’s 

significance. Better orientation information 

would help visitors make the best use of their 

time. Long-term improvements over the current 

information and interpretation programs (which 

are hampered by general crowding) would 

benefit most visitors; this would be a major 

beneficial effect. 

Visitor Safety 

Reducing traffic at the Tower area and providing 

pullouts on both sides of the road in the prairie 

dog town would decrease the potential for 

vehicle and vehicle-pedestrian accidents. 

Although vehicle accidents have been infrequent, reducing the risks would be a moderate 

long-term beneficial effect because the results of 

an accident could be major to the people 

involved. 

Conclusion: Managing visitation levels and 

instituting a shuttle system during peak times 

would decrease crowding, noise, and disruption 

in the Tower area. Many visitors would be able 

to experience the monument’s scenery without 

the pressures of driving. Over time, most visitors 

would benefit from the overall reduction in 

crowding and traffic; this beneficial effect on the 

visitor experience would be major, especially 

during peak seasons. Redesigning the access to 

the Tower trail would facilitate movement to the 

base of the Tower for a significant number of 

visitors; therefore, this beneficial effect would 

be moderate to major. 

Removing the campground would result in the 

loss of overnight experiences for some visitors. 

Only a small percentage of visitors camp in the 

monument, but those who do value the quiet, 

shady character of the area. Because a relatively 

small number of visitors would be affected, the 

loss of the campground would be a long-term 

minor adverse impact. 

Visitors would not have the freedom to move 

around the monument at their own pace when 

the shuttle system was operating, and the shuttle 

might increase the cost of visiting the monument. Some visitors might choose not to visit 

Devils Tower because they would prefer not to 

use the shuttle. Overall, the shuttle system would 

result in a long term major adverse impact on 

visitors who place high value on spontaneity, 

privacy, and independence. This impact would 

be mitigated somewhat because the shuttle 

would operate only during the peak use season, 

and even during peak use times there would be 

hours in the morning and evening when visitors 

would not be required to use the shuttle. 

Opportunities for ranger contact and for more 

effective dissemination of interpretation and 
Effects of Alternative 3 (Preferred Alternative) 

123 

information would be greatly enhanced by the 

modifications in the Tower area, reduced 

crowding, and the improvements at the prairie 

dog viewing area. There would be more opportunities for new programs, and more in-depth 

treatment of some themes would be available at 

the shuttle staging area and on the shuttle itself. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Although past actions 

have affected the visitor experience, no ongoing 

or future actions such as repaving the main road 

would have a perceptible impact on it. The 

actions of alternative 3 would not add appreciably to cumulative impacts. 

SOCIOECONOMIC RESOURCES 

Businesses and Neighbors 

The location of the Trading Post and KOA directly next to the monument would continue to 

give those businesses a distinct competitive advantage over commercial outlets farther from the 

entrance. This would be a moderate beneficial 

long-term effect for those businesses. 

As described before, a transportation study 

(Robert Peccia & Associates 1999) indicates that 

34% of the vehicles entering Devils Tower 

National Monument first enter the retail area 

immediately outside the entrance, 41% of the 

vehicles leaving enter the retail area immediately outside the entrance. Anecdotal reports 

from these businesses indicate that lines of 

traffic block monument visitors from entering 

the businesses. Without data on how many 

visitors want to stop at the retail area, and 

assuming that the same vehicles are not stopping 

upon entrance and exit, it appears that about 

75% of vehicles manage to stop at the retail 

area. Assuming that all 25% of the vehicles that 

do not stop contain visitors who would like to 

stop but are prevented from doing so by the 

traffic, moving the entrance station would allow 

most visitors to stop even during extreme 

periods of peak times. This intermittent longterm beneficial effect would be minor, occurring 

during the entire visitor use season. 

Eliminating campground loops A and B (50 

sites) would not cause a serious problem because 

campsites are available at other places in the surrounding area, and neighboring campgrounds 

would be able to absorb the campers who otherwise would have stayed at Devils Tower. For 

campers interested in being as close to the monument as possible, the KOA campground just 

outside the entrance would be the most likely 

beneficiary of the new business. For campers 

looking for the least expensive camping option, 

free camping is available at Tower View and on 

nearby Forest Service property. If campers displaced from Devils Tower chose to camp at the 

KOA campground, that would be a moderate to 

major beneficial effect in the long term on KOA 

revenues. Campers choosing to camp at Tower 

View would have a minor to moderate beneficial 

effect on that business in the long term, because 

even though camping there is free, campers 

staying there might buy food or other items. 

Eliminating camping in the monument would 

not decrease the overall number of people 

camping in the Devils Tower area. Consequently, overall visitor spending in the region 

would not decline. For purposes of example, the 

KOA campground charges roughly $25 per 

night for camping. At this rate, over the course 

of the camping season, revenues from camping 

at private campgrounds would increase by 

$102,500 per year. This would result in a moderate intermittent beneficial effect on local 

businesses. 

Conclusion: Assuming that all 25% of 

vehicles that do not stop at businesses adjacent 

to the monument contain visitors who would 
ENVIRONMENTAL CONSEQUENCES

like to stop but are prevented from doing so by 

the traffic, moving the entrance station would 

allow more of these visitors to stop. This minor 

beneficial effect would be intermittent and long 

term, occurring at peak times. 

Privately owned campgrounds in the region 

could potentially gain up to $102,500 per year in 

new business, a moderate and intermittent beneficial effect on local businesses in the long term.

Local and Regional Economy 

Local businesses could gain revenue of approximately $102,500 per year. Revenues from camping in the area would increase by about $20,500 

per year, a minor beneficial effect on the regional economy in the long term. Because revenue 

from camping in the monument is not taxable, as 

is camping outside the monument, alternative 3 

would result in an increase of approximately 

$102,500 in taxable revenues. This would be a 

minor beneficial long-term effect on local taxing 

authorities. 

Establishing a shuttle system to be operated 

during peak visitation periods would require that 

the Park Service contract with a shuttle operator. 

This would increase the potential income revenue for the area, a minor beneficial long-term 

effect on the local economy. 

A report prepared for the National Park Service 

by BRW (Byrne 2000) indicates that between 5 

and 20 shuttle drivers would be required. These 

would be part-time seasonal jobs. Depending on 

the shuttle option selected, the total hours of 

operation would range from 2,318 hours to 

10,046 hours. The BRW report also shows that a 

maintenance staff of two to five persons would 

be required to service the shuttle vehicles under 

various options. Maintenance would not be required year-round, but it would extend beyond 

the 17-week period in which the shuttle system 

would operate. An administrative staff of one to 

four people would be required to manage the 

system for the same period. 

Data in the 1998 Occupational Employment 

Statistics Wage Survey (WY Dept. of Employment 1998) show that auto repair, services, 

and parking jobs in the Devils Tower region pay 

an hourly mean wage of $8.99 for drivers and 

maintenance workers and $23.79 for managers. 

On the basis of projected hours of operation, the 

total seasonal wages paid to part-time shuttle 

drivers would range from $20,839 to $90,314. 

Maintenance wages would range from $16,542 

(shared by two persons) to $41,354 (shared by 

five persons) per year of shuttle operation. 

Managers’ wages would total from $21,887 (for 

one manager) to $87,547 (for four) per year of 

shuttle operation. 

Shuttle system employees would add to the 

food, fuel, and retail expenditures made at commercial enterprises near the monument. Fuel expenditures for the shuttles would be made locally, even if the fuel was obtained from Park 

Service fuel tanks inside the monument. This 

spending would be a long-term moderate benefit 

to retailers immediately outside the Devils 

Tower National Monument entrance and in 

nearby towns. Local jurisdictions would collect 

sales taxes on these expenditures, a minor longterm beneficial effect. 

According to an NPS cost estimate (under an 

option requiring only five buses) the cost of 

purchasing shuttle buses would be $1,240,000. 

These vehicles might or might not be bought in 

the region. If they were purchased in the region, 

the estimated sales tax revenue (with a 5% sales 

tax rate) would be $62,000, a minor short-term 

beneficial effect on Crook County. 

Crook County would also receive certain minimal sales and use tax revenues from the shuttle 

service provider, including a $60 fee for a sales 

tax license as well as an operating fee of $50 per 

vehicle per year. This would be a minor longterm beneficial effect on Crook County. 

The new restroom facilities included in this 

alternative would not affect local sewage and 

water systems because water and wastewater 

systems would be developed in the monument. 
Effects of Alternative 3 (Preferred Alternative) 

125 

The National Park Service’s cost estimate for the 

construction work of alternative 3 is roughly 

$3.8 million (excluding the cost of shuttle vehicles), of which approximately 50% would go 

toward labor, with the rest going for materials 

and services, according to rule-of-thumb estimates for the construction industry. This translates into the equivalent of 61 one-year construction jobs over the duration of the various construction periods. (The construction projects of 

this alternative, which could last from a week to 

more than a year, could include widening or 

narrowing monument roads, converting roads to 

hiking trails, converting the upper parking lot to 

a pedestrian plaza, removing the campground, 

preparing new exhibits and orientation space, 

and constructing shuttle system facilities. The 

Devils Tower staff might complete some projects, but private contractors would be hired for 

most of the work. Multiple projects might occur 

simultaneously.) 

Data in the 1998 Occupational Employment 

Statistics Wage Survey (Wyo. Dept. of Employment 1998) show that construction jobs in 

the Devils Tower region pay an hourly mean 

wage of $12.41. The equivalent of 61 one-year 

jobs would be created during the construction 

period, with a total payroll of roughly $1.9 

million. The short-term construction projects 

would contribute only a small percentage of the 

regional economy’s jobs and earnings. According to the Wyoming Department of Employment, approximately 2,100 of the 26,500-person 

labor force in Crook, Campbell, and Weston 

Counties were employed in the construction 

industry during the third quarter of 1999 (1,900 

of them in Campbell County). The creation of 61 

one-year construction jobs at Devils Tower 

would represent a small portion of the 2,100 

construction jobs in the area. Therefore, the construction at Devils Tower under alternative 3 

would have a minor short-term beneficial effect 

on the region’s overall employment. 

Short-term construction also would have certain 

spinoff effects. Construction laborers would add 

to the food, fuel, and possibly lodging expenditures made in the region for the duration of the 

construction period. This would directly benefit 

retailers immediately outside the Devils Tower 

National Monument entrance and in the nearest 

towns. This minor beneficial effect would be 

short term. 

Sales taxes collected on the expenditures of 

construction laborers would benefit local jurisdictions. According to the Crook County 

Treasurer’s Office, Crook County’s sales tax 

rate is 5%. Thus, sales taxes resulting from 

expenditures by construction laborers under 

alternative 3 would be a minor short-term beneficial effect on Crook County’ revenues. 

Assuming that construction materials purchased 

by contractors would not be subject to the 

National Park Service’s tax exempt status, local 

jurisdictions would have tax revenues of 

$95,000 on $1.9 million in purchases. The collection of about $95,000 in tax revenues would 

be a minor short-term beneficial effect on local 

jurisdictions. 

Construction materials (estimated at $1.9 

million) could be purchased in the region, 

resulting in a minor short-term beneficial effect 

for regional suppliers. 

Over roughly three years, dollars spent on construction would be circulated throughout the regional economy. According to data from the 

U.S. Bureau of Economic Analysis (BEA), the 

estimated amount of income generated throughout the state economy (above and beyond the 

$3.8 million in construction)by $3.8 million of 

new construction would be an additional total of 

$2,090,000 to $2,774,000. The range of spinoff 

income reflects the different BEA multipliers for 

new construction (1.5532) or maintenance and 

repair construction (1.7318) in Wyoming. This 

would be a minor long-term (3 years) beneficial 

effect on the regional economy. 

Conclusion: Converting the 50-site campground to other uses would increase revenues 

from camping to area businesses by about 

$102,500 per year, a long-term minor beneficial 

effect on the regional economy. Because revenue from camping in the monument is not taxable, as is revenue from camping outside the 
ENVIRONMENTAL CONSEQUENCES

monument, alternative 3 would result in an 

increase of approximately $102,500 in taxable 

revenues. This would be a minor beneficial 

long-term effect on local taxing authorities. 

Operating a shuttle service would have a small 

positive effect on employment opportunities and 

on the local and regional economy, including 

indirect effects on local businesses and tax revenues. Between 8 and 29 jobs could be created, 

with a total annual payroll of between $60,000 

and $220,000. Overall, the shuttle service would 

contribute only a small percentage of the regional economy’s jobs and earnings. 

The short-term construction projects of alternative 3 would positively affect employment opportunities and the local and regional economy, 

including indirect effects on local businesses and 

tax revenues. The equivalent of 61 one-year jobs 

would be created during the construction period, 

with a total payroll of roughly $1.9 million. The 

total benefit to Wyoming’s economy from the 

proposed construction would be up to 

$6,574,000. The short-term construction projects 

would contribute only a small percentage of the 

regional economy’s jobs and earnings. The 

creation of 61 one-year construction jobs at 

Devils Tower would represent a small portion of 

the 2,100 construction jobs in the area; therefore, 

construction at Devils Tower under this alternative would have a minor short-term effect on the 

region’s overall employment. 

Over roughly three years, the $3.8 million spent 

on construction would circulate throughout the 

regional economy to generate an additional total 

of $2,090,000 to $2,774,000 (above and beyond 

the $3.8 million in construction). This would be 

a minor long-term (3-year) beneficial effect on 

the regional economy. 

Cumulative Effects: Although past actions 

have impacted socioeconomic resources, no 

ongoing or future actions such as repaving the 

main road would have a perceptible impact on 

them. The actions of alternative 3 would not add 

appreciably to cumulative impacts. 

UNAVOIDABLE ADVERSE IMPACTS 

The following paragraphs describe the more 

important (moderate and major intensity) adverse impacts that would result from alternative 

3. These are residual impacts that would remain 

after mitigation was implemented. The negligible and minor impacts are described in the 

foregoing analysis. 

Cultural Resources 

Adding high visibility visitor use areas would 

result in the perception of greater human presence in the viewshed, potentially disturbing 

traditional religious cultural practices. This 

moderate adverse impact would be long term. 

Visitor Experience 

Modifying the Tower facilities, constructing a 

new shuttle staging area, and relocating the fee 

collection kiosk and the prairie dog town pullouts would result in short-term impacts from 

construction activities. The visitor experience 

would be affected by noise from construction 

vehicles and equipment, visual intrusions from 

ground and vegetation disturbance, more traffic, 

the presence of large construction vehicles, and 

general disruption of circulation and activities. 

These effects, although short term (less than one 

year) could be moderate to major because they 

would take place in the prime resource areas. 

The impacts would be particularly severe for 

visitors who might have only one opportunity to 

visit the monument and whose experiences were 

degraded by construction activities. 

New development and parking at the shuttle 

staging area would be visible from the Tower 

and the trails. Because of the size of this development, impacts on the viewshed would be 

major; however, some of it could be mitigated 

by using design and materials that would blend 

with the scene and by maximizing vegetative 

screening. Noise would increase in the general 

area, and some animals and birds would be displaced, reducing visitors’ opportunities for viewing wildlife. Because these impacts would not 
Effects of Alternative 3 (Preferred Alternative) 

127 

occur in prime resource areas, the impacts would 

be considered moderate. 

Visitors would not be free to move around the 

monument at their own pace when the shuttle 

system was operating, and the shuttle might 

increase the cost of visiting the monument. 

Some visitors might choose not to visit Devils 

Tower because they would prefer not to use the 

shuttle. The shuttle would also change visitors’ 

experiences from one of family or peer group to 

sharing at least part of the experience with 

people unknown to them. Overall, the shuttle 

system would result in a long-term major adverse impact on visitors who place high value on 

spontaneity, privacy, and independence. This 

impact would be mitigated somewhat because 

the shuttle would operate only in the peak use 

season, and even during peak use times there 

would be morning and evening hours when use 

of the shuttle would not be required. 

Reducing road access in the monument’s northwest corner and requiring use permits would 

increase restrictions on visitors’ freedom of 

movement. Because of the small number of 

people affected, this would be a minor impact. 

However, for visitors with impaired mobility, 

the effect would be moderate because of the loss 

of vehicle access to parts of the area. 

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

Some regrading of the graveled parking area at 

the base of the Tower could cause the loss of a 

small part of the natural soil profile on less than 

1 acre. This loss would be permanent and irreversible. 

RELATIONSHIP OF SHORT-TERM USES 

OF THE ENVIRONMENT AND LONGTERM PRODUCTIVITY 

In alternative 3, construction would disturb 

about 15 acres of natural resource areas in the 

short term. Less than half of the area would be 

covered by hardened surfaces, and more than 

half would be rehabilitated over the long term. 

For American Indians and other visitors, the 

short-term visual intrusions from demolition, 

construction, and rehabilitation would give way 

to long-term improvements in the historic setting 

of the national register-listed historic district at 

the base of the Tower and improvements in the 

views from the Tower. The long-term integrity 

of the national register-listed road could be 

compromised by realigning the administrative 

junction to accommodate the shuttle system. 

Reducing visitor and traffic congestion at the 

base of the Tower by using a shuttle system at 

peak times would cause a major long-term improvement in the visitor experience. Natural and 

cultural resource values at the Tower and natural 

values at the former campground, picnic, and 

trailer dropoff area would be improved.

Visitors would not have the option of driving to 

the base of the Tower unless there were special 

circumstances; this would represent a loss of 

some freedom. However, more interpretation 

and information would be available at the 

staging area and on the shuttle en route to the 

Tower. Air quality and natural sound would be 

improved at peak times over the long term. If 

visitors changed their visits from peak to offpeak times so that they could avoid using the 

shuttle system, there might be a minor long-term 

degradation of air quality and natural sound 

during off-peak times. 

IMPAIRMENT 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents.
128 

EFFECTS OF ALTERNATIVE 4 

NATURAL RESOURCES 

Soils 

In the lower parking area at the base of the 

Tower, some regrading and possible construction of retaining walls would be necessary before the area could be paved. A small part of the 

natural soil profile could be lost on less than 1 

acre. This would be a minor adverse long-term 

impact. 

A site has not been chosen, but about 5 acres 

outside the monument boundaries would be 

needed for about 5 acres of staging and other 

facilities. If an undisturbed site was chosen, 

construction activities could disrupt the natural 

soil profile on up to 5 acres, resulting in a minor 

long-term adverse impact on soils. 

Approximately 10 acres of monument soils 

would be disturbed in the short term by the 

actions of alternative 4. Most areas that would 

be affected have been previously disturbed. 

Erosion would be accelerated at least temporarily on sites where soils were disturbed until 

drainage structures were fully operational and 

vegetation had recovered. Inside the monument, 

such an impact would result from converting the 

upper parking area at the base of the Tower to a 

pedestrian plaza, paving the gravel-surfaced 

parking area, rehabilitating one track of Joyner 

Ridge trail, building a spur connecting the Joyner Ridge and Red Beds trails, widening the trail 

around the prairie dog town (gravel), building a 

new intersection off the main road leading to the 

shuttle dropoff area in the campground, removing the existing prairie dog town pullouts, and 

removing headquarters, parking, and 

maintenance. 

The site outside the monument would be disturbed by constructing an entrance station, a 

pedestrian plaza, facilities for headquarters and 

maintenance, passenger waiting areas, interpretive displays, restrooms, bus maintenance, and 

visitor parking. 

To mitigate the disturbance, construction would 

be restricted to the minimum area needed, topsoil would be retained and replaced where possible, and the developments would be built 

where slopes are less than 15% to minimize soil 

erosion from foot traffic. To minimize damage, 

trails would be paved in areas where heavy foot 

traffic was expected, and visitors would be 

encouraged to stay on maintained trails. In 

addition, special design methods would be used 

in areas with high slopes and easily eroded soils. 

With mitigation as described, the adverse effects 

on soils would be minor and short term. 

There would be no net increase of hardened 

surfaces (including gravel) inside the monument 

from converting the paved parking at the Tower 

to a pedestrian plaza, enlarging and paving the 

graveled parking area at the Tower, widening 

the existing lanes at the entrance station, widening and paving the trail in the prairie dog town, 

constructing a new intersection for the main 

road, and adding shuttle stops. Converting 

campground loop A to a shuttle stop would result in no net gain in hardened surface. The 

maximum increase in hardened surface outside 

the monument would be 5 acres; this would 

result from creating a shuttle staging area and 

adding facilities for headquarters and 

maintenance. 

Because the site for a staging area outside the 

monument has not been selected, it is not known 

if the site will have been previously disturbed. 

The total amount of hardened surface inside the 

monument would be reduced by removing the 

paved upper parking area at the base of the 

Tower and replacing it with a pedestrian plaza, 

removing pullouts from the prairie dog town, 

and removing headquarters, parking, and 

maintenance from the administrative area. 

In areas with hardened surfaces, the direct 

inflow of water to soil would be partially or 

totally eliminated, and precipitation would be 

collected and diverted to natural drainages. 

Runoff not collected and diverted to natural 
Effects of Alternative 4 

129 

drainages would pour out onto adjacent areas, 

increasing the local soil moisture regime. Increased runoff in these areas would result in 

localized increases in erosion, changes in soil 

nutrient transport, and changes in the natural 

composition of vegetation. In addition to conserving and replacing topsoil from disturbed 

areas to minimize the loss of organic material, 

these areas would be reseeded with native species to speed the rate of recovery and to minimize the encroachment of invading species. 

Altered vegetative composition would create 

slight changes in the soil chemistry. These impacts have already occurred to some degree 

because all the areas involved have been disturbed previously. The adverse impacts on soil 

erosion, soil nutrient transport, and vegetative 

composition from hardened surfaces would be 

minor and long term. 

A total of 4 acres of soil would be rehabilitated 

under alternative 4 by creating the pedestrian 

plaza, removing the prairie dog town pullouts, 

rehabilitating one track of the Joyner Ridge trail, 

and moving headquarters, parking, and maintenance facilities to areas outside the monument. 

This minor beneficial effect would be long term. 

Conclusion: Overall, up to 8 acres of 

natural soil profile would be lost. Despite efforts 

to prevent soil erosion, some soil probably 

would be eroded on about 10 acres that would be 

disturbed by construction and revegetation. A 

total of 4 more acres of soil would be covered 

with hardened surface, and 2 acres would be 

rehabilitated. Implementing alternative 4 would 

result in minor long-term adverse impacts on 

soils. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Vegetation 

About 2 acres of vegetation in the monument 

would be lost from modifying the graveled 

parking area at the base of the Tower, widening 

the lanes at the entrance station and the prairie 

dog town trail, constructing a new intersection 

for the main road near the shuttle stop at the 

campground area, and creating a shuttle stop. 

About 5 acres of vegetation outside the monument would be lost through creating an entrance 

station, a shuttle staging area, and facilities for 

headquarters, maintenance, and bus storage. 

This adverse impact on vegetation would be 

minor and long term. 

Clearing some vegetation during construction 

could increase the relative abundance of species 

that invade disturbed areas. Increased erosion at 

these areas could expose root systems and lead 

to the subsequent death of more mesic plants 

(those needing a moderate amount of water). 

This adverse impact would be minor and long 

term, probably on previously disturbed areas. 

Topsoil would be scraped off and set aside before construction began. It subsequently would 

be replaced and reseeded with seeds of native 

species gathered in the monument or with seeds 

gathered in the monument and propagated elsewhere to allow more rapid recovery of native 

vegetation and to minimize the encroachment of 

invading species. During the recovery period, 

the artificially seeded or replanted native vegetation would not be identical in composition to 

vegetation in adjacent areas. A reduction in the 

organic content of the soil would cause a slight 

change in species composition for several years. 

This adverse impact on previously disturbed 

vegetation would be minor and long term. 

The preservation of a prairie remnant in the 

northwest corner of the monument would be 

enhanced by closing the west and north roads to 

all but administrative and private use and reseeding one track of the Joyner Ridge trail with 

native species. This beneficial effect on the 

prairie remnant would be minor and long term.
ENVIRONMENTAL CONSEQUENCES

Approximately 2 acres would be revegetated at 

Joyner Ridge trail, the prairie dog pullouts, 

headquarters, headquarters parking, and maintenance. Reseeding these areas with native species would speed the rate of recovery and minimize the encroachment of invading species. This 

beneficial effect on vegetation inside the monument would be minor and long term. 

Conclusion: About 2 acres of disturbed 

vegetation inside the monument would be lost; 

as would up to 5 acres outside the monument. 

Clearing some vegetation during construction 

could increase the relative abundance of species 

that invade disturbed areas. Increased erosion at 

cleared areas could expose root systems, leading 

to the death of more mesic plants (those needing 

a moderate amount of water). Overall, implementing alternative 4 would result in minor 

long-term adverse impacts on vegetation. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wildlife 

Approximately 3 acres of wildlife habitat in the 

monument would be lost through enlarging the 

graveled parking at the Tower, building a trail 

spur, widening the lanes at the entrance station 

and the trail in the prairie dog town, building a 

new intersection for the main road near the 

shuttle stop at the campground area, and creating 

shuttle stops. Every effort would be made to 

avoid harm to the large cottonwood trees in the 

campground area, which provide habitat for 

wildlife. About 5 acres of wildlife habitat outside the monument would be lost through creating an entrance station, a shuttle staging area, 

and facilities for headquarters, maintenance, and 

bus storage. This adverse impact on wildlife 

habitat would be minor and long term. 

Wildlife habitat would be increased by about 2 

acres in the long term by rehabilitating one track 

of the Joyner Ridge trail, the prairie dog pullouts, and the former headquarters, parking, and 

maintenance facilities. This beneficial effect on 

wildlife habitat would be minor and long term. 

This alternative would result in a net loss of 

wildlife habitat of about 6 acres, which would be 

a minor long-term adverse impact. 

Invertebrates and small vertebrates can be destroyed by construction or displaced by changes 

in vegetation resulting from construction. Small 

animals and birds usually are displaced and disrupted by the development of an area. Most 

areas that would be developed under alternative 

4 already have been disturbed. The adverse 

impact on invertebrates and small vertebrates 

would be negligible and short term. 

Conclusion: Alternative 4 would result in 

the loss of approximately 8 acres of wildlife 

habitat, and 2 acres would be rehabilitated, so 

the net loss would be about 6 acres. Construction 

would destroy invertebrates and small vertebrates and probably displace and disrupt small 

mammals and birds. Overall, implementing 

alternative 4 would result in minor long-term 

adverse impacts on wildlife. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 
Effects of Alternative 4 

131 

Air Quality 

The air quality at the Tower would improve because visitors’ vehicles would not go there during peak times. The air quality also would be 

improved because circling the parking lot to find 

a parking space would become unnecessary. 

There would be increased bus traffic, but drivers 

would not be allowed to idle bus engines, and 

buses would not be queuing because they would 

be on a schedule. This minor beneficial effect 

would last approximately four hours per day for 

17 weeks each year. 

Requiring visitors to use the shuttle bus to get to 

the Tower at peak times could result in the 

degradation of air quality because the level of 

bus activity in the monument could be high. Air 

quality would be most compromised at the 

shuttle staging area and at the shuttle stop (now 

the picnic area, campground, trailer dropoff, and 

amphitheater) because automobile traffic, 

parking, and shuttle activity would be added. 

Shuttles would use the best available practical, 

low emission technology. The adverse effects on 

air quality from the shuttle system would be 

minor and short term. 

Air quality would be improved at the shuttle 

stop in the campground area because fewer 

vehicles would drive and park there, and wood 

smoke would be reduced. This minor beneficial 

effect would be long term. 

Construction would cause only temporary, localized impacts on air quality, such as dust and 

diesel fumes from heavy equipment. This minor 

adverse effect would be short term. 

Conclusion: Establishing a shuttle system 

would improve the air quality at the Tower and 

the shuttle stop at the former campground area 

and degrade it at the shuttle staging area outside 

the monument during peak times. The monument’s air quality would be improved by the 

absence of wood smoke from campground loop 

A and the special permit camping area. The 

overall effect on air quality from alternative 4 at 

the peak season would be minor short-term adverse changes at the shuttle staging area during 

peak times. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Threatened, Endangered, and 

Candidate Species 

Removing all automobile pullouts from the 

prairie dog town (0.2 acre) would disrupt prairie 

dog activity during construction, a minor shortterm negative impact. Restoring these areas to 

more natural conditions would reduce the interactions between visitors and prairie dogs. It also 

would reduce stress on the prairie dogs, eliminate their chances of being run over in pullouts, 

and make it more difficult for visitors to feed 

them human food. This would be a minor longterm beneficial effect on the prairie dogs.

Widening the trail around the prairie dog town 

and covering it with gravel would reduce the 

habitat slightly (0.3 acre) and could lead to stress 

on individual prairie dogs along the trail edge. 

Widening would discourage visitors from 

wandering off the trail, therefore benefiting the 

prairie dogs. Any displaced prairie dogs probably would move their burrows outside the new 

trail perimeter. This minor adverse impact on 

prairie dogs would be long term. 

Realigning the main road at the administrative 

junction would degrade prairie dog habitat on 

approximately 0.7 acre. This would be a minor 

long-term adverse impact on prairie dogs. 

Conclusion: A net loss of 0.8 acre in 

prairie dog habitat would be a minor long-term 

adverse impact on prairie dogs. 
ENVIRONMENTAL CONSEQUENCES

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wetlands 

Removing the headquarters and maintenance 

facilities and the trailer dropoff area and restoring the wetlands in that area would restore 

natural and beneficial wetlands values. This 

beneficial effect would be moderate and long 

term. 

Conclusion: Removing development from 

the wetlands and restoring natural and beneficial 

values would result in a long-term moderate 

beneficial effect. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Floodplains 

Natural and Beneficial Floodplain Values. 

Constructing a shuttle stop would decrease the 

absorption of water by the soil and occupy the 

floodplain. This major adverse impact on floodplains would be long term. It would be in conflict with the NPS policy of protecting natural 

and beneficial floodplain values and avoiding 

the occupancy of floodplains. If this alternative 

was selected, a statement of findings for 

floodplains would be prepared. 

Removing the maintenance complex from the 

500-year floodplain would increase natural and 

beneficial values in that area of the floodplain. 

This minor beneficial effect on floodplains 

would be long term. 

Flooding. Removing 20 of the 50 campground 

sites would decrease the overnight use of the 

floodplain, but some of the campground still 

would be occupied. If a 100-year flood occurred 

on the Belle Fourche River, the water in the 

campground would be 2 to 4 feet deep and of 

moderate velocity. In the past 40 years, two 

flood events from spring runoff and heavy rain 

covered the campground with 5 feet of water. 

Such an occurrence could be caused by heavy 

rain when the dam is already full or by flooding 

on one or more tributaries of the Belle Fourche. 

A breach of the Keyhole Dam would potentially 

cause a level of flooding that would endanger 

campers. These conditions would be hazardous 

to campground occupants; however, there is a 

convenient escape route to higher ground toward 

the northwest, and an evacuation plan would be 

developed in accordance with NPS policy. 

The Crook County Emergency Plan indicates 

that, “In the event of a dam breach at Keyhole, it 

will be approximately 3 hours before floodwaters reach Devils Tower National Monument.” 

However, even though an evacuation plan would 

be prepared and potential warning from operators of the Keyhole Dam would reduce the risk 

to campers, these visitors would remain in some 

danger. Communications might not always be 

fully comprehended or acted upon. Miscommunications could leave campers at risk in the 

event of a 100-year flood or breach of the 

Keyhole Dam. Severe flooding has been infrequent, and the risks are minor to moderate, but 

flooding could result in major adverse impacts 

on the visitors involved.

Conclusion: The occupation of the 100-

year floodplain by 30 campsites and the replacement of 20 campsites with a shuttle staging area 

would continue to have major long-term adverse 
Effects of Alternative 4 

133 

impacts on natural processes. These effects 

would be offset only partially by the long-term 

minor beneficial effect of removing the maintenance complex from the 500-year floodplain. 

Fewer campsites would remain in the 100-year 

floodplain. Severe flooding has been infrequent, 

and risks are minor to moderate, but flooding 

could result in major adverse impacts on the 

visitors involved. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Agriculture (including 

dryland farming) and ranching uses have greatly 

reduced native prairie plants and animals and led 

to the alteration and erosion of soils. Wildlife 

have been affected by being displaced, and habitat has been lost through agricultural uses, animals, and plants. Probably the greatest impact on 

wildlife at the monument has been the restriction 

of movement caused by fencing much of the 

perimeter along the south, east, and west boundaries. Wildlife are also disrupted by development, employees, and visitors. 

If the repaving and widening of the road was 

approved, approximately 1 acre of previously 

disturbed herbaceous vegetation along the road 

would be lost. Placing riprap in several locations 

to reduce the erosion of drainage ditches would 

result in the loss of 0.01 acre of grassland. Removing and revegetating at least four existing 

pullouts would result in the establishment of 

approximately 0.2 acre of additional grassland 

habitat dominated by native grasses and wildflowers. Small mammals would be displaced and 

native vegetation removed by these actions. 

Developing some private or state lands for 

tourist-related activities or for residential or 

other uses could increase runoff and soil compaction and could alter soil regimes and vegetative communities, as well as causing the loss of 

plants in some areas. Increased development 

outside the monument would further fragment 

wildlife habitat and interrupt wildlife habits and 

movement. Less land would be available for 

prairie dog habitation. Road kills of rodents, 

larger mammals, and birds would increase 

because more development probably would increase traffic. If visitation increased, bringing 

more traffic, the air quality would be degraded 

further. 

“The black-tailed prairie dog has undergone 

severe reduction in occupied range and population in Wyoming since settlement and the 

advent of farming and ranching. Occupied range 

has been reduced by over 80% from presettlement” (Campbell and Clark 1981). “Similar to other parts of the historical range, the 

major reduction in prairie dog populations 

probably occurred in the early 1900s when 

poisoning programs began in earnest”( AZ 

Game and Fish Dept. 1999). 

The implementation of the “Memorandum of 

Understanding among State Fish and Wildlife 

Agencies within Black-tailed Prairie Dog Range: 

Conservation and Management of Black-tailed 

Prairie Dog in North America” (9 of 11 states) 

might lead to the development and implementation of comprehensive state plans. These plans 

would be designed to maintain the broadest distribution and greatest abundance possible within 

the fiscal realities of the state agencies and 

cooperating partners. 

Cooperative partnerships might be developed 

with interested individuals and with private, 

state, tribal, and federal land managers. However, implementing such plans would take 

several years. For the time being, it is not 

expected that landowners outside the monument 

would allow prairie dogs to move onto their 

land. Therefore, the prairie dog colony at Devils 

Tower would be unlikely to grow large enough 

to support ferrets and mountain plover. The 

population in the monument probably would 

continue to be small and isolated. 
ENVIRONMENTAL CONSEQUENCES

As part of road repaving, wooden posts would 

be replaced along the road and at pullouts 

adjacent to the prairie dog colony. This could 

temporarily displace individual animals but 

would not be likely to result in mortality. In 

areas occupied by prairie dogs, the centerline of 

WY 110 would be shifted north to avoid impacts 

on numerous burrows adjacent to the southern 

edge of the road (NPS 2000a). 

The construction of the Keyhole Dam has 

greatly reduced the extent of the floodplain, 

associated wetlands, and the natural and beneficial values of floodplains and wetlands. At 

least some wetlands in the area probably have 

been filled to make more land available for 

growing crops. Cattle and sheep probably have 

been allowed to use some wetland and riparian 

areas in the vicinity of the monument. These 

practices decrease the area of wetlands and degrade natural and beneficial floodplain values in 

exchange for benefits to agricultural uses. 

NPS structures and visitor uses in wetland and 

floodplain areas contribute to the loss of natural 

and beneficial values. Removing the headquarters building, the maintenance facility, and the 

trailer dropoff area and restoring wetlands in 

those areas would result in a moderate long-term 

beneficial effect on wetlands. Replacing 20 

campsites in the 100-year floodplain with a lesspermeable shuttle staging area would be a moderate adverse impact. The presence of the dam 

would result in major long-term reductions in 

area and would reduce beneficial values in 

floodplains and wetlands downstream of the 

dam on the Belle Fourche River. Repaving the 

main monument road would not result in any 

effect on any floodplain or wetland. Further 

developments in floodplains and wetlands for 

residential, agricultural, or commercial uses 

would decrease the area on which natural and 

beneficial wetland and floodplain values would 

be preserved. 

Overall, the above past, present, and future 

actions, in conjunction with the impacts of 

alternative 4, would result in major long-term 

adverse impacts on natural resources, including 

soils, vegetation, wildlife, prairie dogs, wetlands, and floodplains. Most of the impacts 

would result from previous actions, including 

agriculture, ranching, and dam construction. The 

actions of alternative 4 would contribute a very 

small increment to the overall cumulative 

impact. 

CULTURAL RESOURCES 

Ethnographic Resources 

The viewshed in the Tower area would be improved through converting the paved upper 

parking area at the Tower to a pedestrian plaza, 

upgrading the gravel-surfaced parking area at 

the Tower, removing the prairie dog town pullouts and the headquarters and maintenance 

facilities, and rehabilitating trails and disturbed 

areas. This would leave fewer traffic-related 

visual intrusions on culturally sensitive areas. 

Although the shuttles might be noisier than automobiles, the traffic noise would be of shorter 

duration, and there would be fewer cars at the 

base of the Tower. Requiring visitors to use the 

shuttle or other nonmotorized means to reach the 

Tower at peak times would reduce crowding at 

the Tower. These actions would improve the 

ethnographic context of the area, offer more opportunities for solitude and quiet for traditional 

uses, and benefit American Indian tribes that 

might want to conduct religious activities at the 

Tower. This long-term beneficial effect on 

ethnographic resources would be moderate. 

Reducing the concentrations of people in the 

special permit zone (northwest corner of the 

monument) through permitting would give more 

protection to culturally sensitive areas and increase the opportunity for solitude in a larger 

area than in alternative 1. This beneficial effect 

on traditional cultural practices would be negligible and long term. Because most American 

Indian religious practitioners come as individuals or in very small groups, the permitting requirements would result in a negligible longterm adverse impact on their traditional cultural 

practices. Larger groups already are required to 

obtain permits; therefore, requiring groups of six 

or more to register with a ranger would continue 
Effects of Alternative 4 

135 

an existing practice. The long-term adverse 

effect on ethnographic resources would be 

negligible. 

Not allowing visitors on the north and west 

roads would reduce visual and auditory intrusions in this culturally sensitive area and 

increase the sense of solitude. This beneficial 

effect would be minor and long term. Closing 

two little-used roads to visitor use would not 

impede access to traditional areas because the 

main road would remain open. This long-term 

adverse impact would be negligible. 

Adding a spur trail between the Red Beds and 

Joyner Ridge trails could bring more visitors 

into an area that is now little used, which offers 

great solitude for religious ceremonies. Funneling more visitors into the area could change the 

perception of solitude. This adverse impact 

would be moderate and long term. 

Discontinuing the use of the special permit 

camping area could inconvenience up to two 

parties of American Indians per year. No groups 

have used the campground since 1999. This 

would be a minor long-term adverse impact on 

American Indians who might want to camp 

there. 

Visual and auditory intrusions would occur in 

the vicinity of all construction and rehabilitation 

activities. This minor adverse impact would be 

short term. 

Conclusion: Construction would have a 

minor short-term adverse impact on ethnographic resources. Some adverse impacts also would 

result from adding high visibility visitor use 

areas and from adding a spur trail between the 

Red Beds and Joyner Ridge trails. However, on 

balance, alternative 4 would result in a moderate 

beneficial effect on ethnographic resources in 

the long term. This is because removing the 

paved upper parking area, creating a pedestrian 

plaza, moving the main parking area farther 

away from the base of the Tower, and eliminating the prairie dog town pullouts would 

benefit ethnographic resources, as would rehabilitating trails, disturbed areas, and 20 sites of 

the developed campground. These actions 

potentially would allow fewer visitors at the 

base of the Tower at one time. Ethnographic 

resources also would benefit from reducing the 

concentrations of people, establishing a shuttle 

system, eliminating visitor access to the north 

road, and eliminating the west road. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Although past actions 

have affected ethnographic resources, no ongoing or future actions such as repaving the main 

road would have a perceptible impact on them. 

The actions of alternative 4 would not add 

appreciably to cumulative impacts. 

Historic Resources 

Converting the paved parking area at the base of 

the Tower to a pedestrian plaza would partially 

restore the setting of the historic district listed on 

the national register, improve its integrity, and 

remove some visitor intrusions. Upgrading the 

graveled parking area for use as the principal 

parking area would move primary parking 

farther from the historic district. This beneficial 

effect would be moderate and long term. 

Removing the prairie dog town pullouts would 

restore the original alignment of the national 

register-listed main road in that area. This beneficial effect on historic resources would be 

minor and long term. 

Operating a shuttle system during peak visitation 

periods and scheduling tour bus visits to the 

Tower would result in fewer traffic-related visual intrusions on culturally sensitive areas. This 
ENVIRONMENTAL CONSEQUENCES

moderate long-term beneficial effect would 

occur during peak use periods. 

Removing the headquarters and maintenance 

area from the monument would eliminate visual 

intrusions on the historic road corridor and 

improve the viewshed from the Tower, a culturally sensitive area. This moderate beneficial 

effect on the historic road corridor would be 

long term. 

Construction activities would cause visual and 

auditory intrusions. These short-term adverse 

impacts would be minor. 

Conclusion: Visual and auditory intrusions 

from construction would result in short-term 

adverse impacts on historic resources. Longterm beneficial effects on historic resources 

would result from converting the paved parking 

area at the base of the Tower to a pedestrian 

plaza, paving the graveled parking lot, operating 

a shuttle during peak visitation periods, and 

scheduling tour bus visits to the Tower. 

Realigning the main road at the administrative 

junction and the entrance road to accommodate 

the shuttle system could have adverse impacts 

on historic resources. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: The number and integrity of CCC-made roadway features (such as 

rock walls and culvert headwalls) would continue to be gradually reduced by traffic, erosion, 

natural processes, and highway construction. 

With continuing aging of these 1930s structures, 

there is the potential for accelerated deterioration from natural causes, which could result in 

the loss of structural integrity and original 

materials. 

Repaving the main monument road would not 

affect the historic buildings. Burying the culvert 

headwall would have a minor long-term adverse 

impact on one roadway-contributing feature. A 

moderate long-term beneficial effect would result from rehabilitating the roadway. Traffic, 

natural processes, and new construction could 

damage or destroy CCC roadway structures, 

resulting in moderate adverse cumulative 

impacts in the long term. 

Overall, the above past, present, and future 

actions, in conjunction with the impacts of this 

alternative, would result in long-term minor to 

moderate adverse impacts on historic resources. 

Most of these impacts would result from past 

actions and processes, including traffic, erosion, 

natural processes, and highway construction. 

The impacts of alternative 4 would contribute a 

very small increment to the overall cumulative 

impact. 

Section 106 Summary: This summary was 

prepared with the use of the definitions of section 106 of the National Historic Preservation 

Act. 

Under the regulations of the Advisory Council 

on Historic Preservation (36 CFR 800.9) addressing the criteria of effect and adverse effect, 

the National Park Service finds that converting 

upper Tower parking area to a pedestrian plaza 

and moving the principal parking area farther 

away would have an effect that would not be 

adverse. 

Because the main road has been realigned in the 

past, realigning it in this alternative would have 

an effect that would not be adverse. 

Continuing the requirement for permits to use 

the northwest corner of the monument would 

have an effect on ethnographic resources that 

would not be adverse. 
Effects of Alternative 4 

137 

The actions of alternative 4, taken together, 

would have an effect on cultural resources that 

would not be adverse. 

VISITOR EXPERIENCE 

Visitors’ Experience of Monument Resources 

As in the preferred alternative, managing visitation levels and requiring visitors to use a shuttle 

system during peak times would decrease noise, 

crowding, and disruption in the Tower area. 

When the shuttle was operating, there would be 

a change from constant traffic noise to louder 

but less frequent noise events. Visitors would be 

free of the frustrations of searching for parking 

places and competing with large vehicles for 

parking and circulation space. Many would enjoy the opportunity to experience the scenery 

without the pressures of driving. Adding restrooms at the shuttle staging area would decrease 

visitor discomfort and frustration at the inadequacy of these facilities in the Tower area. Over 

time, most visitors would benefit from the overall reduction in crowding and traffic. This would 

be a major long-term beneficial effect on the 

visitor experience, especially at peak times. 

Replacing the existing paved parking area with a 

more natural pedestrian plaza and parking vehicles in the existing overflow parking area 

(farther from the base of the Tower) would make 

the setting for viewing the Tower quieter and 

more contemplative. For many visitors, this setting would be much more commensurate with 

the Tower’s meaning and significance. Views 

from the Tower and areas at its base would be 

enhanced by the reduction of pavement near the 

Tower and by vegetative screening of parked 

vehicles; however, paving the existing overflow 

parking area could have a minor adverse effect 

on the view in the long term. Overall, these 

changes would result in major long-term beneficial effects on visitors, especially those who 

came during peak use times, because they would 

affect most visitors’ experiences of the monument’s prime resources. 

Construction activities to modify the Tower area 

facilities, remove the administrative and maintenance facilities, redesign the road intersection, 

and remove the parking pullouts at the prairie 

dog town would result in short-term adverse 

impacts. The visitor experience would be 

affected by noise from construction vehicles and 

equipment, visual intrusions from ground and 

vegetation disturbance, more traffic, the presence of large construction vehicles, and general 

disruption of circulation. These effects, although 

short term, could be moderate to major because 

they would affect many visitors and would occur 

in the monument’s prime resource areas. These 

impacts would be particularly severe for visitors 

who might have only one opportunity to visit 

Devils Tower and whose experiences were 

degraded by construction activities. 

At a staging area for the shuttle system outside 

the monument boundaries, visitors would have 

an opportunity to transition from driving the 

highway to entering the national monument. 

Minor confusion could result from visitor uncertainty about the relationship between the staging 

area and the actual entrance to the monument. 

New development would change the character of 

the existing entrance and modify the rural character of the surrounding area. Visitors might 

view these changes as beneficial or adverse, but 

they would be considered long-term minor effects because they would not affect experiences 

in prime resource areas. Depending on the location, design, and landscaping of the staging area, 

the development could be visible from the 

Tower or from the trails. An intrusive facility 

could cause a moderate to major adverse impact 

on views, especially if the experience in the 

Tower area was negatively affected. 

New development at the shuttle stop near the 

campground would be visible from the Tower 

and the trails. The adverse impacts on the viewshed from this development would be minor. 

Using design and materials that would blend 

with the scene and maximizing vegetative 

screening could mitigate some of this impact. 

Noise would increase in the general area, and 

some animals and birds would be displaced, 

reducing visitors’ opportunities for viewing 
ENVIRONMENTAL CONSEQUENCES

wildlife. Because these impacts would not occur 

in prime resource areas and the development 

would be small, the long-term adverse impacts 

would be minor. 

Providing new access to the prairie dog town 

and improving area trails would enhance most 

visitors’ experience of seeing the prairie dogs. 

People could watch the prairie dogs in a quieter 

setting free from the distraction of traffic congestion and from the safety concerns present at 

the existing parking pullouts along the main 

road. When the shuttle was not operating, some 

visitors might be frustrated because they would 

want to stop along the road at the first area 

where prairie dogs can be seen, but overall the 

effect on visitors from these changes would be 

long term and beneficial because most visitors 

value a chance to see wildlife. Removing the 

pullouts along the road, thus eliminating parked 

vehicles along the road, would result in a longterm beneficial effect on the viewshed from the 

Tower and the trails. The effect would be minor, 

because the viewshed still would be impaired by 

vehicles moving along the road.

Reducing the available campsites in the monument from 50 to 30 would result in some visitors 

being unable to spend a night in the national 

monument. Only a small number of visitors use 

the campground, but those who do value the 

quiet, shady character of the area. Camping is 

not fundamental to the mission of the monument, and other campgrounds are readily available outside the monument. For these reasons, 

and because a relatively small number of visitors 

would be affected, the loss of 20 camping spaces 

would be a negligible to minor long-term 

adverse effect. 

As in the preferred alternative, managing monument use in the northwest corner to protect the 

quiet, contemplative character of the visitor 

experience would result in some long term 

beneficial effects, as would closing two road 

segments to visitor use. The viewshed would be 

improved, and vehicle traffic would disrupt 

natural sounds only infrequently. Although only 

a small percentage of visitors would be affected 

directly by these changes, continuing to offer 

opportunities for solitude and quieter experiences would be a long-term benefit for visitors 

seeking these kinds of experiences. Because the 

area involved would be smaller than in alternative 2, this beneficial effect would be moderate. 

Reducing road access could make access more 

difficult for some visitors, but this would be a 

minor impact because of the relatively short 

distances from the remaining road and the small 

number of visitors that would be affected. 

Adding a new trail spur to connect the Joyner 

Ridge and Red Beds trails would enhance visitor 

opportunities for solitude and wildlife viewing. 

Because only a small numbers of visitors would 

be affected, this long-term beneficial effect 

would be minor. 

Eliminating the special permit camping area 

would increase the overall natural setting. Since 

the disruption caused by the existing use and 

condition of the area would be minor, this 

change would result in a minor effect. The special permit camping area, although not heavily 

used and not fundamental to the monument’s 

mission, offers expanded opportunities for group 

recreation. However, because the number of 

visitors affected would be small, eliminating 

camping in this area would result in a negligible 

long-term adverse impact on groups. 

Relocating the administrative headquarters and 

maintenance facilities would improve the viewshed from the Tower and the trails and along the 

main road. Removing these facilities from their 

present location and rehabilitating the area to a 

natural appearance would result in a long-term 

major beneficial effect on most visitors because 

the scenery along the road would be improved. 

The minor impacts resulting from visitor confusion between the administrative headquarters 

and the visitor center would be eliminated. 

Access and Freedom to Go 

at One’s Own Pace 

As in alternative 3, visitors would not be free to 

move around the monument at their own pace 

when the shuttle system was operating, and the 
Effects of Alternative 4 

139 

shuttle might increase the cost of visiting the 

monument. Some visitors might choose not to 

visit Devils Tower because they would prefer 

not to use the shuttle. People carrying gear for 

picnics or other activities would be inconvenienced by the need to transfer their belongings 

from their cars to the shuttle. The shuttle would 

also change visitors’ experience from one of 

family or peer group to sharing at least part of 

the experience with people unknown to them. 

Overall, the shuttle system would result in a 

long-term major adverse impact on visitors who 

place high value on spontaneity, privacy, and 

independence. This impact would be mitigated 

somewhat because the shuttle would operate 

only during the peak use season, and even at 

peak times there would be morning and evening 

hours when shuttle use would not be required. 

The shuttle system would increase some visitor 

options for different experiences. For example, 

trails could be hiked one-way since visitors 

could use the shuttle to trailheads or to return to 

their cars after the hike. Based on current use 

patterns, it appears that a small percentage of 

visitors would be likely to take advantage of 

these opportunities; therefore, the long-term 

beneficial effect would be minor to moderate. 

Removing visitor parking from the existing 

paved area would slightly increase the walking 

distance to visitor facilities and the Tower’s 

base. This could particularly affect visitors with 

impaired mobility. Because the distance would 

not be great and design could minimize the 

grade, this long-term impact would be minor. 

During times when the shuttle was operating, 

visitors might be dropped off closer to the 

Tower than the parking spaces many are able to 

find at present. 

Redesigning the approach would make access to 

the Tower trail easier. Because the current 

approach is steep, redesign could improve access 

to the base of the Tower for a significant number 

of visitors, resulting in a long-term moderate to 

major beneficial effect. 

Reducing road access in the northwest corner of 

the monument and requiring use permits would 

increase the restrictions on freedom of movement. Because only a small number of visitors 

would be affected, this long-term impact would 

be minor. However, for visitors with impaired 

mobility, the impact would be moderate because 

of the loss of vehicle access to some parts of the 

monument. 

Visitors no longer would be inconvenienced by 

the need to drop off towed vehicles before 

continuing along the road to the Tower area. 

Because of the small number of people affected, 

this long-term beneficial effect would be minor. 

Access to Orientation and Interpretation 

Opportunities for ranger contact and for more 

effective dissemination of interpretation and 

information would be greatly enhanced by the 

modifications in the Tower area, the reduced 

crowding, and the improvements to the prairie 

dog viewing area. Visitors would be less distracted in the visitor center, and more space in 

the pedestrian plaza and at the prairie dog town 

would allow for better, quieter, less disrupted 

interpretive programs. There would be opportunities for new programs, and more in-depth 

treatment of some themes would be available at 

the shuttle staging area, an improvement over 

the existing facilities. Visitors would have time 

to absorb more information while waiting for the 

shuttle, and more interpretation could be offered 

on the shuttle itself. 

More effective in-depth interpretation would 

result in greater visitor understanding of the 

monument’s significance. Better orientation 

information would help visitors make the best 

use of their time. Long-term improvements over 

the current information and interpretive programs (which are hampered by general crowding 

and inadequate facilities) would benefit most 

visitors; this would be a major beneficial effect. 

Visitor Safety 

Reducing traffic at the Tower area and along the 

main road and removing the parking pullouts at 

the prairie dog town would decrease the poten-
ENVIRONMENTAL CONSEQUENCES

tial for vehicle and vehicle-pedestrian accidents. 

Realigning the intersection between the main 

road and the access road to the new shuttle 

staging area would facilitate the safe movement 

of shuttle buses and visitor vehicles. Although 

vehicle accidents have been infrequent, reducing 

the risks would be a moderate long-term beneficial effect because the results of an accident 

could be major to the people involved. 

Cumulative Effects: Although past actions 

have affected the visitor experience, no ongoing 

or future actions such as repaving the main road 

would have a perceptible impact on it. The actions of alternative 4 would not add appreciably 

to cumulative impacts. 

Conclusion: Managing visitation levels and 

establishing a shuttle system for use at peak 

times would decrease crowding, noise, and disruption in the Tower area. The use levels probably would be lower than at present during peak 

use times, increasing somewhat at off-peak 

times. Many visitors would be able to experience the monument’s scenery without the 

pressures of driving. At a shuttle staging area 

outside the monument boundaries, visitors could 

transition from driving the highway to entering 

the national monument. Over time, most visitors 

would benefit from the overall reduction in 

crowding and traffic; this beneficial effect on the 

visitor experience would be major, especially 

during peak seasons. Redesigning the access to 

the Tower trail would facilitate movement to the 

base of the Tower for a significant number of 

visitors; therefore, this long-term beneficial 

effect would be moderate to major. 

Opportunities for ranger contact and more effective dissemination of interpretation and information would be greatly enhanced by the 

modifications in the Tower area, reduced crowding, and the improvements in the prairie dog 

viewing area. There would be more opportunities for new programs, and more in-depth treatment of some themes would be available at the 

shuttle staging area and on the shuttle itself. 

Overall, these long-term beneficial effects would 

be major. 

Visitors would not be free to move around the 

monument at their own pace when the shuttle 

system was operating, and the shuttle might increase the cost of visiting the monument. Some 

visitors might choose not to visit Devils Tower 

because they would prefer not to use the shuttle. 

Overall, the shuttle system would result in a 

long-term major adverse impact on visitors who 

place high value on spontaneity, privacy, and 

independence. This impact would be mitigated 

somewhat because the shuttle would operate 

only in the peak use season, and even during 

those times there would be morning and evening 

hours when shuttle use would not be required. 

Reducing the available campsites in the monument from 50 to 30 would result in some visitors 

being unable to spend a night in the national 

monument. Only a small number of visitors use 

the campground, but those who do value the 

quiet, shady character of the area. Because a 

relatively small number of visitors would be 

affected, the loss of 20 campsites would be a 

long term minor to moderate beneficial effect. 

SOCIOECONOMIC RESOURCES 

Businesses and Neighbors 

The location of the Trading Post and KOA 

adjacent to the monument would continue to 

give those businesses a distinct competitive 

advantage over commercial outlets farther from 

the entrance. This would be a moderate beneficial long-term effect for those businesses. 

As described before, a transportation study 

(Robert Peccia & Associates 1999) indicates that 

34% of the vehicles entering Devils Tower National Monument first enter the retail area immediately outside the entrance, 41% of the vehicles leaving enter the retail area immediately 

outside the entrance. Anecdotal reports from 

these businesses indicate that lines of traffic 

block monument visitors from entering the businesses. Placing another entrance station outside 

the monument would mean that there would be 

no waiting line of vehicles at the entrance during 

peak times because most visitors would enter on 
Effects of Alternative 4 

141 

shuttles from the staging area. Without data on 

how many visitors want to stop at the retail area, 

and assuming that the same vehicles are not 

stopping upon entrance and exit, it appears that 

about 75% of vehicles manage to stop at the 

retail area. Assuming that all 25% of the vehicles that do not stop contain visitors who 

would like to stop but are prevented from doing 

so by traffic, adding an entrance station at the 

shuttle staging area outside the monument 

boundary would allow all these visitors to stop. 

This long-term beneficial effect would be minor. 

Eliminating 20 campsites to make room for a 

paved parking area, a shuttle stop, and restrooms 

would not cause a serious problem because 

campers could camp in the surrounding area. 

Eliminating 40% of the monument’s campsites 

would not affect campers throughout most of the 

camping season; however, at peak times the 

remaining 30 monument campsites in loop B 

might not serve all prospective campers. Neighboring campgrounds have enough capacity for 

the campers who otherwise would have stayed in 

the national monument. This would be a minor 

short-term adverse impact on some campers 

during peak season. The KOA campground just 

outside the Devils Tower entrance would be the 

most likely beneficiary of the new business; 

thus, there would be a minor beneficial longterm effect on revenues at the KOA campground 

if campers displaced from Devils Tower campground chose to camp there. 

People looking for the least expensive camping 

option might take advantage of free camping at 

Tower View or on nearby Forest Service property. Campers who camped free might buy food 

or other items. This would result in a minor 

beneficial long-term effect on local business.

The overall number of people camping in the 

Devils Tower area would not decrease because 

monument campsites were reduced. Consequently, overall visitor spending in the region 

would not decline. For purposed of example, the 

KOA campground charges roughly $25 per 

night for camping. At this rate, over the course 

of the camping season, revenues from camping 

at private campgrounds would increase by 

$12,500 per year. This would result in a minor 

beneficial long-term effect on local businesses 

during camping season. 

Conclusion: Assuming that all 25% of the 

vehicles that do not stop at businesses adjacent 

to the monument contain visitors who would 

like to stop but are prevented from doing so by 

traffic, adding an entrance station at the shuttle 

staging area would allow all these visitors to 

stop. This minor beneficial effect would be long 

term. 

Privately owned campgrounds in the region 

could potentially gain up to $12,500 per year in 

new business. This would be a minor, intermittent beneficial effect on local businesses in the 

long term. 

Local and Regional Economy 

Local businesses could gain revenue of about 

$12,500 per year. Revenues from camping in the 

area would increase by about $2,500 per year, a 

minor long-term beneficial effect on the local 

and regional economy. Because revenue from 

camping in the monument is not taxable, as is 

revenue from camping outside the monument, 

alternative 4 would result in an increase of approximately $12,500 in taxable revenues. This 

would be a minor beneficial long-term impact on 

local taxing authorities. 

Establishing a shuttle system to be operated in 

peak use periods would require that the National 

Park Service contract with a shuttle operator. 

This would increase the potential income revenue for the area, a minor beneficial long-term 

effect on the local economy. 

A report prepared for the National Park Service 

by BRW (Byrne 2000) indicates that between 5 

and 20 shuttle drivers would be required. These 

would be part-time seasonal jobs. Depending on 

the shuttle option selected, the total hours of 

operation would range from 2,318 hours to 

10,046 hours. The BRW report also shows that a 

maintenance staff of two to five persons would 

be required to service the shuttle vehicles under 
ENVIRONMENTAL CONSEQUENCES

various options. Maintenance would not be required year-round, but it would extend beyond 

the 17-week period in which the shuttle system 

would operate. An administrative staff of one to 

four people would be needed to manage the system for the same period. 

Data in the 1998 Occupational Employment 

Statistics Wage Survey (Wyo. Dept. of Employment 1998) show that auto repair, services, and 

parking jobs in the Devils Tower region pay an 

hourly mean wage of $8.99 for drivers and 

maintenance workers and of $23.79 for managers. On the basis of projected hours of operation, the total seasonal wages paid to part-time 

shuttle drivers would range from $20,839 to 

$90,314. Maintenance wages would range from 

$16,542 (shared by two persons) to $41,354 

(shared by five persons) per year of shuttle 

operation. Managers’ wages would total from 

$21,887 (for one manager) to $87,547 (for four) 

per year of shuttle operation. 

Shuttle system employees would add to the 

food, fuel, and retail expenditures made at commercial enterprises near the monument. Fuel 

expenditures for the shuttles would be made 

locally, even if the fuel was obtained from Park 

Service fuel tanks inside the monument. This 

spending would be a long-term minor benefit to 

retailers immediately outside the Devils Tower 

National Monument entrance and in nearby 

towns. Local jurisdictions would collect sales 

taxes collected on these expenditures, a minor 

long-term beneficial effect. 

According to an NPS cost estimate (under an 

option requiring only five buses) the cost of 

purchasing shuttle buses would be $1,240,000. 

These vehicles might or might not be purchased 

in the region. If they were bought in the region, 

the estimated sales tax revenue (with a 5% tax 

rate) would be $62,000, a minor short-term 

beneficial effect on Crook County. 

Crook County would also receive certain minimal sales and use tax revenues from the shuttle 

service provider, including a $60 fee for a sales 

tax license as well as an operating fee of $50 per 

vehicle per year. This beneficial effect on Crook 

County would be minor and long term. 

The new restroom facilities included in this 

alternative would not affect local sewage and 

water systems because water and wastewater 

systems would be developed in the monument. 

Construction impacts would be felt primarily 

while construction was taking place, which 

would vary by project. Multiple projects could 

occur simultaneously. The National Park Service’s cost estimate for the construction work of 

alternative 4 is roughly $3.8 million (excluding 

the cost of the shuttle vehicles), of which approximately 50% would go toward labor, with 

the rest going for materials and services, according to the rule-of-thumb estimates for the construction industry. This translates into the equivalent of 61 one-year construction jobs over the 

duration of the various construction periods. 

(The construction projects of this alternative, 

which could last from a week to more than a 

year, could include widening or narrowing 

monument roads, converting roads to hiking 

trails, converting the upper parking lot to a 

pedestrian plaza, preparing new exhibits and 

orientation space, and constructing shuttle 

system facilities. The Devils Tower staff might 

complete some projects, but private contractors 

would be hired for most of the work. 

Data in the 1998 Occupational Employment 

Statistics Wage Survey (Wyo. Dept. of Employment 1998) show that construction jobs in the 

Devils Tower region pay an hourly mean wage 

of $12.41. The equivalent of 61 one-year jobs 

would be created during the construction period, 

with at total payroll of roughly $1.9 million. The 

construction projects would be short term and 

would amount to only a small percentage of the 

regional economy’s jobs and earnings. According to the Wyoming Department of Employment, approximately 2,100 of the 26,500-person 

labor force in Crook, Campbell, and Weston 

Counties were employed in the construction industry during the third quarter of 1999 (1,900 of 

them in Campbell County). The creation of 61 

one-year construction jobs at Devils Tower 

would represent a small portion of the 2,100 
Effects of Alternative 4 

143 

construction jobs in the area. Therefore, the 

construction at Devils Tower under alternative 4 

would have a minor short-term beneficial effect 

on the region’s overall employment. 

Short-term construction also would have certain 

spinoff effects. Construction laborers would add 

to the food, fuel, and possibly lodging expenditures made in the region for the duration of the 

construction period. This would directly benefit 

retailers immediately outside the Devils Tower 

National Monument entrance and in nearby 

towns. This minor beneficial effect would be 

short term. 

Sales taxes collected on the expenditures of 

construction laborers would benefit Crook 

County. According to the Crook County Treasurer’s Office, Crook County’s sales tax rate is 

5%. Assuming that construction materials purchased by contractors would not be subject to 

the National Park Service’s tax-exempt status, 

local jurisdictions would have tax revenues on 

$1.35 million in purchases of construction materials. The collection of about $67,500 in tax 

revenues would be a moderate short-term beneficial effect on county sales tax revenues. Construction in Crook County outside city limits is 

not subject to a permitting fee. There would be a 

minor beneficial short-term effect on Crook 

County from sales tax collected on the expenditures of construction laborers.

Construction materials (estimated at $1.9 

million) could be purchased in the region, benefiting regional suppliers. This beneficial effect 

would be minor and short term. 

Over roughly three years, money spent on construction would be circulated throughout the 

regional economy. According to data from the 

U. S., Bureau of Economic Analysis, the estimated amount of income generated by $3.8 

million of new construction would add 

$2,090,000 to $2,774,000 throughout the state 

economy (above and beyond the $3.8 million in 

construction). The range of spinoff income reflects the different BEA multipliers for new 

construction (1.5532) or maintenance and repair 

construction (1.7318) in Wyoming. This would 

be a minor long-term (approximately 3-year), 

beneficial effect on the regional economy. 

Conclusion: Converting the 20-site campground loop A to other uses would increase 

camping revenues to area businesses by about 

$2,500 per year, a long-term minor beneficial 

effect on the regional economy. Because revenue from camping in the monument is not taxable, as is revenue from camping outside the 

monument, alternative 4 would result in an increase of approximately $12,500 in taxable revenues. This would be a minor beneficial longterm effect on local taxing authorities. 

Operating a shuttle service would have a minor 

beneficial effect on employment opportunities 

and on the local and regional economy in the 

long term. There also would be indirect effects 

on local businesses and tax revenues. Between 8 

and 29 jobs could be created, with a total annual 

payroll of between $60,000 and $220,000. Overall, the shuttle service would contribute only a 

small percentage of the regional economy’s jobs 

and earnings. 

The short-term construction projects of alternative 4 would have a beneficial effect on employment opportunities and on the local and regional 

economy, including indirect effects on local 

businesses and tax revenues. The equivalent of 

61 one-year jobs would be created during the 

construction period, with a total payroll of 

roughly $1.9 million. The total benefit to Wyoming’s economy from the proposed construction 

would be up to $6,574,000. The short-term 

construction projects would contribute only a 

small percentage of the regional economy’s jobs 

and earnings. The creation of 61 one-year construction jobs at Devils Tower would represent a 

small portion of the 2,100 construction jobs in 

the area; therefore, construction at Devils Tower 

would have a minor short-term beneficial effect 

on the overall regional employment, businesses, 

and the local and regional economy. 

Over roughly three years, the $3.8 million spent 

on construction would circulate throughout the 

regional economy to generate an additional total 

of $2,090,000 to $2,774,000 (above and beyond 
ENVIRONMENTAL CONSEQUENCES

the $3.8 million in construction). This would be 

a minor long-term (approximately 3-year) beneficial effect on the regional economy. 

Cumulative Effects: Although past actions 

have impacted socioeconomic resources, no 

ongoing or future actions such as repaving the 

main road would have a perceptible impact on 

them. The actions of alternative 4 would not add 

appreciably to cumulative impacts. 

UNAVOIDABLE ADVERSE IMPACTS 

The following paragraphs describe the more 

important (moderate and major intensity) adverse impacts that would result from alternative 

4. These are residual impacts that would remain 

after mitigation was implemented. The negligible and minor impacts are described in the 

foregoing analysis. 

Natural Resources 

The occupation of the 100-year floodplain by 30 

campsites and the replacement of 20 campsites 

with a shuttle staging area would continue to 

have major long-term adverse impacts on natural 

processes. These effects would be offset only 

partially by the long-term minor beneficial effect 

of removing the maintenance complex from the 

500-year floodplain. Fewer campsites would 

remain in the 100-year floodplain. Severe flooding has been infrequent, and risks are minor to 

moderate, but flooding could result in major 

adverse impacts on the visitors involved. 

Cultural Resources 

Adding a spur trail between the Red Beds and 

Joyner Ridge trails could bring more visitors 

into a currently little used area that offers great 

solitude for religious ceremonies. Funneling 

more visitors into the area could change the 

perception of solitude. This moderate adverse 

impact would be long term. 

Visitor Experience 

Modifying the Tower facilities, moving the administrative and maintenance facilities to a 

location outside the boundaries, redesigning the 

road intersection, and removing the parking 

pullouts at the prairie dog town would result in 

short-term adverse impacts from construction 

activities. The visitor experience would be 

affected by noise from construction vehicles and 

equipment, visual intrusions from ground and 

vegetation disturbance, more traffic, the presence of large construction vehicles, and general 

disruption of circulation and activities. These 

effects, although short term, could be moderate 

to major because they would affect many visitors and would take place in the prime resource 

areas. The impacts would be particularly severe 

for visitors who might have only one opportunity to visit the monument and whose experiences 

were degraded by construction activities. 

At a shuttle staging area outside monument 

boundaries, visitors could transition from 

driving the highway to entering the national 

monument. Minor confusion could result from 

visitor uncertainty about the relationship between the staging area and the actual entrance to 

the monument. New development would change 

the character of the existing entrance and modify 

the rural character of the surrounding area. 

Visitors might view these changes as beneficial 

or adverse, but the impacts would be considered 

long-term and minor because they would not 

affect experiences in prime resource areas. 

Depending on the location, design, and landscaping of the staging area, the development 

could be visible from the Tower or from the 

trails. An intrusive facility could have a moderate to major adverse impact on views, especially if the experience in the Tower area was 

negatively affected. 

As in alternative 3, visitors would not be free to 

move around the monument at their own pace 

when the shuttle system was operating, and the 

shuttle might increase the cost of visiting the 

monument. Some visitors might choose not to 

visit Devils Tower because they would prefer 

not to use the shuttle. People carrying supplies 
Effects of Alternative 4 

145 

for picnics or other activities would be inconvenienced by the need to transfer their belongings from their cars to the shuttle. The shuttle 

would also change visitors’ experience from one 

of family or peer group to sharing at least part of 

the experience with people unknown to them. In 

total, the shuttle system would result in a longterm major adverse impact on visitors who place 

high value on spontaneity, privacy, and independence. This impact would be mitigated somewhat because the shuttle would operate only 

during the peak use season, and even at peak 

times there would be morning and evening hours 

when shuttle use would not be required. 

Reducing road access in the northwest corner of 

the monument and requiring use permits would 

increase the restrictions on freedom of movement. Because of the small number of visitors 

affected, this long-term impact would be minor. 

However, for visitors with impaired mobility, 

the effect would be moderate because of the loss 

of vehicle access to parts of the area. 

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

Some regrading of the graveled parking area at 

the base of the Tower could result in the loss of 

a small part of the natural soil profile on less 

than 1 acre. This loss would be permanent and 

irreversible. 

No selection has been made of a site outside the 

monument that would be used for staging and 

other facilities. About 5 acres would be needed. 

If an undisturbed site was chosen, up to 5 acres 

of the natural soil profile could be disturbed by 

construction. This adverse impact on soils would 

be minor and long term. 

Severe flooding has been infrequent, and the 

risks are minor to moderate; however, flooding 

could result in major adverse impacts on the 

visitors involved. Any loss of life would be 

irreversible. 

RELATIONSHIP OF SHORT-TERM USES 

OF THE ENVIRONMENT AND LONGTERM PRODUCTIVITY 

In alternative 4, about 10 acres of natural resource areas in the monument and 5 acres outside its boundaries would be disturbed in the 

short term by construction. There would be no 

net long-term increase in hardened surfaces in 

the monument, but hardened surfaces would be 

added to 5 acres outside the monument. For 

American Indians and other visitors, the shortterm visual intrusions from demolition, construction, and rehabilitation would give way to 

long-term improvements in the historic setting 

of the national register-listed historic district at 

the base of the Tower and improved views from 

the Tower. 

Reducing visitor and traffic congestion at the 

base of the Tower by using a shuttle system at 

peak times would cause a major long-term improvement in the visitor experience. Locating 

the shuttle staging area outside the monument 

would mean that land for parking could be expanded without enlarging the development footprint. A long-term loss of 20 campsites would 

result from shuttle staging and visitor parking. 

This course of action would remove two-thirds 

of the overnight visitor use from the floodplain, 

replacing it with daytime infrastructure and 

more daytime visitor use. Natural and cultural 

resource values at the Tower would be improved, but those values would be diminished in 

the campground, the picnic area, and the trailer 

dropoff area. 

Visitors would not have the option of driving to 

the base of the Tower at peak use times unless 

there were special circumstances; this would 

represent a loss of some freedom. However, 

more interpretation and information would be 

available at the staging area and on the shuttle en 

route to the Tower. There would be a long-term 

improvement of air quality and natural sound in 

the monument during peak times. If visitors 

changed their visits from peak to off-peak times 

so that they could avoid using the shuttle, there 

might be a minor long-term degradation of air 

quality and natural sound during off-peak times. 
ENVIRONMENTAL CONSEQUENCES

IMPAIRMENT 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 
147 

EFFECTS OF ALTERNATIVE 5 

NATURAL RESOURCES 

Soils 

Some regrading and possible construction of 

retaining walls would be necessary for enlarging 

the lower parking area at the base of the Tower 

and for widening Joyner Ridge Road and the 

main road through the prairie dog town. A small 

part of the natural soil profile could be lost on 

less than 1 acre. This would be a moderate 

adverse long-term impact. 

About 5 acres of soils would be subjected to 

short-term disturbance by the actions of alternative 5. Some areas that would be affected have 

been disturbed previously. Erosion would be 

accelerated at least temporarily on sites where 

soils were disturbed until drainage structures 

were fully operational and vegetation had recovered. This impact would result from enlarging 

the parking area at the Tower, constructing a 

comfort station, widening and paving Joyner 

Ridge Road, adding parking for 10 cars at the 

Joyner Ridge trailhead, widening the prairie dog 

town trail, , widening the main road at the prairie 

dog town to allow parking on both sides, and 

expanding the headquarters facility. 

To mitigate the disturbance, construction activity would be restricted to the minimum area 

needed, and topsoil would be retained and 

replaced where possible to conserve available 

organic matter. To minimize the soil erosion 

created by foot traffic, most developments 

would be constructed where the slopes are less 

than 15%, trails would be paved in areas where 

heavy foot traffic was expected, and visitors 

would be encouraged to stay on maintained 

trails. In addition, special design methods would 

be used in areas with high slopes and easily 

eroded soils. With mitigation as described, the 

adverse effects on soils from this alternative 

would be minor and short term. 

The net increase in hardened surfaces (including 

gravel) would be about 2 acres. This would result from building a comfort station and increasing paved parking at the Tower, expanding the 

headquarters, widening Joyner Ridge Road, enlarging trailhead parking, and widening prairie 

dog town trail and widening the road that leads 

through the prairie dog town to allow parking on 

both sides. In areas with hardened surfaces, the 

direct inflow of water to soil would be partially 

or totally eliminated, and precipitation would be 

collected and diverted to natural drainages. Runoff not collected and diverted to natural drainages would pour out onto adjacent areas, 

increasing the local soil moisture regime. More 

runoff in these areas would result in localized increases in erosion, changes in soil nutrient transport, and changes in the natural composition of 

vegetation. 

Altered vegetative composition would create 

slight changes in soil chemistry. Some of these 

impacts have already occurred in areas that have 

been disturbed. The adverse effects on soil 

erosion, soil nutrient transport, and vegetative 

composition from hardened surfaces would be 

moderate and long term, and much of it would 

occur in the prime resource area near the Tower. 

Conclusion: About 1 acre of natural soil 

profile would be lost under alternative 5. Despite 

efforts to prevent soil erosion, some soil probably would be eroded on about 5 acres disturbed 

by construction. About 2 more acres of soil 

would be covered with hardened surface, and 

none would be rehabilitated. Implementing alternative 5 would result in long-term moderate 

adverse impacts on soils. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 
ENVIRONMENTAL CONSEQUENCES

Vegetation 

About 3 acres of vegetation would be lost from 

enlarging the parking area at the Tower, widening and improving Joyner Ridge Road from the 

intersection with the main road to the Joyner 

Ridge trailhead, widening the prairie dog town 

trail, placing paved parking areas on both sides 

of the road through the prairie dog town, and 

enlarging the monument headquarters. This 

long-term adverse impact on vegetation would 

be minor. 

Clearing some vegetation during construction 

could increase the relative abundance of species 

that invade disturbed areas. Increased erosion at 

these area could expose root systems and lead to 

the subsequent death of more mesic plants (those 

requiring a moderate amount of water). This 

adverse impact on previously disturbed vegetation would be minor and long term. 

As mitigation, topsoil would be scraped off and 

set aside before construction began. It subsequently would be replaced and reseeded with 

seeds of native species gathered in the monument or with seeds gathered in the monument 

and propagated elsewhere to allow more rapid 

recovery of native vegetation and to minimize 

the encroachment of invading species. During 

the recovery period, the artificially seeded or 

replanted native vegetation would not be identical in composition to vegetation in adjacent 

areas. A reduction in the organic content of the 

soil would cause a slight change in species 

composition for several years. This adverse 

impact on previously-disturbed vegetation 

would be minor and long term. 

Conclusion: About 3 acres of disturbed 

vegetation would be lost under alternative 5, and 

none of the areas would be revegetated. Clearing 

some vegetation during construction could increase the relative abundance of species that 

invade disturbed areas. Increased erosion at 

cleared areas could expose root systems and lead 

to the death of more mesic plants (those needing 

a moderate amount of water). Overall, implementing alternative 5 would result in minor 

long-term adverse impacts on vegetation 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wildlife 

About 3 acres of wildlife habitat in the monument would be lost from enlarging the lower 

parking area at the Tower, widening and improving Joyner Ridge Road from the intersection 

with the main road to the Joyner Ridge trail access, widening the trail through the prairie dog 

town, placing paved parking areas on both sides 

of the road through the prairie dog town, and 

enlarging the monument headquarters. This adverse impact on wildlife habitat would be minor 

and long term. 

A net loss of about 3 acres of wildlife habitat 

would result from implementing alternative 5. 

This adverse impact would be minor and long 

term. 

Invertebrates and small vertebrates can be destroyed by construction or displaced by changes 

in vegetation resulting from construction. Small 

mammals and birds usually are displaced and 

disrupted by the development of an area. Some 

areas that would be developed under alternative 

5 have been disturbed already. This negligible 

adverse impact on invertebrates and small 

vertebrates would be short term. 

Conclusion: Alternative 5 would result in 

the loss of approximately 3 acres of wildlife 

habitat. Construction would destroy invertebrates and small vertebrates and probably displace and disrupt small mammals and birds. 

Overall, alternative 5 would cause minor longterm adverse impacts on wildlife. 
Effects of Alternative 5 

149 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Air Quality 

During peak visitation periods, the monument’s 

air quality would be further degraded by greater 

numbers of vehicles at the base of the Tower. 

The impacts would be greatest during the peak 

visitor season. Continued degradation of the air 

quality might result from tour buses idling their 

engines while parked near the Tower. These 

adverse impacts on air quality would be 

negligible and long term. 

Construction would cause only temporary, localized impacts on air quality, such as dust and 

diesel fumes from heavy equipment. This negligible adverse impact would be short term. 

Conclusion: Compared to alternative 1, the 

impacts on air quality from alternative 5 would 

be greater because there would be more visitors 

and visitor vehicles, especially at the base of the 

Tower. These adverse impacts would be negligible and long term. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Threatened, Endangered, and 

Candidate Species 

Adding parking on both sides of the road 

through the prairie dog town would disrupt 

prairie dog habitat more than the actions of any 

other alternative. The net increase in disrupted 

area would amount to about 1 acre more than in 

the no-action alternative. Increasing parking 

would make conditions less-natural, increase 

interactions between visitors and prairie dogs, 

cause more stress on the prairie dogs, and increase areas where visitors might feed them 

human food. This would be a minor long-term 

adverse impact on prairie dogs and their habitat. 

Widening and paving the trail around the prairie 

dog town would reduce the habitat slightly (0.3 

acre) and could lead to stress on individual 

prairie dogs along the trail edge. Widening 

would discourage visitors from wandering off 

the trail and therefore would benefit the prairie 

dogs. Any displaced prairie dogs probably 

would move their burrows outside the new trail 

perimeter. This minor adverse impact on prairie 

dogs would be long term. 

Conclusion: A net loss of about 1 acre of 

prairie dog habitat would be a minor long-term 

adverse impact on prairie dogs. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Wetlands 

Enlarging the headquarters building would result 

in the long-term loss of natural and beneficial 

wetland values on less than 0.04 acre. A statement of findings for wetlands would be prepared 
ENVIRONMENTAL CONSEQUENCES

if this alternative was selected for implementation. The loss of wetland values of 0.04 acre 

would be a minor long-term adverse impact on 

wetlands. 

Continuing the use of the special permit campground once or twice a year would continue the 

risk that campers might walk through a nearby 

wetland on their way to the river; this would 

compromise the natural functioning of this 

wetland. This negligible adverse impact on 

wetlands would be long term. 

Conclusion: Enlarging the monument 

headquarters would result in the loss of 0.04 acre 

of wetland, a minor long-term adverse impact on 

wetlands. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Floodplains 

Natural and Beneficial Floodplain Values. 

The natural and beneficial values of floodplains 

would continue to be compromised by the presence of the 50-site campground. This continuing 

adverse impact on natural processes would be 

major and long term. 

Flooding. Under alternative 5 the 50-site campground would continue to occupy the 100-year 

floodplain. If a 100-year flood occurred on the 

Belle Fourche River, water in the campground 

would be 2 to 4 feet deep and of moderate 

velocity. In the past 40 years, two flood events 

from spring runoff and heavy rain covered the 

campground with 5 feet of water. Such an occurrence could be caused by heavy rain when the 

dam is already full or by flooding on one or 

more tributaries of the Belle Fourche. A breach 

of the Keyhole Dam would potentially cause a 

level of flooding that would endanger campers. 

These conditions would be hazardous to campground occupants, but there is a convenient 

escape route to higher ground toward the northwest, and an evacuation plan would be developed in accordance with NPS policy. 

The Crook County Emergency Plan indicates 

that, “In the event of a dam breach at Keyhole, it 

will be approximately 3 hours before floodwaters reach Devils Tower National Monument.” 

However, even though an evacuation plan would 

be prepared and potential warning from operators of the Keyhole Dam would reduce the risk 

to campers, these visitors would remain in some 

danger. Communications might not always be 

fully comprehended or acted upon. Miscommunications could leave campers at risk in the 

event of a 100-year flood or breach of the Keyhole Dam. Severe flooding has been infrequent, 

and risks are minor to moderate, but the results 

of flooding could cause major adverse impacts 

on the visitors involved.

Conclusion: The natural and beneficial 

values of floodplain areas would continue to be 

compromised by the presence of the 50-site 

campground. This continuing long-term adverse 

impact on natural processes would be major. 

Although severe flooding has been infrequent 

and risks are minor to moderate, flooding could 

result in major adverse impacts on the visitors 

involved. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Agriculture (including 

dryland farming) and ranching uses have greatly 
Effects of Alternative 5 

151 

reduced native prairie plants and animals and led 

to the alteration and erosion of soils. Wildlife 

have been affected by being displaced, and habitat has been lost through agricultural uses, animals, and plants. Probably the greatest impact on 

wildlife at the monument has been the restriction 

of movement caused by fencing much of the 

perimeter along the south, east, and west boundaries. Wildlife also are disrupted by development, employees, and visitors. 

If the road was widened and repaved, approximately 0.68 acre of previously disturbed herbaceous vegetation along the road would be lost. 

Placing riprap in several locations to reduce the 

erosion of drainage ditches would result in the 

loss of 0.01 acre of grassland. Removing and 

revegetating at least four existing pullouts would 

result in the establishment of approximately 0.2 

acre of additional grassland habitat dominated 

by native grasses and wildflowers. Small mammals would be displaced and native vegetation 

would be removed by these actions. 

The development of some private or state lands 

for tourist-related activities or for residential or 

other uses could increase runoff and soil compaction and could alter soil regimes and vegetative communities, as well as causing the loss 

of plants in some areas. Increased development 

outside the monument would further fragment 

wildlife habitat and interrupt wildlife habits and 

movement. Less land would be available for 

prairie dog habitation. Road kills of rodents, 

larger mammals, and birds would increase 

because more development probably would 

increase traffic. If visitation increased, bringing 

more traffic, the air quality would be degraded 

further. 

“The black-tailed prairie dog has undergone 

severe reduction in occupied range and population in Wyoming since settlement and the advent of farming and ranching. Occupied range 

has been reduced by over 80% from presettlement” (Campbell and Clark 1981). “Similar to other parts of the historical range, the 

major reduction in prairie dog populations probably occurred in the early 1900s when poisoning 

programs began in earnest”(AZ Game and Fish 

Dept. 1999). 

The implementation of the “Memorandum of 

Understanding among State Fish and Wildlife 

Agencies within Black-tailed Prairie Dog Range: 

Conservation and Management of Black-tailed 

Prairie Dog in North America” (9 of 11 states) 

might lead to the development and implementation of comprehensive state plans. These plans 

would be designed to maintain the broadest distribution and greatest abundance possible within 

the fiscal realities of the state agencies and 

cooperating partners. 

Cooperative partnerships might be developed 

with interested individuals and with private, 

state, tribal, and federal land managers. 

However, implementing such plans would take 

several years. For the time being, it is not 

expected that landowners outside the monument 

would allow prairie dogs to move onto their 

land. Therefore, the Devils Tower prairie dog 

colony would be unlikely to grow large enough 

to support ferrets and mountain plover. The 

population probably would continue to be small 

and isolated. 

As part of road repaving, wooden posts would 

be replaced along the road and at pullouts adjacent to the prairie dog colony. This could 

temporarily displace individual animals but 

would not be likely to result in mortality. In 

areas occupied by prairie dogs, the centerline of 

WY 110 would be shifted north to avoid impacts 

on numerous burrows adjacent to the southern 

edge of the road (NPS 2000a). 

The construction of the Keyhole Dam has 

greatly reduced the extent of the floodplain, 

associated wetlands, and the natural and beneficial values of floodplains and wetlands. At 

least some wetlands in the area probably have 

been filled to make more land available for 

growing crops. Cattle and sheep probably have 

been allowed to use some wetland and riparian 

areas in the vicinity of the monument. These 

practices decrease the area of wetlands and 

degrade natural and beneficial floodplain values 

in exchange for benefits to agricultural uses. 
ENVIRONMENTAL CONSEQUENCES

NPS structures and visitor uses in wetland and 

floodplain areas contribute to the loss of natural 

and beneficial values. Enlarging the headquarters building would result in the long-term loss 

of 0.04 acre of wetland and a short-term disturbance of 0.5 acre. Should this alternative be 

implemented, a statement of findings for wetlands would be prepared, including a wetlands 

restoration plan. Alternative 5 would not involve 

removing activities and structures from floodplains and wetlands or restoring natural and 

beneficial values in or outside the monument. 

The presence of the dam would result in major 

long-term reductions in area and in beneficial 

values in floodplains and wetlands downstream 

of the dam on the Belle Fourche River. Repaving the main monument road would not result in 

any effect on any floodplain or wetland. Further 

development of floodplains and wetlands for 

residential, agricultural, or commercial uses 

would decrease the area on which natural and 

beneficial wetland and floodplain values would 

be preserved. 

Overall, the above past, present, and future 

actions, in conjunction with the actions of this 

alternative, would result in major long-term 

adverse impacts on natural resources, including 

soils, vegetation, wildlife, prairie dogs, wetlands, and floodplains. Most impacts would 

result from previous actions, including agriculture, ranching, and dam construction. Alternative 5 would contribute a very small increment 

to the overall cumulative impact. 

CULTURAL RESOURCES 

Ethnographic Resources 

Increased visitor access and associated development in several areas of the monument would 

detract from the solitude sought for religious 

ceremonies. This alternative, which calls for the 

highest level of development, would compromise the ethnographic resources of the Tower 

area and degrade the viewshed by increasing 

visitor use and vehicular traffic at the Tower and 

at the Joyner Ridge access road and trailhead. 

The ethnographic resources also would be compromised by paving the former trailer dropoff 

area to be used for tour bus parking. This longterm adverse impact on ethnographic resources 

would be moderate. 

Reducing the concentrations of people in the 

northwest corner of the monument would give 

more protection to culturally sensitive areas and 

increase the opportunity for solitude in a smaller 

area than in alternatives 2, 3, and 4. Because 

most American Indian religious practitioners 

come as individuals or in very small groups, the 

permitting requirements would result in a negligible long-term adverse effect on their traditional cultural practices. Larger groups already are 

required to obtain permits; therefore, requiring 

groups of six or more to register with a ranger 

would continue an existing practice. The longterm adverse effect on ethnographic resources 

would be negligible. 

Visual, auditory, and atmospheric intrusions 

would occur in the vicinity of all construction 

activities. These minor adverse impacts would 

be short term. 

Conclusion: Increased visitor access and 

associated development in several areas of the 

monument would detract from the solitude 

sought for religious ceremonies. This alternative, 

which calls for the highest level of development, 

would compromise the ethnographic resources 

of the Tower area and degrade the viewshed by 

increasing visitor use and vehicular traffic at the 

Tower and at the Joyner Ridge access road and 

trailhead. .The ethnographic resources also 

would be compromised by paving the trailer 

dropoff area to be used for tour bus parking. 

This long-term adverse impact on ethnographic 

resources would be moderate. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 
Effects of Alternative 5 

153 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Although past actions 

have affected ethnographic resources, no ongoing or future actions such as repaving the main 

road would have a perceptible impact on them. 

The actions of alternative 5 would not add 

appreciably to cumulative impacts. 

Historic Resources 

Visitor activity and traffic congestion would 

continue at the historic district at the base of the 

Tower and in the viewshed from the Tower. The 

buildings were intended to facilitate visitor use 

of the area, but the degree of congestion has 

increased so much over the years that each year 

there is a minor adverse impact on the historic 

setting during peak times. 

Historic fabric could be lost and new visual 

nonhistoric elements could be introduced as a 

result of making historic buildings and structures 

accessible to people with impaired mobility to 

comply with the Architectural Barriers Act of 

1968 and the Rehabilitation Act of 1973. The 

monument would develop design solutions using 

the Secretary of the Interior’s Standards to meet 

accessibility requirements while minimizing 

impacts on cultural resources. Impacts would be 

assessed when specific proposals were evaluated. Any actions would be expected to have no 

more than a minor effect on historic buildings 

and structures. 

The historic road corridor would be modified by 

adding parking lanes on both sides of the road at 

the prairie dog town, redesigning the entrance 

station area, and enlarging the headquarters 

building. These long-term adverse effects would 

be moderate. 

Redesigning the entrance station area would 

change the setting of the national register-listed 

entrance station. The impact that this action 

would have cannot be known without more 

information on the details of design. This action 

could require additional mitigation to comply 

with section 106 of the National Historic 

Preservation Act. 

Widening the road through the prairie dog town 

could alter some of the CCC elements of the 

historic road, such as culverts. The impact that 

this action would have cannot be known without 

more information on the details of design. This 

action could require additional mitigation to 

comply with section 106 of the National Historic 

Preservation Act. 

Construction activities would cause visual, 

auditory, and atmospheric intrusions. These 

short-term adverse impacts would be minor. 

Conclusion: Visitor activity and traffic 

congestion would continue at the historic district 

at the base of the Tower and in the viewshed 

from the Tower. This adverse impact on the historic setting during peak times would be minor. 

Modifying the historic road corridor by adding 

parking lanes on both sides at the prairie dog 

town, redesigning the entrance station area, and 

increasing the size of the headquarters would 

result in a moderate long-term adverse impact. 

Redesigning the entrance station area would 

change the setting of the national register-listed 

entrance station. Widening the road through the 

prairie dog town could alter CCC elements of 

the historic road, such as culverts. The impacts 

that these actions would have cannot be known 

without more information on the details of design. One or both of these actions could require 

additional mitigation to comply with section 106 

of the National Historic Preservation Act. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 
ENVIRONMENTAL CONSEQUENCES

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: The number and integrity of CCC-made roadway features (such as 

rock walls and culvert headwalls) would continue to be gradually reduced by traffic, erosion, 

natural processes, and highway construction. 

With continuing aging of these 1930s structures, 

there is the potential for accelerated deterioration from natural causes, which could result in 

the loss of structural integrity and original 

materials. 

Repaving the main monument road would not 

affect the historic buildings. Burying the culvert 

headwall would have a minor long-term adverse 

effect on one roadway contributing feature. A 

moderate long-term beneficial effect would 

result from rehabilitating the roadway. Traffic, 

natural processes, and new construction could 

damage or destroy CCC roadway structures, 

resulting in moderate long-term adverse cumulative impacts. 

Overall, the above past, present, and future 

actions, in conjunction with the actions of this 

alternative, would result in long-term minor to 

moderate adverse impacts on historic resources. 

Most impacts would result from past actions and 

processes, including traffic, erosion, natural 

processes, and highway construction. Alternative 5 would contribute a very small increment 

to the overall cumulative impact. 

Section 106 Summary: This summary was 

prepared with the use of the definitions of section 106 of the National Historic Preservation 

Act. 

Under the regulations of the Advisory Council 

on Historic Preservation (36 CFR 800.9) addressing the criteria of effect and adverse effect, 

the National Park Service finds that enlarging 

the paved and gravel-surfaced parking areas at 

the base of the Tower would be a visual intrusion on the historic district and the ethnographic 

resource. It would be adverse. 

Because the main road has been realigned in the 

past, realigning it in this alternative would have 

an effect that would not be adverse. 

Continuing the requirement for permits to use 

the northwest corner of the monument would 

have an effect on ethnographic resources that 

would not be adverse. 

The actions of alternative 5, taken together, 

would have an effect on cultural resources that 

would be adverse. 

VISITOR EXPERIENCE 

Visitors’ Experience of Monument Resources 

Adding more parking at the Tower area would 

reduce visitor frustration because visitors could 

find parking places more easily than at present. 

Improving the area’s overall design would improve safety and help traffic to flow more efficiently. However, congestion and noise in the 

area would continue. The sounds and smells of 

automobiles and buses would mask natural 

sounds and smells, especially during peak use 

times. 

More pavement would be visible from the 

Tower and the Tower trail. For many visitors, 

the overall level of development and activity at 

the base of the Tower would be inconsistent 

with the Tower’s significance. Adding more 

restrooms would reduce the time that visitors 

would spend waiting in line. Although these 

effects would be an improvement over existing 

conditions, the experience of the prime monument resource would continue to be degraded by 

noise, traffic, and vehicle smells. Because most 

visitors in this prime resource area would be affected, this long-term adverse impact on visitors 

at peak use times would be moderate to major. 

Adding vehicle pullouts along both sides of the 

road at the prairie dog town would increase the 

opportunities for visitors to stop, get out of their 

cars, walk along a widened surfaced trail, and 

watch prairie dogs “up close.” This opportunity 

for close interaction with wildlife would be a 
Effects of Alternative 5 

155 

continued major beneficial effect for most visitors because of the high value that many people 

place on viewing wildlife. 

Construction activities to add a new parking area 

near the Tower, improve the entrance station, 

enlarge the headquarters, pave the trailer dropoff 

area, improve parking at the Joyner Ridge trailhead parking area, and add new parking pullouts 

at the prairie dog town would result in shortterm impacts. The visitor experience would be 

affected by noise from construction vehicles and 

equipment, visual intrusions from ground and 

vegetation disturbance, more traffic, the presence of large construction vehicles, and general 

disruption of circulation. These effects, although 

short term, could be moderate to major because 

they would occur in the monument’s prime resource areas. These effects would be particularly 

severe for visitors who might have only one 

opportunity to visit Devils Tower and whose 

experiences were degraded by construction 

activities. 

The visitor experience offered by the campground and the picnic area, while important to 

some visitors, is not fundamental to the monument’s significance. Nevertheless, continuing 

these assets would constitute a long term moderate beneficial effect for visitors because of the 

popularity of these facilities. 

The natural setting of the Tower area and the 

view from the Tower and the trails would be 

degraded by visual intrusions from parked vehicles, lights at night, and developments associated with the campground, the picnic area, the 

trailer dropoff area, and administrative headquarters. However, these adverse visual impacts 

would be minor because the developments 

would be relatively low key and would be somewhat screened by vegetation. Nevertheless, 

lights at night would continue to disrupt the 

view for the small numbers of visitors who 

might be at or on the Tower at night. This 

impact would be minor. 

The quietest, most natural experiences in the 

monument are available in its northwest corner. 

Views of the Tower are outstanding, and the 

viewshed is virtually pristine. Although this area 

is not heavily visited, these kinds of experiences 

are important to the visitors who go there. Managing this small area specifically for these opportunities would result in a long-term moderate 

benefit for visitors. 

Although the undeveloped, informal large group 

permit camping area near the entrance is not 

heavily used and not fundamental to the monument’s mission, this area offers expanded opportunities for group recreation, but it also results in 

a minor adverse impact on the viewshed from 

the Tower and the trails. Continuing the availability of permit camping in this area would 

result in a minor long-term benefit for the 

groups served. 

Access and Freedom to Go 

at One’s Own Pace 

Under alternative 5, visitors would be free to 

come and go around the monument at their own 

pace, depending on the availability of parking. 

For visitors to whom spontaneity is important, 

this freedom of movement would be perceived 

as a long term major beneficial effect. 

Access to the Tower trail would continue to be 

congested during peak times, but modifying the 

steep trail approach for easier access would. 

result in a long term major beneficial effect for 

visitors who otherwise might be unable to 

experience the Tower. 

Traffic congestion at the prairie dog town would 

cause frustration for visitors. This would be a 

minor adverse impact on most visitors during 

periods of low visitation. However, at peak use 

times the impact would be moderate, particularly 

if a visitor’s time in the monument was limited. 

Under alternative 5, visitors would not be inconvenienced by the need to drop off their towed 

vehicles before driving up to the Tower. This 

beneficial long-term effect would be minor because of the small number of people involved. 
ENVIRONMENTAL CONSEQUENCES

Upgrading the fee collection kiosk would reduce 

waiting times. Because most visitors would be 

affected, these changes could result in a moderate beneficial effect on visitors, especially at 

peak use times. 

Upgrading the access road and parking at the 

Joyner Ridge trailhead could encourage more 

visitors to use the trail system. This would increase the range of activities and experiences for 

visitors who chose to hike. Because only a small 

number of visitors would be attracted to the 

Joyner Ridge area, this long-term beneficial 

effect would be minor. 

Access to Orientation and Interpretation 

The Tower visitor center facility would be too 

small to accommodate orientation and interpretive functions. Interpretive programs outside the 

visitor center in the Tower area would be limited 

by inadequate space and disruption by crowding, 

noise, and traffic. Some interpretation would be 

offered at the enlarged administrative headquarters building along the main road. 

Overall, visitor frustration over a lack of orientation and interpretation would continue because 

of the facility limitations and crowding at the 

Tower area and in the visitor center. The limitations on interpretive opportunities would 

constitute a moderate to major adverse impact 

on visitors, many of whom place a high value on 

interpretive services. 

Visitor Safety 

Some vehicle accidents in the Tower area might 

result from traffic congestion and the need to 

manipulate large vehicles in a small space. The 

parking pullouts and pedestrian activity at the 

prairie dog town would lead to some traffic congestion and threaten the safety of vehicles and 

pedestrians. Vehicle accidents in the monument 

have been infrequent, and risks are considered 

minor to moderate, but an accident could cause a 

major adverse impact on the people involved. 

Conclusion: Added parking in the Tower 

area would reduce visitor frustration because 

finding a parking place would be easier than 

before. Better overall design would foster more 

efficient and safer traffic flow. However, congestion and noise would continue. Although 

these effects would be an improvement over 

existing conditions, noise, traffic, and vehicle 

smells would continue to degrade the experience 

of the monument’s prime resources. This longterm adverse impact on visitors would be moderate to major at peak use times. An improved 

approach to the Tower trail would have a major 

beneficial effect on visitors who otherwise might 

be unable to have a close experience of the 

Tower. 

The Tower visitor center facility would be too 

small to accommodate orientation and interpretive functions, and its size could be reduced 

further to increase the number of restrooms. 

Some interpretation would be offered at the 

enlarged administrative headquarters building 

along the main road. Overall, visitor frustration 

over a lack of orientation and interpretation 

would continue because of the facility limitations and crowding at the Tower area and in the 

visitor center. The limitations on interpretive 

opportunities would constitute a long term moderate to major adverse impact on visitors. 

Visitors would be free to come and go around 

the monument at their own pace, depending on 

the availability of parking. For visitors to whom 

spontaneity is important, this freedom of movement would be perceived as a long term major 

beneficial effect. 

Although it is important to some visitors, the 

visitor experience offered by the campground 

and picnic area is not fundamental to the monument’s significance. Nevertheless, continuing 

these assets would constitute a long term moderate beneficial effect on visitors because of the 

popularity of these facilities. 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 
Effects of Alternative 5 

157 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 

Cumulative Effects: Although past actions 

have affected the visitor experience, no ongoing 

or future actions such as repaving the main road 

would have a perceptible impact on it. The 

actions of alternative 5 would not add appreciably to cumulative impacts. 

SOCIOECONOMIC RESOURCES 

Businesses and Neighbors 

The location of the Trading Post and KOA 

adjacent to the monument would continue to 

give those businesses a distinct competitive 

advantage over commercial outlets farther from 

the entrance. This would be a moderate beneficial long-term effect on those businesses. 

As was described before, a transportation study 

(Robert Peccia & Associates 1999) indicates that 

34% of the vehicles entering Devils Tower 

National Monument first enter the retail area 

immediately outside the entrance, and 41% of 

the vehicles leaving enter the retail area immediately outside the entrance. Anecdotal reports 

from these businesses indicate that lines of traffic block monument visitors from entering the 

businesses. Redesigning the entrance station to 

improve traffic flow and perhaps increasing the 

number of lanes or road width would make the 

line of waiting vehicles less likely to reach the 

front of businesses adjacent to the monument. 

This would not hold true during extreme periods 

of peak times 

Without data on how many visitors want to stop 

at the retail area, and assuming that the same 

vehicles are not stopping upon entrance and exit, 

it appears that about 75% of vehicles manage to 

stop at the retail area. Assuming that all the vehicles that do not stop do not do so because the 

visitors in them do not want to stop, there would 

be no impact on businesses from redesigning the 

entrance station. Assuming that all 25% of the 

vehicles that do not stop contain visitors who 

would like to stop but are prevented from doing 

so by traffic, redesigning the entrance station 

would allow most of these visitors to stop. This 

long-term beneficial effect would be minor and 

intermittent, occurring at all but the most extreme peak times. 

Adding parking along both sides of the road 

through the prairie dog town would improve 

traffic safety along the main road. This longterm beneficial effect would be minor. 

Widening the access road to the Joyner Ridge 

trailhead, improving the road surface, and 

expanding the parking lot might cause increased 

visitor traffic in this area. This long-term adverse impact on access to private property would 

be negligible. 

Conclusion: Assuming that all 25% of the 

vehicles that do not stop at businesses adjacent 

to the monument contain visitors who would 

like to stop but are prevented from doing so by 

traffic, redesigning the entrance station to improve the traffic flow would allow more of these 

visitors to stop. This minor beneficial effect 

would be long term, occurring at peak use times. 

Adding parking along both sides of the road 

through the prairie dog town would result in a 

minor beneficial effect in the long term for owners of adjacent property. However, developing 

the Joyner Ridge access road would result in a 

negligible long-term adverse impact on their access to private property. On balance, the effects 

of these two actions would be beneficial. 

Local and Regional Economy 

The new restroom facilities included in this 

alternative would not affect local sewage and 

water systems because water and wastewater 

systems would be developed in the monument. 
ENVIRONMENTAL CONSEQUENCES

Construction impacts would be felt primarily 

while construction was taking place, which 

would vary by project. Multiple projects could 

occur simultaneously. The National Park Service’s cost estimate for the construction work of 

alternative 5 is roughly $2.3 million, of which 

approximately 50% would go for labor, with the 

rest going toward materials and services, according to rule-of-thumb estimates for the construction industry. This translates into the equivalent 

of 37 one-year construction jobs over the duration of the various construction periods. (The 

construction projects of this alternative, which 

could last from a week to more than a year, 

could include widening or narrowing monument 

roads, paving the Tower parking area, building a 

new comfort station, and expanding the existing 

headquarters. The Devils Tower staff might 

complete some projects, but private contractors 

would be hired for most of the work.) 

The short-term construction projects would contribute only a small percentage of the regional 

economy’s jobs and earnings. Approximately 

2,100 of the 26,500-person labor force in Crook, 

Campbell and Weston Counties were employed 

in the construction industry during the third 

quarter of 1999 (1,900 of them in Campbell 

County). Because 37 jobs is a very small portion 

of the 2,100 construction jobs in the area, this 

short-term beneficial effect on the local and 

regional economy would be minor. 

Short-term construction also would have certain 

spinoff effects. Data in the 1998 Occupational 

Employment Statistics Wage Survey (Wyo. Dept. 

of Employment 1998) show that construction 

jobs in the Devils Tower region pay an hourly 

mean wage of $12.41. The 37 one-year jobs that 

would be created during the construction period 

would have a total payroll of roughly $1.15 

million. Construction laborers would add to the 

food, fuel, and possibly lodging expenditures 

made in the region for the duration of the construction period. This would directly benefit retailers immediately outside the Devils Tower 

National Monument entrance and in nearby 

towns. This minor beneficial effect would be 

short term. 

Sales taxes collected on the expenditures of 

construction workers would benefit local jurisdictions. According to the Crook County Treasurer’s Office, Crook County’s sales tax rate is 

5%. This short-term beneficial effect on Crook 

County’s sales tax revenues would be minor. 

Assuming that construction materials purchased 

by contractors would not be subject to the 

National Park Service’s tax-exempt status, local 

jurisdictions would have tax revenues on $1.1 

million in purchases of construction materials. 

The collection of about $57,500 in tax revenues 

would be a moderate short-term beneficial effect 

on county sales tax revenues. 

A high-end estimate of $1,150,000 of construction materials could be purchased in the region, 

benefiting regional suppliers. This short-term 

beneficial effect on regional suppliers would be 

minor. 

Over roughly three years, the dollars spent on 

construction would circulate throughout the regional economy to generate an additional total of 

$1,265,000 to $1,679,000(above and beyond the 

$2.3 million in construction). This would result 

in a minor long-term beneficial effect on the 

regional economy. 

Conclusion: The short-term construction 

projects of alternative 5 would have a beneficial 

effect on employment opportunities and on the 

local and regional economy, including indirect 

effects on local businesses and tax revenues. The 

equivalent of 37 one-year jobs would be created 

during the construction period, with a total payroll of roughly $1,150,000. The total impact on 

Wyoming’s economy of the proposed construction would be up to $3,979,000. The construction projects would be short term and would 

provide only a small percentage of existing jobs 

and earnings in the regional economy. The creation of 37 one-year construction jobs at Devils 

Tower would represent a small portion of the 

2,100 construction jobs in the area. Construction 

at Devils Tower under alternative 5 would have 

a minor long-term beneficial impact on overall 

employment in the region. 
Effects of Alternative 5 

159 

Cumulative Effects: Although past actions 

have impacted socioeconomic resources, no 

ongoing or future actions such as repaving the 

main road would have a perceptible impact on 

them. The actions of alternative 5 would not add 

appreciably to cumulative impacts.

UNAVOIDABLE ADVERSE IMPACTS 

The following paragraphs describe the more 

important (moderate and major intensity) adverse impacts that would result from alternative 

5. These are residual impacts that would remain 

after mitigation was implemented. The negligible and minor impacts are listed in the 

foregoing analysis. 

Natural Resources 

Less than 1 acre of the natural soil profile could 

be lost through some regrading and the possible 

construction of the retaining walls needed for 

enlarging the lower parking area at the base of 

the Tower, as well as through the widening of 

Joyner Ridge Road and the road through the 

prairie dog town. This long-term adverse impact 

would be moderate. 

Hardened surfaces (including gravel) would increase by 2 acres. The adverse impacts on soil 

erosion, soil nutrient transport, and vegetative 

composition caused by the increase in hardened 

surfaces would be moderate and long term. 

Much of this effect would occur at the prime 

resource area at the Tower. 

The natural and beneficial values of floodplain 

areas would continue to be compromised by the 

presence of the 50-site campground. This continuing long-term adverse impact on natural 

processes would be major. Although severe 

flooding has been infrequent and risks are minor 

to moderate, flooding could result in major 

adverse impacts on the visitors involved. 

Cultural Resources 

Increased visitor access and the associated development in several areas would detract from 

the solitude sought for religious ceremonies. 

Alternative 5, which calls for the highest level of 

development, would compromise the ethnographic resources of the Tower area. It also 

would degrade the viewshed by increasing visitor use and vehicular traffic at the Tower and the 

Joyner Ridge access road and trailhead. The 

viewshed also would be degraded because the 

current trailer dropoff area would be paved for 

tour bus parking. This moderate adverse impact 

on ethnographic resources would be long term. 

Adding parking lanes on both sides of the road 

at the prairie dog town would modify the historic road corridor, as would redesigning the 

entrance station area and increasing the size of 

the headquarters. These moderate adverse 

impacts would be long term. 

Visitor Experience 

Adding more parking at the Tower area would 

reduce visitor frustration because parking places 

would be easier to find than at present. Improving the area’s overall design would improve 

safety and help traffic to flow more efficiently. 

However, congestion and noise would continue. 

The sounds and smells of automobiles and buses 

would mask natural sounds and smells, 

especially during peak use times. 

More pavement would be visible from the 

Tower and the Tower trail. Many visitors would 

regard the level of development and activity at 

the Tower’s base as inconsistent with its significance. Adding more restrooms would reduce 

visitors’ time spent waiting in line. These effects 

would be an improvement over existing conditions, but the experience of the prime monument 

resource would continue to be degraded by traffic, noise, and vehicle smells. Because most visitors in this prime resource area would be affected, this long-term adverse impact on visitors at 

peak use times would be moderate to major. 

Construction activities to add a new parking area 

near the Tower, improve the entrance station, 

enlarge the headquarters, pave the trailer dropoff 

area, improve parking at the Joyner Ridge trail-
ENVIRONMENTAL CONSEQUENCES

head, and add new parking pullouts at the prairie 

dog town would result in short-term impacts. 

The visitor experience would be affected by 

noise from construction vehicles and equipment, 

visual intrusions from ground and vegetation 

disturbance, more traffic, the presence of large 

construction vehicles, and general disruption of 

circulation. These effects, although short term, 

could be moderate to major because they would 

occur in the monument’s prime resource areas. 

These effects would be particularly severe for 

visitors who might have only one opportunity to 

visit Devils Tower and whose experiences were 

degraded by construction activities. 

Traffic congestion at the prairie dog town would 

cause frustration for visitors. This would be a 

minor adverse impact on most visitors during 

periods of low visitation. However, at peak use 

times the impact would be moderate, particularly 

if a visitor’s time in the monument was limited. 

Overall, visitor frustration over a lack of orientation and interpretation would continue because 

of the facility limitations and crowding at the 

Tower area and in the visitor center. The limitations on interpretive opportunities would constitute a moderate to major adverse impact on 

visitors because many of them place a high 

value on interpretive services. 

Some vehicle accidents in the Tower area might 

result from traffic congestion and the need to 

manipulate large vehicles in a small space. The 

parking pullouts and pedestrian activity at the 

prairie dog town would lead to some traffic 

congestion and threaten the safety of vehicles 

and pedestrians. Vehicle accidents in the monument have been infrequent, and risks are considered minor to moderate, but an accident could 

cause a major adverse impact on the people 

involved. 

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES 

Some regrading at the Tower lower parking area 

could result in the loss of a small part of the 

natural soil profile on less than 1 acre. This loss 

would be permanent and irreversible. The loss of 

0.04 acre of wetland from enlarging the headquarters building would be irreversible. 

Severe flooding has been infrequent, and the 

risks are minor to moderate; however, flooding 

could result in major adverse impacts on the 

visitors involved. Any loss of life would be 

irreversible. 

RELATIONSHIP OF SHORT-TERM USES 

OF THE ENVIRONMENT AND LONGTERM PRODUCTIVITY 

Under this alternative, visitors would be accommodated as they came to the monument, rather 

than the monument trying to manage visitation 

to reduce congestion. 

About 5 acres of natural resource areas in the 

monument would be disturbed in the short term 

by construction. Hardened surfaces would increase by 2 acres, and no areas would be rehabilitated. The short-term visual intrusions 

from demolition, construction, and rehabilitation 

would give way to a long-term increase in the 

size the available parking area at the Tower, the 

road to the Joyner Road trailhead, the prairie dog 

town, and headquarters. 

Increased visitor access and associated development in several monument areas would detract from the solitude that American Indians 

seek for religious ceremonies. The ethnographic 

resources in the Tower area would be compromised. Increased visitor use, more vehicle traffic 

at the Tower and the Joyner Ridge access road 

and trailhead, and the changes in the trailer dropoff area (paving it to use tour bus parking) all 

would degrade the viewshed. 

The long-term integrity of the national registerlisted main road could be compromised by 

widening and increasing parking at the prairie 

dog town, redesigning the entrance station area, 

and increasing the size of the headquarters 

facility. Redesigning the national register-listed 

entrance station area would change its setting. 
Effects of Alternative 5 

161 

Increasing the size of the Tower parking area 

would reduce visitor frustration because finding 

parking spaces would be easier. Improving the 

area’s overall design would improve safety and 

help traffic to flow more efficiently. However, 

congestion and noise in the area would continue. 

Although these effects would be an improvement over existing conditions, noise, traffic, and 

vehicle odors would continue to degrade the 

experience of the monument’s prime resource. 

IMPAIRMENT 

The monument’s resources or values would not 

be impaired because there would be no major 

adverse impacts on a resource or value whose 

conservation is (1) necessary to fulfill specific 

purposes identified in the establishing legislation 

or proclamation of Devils Tower National 

Monument, (2) key to the natural or cultural 

integrity of the monument or to opportunities for 

visitor enjoyment, or (3) identified as a goal in 

the monument’s General Management Plan or 

other relevant NPS planning documents. 
ENVIRONMENTAL CONSEQUENCES

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CONSULTATION AND COORDINATION 

WITH OTHERS 
CONSULTATION AND COORDINATION WITH OTHERS

164 

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165 

PUBLIC INVOLVEMENT 

As detailed in the “Purpose and Need” chapter, 

the scoping process for this General Management Plan / Environmental Impact Statement 

began in 1999. Four newsletters were published 

in 1999 and 2000 to inform the public about the 

planning process and solicit comments regarding 

the possible alternatives for managing Devils 

Tower National Monument. Members of the 

public commented at open house meetings, and 

written comments were received as well. 

American Indians were consulted throughout the 

planning process. 

Many comments were received from the public 

during the development of the plan. A significant change in shuttle staging location from the 

present campground to the area north of the 

entrance station was recommended as a direct 

result of public input from Newsletter 4 and 

public meetings held in November 2000. When 

the alternatives were being developed, the public 

expressed concern about three specific topics: 

(a) Moving the campground (and the 

associated rehabilitation of the floodplain 

and the riparian area that it occupies). 

Commenters generally said they would 

prefer that the present Belle Fourche River 

campground be retained. 

(b) Establishing a transportation shuttle. Some 

people expressed discontent about the 

limitations to visitor movement that would 

be imposed by the need to adhere to a 

shuttle schedule; some said they would not 

like being separated from their vehicles; 

others said more time would be needed to 

visit Devils Tower if a shuttle system was 

established. Others commenters supported 

the system, saying the visitor experience 

would be improved by moving the parking 

farther from the historic district. Some said 

they would appreciate having expanded 

restroom facilities (which would be added in 

alternatives in which a shuttle system is 

included). Others mentioned that they would 

like having an opportunity for an additional 

interpretive experience on the shuttle. 

(c) Relocating the picnic area. Public comments were received about the possibility of 

moving the picnic area to a location near the 

orientation center. Some people said they 

like the present picnic area and would like to 

be assured that the quality of the experience 

at the new picnic area would be similar to 

that of the present one. 
166 

AGENCIES AND ORGANIZATIONS TO WHICH 

THIS DOCUMENT WAS SENT 

[Asterisk (*) indicates that a comment on the Draft General Management Plan / Environmental Impact Statement was 

received from this organization.] 

Federal Agencies 

Advisory Council on Historic Preservation 

Federal Emergency Management Agency 

U.S. Army Corps of Engineers 

U.S. Department of Agriculture 

 Big Horn National Forest 

Black Hills National Forest, 

 Bearlodge Ranger District 

 Bridger-Teton National Forest 

 Shoshone National Forest 

Natural Resources Conservation Service 

U.S. Department of the Interior 

 Bureau of Land Management 

 Wyoming State Office 

 Newcastle Field Office 

Bureau of Reclamation 

National Park Service 

 Badlands National Park 

Bighorn Canyon National Recreation 

 Area 

 Fort Laramie National Historic Site 

 Fossil Butte National Monument 

 Grand Teton National Park 

 Jewel Cave National Monument 

 Mount Rushmore National Memorial 

Washington Office of Strategic 

 Planning 

 Wind Cave National Park 

 Yellowstone National Park 

 U.S. Fish and Wildlife Service*

U.S. Geological Survey 

U.S. Environmental Protection Agency*

U.S. Senators and Representatives 

U.S. Representative Barbara Cubin 

Office Of Senator Mike Enzi 

Office Of Senator Craig Thomas 

State Agencies 

Wyoming Department Of Environmental 

 Quality 

Wyoming Department of State Parks 

 and Cultural Resources 

 Keyhole State Park 

 State Historic Preservation Office*

Wyoming Department Of Transportation 

Wyoming Game and Fish Department*

Wyoming Office of Tourism 

Wyoming State Clearinghouse*

 Office for Federal Land Policy 

State Officials 

Wyoming Governor Jim Geringer 

Wyoming State Representative Marlene J 

 Simons 

American Indian Tribes With Potential 

Cultural Affiliation to the Monument 

Assiniboine and Lakota of Montana 

Blackfeet 

Blood (Canada) 

Crow*

Cheyenne River Sioux 

Crow Creek Lakota 

Devil’s Lake Lakota 

Eastern Shoshone 

Flandreau Santee Lakota 

Kootnai and Salish 

Lower Brule Lakota 

Northern Arapaho 

Northern Cheyenne 

Oglala Lakota 

Pigeon (Canada) 

Rosebud Lakota 

Sisseton-Wahpeton Sioux 

Southern Arapaho 

Southern Cheyenne 

Standing Rock Sioux 

Three Affiliated Tribes 

Turtle Mountain Chippewa 

Yankton Lakota 

Local, City, and County Governments 

Crook County 

 Office of County Commissioners*

 School District #1 
Agencies and Organizations to Which This Document Was Sent 

167 

 Sheriff 

 Weed and Pest Control 

Hulett City Council 

Moorcroft City Council 

Pine Haven City Council 

Sundance City Council 

Organizations and Businesses 

Belle Fourche Chamber Of Commerce 

Buffalo Chamber Of Commerce 

Devils Tower Conservation District, 

 Devils Tower Natural History Association 

Devils Tower Tourism Association 

Gillette Chamber Of Commerce 

Hulett Chamber Of Commerce 

National Outdoor Leadership School 

National Parks Conservation Association*

Newcastle Chamber Of Commerce 

Sheridan Chamber Of Commerce 

Sierra Club–Black Hills 

Spearfish Chamber Of Commerce 

Sundance Times 
168 

PUBLIC REVIEW OF THE DRAFT DOCUMENT 

This section contains a summary of comments 

received through letters and e-mail after the 

Draft General Management Plan / Environmental Impact Statement for Devils Tower 

National Monument was released on July 2, 

2001. The National Park Service considered all 

written comments according to the requirements 

of 40 CFR 1503. 

RECORD OF PUBLIC COMMENTS 

A notice of availability of the draft document 

was published in the Federal Register on July 2, 

2001 (FR Vol. 66, No. 127). Approximately 75 

copies of the draft were distributed to government agencies, public interest groups, and individuals. In addition, the complete text of the 

Draft General Management Plan / Environmental Impact Statement was posted on the NPS 

Web site. 

WRITTEN COMMENTS 

The park’s fourth newsletter presented a revised 

draft of the alternatives. Approximately 5,500 

individuals sent preprinted letters indicating 

support for alternative 3, the preferred alternative. A total of 2,000 additional comment letters 

were received in response to the draft document 

itself from governing bodies, government agencies, organized interest groups, and individuals 

during the comment period. Written comments 

were accepted through September 30, 2001. All 

letters from governing bodies, government agencies, and organizations are reproduced on the 

following pages, as are letters from individuals 

that were chosen to represent the range of issues 

included in individual letters. The following 

paragraphs contain the NPS response to suggestions for modification of the draft plan: 

Comment: It was suggested that the preferred 

alternative “provide a specific and detailed plan 

for creating a full and prominent context for . . . 

interpretative exhibits of Native American 

values and history.” 

We suggest that language be added to include specific information about the nature 

and context of the interpretation planned, 

and that the addition clearly state the importance and priority to be placed on Native American activities. When I recently 

visited Devils Tower, I was struck by the 

degree to which 100 years of rock climbing disproportionately capture visitor attention through extensive displays at the 

visitor center while overshadowing thousands of years of indigenous peoples’ use 

and value in the area. NPCA [the National 

Parks Conservation Association] believes 

that this imbalance should be assertively 

addressed and corrected through adoption 

of proactive directions and measures in the 

GMP . . . the Climbing Management Plan 

provides some good examples of ways the 

Monument can improve cultural interpretation as exampled [sic] in relevant sections on pages 15 and 16. Referencing 

Native American sections here could align 

with our recommendations. 

Response: The National Park Service agrees that 

more emphasis on this theme would be desirable. One factor limiting that emphasis has been 

the fact that Devils Tower National Monument 

has been severely limited in places to increase 

the presentation of themes. The preferred alternative provides for additional venues in which to 

locate interpretive media and programs. The 

monument also has begun a project of totally 

replacing the visitor center exhibits. The new 

exhibits will include a much more in-depth treatment of American Indian connections with the 

Tower.

In the National Park Service, a general management plan is used to prescribe the management 

of natural and cultural resources, visitation, and 

development over a 15 to 20 year period. One of 

the implementation plans that normally follow a 

general management plan is an interpretive plan. 

The interpretive plan is the vehicle for examining how interpretive themes such as American 

Indian beliefs and cultural practices at Devils 

Tower will be conveyed. Such a plan will 
Agencies and Organizations to Which This Document Was Sent 

169 

describe specific media and programs to be 

developed. The important theme mentioned in 

public comment will be one subject of a future 

interpretive plan. 

The finding of no significant impact for the 

Final Climbing Management Plan for Devils 

Tower National Monument (1995) is reaffirmed 

on page 4 of the Draft General Management 

Plan / Environmental Impact Statement and 

summarized in appendix B. One of the four 

objectives of the climbing plan (from appendix 

B) is, “to increase visitors’ awareness of American Indian beliefs and traditional cultural practices at Devils Tower.” Since approval of the 

climbing plan, modifications have been made to 

interpretive exhibits, other media, and programs 

to reach this goal. The National Park Service 

believes that pages 15 and 16 of the Climbing 

Management Plan already have been observed 

by reaffirming the entire plan on page 4 of the 

Draft General Management Plan and including 

the summary in appendix B. 

Comment:

NPCA strongly encourages . . . DETO 

[Devils Tower National Monument] to 

amend the current preferred alternative to 

include a dedicated bike/pedestrian path to 

follow the road from the entrance to the 

visitor center. . . . We believe DETO needs 

to add greater specificity and direction to 

its current recommendations in this section 

of the plan. In particular we are deeply 

disappointed in the fact that bicycle transportation options have been largely dismissed and ignored within the DETO plan. 

Response: The option of bicycling to the tower 

is described in the document summary and in the 

first paragraphs of the descriptions of alternatives 3 and 4. The ability of visitors to bicycle to 

the Tower is emphasized in the preferred alternative (alternative 3 — see page 35). One reason 

that alternative 3 was selected as the preferred 

alternative was that it had the greatest ease of 

access for visitors. “Ease of access to the monument” includes the ability to visit the monument 

on one’s own schedule and seldom encountering 

waiting lines at the entrance station. Alternative 

3 was rated highest for this criterion because 

waiting lines at the entrance station would be 

reduced and visitors could enter the monument 

before being required to ride a shuttle; whereas 

in alternative 4 the shuttle staging area would be 

outside the boundaries, making a longer distance 

to walk or bicycle to reach monument features. 

The alternative of building a parallel trail was 

not included for two reasons: first, resource 

impacts of the bicycle trail, including impacts on 

the historic road corridor, would be too great; 

second, at times of the year when the shuttle 

would not be in operation, vehicular traffic 

would be low enough for bicycles to use the 

road safely. During times of the year when the 

shuttle was operating, there would be very little 

traffic on the road, and bicycles could use the 

road safely. 

Comment: Members of the public have expressed some concern to Devils Tower National 

Monument staff about closing the campground.

Response: 

Devils Tower National Monument is primarily a 

day use area, with most visitors spending 1–2 

hours at the park. Limited staffing and funding 

should be concentrated on meeting the needs of 

these daytime visitors. In addition, occupancy of 

the campground has dropped precipitously in the 

last few years, so that one of the two campground loops (30 campsites, rather than 50) can 

accommodate most people who want to camp. 

During this same period, more nearby camping 

options have become available from the private 

sector beyond the existing camping opportunities at the adjacent KOA and Tower View 

campgrounds and on U.S. Forest Service lands. 

The campground is within the 100-year floodplain. Even with the Keyhole Dam on the Belle 

Fourche River upstream of the park, the campground has been and will continue to be flooded 

when high spring runoff combines with high 

precipitation events. It is inappropriate to place 

visitors in overnight facilities such as the 

campground that are subject to flooding. 
CONSULTATION AND COORDINATION WITH OTHERS

170 

The campground facilities are more than 40 

years old. Although they have been maintained 

at an acceptable standard, costs associated with 

this upkeep have been rising steadily, especially 

due to frequent plumbing problems. All the 

campground infrastructure needs to be replaced, 

including the waterline, the septic system, restrooms, campsites, picnic tables, fire grates, and 

roads. The high cost of operating and maintaining the campground, combined with the high 

cost of campground replacement, makes it 

imprudent to reinvest considerable monies to 

reconstruct the campground in a floodplain 

environment. 

The campground lies in a dying cottonwood 

forest, and no regeneration has occurred since 

the construction of the Keyhole Dam. Even 

given cyclic hazard tree reduction work, these 

cottonwoods would present a hazard to campers 

during a significant storm event, as large limbs 

have fallen and will continue to fall, although 

infrequently. 

The campground also is adjacent to a prairie dog 

town. During upswings in the prairie dog population, prairie dogs have moved into the campground, and will continue to do so, posing a 

safety hazard (falling) because of burrows and 

increasing the likelihood of direct contact 

between campers and prairie dogs. 

Some detailed comments were received about 

the design of areas such as the new picnic area. 

These will be passed on to the designers when 

the implementation phase begins after 

completion and approval of the General 

Management Plan.

The following pages contain copies of the letters 

that the National Park Service received from 

governing bodies, government agencies, and 

organizations, along with certain letters from 

individuals that were chosen to represent the 

range of issues included in individual letters. 
Agencies and Organizations to Which This Document Was Sent 

171 

Letters p. 171 - 184 are in separate PDF files.
CONSULTATION AND COORDINATION WITH OTHERS

172 

2 
Agencies and Organizations to Which This Document Was Sent 

173 

3 
CONSULTATION AND COORDINATION WITH OTHERS

174 

4 
Agencies and Organizations to Which This Document Was Sent 

175 

5 
CONSULTATION AND COORDINATION WITH OTHERS

176 

6 
Agencies and Organizations to Which This Document Was Sent 

177 

7 
CONSULTATION AND COORDINATION WITH OTHERS

178 

8 
Agencies and Organizations to Which This Document Was Sent 

179 

9 
CONSULTATION AND COORDINATION WITH OTHERS

180 

10 
Agencies and Organizations to Which This Document Was Sent 

181 

11 
CONSULTATION AND COORDINATION WITH OTHERS

182 

12 
Agencies and Organizations to Which This Document Was Sent 

183 

13 
CONSULTATION AND COORDINATION WITH OTHERS

184 

14 
APPENDIXES, BIBLIOGRAPHY, 

PREPARERS, AND INDEX 
APPENDIXES, BIBLIOGRAPHY, PREPARERS, AND INDEX

186 

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187 

APPENDIX A: DEVELOPING THE PREFERRED ALTERNATIVE 

To develop a preliminary preferred alternative, the 

planning team evaluated the five draft alternatives 

that had been reviewed by the public. To minimize 

the influence of individual biases and opinions, the 

team used an objective analysis process called 

“Choosing by Advantages.” This process, which has 

been used extensively by government agencies and 

the private sector, evaluates different choices (in this 

case, the five draft alternatives) by identifying and 

comparing the relative advantages of each according 

to a set of criteria. 

“GIVENS” AND DESIRED CONDITIONS 

First, it is useful to consider the assumptions or 

“givens” that affected the analysis of the alternatives. 

These givens are based on the purpose and significance, laws and policies, and public concerns and 

comments. The givens are listed below in two categories, one representing conditions that must be met 

by the preferred alternative; the second representing 

conditions that would be desirable for the preferred 

alternative to meet. 

The actions in the preferred alternative must 

accomplish the following: 

• would not adversely impact threatened and 

endangered species in ways that could not be 

mitigated 

• would result in no net loss of wetlands 

• would meet clean air and water standards 

• would allow no loss of cultural resources without 

complete documentation 

• would allow public access 

• would provide safe, sustainable, and efficient 

operations for resource protection and visitor use 

The following actions would be desirable in the 

preferred alternative: 

• would result in little or no adverse impact on 

plants, animals, or soils 

• would preserve properties eligible for the 

National Register of Historic Places 

• would allow maximum public access consistent 

with resource protection and visitor experience 

goals 

• would result in minimum disruption of desired 

experiences for users 

COMPARING THE ALTERNATIVES 

The next step in the Choosing by Advantages process 

was to develop the criteria that would be used to 

compare the alternatives. Using the givens presented 

above and factors that were commonly mentioned by 

the public in commenting about the alternatives, the 

team identified five criteria by which to evaluate the 

alternatives. 

• visitor experience at the base of the Tower 

• ease of access to the monument 

• overall visitor freedom of movement within the 

monument 

• visitor understanding of the monument’s 

significance 

• preservation of the viewshed 

The effects on wildlife habitat and other natural resource criteria were considered; however, the alternatives were found to have only minor impacts on 

resources and to be similar in those impacts, and so 

the criterion was not a major factor in selecting the 

preferred alternative. 

The team identified the relative advantages of each 

alternative for each of the criteria. Each advantage 

was given a point value that reflected its importance. 

Then, by adding up the scores for each alternative, 

the team was able to determine how the alternatives 

compared overall. The costs of implementing the 

alternatives were then compared to examine the relationships between advantages and costs. The relative 

advantages of the alternatives for each criterion are 

summarized below. 

Visitor Experience at the Base of the Tower 

The area in “visitor experience at the base of the 

Tower” is the upper and lower parking areas and the 

visitor center .Alternative 2 best met this criterion 

because of the total reduction in traffic and conges-
APPENDIXES

188 

tion. Alternatives 3 and 4 also represented a significant improvement over existing conditions, despite 

the potential for noise from shuttle vehicles and 

continued high concentrations of visitors in the 

Tower area. Alternative 5 represented only minimal 

improvement over existing conditions. 

Ease of Access to the Monument 

“Ease of access to the monument” includes the ability 

to visit the monument on one’s own schedule and 

seldom encountering waiting lines at the entrance 

station. Alternative 3 was rated highest for this criterion because waiting lines at the entrance station 

would be reduced and visitors could enter the monument before being required to ride a shuttle; whereas 

in alternative 4 the shuttle staging area would be outside the boundaries, making a longer distance to walk 

or bicycle to reach monument features. Alternative 2 

rated lowest because, with a reservation system, some 

visitors might be unable to visit the monument. This 

was considered a major disadvantage and significantly lowered the overall score for alternative 2. 

Alternative 5 rated only slightly higher than existing 

conditions, but lines at the entrance station could still 

be common. 

Overall Visitor Freedom of Movement 

“Overall visitor freedom of movement within the 

monument” includes the ability to visit features on 

one’s own schedule and finding parking easily. 

Alternatives 2 and 5 rated highest in this area because 

both would reduce the parking problem and would 

not require riding a shuttle. Alternatives 3 and 4 

received lower ratings because of the necessity for 

visitors to ride a shuttle at peak times. 

Visitor Understanding of 

the Monument’s Significance 

Visitor understanding of the monument’s significance” includes offering high quality interpretive 

services for visitors. Alternatives 3 and 4 rated highest for interpretive opportunities because of the inclusion of a staging area, interpretive opportunities 

on the shuttle, and the ability to keep more facilities 

open in the winter. Alternative 5 rated lowest because 

of the continued crowding at facilities and features. 

Preservation of the Viewshed 

The viewshed to be preserved comprises views 

within the park from the Tower and from the Tower 

and Red Beds trails. The overall reduction in development in alternative 2 gave it the best score for 

this criterion. Alternative 4 was scored lowest because of the size of new developments and the possibility that screening them might be difficult or 

impossible. The developments called for in alternatives 3 and 5 probably could be screened from many 

areas; therefore, those alternatives were scored higher 

than alternative 4. 

CHOOSING THE PREFERRED 

ALTERNATIVE 

Overall, alternative 3 received the highest score and 

was adopted as the preferred alternative. Alternative 

4 received the next highest score; it also would have 

the minor advantage of removing the administrative 

and maintenance facilities from wetland areas. However, the cost of implementing alternative 4 would be 

significantly higher than alternative 3, and the environmental advantage would not be great enough to 

justify the additional expense. 

As a result of subsequent public comment, alternative 

3 was revised to allow for the restoration of natural 

resources and floodplain values in the existing campground and picnic area complex. The greatly enhanced the overall advantages of the preferred 

alternative. 
189 

APPENDIX B: SUMMARY OF 1995 CLIMBING MANAGEMENT PLAN

The Final Climbing Management Plan / Finding of 

No Significant Impact: Devils Tower National 

Monument, Crook County, Wyoming set a new 

direction for managing climbing activity at the Tower 

for the next three to five years. Its purpose is to 

protect the natural and cultural resources of Devils 

Tower and to provide for visitor enjoyment an 

appreciation of this unique feature. The National Park 

Service will manage Devils Tower as a significant 

natural and cultural resource. The Tower will be 

managed primarily as a crack climbing site in a way 

that will be more compatible with the butte’s 

geology, soils, vegetation, nesting raptors, visual 

appearance, and natural quiet. Recreational climbing 

at Devils Tower will be managed in relation to the 

Tower’s significance as a cultural resource. The 

replacement of existing bolts and fixed pitons will be 

allowed, but no new bolts or fixed pitons will be 

permitted on the Tower. In this way, the National 

Park Service intends that there be no new physical 

impacts on Devils Tower. 

In respect for the reverence many American Indians 

hold for Devils Tower as a sacred site, rock climbers 

will be asked to voluntarily refrain from climbing on 

the Tower during the culturally significant month of 

June. The monument staff will interpret the cultural 

significance of Devils Tower for all visitors, along 

with the more traditional themes of natural history 

and rock climbing. 

There are many benefits to the implementation of this 

plan. Its environmental consequences will include 

increased protection for natural resources. No critical 

habitat for listed species will be negatively affected. 

Visitor experience will be enhanced by a more 

diverse and balanced interpretive program. In turn, 

improved communication and understanding among 

the monument’s user groups will lead to greater 

respect and tolerance for differing perspectives. 

The objectives of the Climbing Management Plan are 

as follows: 

• to preserve and protect the monument’s cultural 

and natural resources for present and future 

generations 

• to manage recreational climbing on the Tower 

• to increase visitors’ awareness of American 

Indian beliefs and traditional cultural practices at 

Devils Tower 

• to provide the monument with a guide for 

managing climbing use that is consistent with 

NPS policies and other monument management 

plans 
190 

APPENDIX C: LEGISLATION 

establishing legislation, map, and addition legislation (3 pages) 
Appendix C: Legislation 

191 

legislation, p. 2 
APPENDIXES

192 

legislation, p. 3. 
193 

APPENDIX D: LETTER FROM U.S. FISH AND WILDLIFE SERVICE 

Letter about T&E species, 3 pages 
APPENDIXES

194 

USFWS letter, p.2 
Appendix D: Letter from U.S. Fish and Wildlife Service 

195 

USFWS letter, p.3 
196 

APPENDIX E: STATEMENT OF FINDINGS FOR WETLANDS 

Statement of Findings for 

Executive Order 11990: Protection of Wetlands 

Expand Existing Headquarters and Relocate Parking Area 

Devils Tower National Monument 

Crook County, Wyoming 

Recommended: 

__________________________________________________________________________________ 

Superintendent, Devils Tower National Monument Date 

Certification of Technical Adequacy and Servicewide Consistency: 

__________________________________________________________________________________ 

Chief , Water Resources Division Date 

Approved: 

__________________________________________________________________________________ 

Regional Director, Intermountain Region Date 
Appendix E: Statement of Findings for Wetlands 

197 

STATEMENT OF FINDINGS FOR EXECUTIVE ORDER 11990 

(PROTECTION OF WETLANDS) 

DEVILS TOWER NATIONAL MONUMENT 

CROOK COUNTY, WYOMING 

GENERAL MANAGEMENT PLAN / ENVIRONMENTAL IMPACT STATEMENT 

INTRODUCTION 

The National Park Service (NPS), in its preferred alternative for its general management plan, is proposing to 

double the size of its 1,150 square foot headquarters building and move the 25-car parking area from in front of 

the building to behind it. This wetland Statement of Findings (SOF) focuses on the wetland impacts that would 

be associated with this construction. The purpose of this SOF is to present the rationale for enlarging the building 

and moving the parking area in a location containing a wetland and to present a mitigation plan to compensate 

for the loss of a small area of this wetland remnant. The project would fill 0.03 acre of the approximately 2-acre 

wetland. The area to be impacted and the proposed mitigation site are shown on the map on a subsequent page. 

In addition to the area of wetlands that has already been impacted by the headquarters building, implementing 

the preferred alternative would result in the long-term loss of 0.03 acre. Constructing the additions to the headquarters building and moving the parking area would result in the short-term disturbance of less than 0.5 acre of 

the wetland. Short-term disturbance would be caused by the use of equipment to dig holes for the placement of 

building foundations, to pour building foundations, and to place the surface on the new parking area. The site 

would be restored by scarifying any compacted areas and revegetating with plants similar to those present before 

the disturbance. The duration of the site disturbance is expected to be less than two months during summer. The 

restoration would be done as part of the final phase of construction. It would probably take several years for the 

disturbed wetland vegetation to fully recover. Please see the discussion of best management practices below, 

under “Wetland Avoidance and Minimization,” for information on the protection measures that would be 

implemented during construction. 

This SOF has been prepared in accordance with the guidelines of NPS Director’s Order 77-1, Wetland Protection. The purpose of this Director’s Order is to establish NPS policies, requirements, and standards for implementing Executive Order (EO) 11990, Protection of Wetlands (42 Fed. Reg. 26961). The objective of that EO is 

to avoid, to the extent possible, the long- and short-term adverse impacts associated with the occupancy, 

modification or destruction of wetlands. 

ALTERNATIVES CONSIDERED 

Alternatives 1 and 2 would make no exterior changes to the headquarters. The impacts on the wetland would not 

change. Alternative 3 is the preferred alternative described in this statement of findings. It would double the size 

of park headquarters and move the parking area to the back of the headquarters building. Moving the parking 

area would take it out of the viewshed of the historic road. Alternative 4 would relocate the headquarters outside 

the park with a shuttle staging area. Alternative 5 would double the size of park headquarters but leave the parking area in front of the building. 

Alternatives 1 and 2 were rejected because they would do nothing to alleviate the crowded conditions at headquarters. Offices for park staff are in four buildings located throughout the park. Only two of these buildings 

were designed for office space. The other two buildings are historic log cabins that have been modified for office 

space. None of these buildings has adequate space for today’s staff and office requirements. In addition, there is 

inadequate storage space and no facilities for staff meetings or break rooms. The cooperating association has 

inadequate office and bookstore space. 

The “Choosing by Advantages” process was used to select the preferred alternative. To comply with Director’s 

Order 77-1, section 2.2.G, which states, “Where natural wetland characteristics or functions have been degraded 

or lost due to previous or ongoing human activities, the National Park Service will, to the extent appropriate and 
APPENDIXES

198 

practicable, restore them to pre-disturbance conditions,” the National Park Service has evaluated an alternative 

(alternative 4) that would remove the headquarters building from its current location on a filled wetland. While 

alternative 4 had the advantage of removing park administrative and maintenance facilities from wetland areas, 

the National Park Service did not choose this as the preferred alternative because the cost of implementing alternative 4 was significantly higher than for alternative 3 and the environmental advantage would not be great 

enough to justify the additional expense. 

Compared to other alternatives, alternative 5 could provide only minimal improvement in the visitor experience 

at the base of the tower, would not solve the problem of lines at the entrance station, and would result in continued crowding at facilities and park features. It would leave the parking area in the viewshed of the historic road 

(see map, next page). 

WETLANDS WITHIN THE PROJECT AREA 

Surveys for wetlands in the project area were performed in June 2000. The wetland survey information included 

descriptions of soils, vegetation, and hydrology. The secondary source data included the U.S. Fish and Wildlife 

Service National Wetland Inventory maps, Crook County soil maps, and preliminary general management plan 

alternatives prepared by the National Park Service. 

Wetlands identified in the project area exhibited the characteristics of jurisdictional wetlands as defined under 

section 404 of the Clean Water Act and the ecological conditions that correspond to the wetland classification 

system in the Cowardin classification of wetlands and deepwater habitats (USFWS 1979). 

Vegetation/wetland surveys were performed over a two-day period for land areas identified for potential development/visitor use in the draft alternatives for the General Management Plan. Dominant species were recorded 

during walk-through surveys. The vegetation lists provided are not comprehensive, but they represent the most 

frequently noted species and/or species that assist in identifying the specific community type. 

It should be noted that wetland identifications were not based on formal wetland delineations, but instead were 

based on visual assessments of soils and hydrology, and on plant identifications made by the vegetation ecologist 

of the Intermountain Support Office, National Park Service. The area to be impacted by the proposed headquarters expansion and construction was identified as deciduous upland forest in a previous vegetation study 

(USGS 2000). It is not known if the specific area associated with the proposed headquarters expansion site was 

actually visited during the above 2000 vegetation analysis or if it was lumped into the larger associated vegetation type. Although the site is considered marginal in nature, the IMSO vegetation ecologist thought a precautionary “wetland” identification was warranted based on the following factors: (1) the location of the site within 

a drainage, (2) the dominance of several FAC to FACW plant species, and (3) visual signs of current seasonal 

short-term (temporary) flooding. 

The following wetland type was identified in the immediate project vicinity: 

PFO1A: Palustrine Forested Broad-Leaved Deciduous, Temporarily Flooded 

The wetland covers approximately 2 acres. The buildings (headquarters, built in 1935, and a residence) appear to 

have been placed on fill material (<0.25 acre) and the land area behind the headquarters building contoured to 

improve drainage. Dominant species include green ash (Fraxinus pennsylvanica — native), bur oak (Quercus 

macrocarpa — native), black cherry (Prunus virginiana — native), hound’s tongue (Cynoglossum officinale — 

exotic), clear weed (Pilea sp. — native), bluegrass (Poa pratensis and compressa — exotic), dame’s rocket 

(Hesperis matronalis — exotic), meadow rue (Thalictrum dasycarpum — native), greenbriar (Similax 

herbacea — native), stinging nettle (Urtica dioica — native), clustered field sedge (Carex praegracilis — 

native), and annual bedstraw (Galium aparine — native). Numerous seedlings of green ash, black cherry, and 

bur oak were noted. Western wheatgrass ( Agropyron smithii — native), smooth brome (Bromus inermis — 

exotic), leafy spurge (Euphorbia esula — exotic), yellow sweet clover (Melilotus officinalis — exotic), and an 

unidentified grass species (possibly quackgrass) were noted along woodland edges or in dryer light gaps. 
Appendix E: Statement of Findings for Wetlands 

199 

Map for appendix E, statement of findings for wetlands 
APPENDIXES

200 

Soils within the area are identified by the Soil Survey for Crook County, Wyoming (NRCS 1983) as Bankard 

loamy fine sand, 0–3%. These soils typically occur on floodplains, are subject to brief periods of flooding, and 

have slow surface runoff. The Bankard soil series is not listed on either the National or State of Wyoming list of 

hydric soils. However, hydric inclusions (typically not named) are possible on the Bankard floodplain soil types 

(Darrel Schroeder, WY State NRCS, personal communication, May 2001). 

Both natural and artificial conditions may be causing water to collect in the headquarters area. The wetland is 

located on the slope between Devils Tower and the Belle Fourche River. The source of water is thought to be 

surface runoff of precipitation from the Tower and other areas upslope of the wetland drainage, as well as from 

direct receipt of precipitation. North of the wetland is the historic park road, also built in the path of runoff from 

the Tower. Multiple small catchments have been dug near the road to keep runoff from flooding it. The roadway 

and established catchments have also served as long-term historic alterations to surface hydrology that would 

have naturally continued on into the wetland drainage. 

Although the degraded wet area associated with the headquarters expansion has undergone several hydrological 

alterations, it still retains some ability (in whole or in part) to provide the following functions: (1) flood storage, 

(2) groundwater recharge, (3) groundwater discharge, (4) sediment trapping, and (5) maintaining a unique 

vegetation type (shaded wetland) within the park. Although not as significant as the above, this wetland provides 

nutrients and short-term seasonal retention and removal of pollutants, thereby improving the quality of surface 

water and groundwater. The diversity of wetland and upland habitats also provides habitat to a variety of wildlife 

species (such as deer, raccoon, small mammals, and numerous local bird species). No federally listed or statelisted threatened or endangered plant or animal species occur within the proposed project area. 

PROJECT IMPACT ON WETLANDS 

Enlarging the headquarters building from 1,150 square feet to 2,300 square feet and relocating the 25-car parking 

would add additional fill over 0.03 acre and add permanent structures to an already filled wetland. The loss of 

0.03 acre of wetland would be a long-term negligible adverse impact. Construction activity would temporarily 

disturb an additional 0.5 acre of the wetland. This would be a minor short-term adverse impact. 

WETLAND AVOIDANCE AND MINIMIZATION 

The alternative of moving the headquarters outside the monument was considered. Land is not currently available, and should land become available, costs would be high. Most of the flat land that could be used for buildings is in or near the floodplain of the Belle Fourche River. Keeping development out of the viewshed from 

Devils Tower is a goal that increases the difficulty of finding a suitable site. The most practicable alternative was 

determined to be adding onto the headquarters building, which is built on fill in a wetland area. The parking area 

is being moved behind the headquarters to remove it from the historic view along the historic road and from the 

Tower. 

All possible wetland avoidance and minimization measures would be incorporated into the design of the headquarters expansion and parking relocation within the constraints of good design, preserving the historic scene, 

and preserving views from Devils Tower. The use of best management practices (BMP) would be employed to 

minimize impacts on wetlands. BMPs used in this project would include, at a minimum, the installation of 

temporary control devices throughout construction (such as: silt fences, slope drains, straw bales, inlet protection, sediment traps, and protective fencing), and the stabilization and restoration of soils exposed as a result of 

grubbing, clearing, filling, and excavation activities following completion of construction. Measures would be 

implemented to control the spillage of fuels, lubricants, or other contaminants that might otherwise enter the 

waterway or wetland. The use of heavy equipment in wetlands would be avoided. Whenever possible, excavated 

material would be placed on an upland site. Existing wetland vegetation materials would be salvaged for replanting in areas receiving short-term disturbance and for use in areas of mitigation where possible. Disturbed areas 

would be revegetated in accordance with NPS policies and guidance. 
Appendix E: Statement of Findings for Wetlands 

201 

The resulting loss of 0.03 acre of wetland and the short-term disturbance of 0.5 acre has been deemed unavoidable. Although a portion of the wetland would be lost, the proposed action would minimize construction impacts 

on the site and provide much needed interior space at headquarters to more effectively manage the monument. 

WETLAND MITIGATION 

A total of 0.03 acre of forested wetland would be lost and 0.5 acre would be temporarily disturbed during the 

course of construction. 

To compensate for the lost wetland acreage, at least 0.03 acre of forested wetland would be restored in 

accordance with Director’s Order 77-1. 

The area for restoration is within the monument. An area of forested wetland of similar species composition has 

been identified as the first choice for wetland restoration. It is on the west side of the meander where the campground is located. The campground would be removed in the preferred alternative. The preferred site is shown 

on the attached map. Should this site fail to be suitable, a forested wetland site in one of the ravines (outside of 

the project area) would be considered. 

The wetland restoration acreage compensation ratio for the project is 1:1. It is anticipated that wetland of 

equivalent type and function can be restored within the monument relatively near the impacted wetland. 

Design and construction funds for Devils Tower headquarters enlargement and parking relocation and the 

removal of the campground, picnic area, and amphitheater would be the funding source for this wetland 

mitigation. As funding for this project became available and construction drawings were prepared, the National 

Park Service would develop a wetland restoration plan for Devils Tower National Monument. 

Restoration at the campground area would be conducted at the same time as the wetland fill activity at headquarters, or earlier. The campground is located on a meander of the Belle Fourche River where wetlands are 

adjacent. Mitigation would consist of the following: 

• removing the fill 

• reestablishing natural elevational contours 

• ensuring that proper hydrologic conditions are present to maintain the wetland 

• planting native vegetation, to include salvaged materials from the disturbed wetland site and additional 

seeded materials of existing native wetland species (a species list for seeded materials, including seed source 

and seeding rate information, would be included in the detailed mitigation plan.) 

• removal of exotics, should they become established on the site 

• replanting vegetation if necessary to ensure the development of a natural vegetated wetland 

Detailed mitigation planning will be done when the project is funded. It may be done through contracting, 

prepared through a technical assistance request to the Intermountain Support Office, or through other means. 

CONFORMITY WITH FEDERAL, STATE, AND LOCAL STANDARDS 

The U.S. Army Corps of Engineers would review the design drawings for the headquarters enlargement and 

parking relocation and wetland delineation report prior to construction. The project designers would request 

authorization to fill the wetland. 

A permit from the U.S. Army Corps of Engineers will not be required to fill less than 0.1 acre of wetland in the 

project area. It falls under the nationwide permits because it is less than one acre. 
APPENDIXES

202 

CONCLUSION 

The National Park Service finds that there are no practicable alternatives to disturbing 0.03 acre of wetlands 

within this project. Wetlands have been avoided to the maximum practicable extent, and the wetland impacts that 

could not be avoided would be minimized, and compensatory mitigation would be implemented. This project is 

consistent with the “no net loss of wetland” policy. The National Park Service, therefore, finds that this project is 

in compliance with Executive Order 11990: “Protection of Wetlands.” 

PREPARERS AND CONSULTANTS 

Mary Magee, Natural Resource Specialist, Denver Service Center, National Park Service 

Pamela Benjamin, Vegetation Ecologist, Intermountain Region, National Park Service 

Leslie Krueger, Natural Resource Specialist, Water Resources Division, National Park Service 

REFERENCES 

National Park Service, U. S. Department of the Interior 

 1998 Director’s Order 77-1: “Wetland Protection.” 

 2000 “Trip Report for field trip to Devils Tower National Monument on June 5-7.” Prepared by Pamela 

Benjamin, Intermountain Region. (Trip taken to survey and assess potential wetland areas). 

 2001 Draft General Management Plan / Environmental Impact Statement: Devils Tower National 

Monument. Denver, CO. 

U.S. Geological Survey, U.S. Department of the Interior 

 2000 Devils Tower National Monument Vegetation Descriptions. Information from the Web site of USGS 

Biological Resources, “The USGS–NPS Vegetation Mapping Program.” Available on Internet at 

http://biology.usgs.gov/npsveg/DETO/descript.html. 
203 

APPENDIX F: MEMORANDUM OF UNDERSTANDING REGARDING 

PRAIRIE DOGS 

(6 pages) 
APPENDIXES

204 

prairie dogs, p. 2 
Appendix F: Memorandum of Understanding Regarding Prairie Dogs 

205 

prairie dogs, p. 3 
APPENDIXES

206 

prairie dogs, p. 4 
Appendix F: Memorandum of Understanding Regarding Prairie Dogs 

207 

prairie dogs, p. 5 
APPENDIXES

208 

prairie dogs, p. 6 
209 

BIBLIOGRAPHY 

Arizona Game and Fish Department. Wildlife 

Management Division 

 1999 The Black-Tailed Prairie Dog Conservation Assessment and Strategy: 

Final Draft. Edited by William E. Van 

Pelt. Phoenix, AZ. 

Arizona, Colorado, Kansas, Montana, Nebraska, 

New Mexico, North Dakota, Oklahoma, South 

Dakota, Texas, and Wyoming 

 1999 Memorandum of Understanding 

among State Fish and Wildlife 

Agencies within Black-tailed Prairie 

Dog Range: Conservation and 

Management of Black-tailed Prairie 

Dog in North America. 

Bureau of Reclamation, U.S. Department of the 

Interior 

 1987 Safety Evaluation of Existing Dams 

(SEED): Keyhole Dam.

Byrne, William 

 2000 “Devils Tower Visitor Transportation 

Analysis.” Prepared for the National 

Park Service by BRW, Inc.

Campbell, T. M., and T. W. Clark 

 1991 “Colony Characteristics and Vertebrate 

Associates of White-tailed and Blacktailed Prairie Dogs in Wyoming.” 

Amer. Mid. Nat. 105:269–276.

Crook County, Wyoming 

 1996 Municipal Emergency Operations 

Plan: Wyoming Hazard Identification 

and Risk Assessment Survey, Wyoming 

Emergency Management Agency. 

 1998 Land Use Plan for Crook County. 

Dobb, Edwin

 2000 “Can Humans Help Other Species 

Defy Extinction?” High Country 

News, December 18. 

Fertig, Walter 

 2000a Rare Plants of Devils Tower National 

Monument. University of Wyoming, 

Wyoming Natural Diversity Database. 

Laramie, WY. 

Fertig, Walter 

 2000b Status Review of the Ute Ladies’ 

Tresses (Spiranthes diluvialis) in Wyoming. Prepared by the University of 

Wyoming Natural Diversity Database 

for the Wyoming Cooperative Fish and 

Wildlife Research Unity, U.S. Fish and 

Wildlife Service, and Wyoming Game 

and Fish Department. Laramie, WY. 

Hanson, Jeffery R., and Sally Chirinos

 1997 “Ethnographic Overview and Assessment of Devils Tower National Monument, Wyoming.” Report prepared for 

the National Park Service by the 

University of Texas at Arlington.

Hyngstrom, Scott E., and Dallas R. Virchow 

 N.d. Prairie Dogs: Damage Prevention and 

Control Methods. Lincoln and Scottsbluff, NE: University of Nebraska 

Marriott, H. 

 1982 “Devils Tower National Monument 

Plant Checklist.” Report prepared for 

the Devils Tower Natural History 

Association. 

Miller, Brian, Gerardo Ceballos, and Richard 

Reading 

 1994 “The Prairie Dog and Biotic 

Diversity.” Conservation Biology 8 3

(Sept. 1994):677–681. 

National Park Service, U.S. Department of the 

Interior 

 1992 Resources Management Plan: Devils 

Tower National Monument. 

 1993a Floodplain Management Guideline. 

Washington, DC.
BIBLIOGRAPHY

210 

National Park Service, U.S. Department of the 

Interior

 1993b Guiding Principles of Sustainable 

Design. 

 1995 Final Climbing Management Plan / 

Finding of No Significant Impact: 

Devils Tower National Monument, 

Crook County, Wyoming. Denver, CO: 

Rocky Mountain Region.

 1998a National Park Service Procedural 

Manual 77-1: Wetland Protection.

Technical Report NPS/NRWRD/ 

NRTR-98/203. Denver, CO. 

 1998b Resources Management Plan: Devils 

Tower National Monument. 3rd ed.

 2000a “Environmental Assessment: Monument Review Draft: Rehabilitate 

Monument Entrance Road and Visitor 

Center Parking, Crook County, 

Wyoming” (December 19, 2000). 

 2000b National Register of Historic Places 

registration form for entrance road, 

Devils Tower National Monument. 

(June 6, 2000). 

 2001a Management Policies 2001. 

Washington, DC. 

 2001b Proposed Transportation System: 

Economic Feasibility Analysis.

Concessions Program Center. 

Robert Peccia and Associates 

 1999 “Summary of Traffic and Visitor Use 

Data Collected in 1999: Technical 

Memorandum, Devils Tower National 

Monument.” Report prepared for the 

National Park Service. 

Sharps, Jon C., and Daniel W. Uresk 

 1990 “Ecological Review of Black-tailed 

Prairie Dogs and Associated Species in 

Western South Dakota,” Great Basin 

Naturalist 50 (4):339–345. 

U.S. Environmental Protection Agency 

 1998 Environmental Justice Guidance.

From the Internet at 

http://es.epa.gov/oeca/ofa/ejepa.html

U.S. Fish and Wildlife Service, U.S. Department of 

the Interior 

 1979 Classification of Wetlands and Deepwater Habitats of the United States.

Prepared for the USFWS by Lewis M. 

Cowardin (USFWS), Virginia Carter 

(USGS), Francis C. Golet (Univ. of 

RI), and Edward T. LaRoe (NOAA). 

Reprint 1992. Washington, DC: U.S. 

Fish and Wildlife Service. 

 1989 Habitat Suitability Index Models: 

Black-tailed Prairie Dog, by Norman 

W. Clippinger. Biological Report 82 

(10.156). Fort Collins, CO: National 

Ecology Research Center. 

 1995a “Recommendations and Guidelines for 

Ute Ladies’ Tresses (Spiranthes 

diluvialis) Recovery and Fulfilling 

Section 7 Consultation 

Responsibilities.” 

 1995b “Ute Ladies’ Tresses (Spiranthes 

diluvialis) Recovery Plan: Agency 

Review Draft. Prepared by the Ute 

Ladies’ Tresses Recovery Team for 

Region 6, USFWS. 

U.S. Forest Service, U.S. Department of 

Agriculture 

 1987 “A Statistical Model of Expansion in a 

Colony of Black-tailed Prairie Dogs,

by R. P. Cincotta, D. W. Uresk, and R. 

M. Hansen. General Technical Report 

RM-154. Rapid City, SD. 

U.S. Geological Service, U.S. Department of the 

Interior 

 2000 Devils Tower National Monument 

Vegetation Descriptions. Information 

from the Web site of USGS Biological 

Resources, “The USGS-NPS Vegetation Mapping Program.” Available 

on Internet at http://biology.usgs.gov/ 

npsveg/DETO/descript.html 
Bibliography 

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University of Minnesota. Department of Forest 

Resources 

 2000 “Devils Tower National Monument: 

1999 Visitor Use Study,” by Cynthia 

A. Warzecha, David W. Lime, and 

Jerrilyn L. Thompson. Prepared for the 

National Park Service by the Cooperative Park Studies Unit (July 26, 

2000). 

University of South Dakota. Archeology 

Laboratory 

 2000 “The Archaeological Survey and 

National Register Evaluation of Devils 

Tower National Monument, Crook 

County, Wyoming 1997–1998,” by 

Brian L. Molyneaux, Nancy J. 

Hodgson, and Rachel M. Hinton. 

Vermillion, SD. 

Wyoming Department of Commerce 

 1995 SCORP: State Comprehensive 

Outdoor Recreation Plan, prepared by 

John. F. Mahoney, Celeste Colgan, 

and Gary Thorson, Division of State 

Parks and Historic Sites. Cheyenne, 

WY. 

Wyoming Department of Employment 

 1998 Occupational Employment Statistics 

Wage Survey. Cheyenne, WY 

Wyoming Game and Fish Department. Wildlife 

Division 

 1997 Atlas of Birds, Mammals, Reptiles and 

Amphibians in Wyoming. Edited by 

Bob Luce, Bob Oakleaf, Andrea 

Cerovski, Lori Hunter and John 

Priday. Cheyenne, WY. 
212 

PREPARERS OF DOCUMENT 

NATIONAL PARK SERVICE 

Denver Service Center 

Marilyn Hof, Senior Planner. Coordinate project 

overall; analyze visitor use and visitor experience; 

B.S., M.S. (Recreation Resources); 27 years with 

National Park Service. 

Nola Chavez, Landscape Architect. Analyze design, 

visual resources, land use, circulation, construction 

costs; BLA (Landscape Architecture and Environmental Planning), MLA (Landscape Architecture); 21 

years with National Park Service. 

Mary Magee, Natural Resource Specialist. Primary 

preparer of document, describe natural and cultural 

resources, analyze impacts; B.S. (Biology); 27 years 

with National Park Service. 

Devils Tower National Monument 

Chas Cartwright, Superintendent. Overall monument 

management, including planning; B.A. (Anthropology); 25 years with National Park Service. 

Christine Czazasty, Chief of Interpretation. Help prepare list of advantages and disadvantages for 

alternatives; B.A. (Forest Management); 13 years 

with National Park Service. 

Robert King, Chief of Maintenance. Provide information on monument and maintenance issues, participate in public meetings; A.S. (Welding); 30 years 

with National Park Service. 

Christopher Moos, Administrative Officer. Participate in all public meetings and planning; write 

alternative descriptions; Ph.D. (Sociology); 13 years 

with federal government. 

Todd Suess, Chief of Natural and Cultural Resources. 

Lead preparer from the monument; B.S. (Recreation 

and Resource Management); 12 years experience. 

Intermountain Region 

Pam Benjamin, Vegetation Ecologist. Wetland 

identification; review natural resource information; 

B.S., M.S. (Biological Sciences); 16 years experience, 12 years with National Park Service. 

Brian Carlstrom, Geographic Information Systems / 

Natural Resource Specialist. Geographic information 

systems; B.S. (Parks, Recreation, and Leisure 

Studies); 13 years with National Park Service. 

Chris Turk, Regional Environmental Quality 

Coordinator. Scoping issues and alternatives; 

B.A.A.S. (Biological Sciences); 5 years Marine 

Scientist, University of Delaware, 23 years with 

National Park Service. 

Washington Office 

Mike Martin, hydrologist, Water Resources Division. 

Floodplain analysis; B.S. (Environmental Geology), 

M.S. (Watershed Science), 15 years experience. 

OTHER PREPARER 

Bill Byrne, Transportation and Transit Engineer and 

Planner, Vice President, David Evans and Associates, 

Inc. Transportation planning, impacts of shuttle 

systems, including costs; B.S., M.S. (Civil 

Engineering), 22 years experience. 

Publication Services, National Park Service 

Lou Layman, Writer-Editor, Denver Service Center 

Linda Ray, Technical Specialist, Denver Service 

Center 
Preparers of Document 

213 

CONSULTANTS 

National Park Service

Rick Ernenwein, Overflights and Noise Program 

Coordinator, Intermountain Region 

Laura Hudson, Program Manager for Threatened and 

Endangered Species, Intermountain Region 

Dan Licht, Regional Wildlife Biologist, Midwest 

Region 

Noel Poe, Superintendent, Theodore Roosevelt 

National Park 

John Reber, Air and Water Resource Coordinator, 

Intermountain Region 

Dave Rupert, Ethnographer, Intermountain Region 

Jim Schlinkmann, former Chief Ranger, Devils 

Tower National Monument 

Barbara Suteer, former Indian Affairs Coordinator, 

Intermountain Region 

Terri Urbanowski, Landscape Architect, Denver 

Service Center 

Palma Wilson, Superintendent, Colorado National 

Monument 

Other 

David Lime, University of Minnesota 

Jerrilyn Thompson, University of Minnesota 

Cynthia Warzecha, University of Minnesota 

Jonathan Weinstein, formerly Associate, Bay Area 

Economics 

Doug Widmeyer, Peccia and Associates 
INDEX

214 

(blank) 
215 

INDEX 

A

air quality, 5, 19, 54, 64, 77, 85, 86, 88, 99, 101, 

111, 114, 116, 127, 131, 133, 145, 149, 151 

American Indians, 3, 8, 9, 10, 11, 19, 22, 27, 28, 

49, 50, 66, 80, 89, 94, 95, 102, 103, 111, 117, 

118, 127, 134, 135, 145, 152, 160, 165, 166, 168, 

169, 189 

archeological sites, 4, 5, 9, 21, 50, 78, 79 

automobiles, 2, 82, 99, 114, 117, 131, 134, 154, 

159 

B

Belle Fourche River, 1, 2, 28, 31, 35, 40, 44, 48, 49, 

51, 63, 64, 65, 69, 76, 87, 89, 100, 102, 116, 117, 

132, 134, 150, 152, 165, 169, 200, 201 

Black Hills, 1, 4, 22, 63, 71, 76, 166 

buses (also see tour buses), 8, 12, 27, 31, 35, 40, 

44, 68, 85, 100, 108, 114, 124, 128, 129, 130, 

131, 140, 142, 154, 159 

C

camping, 25, 28, 31, 32, 40, 43, 44, 48, 49–52, 55, 

56, 58, 59, 65, 67, 68, 81, 85–87, 89, 91, 93, 94, 

97, 100, 101, 103, 105, 106, 107, 108, 112, 116, 

118, 121, 122, 123, 124, 125, 131, 132, 134, 135, 

138, 140, 141, 143, 144, 145, 150, 155, 169, 170 

carrying capacity, 1, 12, 102 

Civilian Conservation Corps (CCC), 2, 67, 68, 90, 

104, 119, 136, 153, 154 

climbers, climbing, 2, 3, 4, 27, 32, 36, 43, 47, 66, 

168, 169, 189, 210 

climbing management plan, 4, 27, 32, 36, 43, 47, 

66, 168, 169, 189, 210 

congestion, 1, 3, 19, 27, 28, 31, 35, 36, 40, 43, 44, 

48, 56, 58, 68, 69, 89, 90, 92, 93, 94, 95, 104, 

105, 127, 138, 145, 153–156, 159, 160, 161, 188 

construction, 1, 6, 13, 20, 32, 39, 43, 47, 48, 49, 50, 

53, 55, 56, 59, 71, 75, 77, 81, 82, 83, 88, 89, 90, 

97, 98, 99, 102, 103, 104, 105, 108, 109, 110, 

111, 112, 113, 114, 115, 117, 118, 119, 120, 125, 

126, 127, 128, 129, 130, 131, 134, 135, 136, 137, 

142, 143, 144, 145, 147, 148, 151, 152, 154, 155, 

158, 159, 160, 170, 197, 198, 200, 201, 212 

cottonwood trees, 53, 98, 99, 114, 130 

cultural resources, 1, 10, 13, 19, 20, 49, 55, 56, 66, 

67, 78, 79, 80, 83, 89, 90, 91, 94, 102, 104, 105, 

117, 120, 126, 134, 137, 144, 152, 153, 154, 159, 

166, 168, 187, 189, 212 

D

disability (see mobility impairment), 5, 12, 25, 77 

E

economy, 20, 59, 71, 80, 81, 82, 94, 109, 124, 125, 

126, 141, 142, 143, 158 

employment, 59, 71, 79, 81, 82, 84, 94, 108, 109, 

124, 125, 126, 141, 142, 143, 158, 200 

environmental justice, 22, 210 

erosion, 4, 6, 49, 53, 63, 76, 77, 84, 85, 88, 90, 97, 

98, 101, 104, 112, 113, 116, 119, 128, 129, 130, 

133, 136, 147, 148, 151, 154, 159 

ethnographic resources, 4, 9, 10, 14, 20, 26, 27, 55, 

66, 78–80, 89, 90, 94, 96, 102, 103, 105, 111, 

117–119, 134, 135, 136, 152, 153, 154, 159, 160 

exotic plant species, 2, 5, 6, 7, 21, 63, 76, 198 

F

fires and firefighting, 2, 7, 8, 64, 170 

floodplains, 2, 5, 6, 19, 35, 36, 48, 49, 55, 63, 65, 

77, 87–89, 94, 100–102, 110, 115, 116, 117, 132, 

134, 144, 145, 150–152, 159, 165, 169, 170, 188, 

200 

floods, flooding, 49, 64, 65, 76, 77, 87, 100, 101, 

132, 150, 200 

forests, 2, 7, 12, 22, 48, 63, 71, 75, 76, 108, 123, 

141, 166, 169, 170, 198, 210, 211, 212 

H

hardened surfaces, 53, 84, 97, 112, 127, 128, 129, 

145, 147, 159 

hikers and hiking, 35, 40, 44, 48, 68, 139, 156 

historic resources, 2, 4, 9, 10, 11, 20, 21, 27, 31, 36, 

43, 44, 48, 49, 50, 56, 66, 77, 78, 79, 80, 89, 90, 

91, 103, 104, 111, 119, 127, 135, 136, 145, 153, 

154, 159, 165, 169, 197, 198, 200 

I

interpretation, 2, 3, 13, 19, 20, 24, 25, 27, 28, 31, 

35, 36, 40, 43, 44, 47, 51, 52, 57, 64, 66, 69, 80, 

92, 95, 100, 106, 107, 122, 127, 128, 139, 140, 

145, 156, 160, 165, 168, 169, 188, 189, 212 

invasive species, 6, 7, 53, 63, 113 

K

Keyhole Dam, 64, 65, 76, 87, 88, 100, 101, 102, 

117, 132, 134, 150, 151, 169, 170, 209 
L

landowners, 39, 58, 63, 71, 88, 102, 108, 117, 133, 

151 

M

mobility impairment, 27, 90, 104, 106, 110, 121, 

122, 127, 139, 145, 153 

N

National Environmental Policy Act (NEPA), 20, 

48, 79, 80 

National Historic Preservation Act, 5, 9, 10, 11, 12, 

20, 56, 78, 79, 80, 90, 104, 119, 136, 153, 154 

National Register of Historic Places, 9, 10, 11, 21, 

27, 56, 66, 67, 78, 79, 83, 89, 94, 103, 104, 111, 

119, 127, 135, 145, 153, 160, 187, 210 

Native Americans (also see American Indians), 10, 

11, 168 

natural resources, 6, 13, 22, 23, 48, 49, 63, 77, 78, 

83, 84, 89, 94, 97, 102, 110, 112, 117, 128, 134, 

144, 147, 152, 159, 166, 188, 189 

noxious plants, 63 

P

prairie dogs, 1, 2, 19, 20, 27, 28, 31, 35, 36, 40, 43, 

44, 51, 52, 54–58, 64, 68, 69, 76, 86, 88, 89, 91, 

92, 95, 97–99, 100–105, 107, 110, 112–118, 120, 

122, 123, 126, 128–131, 133–135, 137–140, 144, 

147–149, 151–157, 159, 160, 170, 204–208 

R

ranches and ranching, 2, 71, 76, 86– 89, 101, 102, 

116, 117, 133, 134, 150–152 

religious significance, religious activities, 4, 9, 10, 

19, 49, 50, 55, 66, 89, 94, 95, 117, 118, 126, 134, 

135, 144, 152, 159, 160, 189 

S

safety, 2, 7, 12, 20, 24–27, 31, 40, 44, 56, 58, 65, 

69, 80, 86, 92, 95, 105, 107, 122, 138, 140, 154, 

156, 157, 159, 160, 161, 170 

section 106 (also see National Historic 

Preservation Act, 56, 79, 80, 90, 104, 119, 136, 

153, 154 

shuttles, 12, 35, 36, 40, 43, 44, 48, 51, 54–59, 112–

114, 117–128, 129–132, 134–139, 140–145, 165, 

169, 188, 197, 212 

socioeconomic resources, 80, 82, 83, 94, 110, 126, 

144, 159 

soils, 2, 19, 21, 53, 63, 76, 77, 84, 88, 89, 97, 98, 

101, 102, 106, 110, 112, 113, 116, 117, 127–129, 

132–134, 145, 147, 148, 151, 152, 159, 160, 187, 

189, 198, 200 

solitude, 25, 32, 36, 43, 55, 102, 103, 106, 117, 

118, 120, 121, 134, 135, 138, 144, 152, 159, 160 

staging area, 21, 24, 35, 36, 40, 43, 48, 51, 54, 55–

58, 112–115, 120, 122, 123, 126–132, 134, 137, 

139–141, 144, 145, 169, 188, 197 

T

threatened and endangered species, 5, 6, 19–21, 64, 

77, 78, 187, 200 

tour buses, 8, 12, 27, 31, 35, 40, 44, 51, 55, 56, 97, 

98, 119, 135, 136, 149, 152, 159, 160 

trails, 1, 3, 11, 24, 25, 27, 28, 31, 35, 36, 40, 43, 44, 

48, 49, 51, 55–57, 63, 64, 66–68, 84, 85, 91, 92, 

95, 97–100, 102, 103, 105–109, 112–115, 117, 

118, 120–122, 125, 126, 128–131, 134, 135, 

137–140, 142, 144, 147–149, 154–156, 159, 169, 

188 

V

vegetation, 1, 2, 7, 19, 21, 31, 32, 36, 40, 43, 52, 

53, 76, 77, 79, 84, 85, 88, 89, 91, 97–99, 101, 

102, 105, 106, 110, 112–114, 116, 117, 120, 126, 

128–130, 133, 134, 137, 144, 147, 148, 151, 152, 

155, 160, 189, 197, 198, 200, 201 

viewsheds, 2, 19, 55, 56, 89–91, 94, 102, 104–106, 

117, 118, 120, 121, 126, 134, 136–138, 152, 153, 

155, 159, 160, 187, 188, 197, 198, 200 

visitor experience, 1, 4, 5, 8, 12, 19, 20, 24, 44, 49, 

56, 80, 91, 92, 105, 107, 110, 111, 120, 122, 123, 

126, 127, 137, 138, 140, 144, 145, 155–157, 160, 

165, 187, 198, 212 

visitors and visitation, 1, 2, 12, 19, 22, 27, 31, 35, 

40, 44, 56, 68, 85, 88, 92, 93, 95, 101, 102, 105, 

111, 116, 119, 120, 122, 124, 133, 135–137, 140, 

149, 151, 155, 160, 168 

W

wetlands, 5, 6, 19, 49, 54, 64, 77, 86, 87, 88, 89, 

100, 102, 115, 117, 132, 134, 149, 150, 151, 152, 

160, 187, 188, 197, 198, 199, 200, 201, 202 

wildlife, 2, 7, 12, 19–21, 53, 63, 64, 68, 76, 77, 80, 

85, 86, 88, 89, 91, 94, 95, 98, 99, 101, 102, 110, 

114, 116, 117, 120, 121, 126, 130, 133, 134, 138, 

148, 151, 152, 154, 166, 187, 193, 198, 200, 

209–211, 213