2020

Park County Montana

 

Old Yellowstone Trail South 

Corridor Study
Old Yellowstone Trail South Corridor Study

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Table of Contents

Definitions.................................................................................................................................................... iv

Executive Summary.......................................................................................................................................1

Introduction ..............................................................................................................................................1

Study Area.................................................................................................................................................2

Focus Areas...............................................................................................................................................2

Existing Conditions....................................................................................................................................3

Public and Stakeholder Participation........................................................................................................3

Problem Statement, Goals, and Objectives..............................................................................................4

Possible Improvements.............................................................................................................................5

Conclusions.............................................................................................................................................10

Chapter 1. Introduction ..............................................................................................................................11

Background .............................................................................................................................................11

Study Area...............................................................................................................................................12

Problem Definition..................................................................................................................................13

Focus Areas.............................................................................................................................................14

Key Considerations .................................................................................................................................16

Chapter 2. Existing Conditions....................................................................................................................19

Geographical Area...................................................................................................................................19

Population...............................................................................................................................................19

Annual Visitors and Tourism...................................................................................................................19

Recreation...............................................................................................................................................20

Wildlife....................................................................................................................................................22

Roadway..................................................................................................................................................23

Railbed ....................................................................................................................................................24

Segment Summary..................................................................................................................................24

Old Yellowstone Trail South Segment Map ............................................................................................25

Chapter 3: Stakeholder Involvement..........................................................................................................47

Planning Process.....................................................................................................................................47
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Public Participation Procedures..............................................................................................................47

Summary Of Public Outreach..................................................................................................................48

Project Team...........................................................................................................................................53

Chapter 4. Problem Statement, Goals, and Objectives .............................................................................59

Problem statements: ..............................................................................................................................59

Goal #1 ....................................................................................................................................................60

Goal # 2 ...................................................................................................................................................60

Goal #3 ....................................................................................................................................................61

Chapter 5. Action Plan ................................................................................................................................63

Geometric and Surface Condition Improvements..................................................................................65

Segment Specific Improvements............................................................................................................71

Additional Recommendations ................................................................................................................92

Appendix A: Geotechnical Report No. 17-18..............................................................................................94

Appendix B: Introductory Environmental Assessment...............................................................................96

Appendix C: Planning Cost Estimate .........................................................................................................108

Appendix D: Cost by Improvement Option...............................................................................................110
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Definitions

ADA Americans with Disabilities Act

BLM Bureau of Land Management

FHWA Federal Highway Administration

FLAP Federal Lands Access Program

FLMA Federal Land Management Agency

MP Milepost

NPS National Park Service

OYTS Old Yellowstone Trail South

ROW Right of Way

USFS United States Department of Agriculture Forest Service

USMP Unstable Slopes Management Plan

WFL Western Federal Lands Highway Division

YELL Yellowstone National Park
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Executive Summary

Introduction

At the request of Park County Montana, Western Federal Lands Highway Division (WFL) conducted a 

study of the Old Yellowstone Trail South (OYTS) road alignment for potential improvements to the 

corridor. Sitting 60- to 90- minutes from Bozeman and less than an hour from Livingston, the county seat 

of Park County, Old Yellowstone Trail South has the potential to be a major recreational destination. 

The objective of the study is evaluation of the corridor which includes a road and trail of the same name,

Old Yellowstone Trail South. The two intertwine one another for 21+ miles and provide access to homes, 

recreation, farming, and a place of worship. This study, referred to as the Old Yellowstone Trail South 

Corridor Study, is a planning level review of safety; operational and geometric conditions; and 

environmental resources within the corridor to identify needs and constraints. This study is not intended 

to be a decision document. This effort strives to identify feasible improvements within the study area

based on needs identified by the public, the study partners, and resource agencies. It will serve as a preNEPA evaluation to identify reasonable options for the 21-mile corridor.

A section of the road was blocked by a rockslide in 2014, and has remained unpassable up to the writing 

of this document. Removing the rockslide, restoring the roadway and reestablishing emergency access is 

the primary objective of Park County officials. Additionally the question was raised of whether the 

corridor is suitable as a recreational corridor. There is anticipation that opening the roadway will 

encourage additional activity. Considering additional activity in the corridor raised further questions: 

Should the road be reopened to the public? Should it provide only emergency access? Should it provide 

recreational access? Should there be a plan for more people? Should there be consideration for 

additional activities? 

A major consideration for this corridor is the proximity to Yellowstone National Park and inclusion within 

Custer Gallatin National Forest. Maintenance, improvements and decisions regarding management of 

the corridor must be a collaborative effort and consider the resources and mission of each of the 

agencies involved. 
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Study Area

OYTS is a roadway and trail of the same name located in Park County, Montana. The study area is a 21.1-

mile-long corridor starting at the Roosevelt Arch Monument in Gardiner, meeting US Highway 89 just 

beyond the landform referred to as Point of Rocks. The corridor is bounded on the east by the 

Yellowstone River and on the west by the Gallatin Range.

Focus Areas

Three main focus areas emerged from discussions with Park County, Land Management Agencies, and 

the public:

• Focus Area 1 – Safety: Provide safer and more adequate transportation access to and through 

CGNF and YNP for residents, recreationists, visitors and resource users.

• Focus Area 2 – Condition: Ensure the future use of the corridor is not inhibited by degradation of 

travel surfaces. 

• Focus Area 3 – Planning for Growth: Establish a balance in developing recreational 

opportunities, while also preserving the existing character of the area. Ensure that increased use 

does not elicit an increase in unwelcome behaviors.

Figure ES- 1 Park County, Montana geographical area with 

study area identified in the lower left corner. Source: Google 

Earth 

Figure ES- 2 Old Yellowstone Trail South Corridor Study Area. 

Source: WFLHD GIS
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Existing Conditions

The OYTS road is used to access recreation and private property within the study area. Recreation in the 

study area includes camping, cycling, hiking, fishing, rafting and boating. Wildlife in the area include

bison, grizzly and black bear, wolves, big horn sheep, pronghorn antelope, elk, and numerous species of 

birds and fish.

Roadway 

The existing roadway is gravel of varying width and condition. Park County performs regular 

maintenance, and deploys a grader at least annually to correct surface irregularities and restore the 

crown of the road. Many large vehicles use the roadway to support ranching and farming operations. 

The National Park Service (NPS) uses the roadway for transport of semi-trailers full of horses and bison

and access to their bison operations.

Safety is a concern in the corridor, due to unstable slopes, wildlife interactions, and roadway geometry 

and condition. Geotechnical concerns such as unstable slopes and lack of catchment ditches contribute 

to the degradation of the road and pose risks to existing users. The road corridor has been closed to 

through traffic since 2014 due to slides at milepost (MP) 14.1 and 14.2. Additional safety concerns 

include limited sight distance, lack of guardrails, narrow sections of road and portions where high 

speeds could produce significant consequences.

Drainage issues at many points along the roadway cause roadway flooding, washboarding, potholes and 

rutting. In addition, runoff has washed away the surface aggregate in places, allowing the remaining 

roadbed to become muddy or impassable.

Railbed

The rail line has long been removed, and the land beneath it has been returned to property owners. An 

informal trail has developed on many segments of the original rail alignment. On the ground, navigating 

the trail is quite simple for the first half of the corridor but becomes progressively more difficult as the 

condition deteriorates and the ownership converts to a higher percentage of private property. A couple

property owners have visible segments of former railbed on their property, while others have obscured 

the original sections through farming or construction of buildings. 

The condition of the trail is deemed good in segments near the start of the study area, and has become 

overgrown or nonexistent in other segments. Current irregularities in the surface of the former railbed 

prevent designation of the alignment as a proper trail.

Public and Stakeholder Participation

WFL met with project partners, the public and other local stakeholders to gather information and 

comments. Attendees of the public meeting were largely interested in the impact the development 

would have on their property and what could be expected from the process. Largely, residents were 

worried about maintaining the nature of the corridor, and were in support of keeping improvements as 

minimal as possible. 
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The main message from public agencies is the interest in improving, enhancing and protecting public 

health and safety; emergency access; recreational opportunities; and environmental and cultural

resources. There is anticipation that this corridor will have growth in population and recreational users. 

A plan is requested that will provide a basis for future decisions regarding investment in recreational 

opportunities and ensure safety of the users. There is concern about condition of the road.

Agencies that also responded to the request for comment include: Montana Fish, Wildlife and Parks; 

Yellowstone Gateway Museum; Royal Teton Ranch; Rails to Trails Conservancy; and archeologists from 

USDA Forest Service.

Problem Statement, Goals, and Objectives

Evaluation of the corridor, discussions with public officials and inputs from stakeholders generated a 

significant list of concerns, suggestions, and needs within the corridor. Based on the results of those 

inputs, we have identified 8 problem areas:

1. Secondary emergency access

2. Roadway condition

3. Impact to wildlife

4. Destruction of archaeological assets 

5. Environmental degradation

6. Impact to property owners

7. Corridor encroachment

8. Visitor experience

Through this study, the following Goals and Objectives were determined. These Goals and Objectives 

will help to guide future construction improvements and/or can be used in the NEPA process.

Goal #1 

Improve the corridor to establish a throughway for vehicle and recreational use.

Objectives

• Provide secondary emergency access through the full corridor.

• Improve roadway elements to better road condition and increase user safety.

• Establish a multi-use trail separated from the roadway where possible.

Goal # 2

Protect cultural and natural resources that make the corridor unique.

Objectives

• Minimize impacts to wildlife and the landscape from corridor usage.

• Minimize impacts to archaeological resources.

• Highlight original transportation connections along the trail.
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Goal #3

Balance visitor experience with landowner property rights.

Objectives

• Involve property owners in the planning process.

• Provide a positive and coherent visitor experience.

Possible Improvements

Corridor-wide Improvements

This section summarizes general geometric and surface condition improvements throughout the 

corridor. The general recommendations are referenced or described in more detail for each segment in 

the sections below.

Road

- Improve roadway to consistent width (20 foot, 24 foot or 28 foot). The width of the existing 

roadway varies throughout the corridor. See Figure 1 for roadway typical cross-section options. 

- Elevate finish grade in low areas to prevent ponding of water on road surface

- Recondition gravel surface to eliminate formation of muddy sections and reduce washboarding

- Improve drainage in problem areas:

o Install, replace, repair, or clean culverts where necessary. 

o Construct drainage ditches. Where drainage ditches are already present, clear them of 

any debris or overgrowth.

o Establish crown on roadway

- Apply dust-free surface applications when multi-use trail shares right-of-way. Consider use of a 

sealant or other treatment that will secure the surface and prevent erosion. 

- Continue regular maintenance

- Clear debris and vegetation from road edge

- Install clear wayfinding signs
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Figure ES- 3 Road Typical Cross Section

Trail

- Improve trail to consistent width (6 to 10 foot) where it is separated from the road. The width of 

the trail varies throughout the corridor. See Figure 2 for trail typical cross-section options.

o The 6-foot wide cross-section could keep the trail surfacing as dirt, or add aggregate

o The 10-foot wide cross-section assumes adding aggregate

- Grubbing and clearing of overgrowth

- Remove large rocks from trail

- Fill potholes, sinkholes, and ruts

- Establish standards for surface preparation, treatment and maintenance

- Install clear wayfinding signs
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Figure ES- 4 Trail Typical Cross Section

Range of Improvement Options

Possible improvements are grouped together below in three options for the entire corridor. It is worth 

noting that the improvement options are packaged together for ease of comparison, but project 

partners may choose to “mix and match” segment options in myriad combinations. The estimated 

construction cost is based on planning-level cost estimates described in Appendix A.

• Option 1: 20-Foot Road with Minimum Improvements (est. construction cost $2.0 million)

o Road: 

 Clear the blockages on the roadway at MP 14.1 and 14.2

 Undertake low-cost slope stabilization measures

 Establish consistent 20-foot road width; except keep one-lane width in Yankee 

Jim Canyon with intervisible turnouts for passing

 Recondition road with aggregate

 Improve drainage:

• Install, replace, repair, or clean culverts where necessary. 

• Construct or clear drainage ditches. 

• Establish crown on roadway

 Install clear wayfinding signs

o Trail:

 Formalize existing trailhead

 Remove rocks and clear and grub vegetation from trail

 Establish or maintain 6-foot dirt trail where trail is separated from road
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 Separate trail from roadway where feasible, but do not acquire easements 

where trail is on private property

• Trail on existing, separated alignment in Segments 1, 3, and most of 5

• Trail on shared ROW with road in Segments 2, 4, portion of 5, and 6, 7, 8

 Install clear wayfinding signs

• Option 2: 24-Foot Road with Moderate Improvements (est. construction cost $5.3-6.4 million)

o Road: 

 Clear the blockages on the roadway at MP 14.1 and 14.2

 Undertake mid-range slope stabilization measures

 Widen to consistent 24-foot road width; except keep one-lane width in Yankee 

Jim Canyon with intervisible turnouts for passing

 Recondition road with aggregate

 Improve drainage:

• Install, replace, repair, or clean culverts where necessary. 

• Construct or clear drainage ditches. 

• Establish crown on roadway

 Install clear wayfinding signs

o Trail:

 Build a trail from the Gateway Arch to the existing trailhead. 

 Remove rocks and clear and grub vegetation from trail

 Improve to 6-foot aggregate trail where trail is separated from road

 Separate trail from roadway where feasible, but do not acquire easements 

where trail is on private property

• Trail on existing, separated alignment in Segments 1, 3, and most of 5

• Trail on shared ROW with road in Segments 2, 4, portion of 5, and 6, 7, 8

 Install clear wayfinding signs

• Option 3: 28-Foot Road with High Improvements (est. construction cost $8.9-$15.1 million.

1

) 

o Road: 

 Clear the blockages on the roadway at MP 14.1 and 14.2

 Undertake extensive slope stabilization measures

 Widen to consistent 28-foot road width; except keep one-lane width in Yankee 

Jim Canyon with intervisible turnouts for passing

 Recondition road with aggregate

 Improve drainage:

• Install, replace, repair, or clean culverts where necessary. 

• Construct or clear drainage ditches. 

 1 The $15.1 million includes a pedestrian bridge over the Yellowstone River at an estimated cost of $4-5 million
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• Establish crown on roadway

 Install clear wayfinding signs

o Trail:

 Build a trail from the Gateway Arch to the existing trailhead or build a 

pedestrian bridge over the Yellowstone River. 

 Remove rocks and clear and grub vegetation from trail

 Widen to 10-foot aggregate trail

 Maximize trail separation from road, including negotiating with property owners 

to try to acquire easements where trail is on private property

• Trail on existing, separated alignment in Segments 1, 3, and most of 5

• Work with landowners to acquire easements for trail in Segments 2, 4, 

portion of 5, 7, and 8

• Trail on shared ROW with road in Segment 6

 Install clear wayfinding signs

Conclusions

This study set out to look at the existing conditions of the corridor and develop an evaluation of the 

future possibilities. Over the course of the development of this report, the opinion has existed that Old 

Yellowstone Trail South is a viable alignment for a mixed-use recreation corridor. It is clear that it 

already is being used as such, and there is no evidence that suggests changing the existing use. 

The authors of the report recommend that at a minimum, the rockslide and landslide in Yankee Jim 

Canyon be removed and reinforced to allow the roadway to be reopened. The lack of a secondary 

emergency access presents an unnecessary risk for the residents and visitors of the Gardiner Basin. In 

addition to removing the rockslide, the roadway approaching the rockslide from the south is in need of 

repair and maintenance to improve the existing condition. There must be a commitment to ensure the 

roadway is passable at all times of the year. 

Once access is restored, it is advisable to perform a baseline visitor use survey. Having a baseline survey 

will give decisionmakers the information they need to ensure that the demand on the corridor does not 

exceed the capacity. The options presented in the report allow the owners of the roadway to pick and 

choose which improvements to implement. Possible projects provide flexibility to proactively address 

increased demand and remain agile to changing usage patterns. No major projects are currently 

recommended in the corridor. It does not appear that current demand justifies major expenditures. It is 

possible that major improvements may never be necessary. 

The primary objective based on feedback from stakeholders and residents is to retain the current 

character of the corridor and to ensure the condition of the roadway and trail do not deteriorate. It is 

recommended that the corridor be monitored closely, especially in response to the reopening of the 

access through Yankee Jim Canyon.
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Chapter 1. Introduction

At the request of Park County Montana (COUNTY), Western Federal Lands Highway Division (WFL)

conducted a study of the Old Yellowstone Trail South (OYTS) alignment for potential improvements to 

the corridor. The study, referred to as the Old Yellowstone Trail South Corridor Study, is a planning level 

review of safety; operational and geometric conditions; and environmental resources within a defined 

corridor to identify needs and constraints. This effort strives to identify feasible improvements within 

the study area based on needs identified by the public, the study partners, and resource agencies. Park 

County Commissioners submitted an application in March 2016 to request Federal Lands Access 

Program (FLAP) funding for a planning feasibility study in the Gardiner Basin. In November 2016, the 

study was selected by the Programming Decisions Committee (PDC), which consists of representation by 

WFL, Montana Department of Transportation (MDT), and Montana Association of Counties (MACo). 

OYTS currently provides the only secondary access option between Tom Miner and Gardiner as an 

alternative to US Highway 89. As of the time of this writing, the roadway is unusable for anything more 

than a walking and cycling path. In 2014, OYTS was rendered impassable by a rockslide covering a 

section of the road, and then a landslide on the cut side of the slope above the river washed out a 

section of the road. OYTS was investigated for the possibility to provide secondary emergency access, as 

well as potentially improving the recreational options along the corridor. This was a collaborative 

process including WFLHD, Park County, the unincorporated Town of Gardiner, the United States Forest 

Service (USFS), National Park Service (NPS) and Bureau of Land Management (BLM). 

Background

Old Yellowstone Trail South holds historical significance for its role in facilitating travel to Yellowstone 

National Park2

. Yellowstone National Park was established in 1872 by President Ulysses S. Grant. Around 

the same time the first road was under construction to provide formal access for visitors. The original 

road may have been a mining road and served mostly stagecoaches and movement of livestock. One 

account states that the road was built by a miner from Cooke City3

. Roads of the time were not always 

well maintained, and often farmers didn’t see the need to improve their roadways for the access of 

outside “tourists”. Government money was not often allocated for their construction or maintenance 

either. After the road was built, one man living in the area claimed ownership of a narrow section of the 

road and established a toll collection, though it is unlikely he did much to maintain it. Stories abound 

about the man Yankee Jim George, who operated the toll road named in his honor. It is also said he may 

have built the toll road, but accounts are inconsistent. In 1883, in response to the demand to visit the 

park, the Northern Pacific Railroad extended a line to Cinnabar, making the toll road somewhat 

obsolete4

. In the process, some of the roadway alignment was acquired for the construction of the 

railroad, and new roadways had to be constructed over more difficult terrain. 

 2 Letter from Gateway Museum

3 Paradise Valley Corridor Planning Study

4 (https://www.nps.gov/yell/learn/historyculture/park-history.htm)
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In 1903, the arch at the north entrance of Yellowstone National Park was dedicated by Theodore 

Roosevelt. The same year, the railroad was also extended from Cinnabar to Gardiner5

. Not long after the 

railroad was completed automobile ownership started becoming more common. There was soon 

demand for an improved roadway leading to Yellowstone. A plan by some businessmen in South Dakota 

to construct a roadway from Chicago to Gardiner started to gain momentum and soon the federal 

government was in support of getting the roadway built. The original idea for a road to connect Ipswich, 

MA to Aberdeen, SD grew into a plan for a transcontinental route to ‘get folks to Yellowstone’ in just a 

few weeks. The route was known as the Yellowstone Trail and was one of a handful of transcontinental 

roadways being planned and constructed in the United States to satisfy the growing demand from 

influential automobile owners6

. The Yellowstone Trail would eventually extend from Providence, Rhode 

Island to Seattle, Washington with a tagline that read “A good road from Plymouth Rock to Puget 

Sound.” In 1912, Park County used the impetus of the Yellowstone Trail to start construction of a Park to 

Park Highway between Glacier National Park and Yellowstone National Park7

. The counties actions in 

improving the road through Yankee Jim Canyon in 1912 facilitated the designation of this route as the 

only spur line off the entire Yellowstone Trail between Plymouth Rock to Puget Sound8

. Late in the 

summer of 1915, cars arrived at the north entrance of Yellowstone for the first time by way of the Old 

Yellowstone Trail. The continued operation and protection of Yellowstone was secured in 1916 under 

the newly created National Park Service. Rail service continued to Gardiner until 1948.

As the demand for automobile access increased, the number of rail passengers declined and the railroad 

discontinued service. Construction of US Highway 89 replaced the Yellowstone Trail and the historic 

alignment of the Yellowstone Trail was abandoned and returned to private property owners. What is 

now called Old Yellowstone Trail South was the western tip of the original Yellowstone Trail and is one 

of the few preserved lengths of the corridor that still exists. 

Study Area

Old Yellowstone Trail South is a roadway and trail of the same name located in Park County, Montana. 

The study area is a 21.1-mile-long corridor starting at the Roosevelt Arch Monument in Gardiner, 

extending generally northwest to Carbella Bridge (Miner) for 17 miles and then shifting direction 

northeast for the remaining 4.1 miles, meeting US Highway 89 just beyond the landform referred to as 

Point of Rocks. The corridor is bounded on the east by the Yellowstone River, and to the west the 

boundary is framed by either the former railbed, or the Old Yellowstone Trail Road, altering, as the road 

and the railbed frequently cross one another. The study area is shown in Figure 1. 

 5 https://www.visitgardinermt.com/about/history

6 https://en.wikipedia.org/wiki/Yellowstone_Trail

7 Allen, Lerick Dean; Convicts, Boosters and Farmers. 8 Letter from Yellowstone Gateway Museum
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Problem Definition

The issues that this study seeks to address are 1) lack of consistent secondary emergency access 

between Livingston and Gardiner, 2) drainage and road condition issues on the Old Yellowstone Trail 

South Road corridor, and 3) the need and desire to plan for anticipated growth and recreation use 

within the corridor. 

Park County is faced with a dilemma of interrupted secondary emergency access on portions of Highway 

89 between Livingston and Gardiner. Alternate roadways are available for sections of the 51 mile 

corridor, but there are impassible segments between mileposts 7.5 and 16.5. Slightly north of milepost 

20, East River Road connects to Highway 89 and extends parallel to Highway 89 on the east side of the 

Yellowstone River and reconnects to Highway 89 approximately 2 miles south of Livingston. On the west 

side of Highway 89, North Old Yellowstone Trail connects in Emigrant and connects to Highway 89 

approximately 2.5 miles south of Livingston. Both roads offer an alternate emergency access in the 

event of a disaster or accident blocking Highway 89. South of milepost 16.5, in the study area of this 

project, such an event on Highway 89 would make Gardiner unreachable by emergency services. 

Figure 5 Park County, Montana geographical area with study 

area identified in the lower left corner. Source: Google Earth 

Figure 6 Old Yellowstone Trail South Corridor Study Area. 

Green dots indicate mileposts. Source: WFLHD GIS

Start

End
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Park County has repaired rockslides in the corridor previously, but the current situation is far more 

severe and requires additional engineering to remove the current cause of a roadblock and repair the 

road for access. In addition to repairing the road, Park County has an opportunity to establish a 

comprehensive vision for managing growth in the corridor. It is expected that the number of annual 

visitors will continue to increase in the corridor, though there are no projections for growth, and no plan 

should that occur. Park County is taking action to prepare a long-range plan for management of the 

corridor. Similar locales in neighboring states have experienced rapid growth without a plan and have 

allowed that growth to occur unchecked. In most cases, communities are left reacting to the problem 

and never quite catching up. There is potential that one day Gardiner Valley will be a major recreation 

destination in addition to a visit to Yellowstone National Park. The challenge being addressed in this 

effort is the management of the corridor in the future in anticipation of a rise in use. Resources to 

improve the corridor are limited, and should be spent towards a unified vision of what the corridor 

should become.

The existing corridor is not currently strained by the amount of visitation. In fact, visitors to the area 

lucky enough to venture across the Yellowstone River will be amazed at the wilderness available to 

them. Herds of bison, elk, deer and antelope are frequently roaming on or near the roadway. In most 

cases, only a handful of vehicles will pass through the corridor daily, and aside from a few short 

stretches connecting residents to one of two bridge crossings of the river, there are very few man-made 

structures. No, the problem is not excessive traffic or recreationists. The challenge of managing such a 

beautiful wilderness area is that eventually what was once a lesser-known destination rockets in 

popularity, and planners are left managing the problem in a reactionary vs. proactive method. Popular 

recreation areas across the country have experienced rapid growth in use that threatens to overwhelm 

available resources and create a challenge for management staff. The FLAP application requested 

assistance in studying the long-range feasibility of improving the corridor and generating a list of 

recommended planning actions. Park County will not await the fate of comparable locales. 

Focus Areas

Three main focus areas emerged from discussions with Park County, Land Management Agencies, and 

the public. Those themes are the result of hundreds of considerations for what is important in 

developing the corridor, many of which will be discussed in this section. Planning efforts are often

initiated in response to a major problem, such as overcrowding, congestion, or ecological impacts. Park 

County elected to plan for future possible outcomes that have been witnessed in similar recreation 

areas in the western United States and have overwhelmed visitor capacity (i.e. Slickrock, Bryce Canyon, 

Zion National Park). Taking action to develop a plan now has the potential to mitigate impacts from 

growth in recreation and visitation.

Focus Area 1 – Safety: Provide safer travel and a secondary emergency access to and through CGNF and 

YNP for residents, recreationists, visitors and resource users

First and foremost, improvements in the corridor must generate a measurable improvement to

emergency vehicle access, safety of the users, and safety of wildlife. US89 is a single point of entry for 

emergency responders, creating concerns about the ability to appropriately respond to a significant 

event in or around Gardiner. In the event of an incident that requires outside assistance it would likely 
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need to be requested from Mammoth or West Yellowstone and would require significant response time. 

Secondary emergency vehicle access is a key objective to improving transportation options in the 

corridor. Correcting the existing Tom Miner Canyon rock slide and preventing future degradation of the 

roadway is important to ensure a reliable access is available in an emergency event. 

Objectives for Safety include:

• Provide Secondary Emergency Access

• Mitigate Rockslides/landslides

• Meet current roadway and trail design standards

• Reduce conflict of animal/human interactions

• Provide emergency response capability

• Ensure stability of significant slopes/grades

Focus Area 2 – Condition: Ensure the future use of the corridor is not inhibited by degradation of travel 

surfaces. 

Another matter at hand is the overall condition of the roadway, trails and recreation amenities. Park 

County Public Works Department establishes a roadway designation for each of the roadways in the 

County road network which determines the level of maintenance a roadway receives. Due to the 

existing rockslides, and the low volume of use, some sections of the roadway in the study corridor 

receive reduced levels of maintenance. Reinstituting access for emergency vehicles is the first step in a 

commitment to improving roadway conditions. Once travel is open, maintaining a positive surface is 

vital to ensure continued availability of the road. 

Objectives for Condition include:

• Maintain roadway to established standards

• Improve drainage to prevent future roadway damage

• Improve rail bed trail surface

• Prolong deterioration from increased use

Focus Area 3 – Planning for growth: Establish a balance in developing recreational opportunities, while 

also preserving the existing character of the area. Ensure that increased use does not elicit an increase in 

unwelcome behaviors.

Federal Land Management Agencies (FLMA) have a mission to serve the public and facilitate access to 

federal lands for the enjoyment of all. Each agency has a slightly different mission and list of objectives, 

and must balance visitation with preservation. That same mission can often present a challenge. 

Encouraging access can invite unwanted activities, increase maintenance costs, impact wildlife and

residents, and diminish the visitor experience. On the upside, increased use of the area offers 

opportunities for self-policing, development of adventure tourism, and collaboration with friends 

groups. Providing options for recreation and creating a network for access along the corridor will ideally 

guide visitors to where they are wanted and not where they aren’t. While often access is something to 

be regulated, shaping access is an opportunity.
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Objectives for Planning for growth include:

• Define additional recreation opportunities

• Manage increased usage

• Protect natural/historic assets

• Maintain current level of service and access to public lands

Key Considerations

Development in National Parks and National Forests presents challenges not found in private lands. 

Public lands are declared national assets by the Federal Government and preserved in accordance with 

their natural characteristics for future generations. The preservation framework that has been put in 

place requires that each decision is analyzed for adverse impact to protected populations, nature, and 

historic integrity. A determination for any action must assess whether that action will have an adverse 

impact either on its own or when considered in combination with any previous action. NEPA requires 

that evaluation of impact analyze cumulative impacts.

Through discussions with FLMA, property owners, and other stakeholders, a list of topics emerged which 

warrant consideration for any future actions. This document does not set out to define future actions, 

nor is the intent to fulfill NEPA. Keeping in mind the major project focus areas, each of the key areas 

listed here may be impacted.

Wildlife

- Animal habitat is defined differently for each of the species in the study area and any decisions 

on increased recreation must consider year round habitat and breeding grounds.

- Hunting is seasonal and is interrelated with migration and breeding and is subject to state 

regulations. Hunting is also tied to tribal traditions and subsistence.

- Migration corridors cross throughout the corridor and are a concern expressed by the Montana 

Department of Fish, Wildlife and Parks

- Protected Species have been identified in the study area and should be a consideration when 

making future planning decisions.

- Human interaction with wildlife is a reason visitors come to the area in and around Yellowstone 

National Park, but those interactions have an impact on animal movement and behavior. 

Agencies aim to promote interactions that are safe for people and wildlife. In rare instances, 

those interactions have negative consequences.

- The overall safety of people and animals throughout the corridor is a primary consideration for 

any future actions

- Noise created by visitors has the potential to impact animals as well as existing residents. Any 

such impacts should be reviewed and analyzed.

Wetlands Rivers and Watersheds

- Additional pollution caused by an increase in users has a potential negative impact on the 

Yellowstone River.

- Commercial outfitter use of Yellowstone River is on the rise, and much of the river is not 

regulated. It seems that use can continue to rise unchecked.
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- Yellowstone River is not currently designated as a Wild and Scenic River, though there are 

various sources indicating it is eligible, and a designation would have definite implications for 

management of the corridor.

- US Army Corps of Engineers has developed the Upper Yellowstone River Special Area 

Management Plan, which addresses existing river impacts in detail and speaks to the threats 

posed by future modifications, and estimates risks for decomposition in the future.

- Capacity tends to be a concern in all categories. It is likely that the river has a carrying capacity 

that once reached will have a detrimental effect on the quality of the waterway. 

Cultural and Archaeological Sites

- Stage Coach Routes once persisted between Livingston and Gardiner and the evidence is still 

visible in the form of signage and wheel ruts in the rocks. 

- Historical Advertisements once painted on rocks to attract travelers are still visible today. 

- Protection of special sites is a priority of archaeologists with the United States Forest Service, 

and land management agencies in general (including NPS). The challenge of protection comes 

from the fact that identification of the sites may draw unwanted attention, but currently 

vandalism is already occurring. 

- Town of Electric was the site of the coke ovens for the Montana Coke and Coal Company. The 

town was originally known as Horr. It was in existence from 1888 to 1910. The town had mine 

adits, a power plant, coke ovens, a railyard, a flume, a general store, warehouses, a saloon, a 

jail, a post office, worker cottages, and various other buildings.

Historical Significance

- Cultural resources cover a long time span from the precontact period through the historic 

period. The precontact occupation covers the Middle Plains Archaic period (begins 3500 BC) to 

the Late Prehistoric periods (ends AD 1800) with a focus of occupation during the Late Plains 

Archaic period (1000 BC - AD 500). The historic period is also well represented with 

transportation and town sites.

- There are at least 15 recorded precontact campsites or stone tool production locations along 

the west side of the Yellowstone River between Point of Rocks and Gardiner. Some rockshelters 

also were used during the precontact period. The historic period sites include the Old 

Yellowstone Trail, the Northern Pacific Railroad, the Yellowstone River Bridge at Corwin Springs, 

a train crash location, and the townsite of Electric.

Geological 

- Landslides are a possibility and there is evidence that the current landscape was largely shaped 

by landslides of a significant nature. The soil conditions are unstable and are described in the 

geotechnical appendix.

- Rockslides present a clear danger to those riding bicycles, hiking or engaging in other activities.

- Fault lines directly under the area are likely responsible for triggering the landslides that have 

shaped the area. 

- Groundwater wells risk contamination.
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Recreation

- White water rafting9 is a popular activity, but as the use grows, there is a related impact. 

- Bicycling is seeing growth in gravel and mountain bike venues. Catering to that growth may 

draw considerable visitors to the area.

- Fishing is already a popular activity in the Yellowstone River. Boating and fishing are ultimately 

limited by the capacity of the river.

- Walking and hiking are ideally low-impact activities, but if not planned for, may produce 

overcrowding of trails, trailheads, and parking areas.

- Camping is often associated with the other recreational activities listed here. As growth happens 

in related activities, camping may grow in demand. Additionally, smaller camp vehicles and offgrid travelers are changing the duration and range for campers.

- Hunting as a recreational activity is linked to conservation and continued use of adjacent private 

lands. Numerous land trusts, conservation groups and special interest groups that support 

hunting have a mission to see public lands protected.

- Animal watching likely extends into all the activities above. In some cases a standalone activity, 

such as in birdwatching, but in others, a factor for attracting runners, cyclists, hikers, etc.

 9 http://www.montanahikes.com/Yankee-Jim-Canyon.php
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Chapter 2. Existing Conditions 

Geographical Area

The study area resides within the geographical defined areas of Gardiner Basin and Paradise Valley. 

Gardiner Basin contains the town of the same name and extends in a mostly north-south manner 

bounded by the Absaroka Range to the east and the Gallatin Range to the west. Gardiner Basin extends 

from a point just south of Gardiner to Yankee Jim Canyon. Paradise Valley continues north from Yankee 

Jim Canyon and extends to Livingston. As defined in the introduction, the study area encompasses 

roughly 22 square miles, however, the greater geographical area accessible from the study area 

potentially includes hundreds of square miles of national forest, national park, private lands, gravel 

roads, and wilderness.

Population

Gardiner, at MP 0 at the southern end of the corridor, is home to almost 900 residents based on 2016 

population estimates10. Emigrant is not an incorporated town, nor is it within the study area, but as the 

next closest census area is home to about 300 additional residents. While there may be additional 

residents not captured in either of these census areas, it likely does not amount to more than a few 

dozen individuals. Overall, the study corridor encompasses roughly 22 square miles, and less than 1200 

residents. Population density works out to 55 residents per square mile, indicating that this is a lowdensity rural area, and inflections of visitors are certainly recognized for their impact to congestion, 

recreation, and the environment. 

Annual Visitors and Tourism

It was not possible to acquire data for the number of visitors to Paradise Valley, or even Gardiner. 

However, the National Park Service collects data at each of their entry gates, and data for the north gate 

can potentially be used as a proxy for the number of visitors. Knowing the number of visitors to 

Yellowstone will provide the number of people passing through Gardiner. Yellowstone receives about 4 

million visits a year. Approximately 22% of all annual traffic passes through the north gate of 

Yellowstone, and thereby passes through Gardiner and Paradise Valley. The north entrance is the only 

year-round automobile access to Yellowstone. Winter visitors enter other entrances on over snow 

vehicles via roads that are groomed, but not plowed, suggesting that all visitors to the park by car in the 

winter will arrive through Gardiner. In 2017-18, 163,000 visitors were counted from November to April. 

In total, around 880,000 people drive through Gardiner each year, to stop for recreation prior to 

arriving in Yellowstone, the increased use would have a significant impact on the area. It is uncertain if 

there will in fact be a significant shift to visit areas outside of Yellowstone in the future, and the 1% 

number cited above is merely to demonstrate the magnitude of the number of visitors to Yellowstone. 

Such behavior has in fact been observed in other national parks in the country.

 10 https://www.visitgardinermt.com/about/about-gardiner-montana
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Recreation

Recreation in the corridor can be rugged and remote. There are few amenities, no stores, no public 

utilities and very little wayfinding or information about the area. It is likely to encounter wild animals. In 

the event of injury, it may be difficult to contact medical assistance, and depending on the location it 

may be difficult to render assistance once requested. Limited mobile phone service is available in the 

valley making online navigation or contact difficult. Many visitors may not be prepared for the lack of 

connectivity, and those relying on online maps are surprised and dismayed to find their maps 

unavailable.

It is not possible to establish estimates for activities as a whole, and it would be helpful to have an 

understanding of the current demand paired with future projections to determine timing on 

recommended actions resulting from the study. The corridor under consideration provides numerous 

opportunities for relaxation, leisure or physical activity. While there are some developed trails and 

formalized recreation areas, there are vast sections of the National Forest that are uncharted and open 

for exploration. 

Camping

Camping is a common activity and Forest Service personnel have reported an increase in use of 

improved sites as well as signs of growing numbers of new dispersed sites appearing. There are 2 

camping areas in the vicinity of the study area. One small dispersed camping area exists at milepost 

12.8, with the opportunity for another one at milepost 12.4. The Canyon Campground is a Forest Service 

operated campground located to the east of the Yellowstone River near Emigrant. It is not directly 

within the study area, and it offers 17 semi-improved sites with firepits and picnic tables and serves as a 

starting point for people sleeping and recreating in the area. 

Cycling

Mountain biking is currently not a featured activity in the area. There has been some effort by BLM to 

incorporate trail planning in nearby regions of the state, and they have brought on a specific person to 

manage the task of developing a network of mountain bike trails. Bozeman has a couple of notable 

custom bike builders, and the number of bike shops has actually risen in the past 10 years, while the 

number of shops across the country has declined by 18%11. There is potential for mountain bike 

development in the region. Gravel biking is a sport growing in popularity, and is the only form of cycling 

actually experiencing growth while the rest of the market is in a decline12. Gravel riding is defined by 

bicycles normally ridden on paved roads, slightly modified with wider, better traction tires, disc brakes, 

and clearance for fenders. It is an appealing activity for adventurers that are no longer interested in the 

more extreme sport of mountain biking or have grown tired of the risks associated with road cycling. An 

abundance of gravel roads in Gardiner Basin, particularly spreading out from Cinnabar have potential to 

draw increased numbers of locals and travelers. 

 11 https://streets.mn/2015/07/29/why-are-bicycle-sales-declining-for-the-14th-year/ 12 https://www.outsideonline.com/2332511/gravel-bike-road-cycling-gear
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Hiking

While surveying the corridor, there were few indications of formal hiking trails. In total there are 5 

trailheads in the area. Three of them are located to the east of the river, but Beattie Gulch and Sphinx 

Creek are within the study corridor. Beattie Gulch exists at milepost 4.4 and is identified by the parking 

area and Forest Service signage. The trailhead provides access to 5.5 miles of Forest Service hiking trails, 

and eventually connects to the Yellowstone National Park trail system. The Sphinx Creek trailhead is in 

the corridor at milepost 14 closer to Yankee Jim Canyon and provides access to technical trails. There 

are also less active recreational offerings. Two day-use sites with picnic tables and interpretive signage 

are available in the area. The LaDuke picnic area sits to the east of the Yellowstone River, and Sphinx 

Creek offers picnic tables, a restroom, and a paved Americans with Disability Act (ADA) accessible trail.

Information on hiking in the area is difficult to find on the internet. Forest Service personnel in Gardiner 

can provide detailed information about hiking, but the information is not readily available on the USFS 

website. Maps of the Gallatin Range online show a series of hiking trails originating from the south or 

the west, but do not include hikes starting from the east. 

Hunting

Park County offers abundant hunting options. It is possible to hunt for Antelope, Bighorn Sheep, Black 

Bear, Deer, Elk, Moose, Mountain Goats, Wolf and a variety of birds. More notably, there is the 

possibility to hunt bison. The Gardiner Basin provides a unique hunting experience not found elsewhere

in the state and in just a few locations around the country. Annually, bison migrate from higher 

elevations in Yellowstone National Park to lower elevations in the surrounding basins when winter sets 

in. Seven tribes from across MT, WY, ID, WA, and OR, along with Montana Fish, Wildlife, & Parks 

(MFW&P) participate in traditional hunting as bison leave YNP and enter National Forest System (NFS) 

and private lands. The majority of this hunting occurs along the Old Yellowstone Trail corridor at Beattie 

Gulch, Cinnibar, and Cutler Meadows on public lands.

Management of the bison hunt poses various challenges. There are potential safety issues brought 

about by the number of hunters congregated in a small hunting area. The animals themselves are 

unpredictable and their behavior is modified by the existence of the hunters. Bison hunts are 

coordinated each morning based on the number of hunters and animals. USFS and MFW&P monitor the 

hunts to ensure safety. Cars are parked along the roadway near the hunting site leading to congestion 

and possibly erosion. Traffic flow is impeded by the number of vehicles. Once hunting is over, the animal 

remains are sometimes left on the hunting grounds. 

Waterways

Yellowstone River is the primary water recreation amenity in the corridor. There are 8 named tributaries 

to Yellowstone but none of them provide recreational opportunities. The Yellowstone River is not 

dammed at any point along its 670 mile length13 making it the last great free flowing river in the lower 

 13 https://www.visitmt.com/listings/general/river/yellowstone-river.html
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48 United States1415. There is desire by some members of the community to seek designation of 

Yellowstone River as a Wild and Scenic River. Such a designation may place additional requirements on 

future development. Depending on perspective, this may be interpreted as a protection or limitation. 

The state of Montana does not impose a daily capacity limit for use of the river. In some cases, the daily 

use has the potential to overwhelm the capacity of the river, but an official threshold has never been 

established. Primary river use starts in April and extends until October with peak usage in July and 

August. 

Fishing

Perhaps the most popular, or most notable activity is fly-fishing. World class fly-fishing is a term oft used 

by tourism websites and sportsmen who write about the activity online. As the longest uninterrupted 

river in the United States, providing unhindered habitat for trout, fly-fishing is a regular activity in the 

river. The Salmon Fly hatch occurs in early summer and is a big draw for fly fisherman.

Montana Fish, Wildlife and Parks has 5 fishing access sites along the Yellowstone River. Bureau of Land 

Management also has a site at Carbella Bridge. All but one are located on the east side of the river out of 

the study corridor, but access to the river is pertinent to the discussion. Fishermen accessing the 

Yellowstone River from the east are still impacting the same recreation corridor and count towards the 

overall users.

Boating

In addition to fly-fishing, rafting or floating down the river are popular activities, and the segment north 

of Gardiner offers some of the best whitewater rafting in the state. Access permits are at maximum 

capacity for the 2 landings controlled by USFS. Rafters are also known to enter the river in spots not 

controlled by the Forest Service. Some outfitters access from private property and some users access 

illegally. In addition to rafts, kayaks and canoes, fishing boats also use the river. There are 3 Forest 

Service boat launches within the corridor and one BLM boat launch. McConnell and Cinnabar launch 

each have capacity for 10 single vehicles, or 5 trucks and trailers. Yankee Jim launch is good for 15 single 

vehicles or 10 trucks and trailers. Each location has overflow parking.

Wildlife

Animals migrate annually between the higher elevations in Yellowstone Park and the lower elevations of 

the Gardiner Basin. The area is home to many large wildlife species. Populations of bison, bear and 

wolves are increasing annually, and there is a permanent population of grizzlies near Cinnabar. Bison 

move in herds, are generally not greatly impacted by presence of humans, and are not allowed to travel 

throughout the entire extent of the corridor. Their territory is limited by physical intervention that keeps 

them from passing through Yankee Jim Canyon. After the winter, the cows and their calves are herded 

back into the park by the Montana Department of Livestock. The bison bull is allowed to remain. There 

is some contention over the number of animals that should remain in the herd each year. Yellowstone 

National Park has been appointed to keep the number from growing, but environmental groups and 

 14 https://www.visitmt.com/listings/general/river/yellowstone-river.html 15 https://www.americanrivers.org/river/yellowstone-river/
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hunters are encouraging population growth. As the numbers rise, that means more animals ending up in 

Gardiner Basin, and increased opportunity for interaction with them. It also means more opportunity for 

conflict. As buffalo populations increase, predators are likely to be drawn in. Wolves are commonly seen 

within the corridor, and may be attracted to the area with a higher buffalo population. 

Bighorn sheep, pronghorn antelope, elk, and black bears are also frequently seen in the valley. The 

existence of wildlife is one of the most commonly cited aspects why residents enjoy living in the area. It 

is also listed as a concern by residents and wildlife agencies for encouraging activity along the corridor. 

Roadway

Many large vehicles use the roadway to 

support ranching and farming operations. 

The National Park Service uses the 

roadway for access to their bison 

operations and hauls semi-trailers full of 

horses and bison. While this also 

contributes to road degradation, the NPS is 

a victim of the poor roadway condition. 

The existing roadway is a bumpy gravel 

road16. Drainage issues at many points 

along the roadway cause roadway 

flooding, washboarding, potholes and 

rutting. In addition, runoff has washed 

away the surface aggregate in places, 

allowing the remaining roadbed to become 

muddy and rutted. Utility installation has 

led to erosion and is suspected as a 

contributing factor in the rockslide within 

the Yankee Jim Canyon. 

Park County performs regular 

maintenance, and deploys a grader at least 

annually to correct surface irregularities 

and restore the crown of the road. Annual 

maintenance records indicate the highest 

maintenance cost comes from a 

commitment to grading. The second 

highest maintenance cost is plowing snow. 

Unfortunately, it is likely that clearing 

snow in the winter contributes to the need 

to grade in the spring and summer as well as replace lost gravel.

 16 https://www.eenews.net/stories/1060100069

Figure 7 Mile 5.4 looking north.
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Railbed

The rail line has long been removed, and the land beneath it has been returned to property owners. 

Easements on the property were originally granted for railroad use, and were void once the rail was 

removed. On the ground, navigating the trail is quite simple for the first half of the corridor but becomes 

progressively more difficult as the condition deteriorates and the ownership becomes a higher 

percentage of private property. A couple of large property owners have visible segments of the railbed 

on their property, and others have made the original sections obsolete through farming or construction 

of buildings. An informal trail has developed on many segments of the original rail alignment. There are 

no official counts but estimates for use are extremely low. Footprints and bike tracks left in the mud or 

dust provide evidence of prior usage, but without the ability to quantify the frequency. The condition of 

the surface varies, but from aerial imagery, much of the original alignment is still visible. 

Segment Summary

Along the 22-mile corridor, condition of the roadway, geology, and traffic intensity varies considerably. 

Traffic data was not collected prior to the rockslide, therefore we may not say definitively that traffic has 

subsided. Based on anecdotal information from residents and staff of partner agencies, it is clear that 

the roadway served as a throughway. Throughout the corridor, the current roadway and the historic rail 

alignment carry the same name of Old Yellowstone Trail South, making it challenging to distinguish 

between the two in the body of this report and online maps. This effort evaluates the corridor for 

emergency access as well as recreation, which make it necessary to review the roadway and the 

standalone trail when they exist. It was decided to divide the corridor into segments to evaluate the 

type and volume of use, and summarize potential improvements and limitations within each segment.

It is the intent of this study to evaluate options and feasibility of a multi-use trail along the extent of the 

corridor. The alignment of such a trail may at times utilize the old rail bed, and at other times may 

merge and share right-of-way with the road. In areas where the trail is likely to share the roadway, 

improvements must take into consideration the potential for shared-use, and plan accordingly. Ideally, 

the trail will follow the rail alignment whenever possible, which will provide safe and comfortable 

separation from vehicle traffic; gentle grades the length of the corridor; and a connection to the historic 

alignment that shuttled the first visitors to Yellowstone. An existing conditions analysis is meant to 

summarize the condition of each alignment and report on where it may be feasible to stay true to this 

ideal. Where it is not possible to physically separate the two forms of transport, every effort should be 

incorporated to provide a safe and identifiable visual or aesthetic separation of vehicle and pedestrian 

traffic. 
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Figure 8 Segment summary for extent of study corridor. Pins mark the end of each segment, with the first segment beginning in Gardiner.

Old Yellowstone Trail South Segment Map
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Following is a summary of the segments in the corridor. Based on a segment/node analysis of the 

corridor, the 22 miles was divided into 8 unequal segments and are identified by milepost. Nodes were 

established at property lines, intersections, and changes in maintenance category. Descriptions of the 

corridor start with milepost 0 in Gardiner at the Roosevelt Arch and generally trend north to the 

intersection with US-89 at milepost 22. Contained within this section is a broad overview of the surface 

condition, geotechnical assessment, environmental considerations, and safety concerns. Geotechnical 

information is summarized for each segment based on information contained from a geotechnical 

assessment. Slopes along the corridor were input into a Federal Highways Administration (FHWA) 

database named the Unstable Slopes Management Plan (USMP). The USMP provides a risk score based 

on inputs from the geotechnical expert performing the survey. A detailed report on the rockfall and 

landslide hazards, how the score is determined, and what the score means is included in this report as 

Appendix A. A FHWA environmental specialist performed an introductory environmental analysis which 

is included as Appendix B.

Segment 1: Gardiner to NPS Boundary, MP 0 - 4.4

The first 4.4 miles of the corridor reside on National Park Service land, but are outside of the fee area of 

Yellowstone National Park. Many visitors to this area are likely unaware they are in the park boundary 

since they have not entered the gate. It is a potential advantage to have the segment of trail adjacent to 

the population center located on federal land. Future improvements will not require acquisition of 

easements and the mission of the Park Service is to protect park resources and provide opportunities for 

recreation and visitor use. 

Road: OYTS road is of substantial width throughout this entire stretch, and is in fair to good 

condition. Park County classifies the section of road as a Class 2 – high priority road and performs 

regular maintenance, typically deploying a grader 3 times annually to correct surface irregularities 

Figure 9 Segment 1 begins at the Roosevelt Arch and continues to the creek crossing at milepost 4.4, which coincides with the 

end of NPS property.
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and restore the crown of the road. The most recent concurrent average daily traffic count data (est. 

2012) for this section of roadway at Gardiner was 194 and at the Yellowstone National Park 

Boundary was 60. Emergency vehicle access is sufficient. Some wash boarding occurs in the steeper 

areas, which makes it more difficult to ride a bicycle. It is anticipated that improvements are needed 

for drainage but not to accommodate cyclists. Some changes in elevation, including steep grades, 

result in rather strenuous climbs for less experienced cyclists and is not the preferred option for the 

first stretch of riding that will likely also be the most used. Drainage for the adjacent roadway is an 

overall concern in this area, as significant rutting and erosion occurs due to winter rains and snow 

melt. Maintenance crews have expressed a desire to have drainage improved in known problem 

areas. The road starts near Roosevelt Arch, skirts around the community park and then passes the 

school. The road is narrow in this section, with a retaining wall to one side and the community park 

on the other. Beyond the school and the Yellowstone Heritage and Research Center there is a small 

parking spot with a narrow footpath leading to the railbed. This is the only indication that a trail 

exists. 

Trail: The trail consists of a gravel base with a width between 6-10 feet. The entirety of this first 

segment of railbed is largely intact and well defined. The stretch along the river is beautiful and flat 

and provides a great opportunity to serve a greater population. In places, the gravel aggregate has 

been washed away, and animal tracks and tire ruts formed during the rainy season make for a 

bumpy surface when the ground dries up. Sections of the trail have suffered from washout and 

erosion from uncontrolled drainage. Sinkholes have appeared in one location from erosion beneath 

Figure 4 Mile 0.2. The trail has no clearly distinguished 

starting point. Much of the trail is devoid of any signage. A 

young elk is pictured in the left of the picture. It is common to 

see wildlife at many points along the trail.

Figure 5 Mile 0.5. The trail is well established, but foliage is 

starting to grow over the path.
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the surface, but current impact is minimal. It is likely that an existing culvert has experienced 

damage and needs replacement.

Judging by tracks in the dirt and the lack of vegetation, it appears this segment currently experiences 

significant use by recreationists. It is not well understood how the trail is primarily accessed. The 

trail does not make a clear connection back to the town. An informal trail connects through the 

community park and the shoulder is wider near the running track and sports field, but no official 

pedestrian connection exists. It is also possible to connect to the trail from 4th Street behind the 

school, but the school has indicated a preference not to have the path connect behind the school in 

the future.

Geotech: Much of the trail in this area is cut into ancient earthflows, landslides and glacial deposits. 

Unstable slopes assessed in this section are either local cut-slopes or eroding fill-slopes along the 

corridor and not considered unstable due to being a part of the large earth flows. Although there 

are mostly no catchment ditches along most of this section, the trail width is wide enough to 

provide some catchment for rockfall along the old railroad grade. Potential avenues for mitigating 

rockfall in this section could be selective rock scaling, lessening cut slope angles, improving the 

catchment ditch, or various trail-side barrier types. Erosion closer to the riverbank is also leading to 

destabilization of the slope below the old railroad grade.

Environment: It is not uncommon to find herds of bison, elk, antelope and sheep in this area. During 

winter months, many animals come out of the mountains of northern Yellowstone and into the 

lower areas of Gardiner Basin. This provides a great opportunity for animal viewing, but also 

increases the possibility of negative interactions either for the animals or for corridor users. 

Figure 10 Mile 0.75. Falling rocks have blocked sections of 

the trail.

Figure 7 Mile 0.75. Erosion on the fill side 

above the Yellowstone River.
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Safety: There are certainly safety concerns for interaction with automobiles, hunters and single 

person mishaps, but the greatest threat is likely that of wildlife interactions. Not only is there a

possible threat to humans, but there is the risk of safety to the wildlife as well. Increased numbers of 

people using the corridor may cause changes in animal behavior, and travelers unfamiliar with wild 

animals may not possess an appreciation for the unpredictability and protectionist tendencies of 

animal mothers. 

Figure 11 Mile 1.4 facing north. Figure 9 Mile 1.4 facing cut slope to the east (left) of the trail.
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Segment 2: NPS Boundary to Corwin Springs Bridge, MP 4.4 - 7.7

National Park Service property abuts a small section of Forest Service land which covers only a short 

distance before the former rail corridor continues on private property. Along this segment and the next, 

significant sections of private property reside under the old rail alignment. There has been no discussion 

with property owners about the possibility of utilizing this historic alignment. In the next phase of 

development, the NEPA process will evaluate the possibility of easements or land swaps. The likelihood 

certainly exists that bicycles, hikers and other users of the corridor will share right of way with the road 

if property owners are not supportive of using the alignment. Final alignment will depend on factors of 

safety, environment and ownership.

The original extent of the railbed is visible throughout, but passes through private property, and in some 

cases crosses active agricultural fields. Close proximity to the road allows for relatively easy access to the 

railbed, and it appears that hikers and bikers are using it currently. An elevated length of trail extending 

from approximately MP 6.8 to MP 8.3 shows signs of use, but is becoming overgrown with brush. 

Signage in the area is not clear on whether this is usable by the general public or if it is private land. 

Figure 10 Segment 2 extends from NPS property line to Corwin Springs Bridge.
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Road: Roadway condition is good as well. 

Aggregate base layers appear to be solid, 

though the surface suffers from some wash 

board ripples. Dry summer and fall conditions 

make this stretch extremely dusty with even a 

single vehicle pass. Fine dust particles coupled 

with dry conditions can cause difficulty 

breathing for anyone exercising or with 

respiratory issues. Park County classifies the 

section of road as a Class 2 – high priority road 

and performs regular maintenance, typically 

deploying a grader 3 times annually to correct 

surface irregularities and restore the crown of 

the road.

Trail: Overall condition on this section of 

railbed is quite good. The base layer of 

aggregate is solid and shows little to no sign of 

major degradation. Vegetation has started to 

obscure the original surface though, and 

eventually will begin to greatly degrade the 

integrity. Lack of major gradients limits the 

amount of erosion caused from water. The 

biggest concern for cyclists within this stretch, and along the entire corridor for that matter, is the 

proliferation of vegetation with thorns. 

Figure 132 Mile 7. Overgrowth obscures the trail.

Figure 121 Mile 5 standing on OYTS Road looking north. 
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Geotech: No significant areas of concern

Environment: Wildlife is present in significant numbers within this section of the corridor. The 

natural landforms create a natural funnel thereby reducing the distance between the base of the 

mountains and the river. This natural reduction likely results in a closer proximity between wildlife 

and people. Future planning should devote special attention to wildlife corridors in this area. 

Historic artifacts have long been discovered on or near the railbed. Coke ovens can be seen from the 

Old Yellowstone Trail - where the community of Electric once stood. The foundations, and in some 

cases the structure of those ovens still stand. Access to these sites is not readily available, and some 

consideration should be given to the protection, preservation and prominence of these buildings in 

the interpretive story of Old Yellowstone Trail. 

Safety: There are certainly safety concerns for interaction with automobiles, hunters and single 

person mishaps, but the greatest threat is likely that of wildlife interactions. Not only is it a threat to 

humans, but there is the risk of safety to wildlife. Increased numbers of people using the corridor 

may cause changes in animal behavior. 

Figure 153 Mile 7.6 standing on the rail bed looking north. Figure 154 Mile 7.6 standing on the rail bed looking south. 
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Segment 3: Corwin Springs Bridge to Cinnabar Basin Road, MP 7.7 - 8.3

Though this segment is short in length, it has been identified as a standalone segment for its role in 

providing access to Royal Teton Ranch and the associated traffic volume. The ranch periodically applies 

dust control between the bridge and the ranch entrance. It is likely the most heavily utilized segment in 

the corridor, but this assumption will need to be verified with future traffic counts. Royal Teton Ranch 

generates the majority of the traffic demand, with Cinnabar Basin Road residents producing the 

remaining demand. There is limited public access off Cinnabar Basin Road. Most of the land ownership is 

private. There are likely some hunters, hikers and OHV users looking for access or entering areas illegally 

because there is evidence of these activities in the form of tire tracks and bullet casings. 

At approximately MP 8.3 the original railroad alignment serves as the access road for Royal Teton Ranch 

(Figure 16). Cinnabar Basin Road intersects Old Yellowstone Trail South Road where most of the traffic is 

diverted. 

Figure 165 Segment 3 extends from Corwin Springs bridge to Cinnabar Basin Road.
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Road – The condition of road in this section is greatly deteriorated. There is evidence of excessive 

rutting, and pictures provided by Royal Teton Ranch show that the road gets very muddy when it 

rains. Trail activity is harder to distinguish in this area, and it is unclear whether the trail is on private 

property or is accessible for potential users.

Trail - Similar to the section of previous railbed, the condition is quite good, but there is little 

remaining of the aggregate base course. As the distance from town increases there is less evidence 

of trail use. Vegetation overgrowth has become more significant and the surface condition is much 

rougher from rocks and dead plants. Permission to access the path is unclear. Signage is badly 

damaged. 

Cinnabar Basin Road

Old Yellowstone Trail South

Royal Teton Ranch Road Railroad Alignment

Figure 176 Mile 8.3. Intersection of Old Yellowstone Trail South, Cinnabar Basin Road and Royal Teton Ranch Road. Photo credit: 

Google Earth

Figure 187 (L) Mile 8.3 looking south on OYTS Road. Drainage is inadequate to handle heavy rains. Photo credit: Alan 

Shaw; Figure 198 (R) Mile 8.3 Looking south on old railbed.
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Geotech - No significant areas of concern.

Environmental – No significant areas of concern.

Safety - The intersection of the railbed and Cinnabar Basin Road where it meets Old Yellowstone 

Trail South Road poses nominal safety concerns. Average daily traffic is very low and does not pose 

significant risk for vehicle collisions. A greater risk arises from the deteriorated road condition 

causing rutting and uneven surfaces. In the wet season, the muddy conditions can make roads 

difficult for bicycles, especially at intersections, where tire tracks worn into the mud cross one 

another. In the dry season, the ruts can turn into lips and edges that can catch a bike tire, or roll an 

ankle. 

Segment 4: Cinnabar Basin Road to Cutler Lake, MP 8.3 - 10.6

Shortly beyond Cinnabar Basin Road, the roadway and the railbed encounter a chokepoint as they come 

together to cross Mulherin Creek Bridge. There was once a railroad bridge in this location that is no 

longer here. The existing roadway bridge should be evaluated, improved or replaced to facilitate access 

for multi-modal users. North of the bridge, as the segment continues, the classification of the road 

changes from Class 2 to Class 4 in the Park County roadway classification system, signifying seasonal use 

as opposed to high priority use17. The reduced level of maintenance is reflective of lack of users in the 

area. What was once the railroad is now essentially non-accessible. A private fence separates the former 

rail alignment with the roadway, and no trespassing signs communicate the desire to keep recreational 

users off what was perhaps once a trail.

As mentioned, traffic beyond this point is limited. There are no additional roadway outlets beyond this 

point due to the rockslide in Yankee Jim Canyon. Any vehicle traveling north will be turned back by the 

barriers at MP 13.6. 

 17 http://parkcounty.maps.arcgis.com/apps/webappviewer/index.html?id=876e7852b92f48ceb2cc0671a69e92b9

Figure 209 Segment 4 extends from Cinnabar Basin Road to Cutler Lake.
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Road - Road condition deteriorates somewhat as the road extends north, but has not declined to a 

point to be considered in poor condition. In light of the reduced maintenance standards, this 

segment remains in remarkably good condition.

Trail - Trail access is not permitted, and therefore unable to be evaluated. Aerial photographs reveal 

a largely intact alignment of the former railbed, and from the road, it appears that the property 

owners have developed the alignment into a gravel farm road for accessing their fields.

Geotech - No areas of significant concern

Environment – No areas of significant concern

Safety - Immediately north of Mulherin Creek, the road bends uphill into an S-curve. There is loose 

gravel, poor visibility, and a short, steep slope. High speed or inexperience on the part of a cyclist 

could result in tires sliding out from under the bike. The bridge crossing itself is a narrow vehicle 

bridge with minimal fall protection. Probability of a mishap is very low, but the consequences rate 

moderate. Due to the low volume usage, potential conflicts with vehicles is expected to be lower 

proportional to the distance from Cinnabar Basin Road.

Figure 20 Mile 9.7. Trail access is plausible, but requires coordination with current land owner.
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Segment 5: Cutler Lake to Yankee Jim Canyon, MP 10.6 - 13.6

MP 10.6 indicates a significant departure of the railbed from the road. The railbed continues at grade 

along the river, whereas the road rises up to the crest of Cutler Hill. It likely took a blasting effort in the 

1890s to create the original rail line and evidence suggests that rock stabilization was not incorporated 

into the construction. The integrity of the area has suffered as a result and today this site suffers from 

rockfall activity and alluvial sediment deposits. 

At the top of the climb is Cutler Lake with access for hiking, camping and mountain biking nearby. Just 

north of the hill is a rental home, which is the only residential property in this segment. Towards the end 

of the segment, the road and the railroad alignment merge to be one in the same, and remain together 

for much of the remainder of the corridor. 

Avid cyclists will likely welcome the challenge of navigating this section of roadway, but beginner cyclists 

may find it difficult in either direction. While traveling north, the road rises an average of 7.7 percent for 

Figure 22 Mile 10.2. Loose Rock. Figure 213 Mile 10.6. Errosion and resulting 

sediment deposits.

Figure 21 Segment 5 extends from Culter Lake to Yankee Jim Canyon.
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just over a mile, with a maximum slope over 21 percent. Traveling south, those numbers are 8.3 and 

29.7 percent. Add to this the difficulty of breathing while exercising at an elevation above 5,000 feet, 

and this may be a discouraging ride for cyclists of all but the most high level. Depending on the direction 

of travel, both sides of the hill have drawbacks and safety concerns, and regardless of the direction, a 

climb and descent are necessary. The viability of the corridor as a recreational mixed-use corridor is 

highly dependent on this segment. This is the most challenging segment both from the standpoint of 

physical ability and dependence on generosity of private property owners.

Road - Once again, the maintenance 

classification of the roadway drops, this time 

from class 3 to class 4, and because there are 

no additional residences beyond this point, 

roadway users tend to be Forest Service 

personnel, outdoorsmen utilizing the Sphinx 

Creek TH, or the occasional visitor who may 

have just stumbled upon the corridor. The road 

varies greatly in condition, especially with the 

season. Large rocks, rutting, and lose surface 

describe the southern approach to the summit. 

The northern extent is well compacted gravel 

and shows very little sign of deterioration. 

Trail – The section of trail that was accessible 

looks to be in good condition. Vegetation has 

overgrown the path, and overgrowth loaded 

with thorns threatens to flatten bicycle tires at 

any moment. 

Geotech- Both the river and the railbed are cut 

into an ancient, inactive landslide that includes 

the Cutler Lake feature. It is not anticipated 

that the larger feature is a threat, but slopes cut into the feature currently exceed what is expected 

stability for similar soils. Composition of the soil consists of large chunks of rock suspended in a mix 

of sand and gravel. Railroad construction likely oversteepened the slopes. Water and debris moving 

downslope create erosion channels on the slopes and deposit debris across the trail up to 2 feet 

deep in some locations. Water flowing over the trail erodes the fill side (river side) of the railroad 

grade and causes some slumping of fill into the river. Erosion at the toe of the slope is not a 

significant concern in this segment.

Environment - The FS has active rangeland restoration ongoing in Cutler Meadows. The railbed 

alignment cuts through the middle of the restoration area and then merges with the road. The 

alignment is not visible from ground level and does not appear to be evidence of an impact from 

Figure 234 Mile 10.7. Path becomes overgrown.
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human use. Aerial photos provide some indication of the historic alignment. Use of the alignment 

may hinder restoration efforts.

Safety - Loose gravel, large rocks and inconsistencies in surface make the traction on the southern 

side of the hill somewhat poor. Some of the turns are also sharp, with sightline limitations, and 

significant exposure. The surface on the north side of the hill is more solidly compacted, but the 

grade is much steeper, raising concerns for unchecked high-speed descents. 

Segment 6: Yankee Jim Canyon, MP 13.6 - 15.6

Known trouble areas within the Yankee Jim Canyon segment of the corridor present the greatest 

challenge for generating a secondary emergency access. A landslide washed out a section of road at 

Figure 267 Landslide at milepost 14.2 

looking north.

Figure 245 Segment 6 extends from Cutler Meadow to Yankee Jim Canyon

Figure 256 Rockslide at milepost 14.1 looking northwest.
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milepost 14.2 in 2011 and a rockslide covered a nearby section of road at milepost 14.1 in 2014. Park 

County has been unable to restore safe access and has endured the road closure since 2014, a 

significant obstacle in the desire to establish an alternative emergency access route. There is evidence of 

off-road vehicles bypassing the road barriers and driving around the landslide, but the rockslide is 

currently impassible. Alternate routes are possible for bicycle and pedestrian access, but both are also 

able to navigate around the slides as they exist.

For the length of the segment, the established roadway is completely within the original railbed. Yankee 

Jim is the most narrow section of the corridor, and with widths ranging from 8 to 12 feet, it is a 

challenging section to develop if the stated objective is to provide separation between the road and the 

trail. There is little opportunity to separate the two, unless the trail is established off to the side of the 

roadway or follows another alignment. A small road branches off the main road and climbs the slopes 

above the old railroad grade. This roadway could provide opportunity for an optional route, though in its 

current condition it likely can only serve as a mountain bike trail (figure 25). Before the train line was 

constructed, it was the only passage through the area. It is tough to imagine that wooden wheeled 

wagons pulled by a team of horses once passed over this terrain, as it presents a challenge for a knobbytired mountain bike equipped with suspension.

Land ownership reverts to USFS for the length of this segment. There have been efforts to add 

interpretive signage, and in 2002 the Forest Service constructed a parking area with toilets and an ADA 

accessible trail. Prior to the unexpected closure of the road, the Forest Service reported regular use of 

the area. Roadway condition has deteriorated slightly, and absence of thru-access has likely inhibited 

visitation. A future development opportunity is certainly possible to highlight historical sites of 

significance, geological features, and recreational opportunities in this dynamic segment of the corridor.

Road - Maintenance in this area ranks as a low priority, and large sections of the road suffer from 

significant rutting. Road classification remains class 4 the length of the segment at MP 15.6. Heavy 

rain leads to deep mud sections where travelers have a difficult time getting through. Due to the 

rock fall and landslide the road closure extends from MP 13.9 to MP 15.1, and the condition is 

classified as impassible. Road width for the railbed is very narrow and prior to the slide events was 

only able to accommodate one-way traffic. Upon repair, two-way travel is unlikely. 

Figure 278 The orange line highlights the alternate path able to be used by bicycles and pedestrians. Off-road vehicles may be 

able to navigate this route as well, but it has not been designated as an OHV trail.
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Trail - The historic toll road today is between 3-5 feet wide, with very uneven terrain and large rocks 

that have either been exposed through erosion or deposited by rockfall. The northern section of 

former toll road bypasses the rockslide area, but the condition of the road is only suitable for offroad vehicles. Emergency vehicles and bicycles would find it difficult to navigate without significant 

improvements.

Geotech - Yankee Jim Canyon is confined on either side by very old granitic sourced garnet gneiss to 

migmatite. The rock is considerably stronger and resistant than previous areas discussed, which 

constricts the Yellowstone River into a canyon with steep walls. A toll road was constructed through 

this pinch point.

A covering of glacially deposited material and colluvial soils is over the resistant gneiss bedrock

in this section as well. These geological materials combined provide conditions for the highest

ranked sites in the investigation, US103 with a total USMP score of 488 and US16, with a total

USMP score of 433.

The slopes measured along the unstable slopes ranged from 25 feet to 92 feet with inclinations

ranging from 42 degrees to 70 degrees. Some of the slopes were overhanging. There is minimal 

catchment ditch availability along both the road and trail.

Landslide slopes in this section are attributed to erosional cutting at the toe of the slope by the 

Yellowstone River. Both of these sites incorporate a longer area than is directly affecting the road 

because they appear to be at risk of future slope toe erosion and upslope failure of the road. Soils in 

these areas appear to be fluvial (river) or glacial deposits with boulders and cobbles being supported 

by an unconsolidated silty sand and gravel matrix. Vegetation was sparse on most of the slopes and 

in the failing areas exposed soils were observed. Fill slopes are generally inclined approximately 38 

to 43 degrees and the axial length of the failures were measured 30 feet to 85 feet, top to bottom. 

Site US106 is a failure affecting half of the roadway.

Environment - Historically, there have been various wagon roads and trails developed, and some 

artifacts of the first wagon road into the park are still remaining. A rock painted with an 

advertisement for souvenirs served as a makeshift billboard in the early 1900’s. The toll roads 

themselves are considered a cultural resource. They are constructed with hand laid dry stone 

masonry retaining walls.

Safety - Repair of the road is essential if it is to be reopened, especially if recreational use is to be 

encouraged. Existing conditions demonstrate the risk and the possibilities. Where the road has slid 

away is a drop of 60-70 feet to the river. If something similar were to occur in the future, the 

consequences could be significant. Additionally, the road is quite narrow, which presents potential 

conflict for multiple users at one time. 
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Segment 7: Yankee Jim Canyon to Carbella Bridge, MP 15.6 - 17.5

As the road reaches milepost 15.6, the road and the railbed divert from one another. The probability of 

utilizing the former railbed is assumed to be very low. The old rail alignment continues parallel to the 

river and serves as a driveway to access a private farm, and is no longer accessible as a public trail. 

Further north, it skirts a field, ends at a stream where a bridge once stood, continues on the other side, 

traverses another private property and reconnects into Tom Miner Creek Road at milepost 17.5. 

Road - Roadway condition is good to excellent in 

this area. Due to the relatively high number of 

residences, and the proximity to active farming 

and recreation, Park County classifies the 

section of road as a Class 2 – high priority road.

Regular grading and maintenance have kept the 

road in good repair. There are no significant 

signs of damage to the roadway. The 

intersection with Tom Miner Creek Road at 

milepost 17.5 suffers some rutting and 

dispersion of surface material, but it is 

anticipated this will be corrected with normal 

maintenance. During rain events, however, this 

area becomes muddy and may benefit with 

rebuilding the roadway subgrade and improving existing drainage.

Trail - Condition is not assessed within this segment, because there is no standalone trail. The 

desired alignment is clearly marked with private property signage. 

Figure 30 Mile 14.7 Looking North.

Figure 289 Segment 7 extends from Yankee Jim Canyon to Carbella Bridge
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Geotech - No significant areas of concern

Environment - No significant areas of concern

Safety - No significant areas of concern

Segment 8: Carbella Bridge to US 89, MP 17.5 - 21.1

The former railbed tracks immediately adjacent to 

the roadway for almost the entire length of the 

segment, apart from Point of Rocks where the 

road grade rises up and over this formation, the 

rail alignment stays tight to the river. Private 

property constitutes the entire length of the 

segment save for a parcel owned by Montana 

Fish, Wildlife and Parks at MP 20.9, the site of the 

boat launch. 

Evaluation from the proximity allowed suggests 

that the alignment is being used by the ranch 

owner for access to their fields and pastures. Due 

to the retained use of the alignment as a road, 

conversion to a trail would be possible with 

modest improvements, if the property owners are 

willing to consider an easement.

Old Yellowstone Trail South Road terminates at 

MP 21.1 where it meets US89. Near this point, 

there is evidence of the rail bed continuing on an 

alignment closely parallel to US 89. Park County 

and MDOT have long term plans to connect 

Livingston and Gardiner with a multi-use path and 

are likely to use the railroad alignment whenever 

possible. 

Road - The roadway is smooth and appears to be 

well graded, but the gravel surface is thin, and 

patches of soil have started to show through. Tire 

tracks are visible on the roadway. The short section at Point of Rocks had some rippling, an early 

sign of future washboard surface. As the grade increases, the surface deteriorates and becomes 

muddy and rippled. Washboard surface develops as the surface dries up and tires spin on the 

steepness of the slope.

Figure 291 Segment 7 extends from Carbella Bridge to US 89.
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Trail - The majority of the rail alignment was not accessible for evaluation during the site survey, as 

it is contained completely within private property, and is within a private fenceline. As most of the 

trail was not accessible, it was difficult to assess the condition. It appeared to be well utilized by the 

property owner as an access road. A limited section that was accessible on foot has been overgrown 

by grass and shows little to no sign of use. 

Much like the Cutler Lake segment, beginner cyclists may find the Point of Rocks surface to be loose 

and bumpy. The steepness of the road, loose gravel, and weather conditions have created a 

washboard surface that is uncomfortable to drive on, and likely uncomfortable for anything other 

than a full suspension mountain bike.

Geotech - Point of Rocks is a mix of large rocks and boulders sitting atop a mix of finer grained 

material. The larger, visible formations on the top with the vertical cliffs are strong and resistant to 

weathering, but with some weathering taking effect on the finer deposits. Rockfall is possible and 

already occurring from erosion. Catchment ditches are possible along the road and trail, and are 

Figure 312 Mile 16.7. Looking North Figure 313 Mile 18. Looking South on OYTS Road.

Figure 334 Mile 18.6. Looking North on OYTS Road. Figure 335 Mile 18.9. Looking North on OYTS Road.
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better than the rest of the areas assessed along the corridor. Rockfall mitigation measures are 

possible. 

The greatest threat for landslide activity is seen to the fill side of the trail adjacent to the river. 

Erosion activity from the river current has washed out exposed soils where not armored with 

bedrock. High water has likely caused the existing soil to be evacuated. Vegetation is sparse on the 

slope and there is no root system to provide support for the soils. The riverbank consists of material 

cast aside during construction of the railroad, and is a mix of silty, sand and gravel.

Environment - No significant areas of concern

Safety - Loose gravel and inconsistencies in surface make the traction on the southern side of the 

pass somewhat poor. Some of the turns are also sharp, with sightline limitations, and significant 

exposure. The surface on the north side of the pass is more solidly compacted, but the grade is 

much steeper, raising concerns for unchecked high-speed descents
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Page Intentionally Left Blank
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Chapter 3: Stakeholder Involvement 

Planning Process

A corridor study is initiated to evaluate the overall impacts, capacity, safety or constraints on a 

transportation system within a defined geographical area. Often the system has not been completely 

defined, and the study considers various alternatives within that corridor for possible implementation. 

The study will look at environmental impacts, cost implications, and safety factors as considerations for 

future actions. Throughout the process citizens in the community, stakeholder groups, and neighboring 

property owners are engaged to provide feedback to the alternatives. In the case of this project, that 

feedback was solicited through a series of public meetings, site visits and public hearings.

Western Federal Lands staff performed site visits to evaluate the corridor and develop a set of potential 

alternatives. The alternatives were presented to members of the project team and briefed to the public. 

Alternatives were assigned a set of pros and cons and a input was solicited from the public as to the 

long-term viability of the various options. Throughout the evaluation process, planning staff engaged 

with the public to solicit inputs regarding the alternatives, and encouraged early communication with 

interested parties.

An initial site visit and scoping meeting was conducted in May 2017 by WFL and Park County Community 

Development staff. Meeting participants discussed the project timeline, and the desire to have a 

completed planning study prior to the 2019 FLAP project data call. A second site visit was conducted in 

October 2017 to evaluate and document the corridor. Park County, United States Forest Service and 

National Park Service staff convened at Carbella Bridge with WFL and toured the corridor. Staff provided 

confirmation of project objectives and highlighted in detail the concerns to be addressed. A Statement 

of Work proposal was drafted by WFL and circulated to FLMA partners. 

WFL staff worked hand in hand with members of the project team to identify factors early on that are 

important to a successful corridor. Frequent calls between the project team ensured that the project 

was on track to produce a usable and relevant final product. 

Public Participation Procedures

It is important to engage the public, stakeholders, and other interested parties throughout a planning 

study to ensure there is a process in place that invites participation. During this study, communication 

with the public occurred infrequently due to the long duration of the study. During all phases of the 

planning process opportunities were provided for FLMA and Park County staff to review and comment 

on draft and final documents. It was emphasized during the October 2017 site visit that stakeholder 

participation would be important for the study, and a plan was developed to meet with stakeholders in 

the spring of 2018.

A series of meetings was held to allow the public to provide input to the process. First, meetings were 

held with various government groups to better understand the considerations and sensitivities of the 

area. Over the course of April 4-5 there were three meetings held with each of the major project 

participants to discuss what was discovered during the site visits and create a list of problem 
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statements. Individual meetings were scheduled for Park County, USFS and NPS. Staff new to the 

process attended the meetings and were provided an overview of the project objectives. Concerns 

reflected in the small group discussions included emergency response, animal migration, river use, and 

remediation of drainage concerns to reduce roadway damage.

Second, an open house was held in Gardiner at the community center on May 31, 2018. This open house 

was arranged to allow the public to discuss concerns with planning staff. A notification was placed in the 

Livingston Enterprise to make residents aware of the opportunity. A total of 11 members of the public 

attended the meeting, and engaged in discussion with County, FLMA and WFL representatives. A onepage handout was provided to attendees. Five tables were set up with aerial photographs of segments 

along the corridor and each table was manned by staff from USFS, NPS, Park County and WFL. Two Park 

County Commissioners also attended the meeting to make themselves available for questions and listen 

to feedback from the community. Attendees of the public meeting were interested in the impact the 

development would have on their property and what could be expected from the process. Residents 

were worried about maintaining the existing character of the corridor. No written comments were 

provided during the meeting. Attendees confirmed preliminary staff concerns and were curious to 

follow the progress in the future. It was explained that no construction would result as a direct outcome 

of this effort. Following the meeting, WFL staff received comments in writing from interested 

stakeholders. One resident supplied comments via email.

Emails requesting written comments were sent to stakeholders who were not able to attend the public 

meeting, largely because they were government agencies or private organizations. Many agencies 

provided comments through email, and many vouched support for a future corridor plan. Agencies who 

responded to the request for comment include Montana Fish, Wildlife and Parks; Yellowstone Gateway 

Museum; Royal Teton Ranch; Rails to Trails Conservancy; and archeologists from USFS. A summary of 

comments is included in the following section.

Summary Of Public Outreach

In initial meetings Park County discussed concerns such as the landslide and rockslide activity that has 

made the current road impassible and the impact it has had on the community. Emergency services 

personnel addressed the lack of an alternate route. USFS staff identified capacity issues with the river. 

Boat launch sites are limited and the restroom facilities are inadequate to support additional growth. 

The following is a summary of comments from those meetings and written comments received from 

various public and private agencies:

Park County meeting, Livingston – April 4, 2018

The main message from the staff of Park County is the interest in improving, enhancing and protecting 

public health and safety; emergency access; recreational opportunities; and historic and prehistoric 

resources. There is anticipation that this corridor will experience growth in population and recreational 

users. A plan is requested that will provide a basis for future decisions regarding investment in 

recreational opportunities and ensure safety of the users.
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It is said that the corridor is underutilized and there is a lot of recreational and historical value. Great 

opportunity exists for collaboration among all agencies located in the corridor. There is currently a good 

working relationship with Park County, USFS, NPS and BLM. It is expected the tribes will also be 

interested in being involved with the corridor development. Tribes may be interested in helping tell their 

story with interpretive signage. Coordination will certainly occur prior to any project development 

within the corridor.

Roadway condition is one of the major categories of discussion. Along the corridor various sections 

require maintenance or rehabilitation if the roadway is going to be opened up again as an access road. 

Yankee Jim Canyon is a very specific area of focus. Emergency access on OYTS has been blocked since 

2014 as a result of a section of roadway washing out.

A summary of additional stakeholder comments is presented below:

- There is a desire to use the old rail bed for recreation, and if possible complete the connection 

with the old town site. A major area of concern is the road condition and associated drainage

issues with the uphill section traveling in the direction of Gardiner after Stephen's creek.

- There has been previous discussion of establishing a trailhead near Cutler Lake. There was a 

loop trail approved in the 2007 travel plan that has not been executed. It has possibly been 

reconsidered because there is a high likelihood for bears in this area.

- Widening near Beattie Gulch for safety possible? Does this raise concerns from residents?

Beattie Gulch doesn't have any major improvements that are being asked for, but as usership 

increases, it may result in conflicts with other users (i.e. tribal hunts). Maybe widen out road at 

Beattie Gulch?

- Park County public works would encourage emphasis on improving the Cinnibar Road access. 

Road work is needed in this area, including an area near the Church Universal and Triumphant 

that has been washed out and may need attention possibly as a result of a drop inlet by Church 

Universal and Triumphant property.

- Outfitter camps utilize Corwin Springs bridge to get to Cinnibar Basin. There are safety concerns 

at the intersection of Cinnibar Road.

- Another vehicle crossing may be required at some point between Corwin and Gardiner. 

- Park County ownership of Aldridge Road will likely be an issue that will come up with the public; 

The roadway is a county road that provides right-of-way through private property. The public is 

able to use the road for access to Aldridge Lake, but cannot get off the road until on USFS land 

at the top near the lake. May need to be more well marked as private property.

- Restoring access is a priority for emergency responders. Emergency vehicles will be expected to 

provide response to recreationists in the corridor. If there is going to be year round access; 

there will be additional demands on emergency response and roadway maintenance.

- The roadway will need to be identifiable (signage for emergency vehicles and rescues). Many of 

the roads and trails do not contain identifying signage which is confusing for recreationists and 

first responders not familiar with the area. This is all part of the bigger concern for wildland and 

urban interface planning.

- Access to powerlines is a priority for emergency response. 

- Changes to recreation in the corridor must take into account impacts to emergency access. 
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- One suggestion was that access be limited to only non-motorized activities and emergency 

response. 

o It is not clear if the roadway can be designed to accommodate emergency vehicles 

without permanently opening the road to traffic. There are likely restrictions on using 

public funding to improve roadways that are not open to the public.

- Multiple types of emergency vehicles need access to the corridor:

o Landing zones for Life Flight helicopters (not necessarily creating them, but knowing 

where they are).

o Ambulances

o Type 6 USFS fire engine

o Structural fire engines

o Sheriff’s office Search and Rescue

o Tow truck access

Federal Land Management Agency meeting, Gardiner – April 4, 2018

Land management agencies were concerned with the condition of the roadway. Many of the attendees 

suggest improving the roadway condition with drainage improvements. Improving drainage will reduce 

roadway erosion and reduce maintenance costs. Improving the strength of the road for large vehicle 

operations will help with bison management. NPS may need to increase operations at Stephens Creek. 

The USFS wants to see responsible development of the area. There is concern that encouraging 

additional visitors will place an extra burden on the corridor. Permitting for river access is at maximum 

capacity, and management of facilities to service recreationists places a costly burden on the USFS 

budget. New dispersed campsites are potentially damaging to the landscape and are very disruptive to 

natural animal corridors.

A summary of stakeholder comments is presented below:

- There are known drainage deficiencies and cross-slope issues along the road

o A previous installation of fiber optic may have led to current roadway degradation.

- USFS agrees that we should plan for increased recreation and use in the corridor, but also 

expressed reservation about making significant investment in improvements until there is 

evidence that the demand makes it necessary. There is an ADA accessible trail in the canyon 

previously developed by the USFS that is underutilized. 

- Activities that utilize river access permits are at maximum capacity. An additional river access 

site may be beneficial if there is another vault toilet, but may also add to the river congestion. 

Rafters who use the landings outside of USFS sites have large impact on the area. Vault toilet 

pumping is already an issue that could impact budgets. Seasonal use starts as early as April, but 

typically extends from early May to October 1. Peak visitation normally occurs in July and 

August. Salmon Fly hatch is “insane” and people are parked along the highway. 

- There is no river management plan in this area:

o USFS working on a multi-agency river management plan. Initiation efforts are underway.

o State does not limit access on this river

o USFS does not regulate along the entire river, only on USFS land
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o 2 companies have USFS permits to use USFS access

o Other companies use private land, Brogans Landing or alternate locations

o Various stakeholders are interested in pursuing a Wild and Scenic Rivers designation for 

the Yellowstone River. Such a designation has implications for the use of the river. 

Coordination through the development of a river management plan is encouraged and 

will likely be required.

- Ensure that any focus on developing the corridor does not overlook the high value of preserving 

and planning for wildlife.

o Recreation will have an impact on the wildlife in the corridor. 

o Grizzly bear conservation efforts have successfully increased the population and there is 

a healthy population that has established a territory.

o Wildlife migration corridors are well established and should not be cutoff.

o Avoid improvements or activities that limit free movement of animals and avoid

funneling animals into choke points if possible. 

- Currently there is no cell service or very limited signal in the canyon, and more recreationists 

could lead to more emergency calls. Education of the public on emergency resources will be a 

challenge.

- The following list of data points were provided throughout the discussion and are seen as the 

minimum components to be addressed in the study:

o Multi-hazard mitigation plan

o Geotechnical unstable slopes management plan (USMP), likely 3 key areas

 Gardiner to Stevens Creek

 Church Universal and Triumphant property to Cutler Hill

 Tom Miner Canyon

o Study and understand sensitive wildlife corridors

 It would be nice to have information regarding movement of wildlife, but the 

length of this study may not lend itself to that. May need to include a 

recommendation for a follow-on study.

 Evaluate the possibility of a wildlife overpass

o Bison Operations 

o Draft forest plan

 USFS draft plan is in development as of the date of the public meeting. 

Components of that plan should align with the recommendations of this study.

o Quantifying use

 Counting of traffic

 Trail counters

 Rec use counts

 Boaters

 Residential development 

 Sensitive Wildlife habitat

 Formal access points

 Informal access points

 Toilet use

 Informal campsite count
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Gardiner Partners meeting, Gardiner – April 5, 2018

The meeting kicked off with a presentation from the NPS regarding the north entrance improvement 

project. Following on the heels of the Gardiner Gateway project, the entrance project is another 

opportunity to improve the connection between Gardiner and Yellowstone National Park. One of the 

important aspects of this project is the separation of bicycle, pedestrian and vehicle traffic. 

After the NPS project discussion, Quinn Newton and Michael Inman presented the concept for the Old 

Yellowstone Trail South Corridor Study. Many of the same concepts from previous meetings were 

shared by the NPS attendees. A summary of unique stakeholder comments is presented below:

- Two water/sewer lines extend under Yellowstone River that are likely to fail at some point. 

These lines are old, and shifting of the river bottom threatens to break them at any time. A new 

bridge constructed to carry pedestrians and emergency vehicles could also carry utility lines 

over the river. 

- It would be very naïve not to plan for increasing the future input and usage. The Gardiner

Chamber of Commerce is often asked where the good bike trails are located. 

- Eagle Creek and Bear Creek campgrounds are often full during peak season. They are located off 

the study corridor but push campers to find new sites.

- Park County was awarded a Tiger Grant for Highway 89 corridor mixed-use path south of 

Livingston. Similar federal programs may be an opportunity for future construction funding.

- Rails to Trails Conservancy is interested in seeing the completion of a trail from Livingston to 

Gardiner. The corridor stretches 55 miles, and there is desire to see a non-motorized option for 

connecting to Yellowstone National Park through Paradise Valley. Ideally, a linkage will be 

created with similar efforts at the West Yellowstone entrance, thereby creating a regional 

connection.

Public Town Hall, Gardiner – May 31, 2018

An open house was held at the community center to give residents an opportunity to learn about the 

planning effort and provide comments to the planning team. Residents were mostly curious about 

changes that would have a potential impact on the current lifestyle enjoyed in the corridor. The 

resounding comment was that people living along OYTS enjoy the quiet, rugged nature of the area, and 

did not wish to see improvements that would change the character. Paved roads and trails is not a 

desirable outcome of this study.

A summary of stakeholder comments is presented below:

- Annual tribal hunting of bison in National Forest is sometimes contentious between different 

user groups. Proximity of hunting to residents is sometimes concerning, and more oversight of

the hunt is desired.

- Increased access in an area that is historically significant/sensitive can be good or bad. 

- Increased usage is not seen as a bad thing, but needs to be managed responsibly.

- Topography along the corridor will present some challenges. 
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- Project area includes 148 residences and 4 local businesses. They should all be contacted about 

any future project work.

- Former Custer Gallatin National Forest Gardiner District Ranger Walt Allen says there are no 

special management considerations for water quality, wildlife security, or connectivity at this 

time. 

- General support was expressed from the local community, land agencies, and recreational land 

users

- Low water conditions on area rivers has resulted in an increase in commercial outfitters using 

Yellowstone River

- Landowners, travelers and outfitters have expressed an increased interest in RV campground 

development based on the increasing market demand

Project Team 

Quinn Newton, Project Manager

360.619.7836

quinn.newton@dot.gov

Western Federal Lands Highway Division

Federal Highway Administration

Vancouver, WA

Seth English-Young, Transportation Planner

360.619.7803

seth.english-young@dot.gov

Western Federal Lands Highway Division

Federal Highway Administration 

Vancouver, WA

Applicant

Michael Inman, Director

Community Development Department

Park County Montana

Livingston, MT

Parks Frady, Director

Public Works Department

Park County Montana

Livingston, MT

Partner Agencies

Michael Thom, District Ranger

Gardiner Ranger District

USDA Forest Service

Gardiner, MT

Joe Regula, Landscape Architect

Yellowstone National Park

National Park Service

Mammoth, WY

Christina White, Outdoor Recreation Planner

Yellowstone National Park

National Park Service

Mammoth, WY
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Chapter 4. Problem Statement, Goals, and Objectives

Transportation improvements within the corridor must accommodate competing factors which make 

implementation of a comprehensive strategy challenging. The length of the road corridor, topography, 

and recreation opportunities generate varied types and levels of use. Execution of future improvements 

will be impacted by the lead agency, roadway type, adjacent landowners, and environmental, cultural, 

and historical considerations. The challenge lies in balancing these objectives and the goal of this report 

is to identify the actions that need to occur from a planning standpoint. Some of the actions identified 

may require additional coordination, study, and a determination of whether they are appropriate.

Evaluation of the corridor, discussions with public officials and inputs from stakeholders generated a 

significant list of concerns, suggestions, and needs within the corridor. Based on the results of those 

inputs, we have identified 8 problem areas, each of which have measurable and attainable targets. 

Some problems are meant to be addressed immediately. Others may not need focus until the intensity 

of use increases in the corridor, and in some cases may never be necessary if the indicators aren’t 

reached.

Problem statements:

1. Secondary emergency access is not available due to current roadway conditions. 

Emergency access is a primary motivation for the FLAP request, and should be the initial 

focus of any investment in the corridor.

2. Roadway condition has degraded along many sections of Old Yellowstone Trail South, 

aside from strictly Yankee Jim Canyon. Most notably, drainage is a consistent issue that has 

resulted in longitudinal and transverse rutting of gravel roadways; long stretches of muddy or 

potholed roadway; and washboarding of gravel surface.

3. Impact to wildlife from increased recreation activity in the valley is a concern shared by 

all stakeholders. Migrating animals utilize established corridors that potentially conflict with 

current and future recreation corridors.

4. Destruction of archaeological assets in the corridor is a known issue. Theft and 

vandalism are problems and additional usage has the potential to increase these issues. 

However, more people on the corridor could act as a deterrent to thieves and vandals.

5. Environmental degradation from unchecked increase in use threatens this unique 

environment. It is not currently known how users of the corridor will impact the 

environment
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6. Impact to property owners by unwanted development of a trail in the corridor. Not 

each resident will be supportive of increased recreation in the corridor. Some residents we 

heard from shared concerns about improvements affecting their properties, and impacting 

the wildlife.

7. Corridor encroachment resulting in the loss of a significant historical connection is a 

lesser known threat. Old Yellowstone Trail South once stretched from Plymouth to Seattle, 

but now, there are sections remaining in only Montana, Wisconsin and Washington18. The 

section between Livingston and Gardiner is possibly one of the longest contiguous sections of 

the original road still remaining. As growth, or opposition to growth, affects the corridor, it is 

possible that the visual history of the trail in the region will be lost completely. 

8. Visitor experience goals must be aligned with a comprehensive plan for the corridor. 

Travelers and residents partake in many outdoor activities and there is potential to expand 

the available options. There is an opportunity for Park County to develop a management plan 

to guide recreation in the region. 

Through this study, the following Goals and Objectives were determined. These Goals and Objectives 

will help to guide future construction improvements and/or can be used in NEPA documentation. 

Goal #1 

Improve the corridor to establish a throughway for vehicle and recreational use.

Objectives

• Provide secondary emergency access through the full corridor.

• Improve roadway elements to better road condition and increase user safety.

• Establish a multi-use trail separated from the roadway where possible.

Goal # 2

Protect cultural and natural resources that make the corridor unique.

Objectives

• Minimize impacts to wildlife and the landscape from corridor usage.

• Minimize impacts to archaeological resources.

• Highlight original transportation connections along the trail.

 18 http://www.yellowstonetrail.org/page141.html
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Goal #3

Balance visitor experience with landowner property rights.

Objectives

• Involve property owners in the planning process.

• Provide a positive and coherent visitor experience.
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Chapter 5. Action Plan 

This chapter describes potential improvement options for the corridor. The problem statements and 

associated general actions are summarized below, followed by possible geometric and surface condition 

improvements, and the chapter ends with additional recommendations.

1. Secondary emergency access. First and foremost, the existing landslide in Yankee Jim Canyon 

must be cleared and corrected. The slide occurred on the cut and fill slopes of the 

roadway, and will need reinforcement and rockfall protection to mitigate the risk of a 

recurring event. Once the landslide has been corrected, access will be restored 

between Miner and Cinnabar Basin. A risk assessment should be performed to determine if the 

access is safe for general access or if access should be restricted to recreation and emergency 

response. Part of the risk assessment should evaluate the addition of intervisible turnouts to 

allow two-way traffic, or consider implementation of one-way travel. Emergency response is 

vital to the corridor as recreation grows. In addition to restoring emergency vehicle access, the 

Park County Emergency Response Chief recommended establishing helicopter landing sites and 

identifying tow truck access to retrieve a vehicle from the river. The risk assessment exercise 

would be useful for identifying probable (high-risk) locations.

2. Roadway condition. Roadway maintenance must be performed at regular intervals with 

consistency applied the entire extent of the corridor. All roadways should be shaped 

and graded to maintain a crown to promote proper drainage. Where needed raise 

roadway grade, replace culverts, widen ditches to handle flows, improve roadway 

surface by adding gravel or compacting, widen roadway, correct rutting and correct the source 

of the problem. In extreme cases, a full depth roadway repair may be needed to correct damage 

to the subbase and basecourse layers of the road section.

3. Impact to wildlife. Recommendations for new recreation should take wildlife into account. 

Critical locations should be studied, identified and compensation measures 

formulated to mitigate impacts. One possibility is to limit access to residents and 

emergency vehicles only. Such restrictions may not be necessary year-round, but may 

correspond with key migration seasons, breeding times, or when an abnormally large 

population of animals is present. Grizzly bear populations in Cinnabar Basin have been reported 

to be growing, and could potentially create conflict with recreators. Based on what is known 

about existing animal populations, it is recommended to define key recreation nodes, and focus 

development of new recreation opportunities in these areas. Trailheads should be established 

to coincide with desired recreation nodes, and in essence encourage activity where it is desired. 

4. Destruction of archaeological assets. The first step in protecting and mitigating impacts to 

historic resources is to identify critical protection zones. This is not a document that 

should be circulated to the public, but should be part of a management strategy for 

the property owners. Visitors should be encouraged to visit these sites, and the public 
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should be educated on the importance of preservation. Preservation presents a key opportunity 

for interpretation and encourages the community to take an active role in monitoring the site. 

Known historic sites should also be part of the monitoring plan for the land owners. Law 

enforcement needs to be part of the discussion of managing protected assets. 

5. Environmental degradation. It is recommended a study be completed that focuses on carrying 

capacity and establishes upper limits for users in the corridor. It is likely that the 

current amount of use requires very little change to the corridor, but higher user 

thresholds may trigger corridor improvements. This document lays out actions that 

should be taken to manage the corridor. From the recommendations in the document, land 

owners should develop a long-range investment plan and continue to make improvements as 

prioritized in that plan. A strategy for encouraging and managing corridor use is to provide 

developed infrastructure in desired locations, and formalize opportunities for off-trail 

exploration in previously disturbed sites. Lack of formalized recreation sites will encourage

dispersed uses and accelerate degradation.

6. Property owners impacts. For any changes that are proposed, it is essential to make contact 

with each property owner along the corridor and provide an opportunity to 

comment. After meeting with property owners, document their interest in accessing 

or providing access to a trail on or near their property. Ensure that property owners 

who are in favor of the trail have an opportunity to understand the impacts. For property 

owners that are not supportive of the trail, mitigate impacts to the maximum extent possible. To 

be prepared for future protests or complaints, ensure that all options are evaluated and well 

documented.

7. Corridor encroachment. The Old Yellowstone Trail South corridor seems largely unchanged 

from how it likely appeared at the turn of the 19th century, and visitors are treated to 

the same sights and sounds as the very first explorers that identified the significance 

and value of preserving what would come to be called Yellowstone Park for 

generations to come. Interpretive signage could be used to highlight original transportation 

connections along the trail, explain the evolution of the corridor over the previous century and 

provide education on how prison labor was used to construct the roadway itself. Not much has 

been done to preserve the history of the once substantial roadway, and only a few segments 

exist. This roadway is seen by some as a national treasure19. Preservation and maintenance of 

the roadway and railbed will enable potential efforts to pursue a national historic trail 

designation. 

 19 http://www.yellowstonetrail.org/page141.html
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8. Visitor experience. There is an opportunity to develop a guided plan that public and private 

investors alike can rally behind. Independent efforts can be inefficient and misguided. 

Some ideas for collaboration include interpretive signage, shared or consistent 

mapping, wayfinding and identification of neighboring amenities. Trailheads should 

include comprehensive information about the area and identify connections with nearby 

amenities and additional recreational opportunities. There is an opportunity for Park County to 

establish more opportunities for year-round activities for locals and visitors along this iconic 

corridor. As visitation has grown in Yellowstone Park so has demand for outdoor activities in 

less congested venues nearby. Park County offers year-round activities like hiking, rock climbing, 

fly fishing, camping, skiing, snowmobiling, and hunting. 

Geometric and Surface Condition Improvements

Corridor-wide Improvements

This section summarizes general geometric and surface condition improvements throughout the 

corridor. The general recommendations are referenced or described in more detail for each segment in 

the sections below.

Road

- Improve roadway to consistent width (20 foot, 24 foot or 28 foot). The width of the existing 

roadway varies throughout the corridor. See Figure 1 for roadway typical cross-section options. 

- Elevate finish grade in low areas to prevent ponding of water on road surface

- Recondition gravel surface to eliminate formation of muddy sections and reduce washboarding

- Improve drainage in problem areas:

o Install, replace, repair, or clean culverts where necessary.

o Construct drainage ditches. Where drainage ditches are already present, clear them of 

any debris or overgrowth.

o Establish crown on roadway

- Apply dust-free surface applications when multi-use trail shares right-of-way. Consider use of a 

sealant or other treatment that will secure the surface and prevent erosion. 

- Continue regular maintenance

- Clear debris and vegetation from road edge

- Install clear wayfinding signs
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Figure 34 Road Typical Cross-Sections
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Trail

- Improve trail to consistent width (6 to 10 foot) where it is separated from the road. The width of 

the trail varies throughout the corridor. See Figure 2 for trail typical cross-section options.

o The 6-foot wide cross-section could keep the trail surfacing as dirt, or add aggregate

o The 10-foot wide cross-section assumes adding aggregate

- Grubbing and clearing of overgrowth

- Remove large rocks from trail

- Fill potholes, sinkholes, and ruts

- Establish standards for surface preparation, treatment and maintenance

- Install clear wayfinding signs

Figure 35 Trail Typical Cross-Sections
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Range of Improvement Options

Possible improvements are grouped together below in three options for the entire corridor. The 

improvements are described in more detail by corridor segment later in this chapter. It is worth noting 

that the improvement options are packaged together for ease of comparison, but project partners may 

choose to “mix and match” segment options in myriad combinations (for example, do minimal 

improvements to the corridor, but build a pedestrian bridge to the trailhead). The estimated 

construction cost is based on planning-level cost estimates described in Appendix A.

• Option 1: 20-Foot Road with Minimum Improvements (est. construction cost $2.0 million)

o Road: 

 Clear the blockages on the roadway at MP 14.1 and 14.2

 Undertake low-cost slope stabilization measures

 Establish consistent 20-foot road width; except keep one-lane width in Yankee 

Jim Canyon with intervisible turnouts for passing

 Recondition road with aggregate

 Improve drainage:

• Install, replace, repair, or clean culverts where necessary. 

• Construct or clear drainage ditches. 

• Establish crown on roadway

 Install clear wayfinding signs

o Trail:

 Formalize existing trailhead

 Remove rocks and clear and grub vegetation from trail

 Establish or maintain 6-foot dirt trail where trail is separated from road

 Separate trail from roadway where feasible, but do not acquire easements 

where trail is on private property

• Trail on existing, separated alignment in Segments 1, 3, and most of 5

• Trail on shared ROW with road in Segments 2, 4, portion of 5, and 6, 7, 8

 Install clear wayfinding signs

• Option 2: 24-Foot Road with Moderate Improvements (est. construction cost $5.3-6.4 million)

o Road: 

 Clear the blockages on the roadway at MP 14.1 and 14.2

 Undertake mid-range slope stabilization measures

 Widen to consistent 24-foot road width; except keep one-lane width in Yankee 

Jim Canyon with intervisible turnouts for passing

 Recondition road with aggregate

 Improve drainage:

• Install, replace, repair, or clean culverts where necessary. 

• Construct or clear drainage ditches. 

• Establish crown on roadway
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 Install clear wayfinding signs

o Trail:

 Build a trail from the Gateway Arch to the existing trailhead. 

 Remove rocks and clear and grub vegetation from trail

 Improve to 6-foot aggregate trail where trail is separated from road

 Separate trail from roadway where feasible, but do not acquire easements 

where trail is on private property

• Trail on existing, separated alignment in Segments 1, 3, and most of 5

• Trail on shared ROW with road in Segments 2, 4, portion of 5, and 6, 7, 8

 Install clear wayfinding signs

• Option 3: 28-Foot Road with High Improvements (est. construction cost $8.9-$15.1 million.

20) 

o Road: 

 Clear the blockages on the roadway at MP 14.1 and 14.2

 Undertake extensive slope stabilization measures

 Widen to consistent 28-foot road width; except keep one-lane width in Yankee 

Jim Canyon with intervisible turnouts for passing

 Recondition road with aggregate

 Improve drainage:

• Install, replace, repair, or clean culverts where necessary. 

• Construct or clear drainage ditches. 

• Establish crown on roadway

 Install clear wayfinding signs

o Trail:

 Build a trail from the Gateway Arch to the existing trailhead or build a 

pedestrian bridge over the Yellowstone River. 

 Remove rocks and clear and grub vegetation from trail

 Widen to 10-foot aggregate trail

 Maximize trail separation from road, including negotiating with property owners 

to try to acquire easements where trail is on private property

• Trail on existing, separated alignment in Segments 1, 3, and most of 5

• Work with landowners to acquire easements for trail in Segments 2, 4, 

portion of 5, 7, and 8

• Trail on shared ROW with road in Segment 6

 Install clear wayfinding signs

All options meet the project goals described in Chapter 5:

 20 The $15.1 million upper limit includes a pedestrian bridge over the Yellowstone River at an estimated cost of $4-

5 million.
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• Goal #1: Improve the corridor to establish a throughway for vehicle and bike use.

• Goal #2: Protect cultural and natural resources that make the corridor unique.

• Goal #3: Balance visitor experience with landowner property rights.

Segment Specific Improvements

Improvements specific to each segment of the corridor are described in more detail below.

Segment 1: MP 0-4.4 

Road

OYTS road is of substantial width throughout this entire stretch, and is in fair to good condition. 

Emergency vehicle access is sufficient. 

Road Condition Improvements

Establishing a 20-foot road width would likely only require reconditioning of the existing roadway. 

Building a 24-foot or 28-foot wide road would require excavation and addition of aggregate. To improve 

drainage with any of the roadway widths, establish ditches and install, replace, or repair culverts every 

500 feet or as needed. 

Trail

Segments closest to Gardiner will likely receive the most traffic, because of the proximity to population. 

It is potentially convenient that the first 4.4 miles of trail is located on Park Service property, and is 

already a largely intact section of trail. It is convenient because use of public lands is typically favorable. 

Many segments of the 22-mile trail will have significant difficulties as compared to the initial extent. 

Trail Alignment

Continue to use the trail on the existing alignment, which is separated from the OYTS road. 

Formalize Main Trailhead

A key to the success of the multi-use corridor is formalized access from Gardiner to the OYTS trail. There 

is currently no official start to the trail nor a connection to the trail from town. Standing at the Gateway 

Arch, there is no accommodation for bicycles or pedestrians to access the trail. A trail exists behind the 

Yellowstone Heritage Center, but it is not visible from the road and there is no signage or map to 

provide confirmation. 

Option A

Formalize the trailhead at the location of the existing pullout at approximately MP 0.4 on the 

OYTS road. To access the trailhead from the Gateway Arch, users will need to walk on the 

roadway of OYTS. Add signage near the Arch to provide directions to the trailhead.

Option B

Build a trail within the ROW of the OYTS road, either separated from the road or on the 

shoulder, from the Gateway Arch to the existing trailhead. The new segment of trail will create a 

clear and intentional connection from the Gateway Arch and Town of Gardiner, and encourage 
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people not to use the connection behind the high school. Add signage near the Arch to indicate 

the start of the trail.

Option C

Build a pedestrian bridge over the Yellowstone River, to facilitate access from uptown 

businesses. The majority of lodging is located along Scott Street and visitors staying in this area 

will likely drive to the start of the trail without a shorter connection. With the introduction of a 

bridge, residents and visitors can access the trail more directly and will likely leave their vehicles 

behind. An added benefit of constructing a bridge is the ability to include replacement of water 

and sewer lines above the river. Current utility lines are buried under the river and pose a risk of 

breaking and contaminating the river, as well as greatly impacting utility operations in Gardiner. 

It is standard practice to hang utility lines under bridges to cross waterways.

Unstable Slopes Mitigation

Two rockfall slopes (US06 - score 327; US07 – score 292) have moderately high scores. Potential avenues 

for mitigating rockfall in this section could be selective rock scaling, lessening cut slope angles, 

improving the catchment ditch, or various trail-side barrier types. Additional geotechnical 

recommendations are included in the geotechnical report, Appendix C.

Trail Condition Improvements

The trail is highly used and in fairly good condition through this segment. Keeping the trail as dirt, 

clearing and grubbing vegetation, and spot improvements as necessary would be the low-cost option. 

The trail could also be widened and surfaced with aggregate. 
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Figure 36 Segment 1 (Map 1 of 2)
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Figure 37 Segment 1 (map 2 of 2)
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Segment 2: MP 4.4-7.7

Road

OYTS road is of substantial width throughout this entire stretch, and is in fair to good condition. 

Emergency vehicle access is sufficient. 

Road Condition Improvements

Establishing a 20-foot road width would likely only require reconditioning of the existing roadway. 

Building a 24-foot or 28-foot wide road would require excavation and addition of aggregate. To improve 

drainage with any of the roadway widths, establish ditches and install, replace, or repair culverts every 

500 feet or as needed. Depending on the placement of the trail, one or both shoulders of the road could 

be widened to give bicyclists and pedestrians more separation from vehicle traffic.

Trail

Trail Alignment

The railroad bed is on private property for the majority of this segment (MP 4.4-7.0). There are two 

sections where it passes through agricultural fields. Depending on property owners willingness to 

provide an easement for a trail on all or part of their property the trail may need to share road ROW for 

a large portion of this segment. Those sections of private property are described below.

MP 4.4 Stream Crossing

At the beginning of the segment, the trail intersects with a stream and there is no crossing. Two options 

for a crossing are described below. The stream delineates between NPS property to the south and 

private property to the north.

Option A

Build a crossing on the existing alignment. Options include pre-fabricated steel bridge, a wooden 

bridge or a box culvert. The crossing is estimated at 10-feet wide and 15-feet long.

Option B

Shift the trail alignment to cross at the road bridge about 600 feet away. 

Trail Private Property Crossing MP 4.4-7.0

The railroad bed passes through properties of a number of private owners before reaching USFS 

property around MP 7.0. 

Option A

Use the road ROW. The trail could share the road or could be built alongside the road but 

separated from the roadway. 

Option B

Acquire easements from the private property owners to use the railroad bed. This option is the 

straightest, but passes through agricultural fields and near ranch buildings at MP 4.6-5.4 and MP 

5.8-6.3.
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Option C

Use the railroad bed, but shift the alignment to run beside the river at MP 4.6-5.4 and MP 5.8-

6.3, where the railroad bed passes through agricultural fields. This option would probably also 

need easements from private property owner, but would skirt the fields and avoid the ranch 

buildings.
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Figure 38 Segment 2
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Segment 3: MP 7.7-8.3

Road

The condition of road in this section is greatly deteriorated with excessive rutting, and the road gets very 

muddy when it rains.

Road Condition Improvements

Establishing a 20-foot road width would require significant reconditioning of the existing roadway. 

Building a 24-foot or 28-foot wide road would require excavation and addition of aggregate. To improve 

drainage with any of the roadway widths, establish ditches and install, replace, or repair culverts every 

500 feet or as needed.

Trail

Trail Alignment

The trail is to the west of the road and it appears to be on USFS land.

Trail improvements

Vegetation overgrowth has become more significant and the surface condition is much rougher from 

rocks and dead plants. Reconditioning the trail and keeping it as dirt, while clearing the vegetation, 

would be the low-cost option. The trail could also be widened and surfaced with aggregate.
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Figure 39 Segment 3
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Segment 4: MP 8.3-10.6

Road

The condition of road in this section is fair with some rutting.

Road Condition Improvements

Establishing a 20-foot road width would likely only require reconditioning of the existing roadway. 

Building a 24-foot or 28-foot wide road would require excavation and addition of aggregate. To improve 

drainage with any of the roadway widths, establish ditches and install, replace, or repair culverts every 

500 feet or as needed. Depending on the placement of the trail, one or both shoulders of the road could 

be widened to give bicyclists and pedestrians more separation from vehicle traffic.

Trail

Trail Alignment

The railroad bed is on private property for the entirety of this segment. 

Trail improvements

Option A

Use the road ROW. Depending on how wide the ROW is, the trail could share the roadbed or 

could be separated from the roadway. 

Option B

Coordinate with private property owners to obtain easements to use the railroad bed. 
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Figure 40 Segment 4
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Segment 5: MP 10.6-13.6

Road

The condition of road in this section varies. Large rocks, rutting, and loose surface describe the southern 

section. The northern extent is well compacted gravel and shows very little sign of deterioration. 

Road Condition Improvements

Establishing a 20-foot road width would likely only require reconditioning of the existing roadway. 

Building a 24-foot or 28-foot wide road would require excavation and addition of aggregate. To improve 

drainage with any of the roadway widths, establish ditches and install, replace, or repair culverts every 

500 feet or as needed.

Trail

Trail Alignment

The railroad bed is on private property for approximately the first 0.25 miles of this segment, then 

continues on USFS property. 

Trail improvements

For the majority of this segment, the trail can be on the railroad bed. The path will need to be cleared of 

vegetation. The trail could remain as a dirt trail or improved to aggregate.

For the portion of the trail on private property, there are two options:

Option A

Use the road ROW for the portion on private property (MP 10.6-10.85). Depending on feasibility 

and how wide the ROW is, the trail could share the roadbed or could be separated from the 

roadway. 

Option B

Coordinate with private property owners to obtain easements to use the railroad bed. 
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Figure 41 Segment 5 (Map 1 of 2)
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Figure 42 Segment 5 (Map 2 of 2)
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Segment 6: MP 13.6-15.6

Road

Known trouble areas within the Yankee Jim Canyon segment of the corridor present the greatest 

challenge for generating a secondary emergency access. A rockslide covers a section of road at milepost 

14.1 and a landslide washed out a section at milepost 14.2. The rockslide at MP 14.1 is the highest 

scoring unstable slope (US 103 - score 488). The landslide at MP 14.2 scores high in the unstable slope 

assessment (site US 106 – score 303).

Unstable Slopes Mitigation Options at MP 14.1 (rockslide) and MP 14.2 (landslide)

- Clear existing rocks and aggregate material from the roadway 

- Reduce cut slope angles

- Reinforce the fill slope between the roadway and the river

o Construct retaining walls

o Install boulders for stabilization

o Provide additional fill material

- Construct rockfall mitigation on the cut slope above the roadway/trail

o Establish rockfall clear zones

o Build gabion walls

o Mount rock netting

o Perform rock scaling

o Establish catchment ditches

o Install trail side barriers

Road Condition Improvements

Large sections of the road suffer from significant rutting. The road is narrow through Yankee Jim Canyon 

and even getting 20-foot width in that section could be impractical. It is possible to keep the section 

through Yankee Jim Canyon as one-lane and add turnouts as necessary or allow one-way travel for the 

public. The remainder of the segment could be 20, 24, or 28 feet, as feasible. Add aggregate, establish a 

crown and install, replace or repair culverts to address drainage. 

Trail

Trail Alignment

The trail is and will probably need to be the same as the road for the entirety of this segment. The 

shared ROW is on the railroad bed on USFS property. Continue to utilize the road, since the corridor is 

narrow and would be difficult to separate a trail. There are two sections where a mountain bike trail 

could veer from the road, but not for the full length of the segment. The second highest scoring unstable 

slope is above the potential mountain bike trail at approximately MP 13.9 (US 16 - score 433).
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Figure 43 Segment 6
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Segment 7: MP 15.6-17.5

Road

Roadway condition is good in this area.

Road Condition Improvements

Establishing a 20-foot road width would likely only require reconditioning of the existing roadway. 

Building a 24-foot or 28-foot wide road would require excavation and addition of aggregate. To improve 

drainage with any of the roadway widths, establish ditches and install, replace, or repair culverts every 

500 feet or as needed. Depending on feasibility and how wide the ROW is, the trail could share the 

roadbed or could be separated from the roadway.

Trail

Trail Alignment

The railroad bed travels through private property, clearly marked with signs, and serves as access to a 

farm. The trail would likely share the road ROW.
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Figure 44 Segment 7
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Segment 8: MP 17.5-21.1

Road

Old Yellowstone Trail South Road terminates at MP 21.1 where it meets US89. The roadway is smooth 

and appears to be well graded, but the gravel surface is thin, and patches of the softer subgrade have 

started to show through. 

Road Condition Improvements

Similar to Segment 7, Establishing a 20-foot road width would likely only require reconditioning of the 

existing roadway. Building a 24-foot or 28-foot wide road would require excavation and addition of 

aggregate. To improve drainage with any of the roadway widths, establish ditches and install, replace, 

or repair culverts every 500 feet or as needed. Depending on feasibility and how wide the ROW is, the 

trail could share the roadbed or could be separated from the roadway.

Trail

Trail Alignment

The railroad bed travels through private property. The trail would likely share the road ROW.
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Figure 45 Segment 8 (Map 1 of 2)
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Figure 46 Segment 8 (Map 2 of 2)
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Additional Recommendations

Corridor Management

- Establish a working group that would continue momentum and help to facilitate improvements 

in the corridor.

- Consider establishing maintenance agreements with National Park Service, Forest Service, 

Bureau of Land Management, Montana Fish and Game, and Park County for collaborative 

approach to corridor maintenance.

Develop a comprehensive signage plan 

- Replace existing signage that is no longer 

current.

- Remove illegal signage

- Review private property posting and ensure 

that no public lands are posted by mistake

- Identify sites for interpretation. There are 

former settlements, wagon train routes, and 

the alignment of the former rail line that are 

prime educational opportunities.

- Another interpretation opportunity exists for 

sharing stories of tribal hunting and how 

native tribes subsisted on the land for 

generations.

- Once a final alignment is decided, create and 

install very clear directional signage.

- Clearly identify property lines. Additional 

signage for NPS and USFS property. 

Recreation Marketing

- Visitors to the area will benefit from a 

consolidated mapping system that provides the location of trailheads, amenities and camping in 

one easy to use system. 

- Include nearby amenities and trail connections on BLM maps.

- Create marketing plan for trail system

- Distribute maps for corridor trail system

- Coordinate with the Adventure Cycling Association

- Network with Montana state tourism office and adventure tour operators to have OYTS 

included in itineraries

- Facilitate public private partnerships to help improve sections of the trail and attract bicycle 

tourism

Figure 47 Sample trail directional signage
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Appendix A: Geotechnical Report No. 17-18

Provided as separate attachment. 
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Page Intentionally Left Blank
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Appendix B: Introductory Environmental Assessment

Environmental Overview Memo

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9/5/19

The purpose of this memo is to present a preliminary environmental overview for the Old Yellowstone

Trail South (OYTS) Corridor Study project – MT PARK 2016(10). The study area begins near Gardiner, 

Montana and extends approximately 21.1miles mostly towards the northwest, paralleling the west bank 

of the Yellowstone River. The proposed project currently has three main objectives:

1. Provide safer and more adequate transportation access through the corridor for emergency 

vehicles as well as residents, recreationists, visitors and resource users

2. Ensure the future use of the corridor is not inhibited by degradation of travel surfaces

3. Establish a balance in developing recreational opportunities, while also preserving the existing 

character of the area

Below is a summary of relevant environmental categories related to the project:

1.0 National Environmental Policy Act

The National Environmental Policy Act (NEPA) is required when a Federal action is taken that may have 

impacts on the human and natural environment. Federal actions are those that require Federal funding, 

permits, policy decisions, facilities, equipment, or employees. NEPA analysis and documentation 

depends on the scope, funding source, and lead federal agency of potential project activities. It is likely 

that the NEPA document for proposed project activities would be a Categorical Exclusion or 

Environmental Assessment, which have shorter timelines than Environmental Impact Statements. Since 

project activities would likely occur at least partially on National Park Service (NPS) and USDA Forest 

Service (USFS) lands, they would determine which type of NEPA document would meet their needs. The 

project activities could potentially fall under the Federal Highway Administration (FHWA) categorical 

exclusions described in 23.CFR.771.117. The NPS and USFS would need to determine if they could use 

FHWA’s categorical exclusion to satisfy their NEPA requirements. 

It is not anticipated that a Montana Environmental Policy Act (MEPA) review would be required as part 

of proposed project activities. However, an environmental review under NEPA may be legally sufficient 

to cover MEPA, if MEPA becomes required.

1.1 Federal Land Management Agency Consistency Determination

Since portions of the OYTS corridor are on NPS and USFS lands, each agency will need to provide a 

determination that the project is consistent with its policies and plans. The determination may be in the 

form of a NEPA document, or it could be a separate document.

2.0 Land Use
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Land use within the OYTS corridor is a mixture of public and privately-owned land. Public land includes 

areas within the corridor that are managed by the NPS and USFS. Park County has coordinated project 

development with the NPS and USFS and both the NPS and USFS support the project. 

Depending on the outcome of the study, right-of-way (ROW) acquisition may be required through 

private lands, including the Church Universal and Triumphant (Royal Teton Ranch) property, in which a 

key section of the OYTS roadway is located. Also, existing segments of the OYTS cross active agricultural 

fields; however, no new impacts are anticipated to occur on prime or unique farmland.

Park County has coordinated with and would continue to coordinate with the land owners to develop 

avoidance measures and/or ways to mitigate for impacts. 

2.1 Public Involvement

Private lands within the corridor include ranches, agricultural lands, and property owned by the Church 

Universal and Triumphant. A public information session was held on May 31st, 2018 to describe the OYTS 

planning study and to receive feedback from the community. Also, private land owners have been 

encouraged to submit comments and suggestions regarding the study. 

Additional public information sessions would be held as the project progresses, also, a public meeting 

and comment period would likely be held during the NEPA process.

2.2 Property Acquisition

Certain sections of the OYTS corridor that are in need of restoration may require acquisition of property, 

but would not require obtaining structures or displacing residents. Any property acquisitions would 

need to comply with the Uniform Relocation Assistance and Real Property Acquisition Act of 1970. 

Property or easement acquisitions could increase project timelines and/or alter project alternatives. 

2.3 Section 4(f) of the Department of Transportation Act

If FHWA is involved in construction activities related to the project, FHWA would need to comply with 

Section 4(f) of the Department of Transportation Act, which stipulates that “FHWA and other DOT 

agencies cannot approve the use of land from publicly owned parks, recreational areas, wildlife and 

waterfowl refuges, or public and private historical sites unless the following conditions apply:

• There is no feasible and prudent avoidance alternative to the use of land; and the action

includes all possible planning to minimize harm to the property resulting from such use;

OR

• The Administration determines that the use of the property will have a de minimis impact.”

(https://www.environment.fhwa.dot.gov/legislation/section4f.aspx)

FHWA would need to determine if 4(f) properties exist in the project area, then determine if the project

will “use” those 4(f) properties. If the “4(f) use” is de minimis, meaning “for parks, recreation areas, and 

wildlife and waterfowl refuges, a de minimis impact is one that will not adversely affect the

features, attributes, or activities qualifying the property for protection under Section 4(f)” then it will

be noted in the file and project can proceed. If the “4(f) use” is determined to be greater than de
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minimis, then a written evaluation must be prepared that describes the use and evaluates the

alternatives, and proposes mitigation and minimization measures.

While it is likely that the project would use 4(f) resources, it is also likely that the impact would be de

minimis or that one of the designated exceptions to the law would apply.

2.4 Section 6(f) of the Land and Water Conservation Act

Section 6(f) of the Land and Water Conservation Act requires that the conversion of lands or facilities 

acquired with Land and Water Conservation Act funds be coordinated with the Department of Interior.

Section 6(f) resources, such as fishing accesses, may be present within the OYTS study area. The 

proposed project is being developed to enhance recreational opportunities within the OYTS corridor; 

therefore, Section 6(f) resources would not be eliminated or degraded as part of the proposed project. 

3.0 Environmental Justice

The project would be open to all and would likely not impact any environmental justice communities

disproportionately. 

4.0 Cultural/Historic Resources

Because the OYTS corridor crosses federal lands, consideration of impacts to cultural/historic resources 

is mandated under Section 106 of the National Historic Preservation Act. 

Preliminary information from the NPS, USFS, and the Yellowstone Gateway Museum indicates that there 

are known cultural/historic resources in the study area. Prior to project implementation and 

construction, additional cultural/historic resource investigations may be required, including an 

Archaeological Resources Protection Act (ARPA) permit for archaeological investigations. 

The federal project lead would be required to coordinate with the State Historic Preservation Office to 

ensure that the project complies with Section 106.

5.0 Tribal Coordination

Tribal coordination, or government-to-government consultation regarding concerns the tribes may have 

regarding the OYTS project, will be conducted by the USFS, NPS, and/or the FHWA as the project 

progresses. 

6.0 Wetlands and Waters 

According to National Wetland Inventory mapping (https://www.fws.gov/wetlands/data/mapper.HTML

– Accessed 12/28/18), small areas of riverine wetlands (freshwater emergent and forested/shrub) 

associated with the banks of the Yellowstone River as well as widely scattered palustrine emergent 

persistent seasonally/temporarily flooded wetlands are mapped within the study area. However, a site 

visit has not been conducted to confirm that the OYTS crosses potentially jurisdictional wetlands. 

The OYTS crosses eight named creeks that are tributaries to the Yellowstone River, from south to north

within the study area (upstream to downstream of the Yellowstone River) these creeks are as follows: 
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• Landslide Creek

• Stephens Creek

• Reese Creek

• Spring Creek

• Mulherin Creek

• Sphinx Creek

• Tom Miner Creek

• Rock Creek

The OYTS also crosses numerous unnamed drainages. These waterways are also tributaries to the 

Yellowstone River. 

The proposed project may include new and/or upgraded bridge and culvert crossings, as applicable. A

site visit has not been conducted to confirm which waterways would require a crossing, if work below 

the ordinary high-water mark (OHWM) of the respective waterways would be necessary, or whether the 

respective waterways may be considered jurisdictional by the U.S. Army Corps of Engineers (USACE). 

Any construction within jurisdictional wetlands or within the OHWM of jurisdictional waterways (rivers, 

streams, creeks, drainages, etc.) would require to be permitted in accordance with the USACE 404 -

Clean Water Act (CWA) permitting process. The permitting process would include a wetlands/waters 

delineation and report, consultation with the USACE to determine the net impact on wetlands/waters, 

and appropriate mitigation, as necessary, to resolve wetland/waters impacts. The Section 404 permit 

would need to be obtained prior to beginning construction activities. 

Impacts to wetlands/waters would also require a 401 Water Quality Certification from the Montana 

Department of Environmental Quality (MDEQ). The 401 Water Quality Certification is obtained jointly as 

part of the Section 404 Permit process. 

Also, a MDEQ Temporary Turbidity - 318 Authorization may be required if proposed construction 

activities result in a release of sediment or turbid water to wetlands/waterways and a Montana Stream 

Protection Act Permit (SPA 124 Permit) from the Montana Department of Fish, Wildlife, & Parks (MFWP) 

if project activities affect the natural existing shape and form of any stream or its banks or tributaries. 

6.1 Water Quality

Water bodies that do not meet water quality standards are placed on the list of impaired water

bodies, the CWA Section 303(d) list, by MDEQ. The Yellowstone River within the study area is 303(d) 

listed for ammonia, arsenic, copper, lead, nitrate-nitrite, and sedimentation-siltation. Probable sources 

include: abandoned mine lands, surface mining, subsurface mining, natural sources, highway runoff, 

land clearance, streambank modifications, and loss of riparian habitat. Water quality permits will dictate 

the level of required conservation measure. 

The Yellowstone River (from Reese Creek to the end of the study area), Reese Creek, and Mulherin 

Creek are designated as a Water Quality Category 4C by MDEQ. A 4C water quality designation is 

characterized as “Identified threats or impairments result from pollution categories such as dewatering 

or habitat modification and, thus, a Total Maximum Daily Load is not required”.
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The Yellowstone River (from the start of the study area to Reese Creek) and Tom Miner Creek are 

designated as a Water Quality Category 5 by MDEQ. A water quality designation of 5 is characterized as 

“Waters where one or more applicable beneficial uses are impaired or threatened, and a TMDL is 

required to address the factors causing the impairment or threat”. The MDEQ is responsible for 

developing necessary TMDLs and implementation plans.

The U.S. Environmental Protection Agency (EPA) National Pollutant Discharge Elimination System 

(NPDES) Program requires a permit for all construction activities that disturb more than 1 acre of land. 

The MDEQ Permitting and Compliance Division administers the NPDES Program through the Montana 

Pollutant Discharge Elimination System (MPDES) Program. If project activities disturb more than 1 acre 

of land, the project would need to obtain a “General Permit for Storm Water Discharges Associated with 

Construction Activity” (General Permit) prior to the initiation of construction activities. As part of the 

permitting process, completion of a Notice of Intent (NOI) Package and preparation of a Storm Water 

Pollution Prevention Plan (SWPPP) would be required. 

Construction contract requirements, including a soil erosion and sediment control plan, would minimize 

temporary water quality impacts. The project is not expected to permanently impact water quality.

6.2 Floodplains

Portions of the OYTS corridor are within the Federal Emergency Management Agency (FEMA) 100-year 

floodplain of the Yellowstone River and the corridor crosses through the FEMA mapped 100-year 

floodplains of Mulherin Creek and Tom Miner Creek. 

Structures constructed within a mapped FEMA 100-year floodplain would require either a “no-rise” 

certification (information here: https://www.fema.gov/no-rise-certification-floodways), or a Conditional 

Letter of Map Revision (CLOMR information here: https://www.fema.gov/conditional-letter-maprevision). Also, construction activities within a floodplain must meet local floodplain zoning ordinance 

requirements, such as the Park County Floodplain Hazard Management Regulations. 

6.3 Navigable Waterways

The Yellowstone River is considered navigable by the U.S. Coast Guard (USCG) within the study area; 

therefore, any structures constructed within or over the Yellowstone River, such as a pedestrian bridge, 

may require a Section 9 USCG permit and/or a Land-Use License or Easement on Navigable 

Waters permit from the Montana Department of Natural Resources and Conservation. 

The Yellowstone River is not considered navigable by the USACE within the study area; therefore, a 

USACE Section 10 permit would not be required. The USACE considers the Yellowstone River navigable 

from Emigrant, Montana downstream to its confluence with the Missouri River.

6.4 Wild and Scenic Rivers

Currently, neither the Yellowstone River, nor its tributaries, are designated as a Wild and Scenic River. 

6.5 Groundwater
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Numerous groundwater wells may be located within the OYTS study area, additional investigation of the 

precise locations of groundwater wells may be warranted as the project progresses.

7.0 Fish and Wildlife

7.1 Fish

The Yellowstone River and several of the streams in the OYTS study area support native species such as 

Yellowstone cutthroat trout, mountain whitefish, longnose sucker, longnose dace, and mottled sculpins. 

Non-native species may include brown trout, rainbow trout, and carp. Many of these species are 

considered “game” fish.

Coordination with local/state agencies during the design phase of waterway crossings is recommended 

to include improved fish passage to the tributaries of the Yellowstone River, where applicable, as well as 

aquatic and riparian habitat enhancements.

7.2 Wildlife

The OYTS corridor passes through areas utilized by a variety of large wildlife species such as: elk, deer

(mule and whitetail), bighorn sheep, pronghorn antelope, bison, bears (black and grizzly), wolves, 

moose, coyotes, and eagles. Many of these animals migrate annually between the higher elevations in 

Yellowstone Park and the lower elevations of the Gardiner Basin. According to the MFWP, the study 

area is an important migratory corridor for numerous species. In particular, Yankee Jim Canyon provides 

important habitat for migrating species because it provides a pinch point between Paradise Valley and 

Gardiner Basin/Yellowstone Park. 

Other wildlife that may be present within the study area include a variety of species including small 

mammals, upland birds and waterfowl, amphibians, and reptiles.

As the project progresses, field investigations for the presence and extent of wildlife species within the 

study area may be warranted with project design and related construction activities kept in 

consideration to avoid and/or minimize impacts on these species.

7.3 Threatened, Endangered, and Special-Status Species

Canada lynx (with designated critical habitat) and grizzly bear are federally listed under the Endangered 

Species Act (ESA) as threatened within the study area and the North American wolverine is proposed for 

listing as threatened. All three species are under the jurisdiction of the U.S. Fish and Wildlife Service 

(USFWS). 

The ESA requires that federal agencies consult with the USFWS regarding potential impacts to federally 

listed species and/or critical habitat. ESA compliance for the project should follow the lead federal 

agencies procedure for complying with the requirement of the ESA, which may include the use of a 

programmatic biological opinion or completing a biological assessment. 

Furthermore, possible usage within the OYTS corridor or surrounding vicinities by State and USFS 

special-status species include but are not limited to the following: gray wolf, elk, bald eagle, olive-sided 
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flycatcher, peregrine falcon, trumpeter swan, northern goshawk, harlequin duck, great gray owl, and 

Yellowstone cutthroat trout. Coordination with the USFS and MFWP would need to be conducted to 

address potential impacts to special-status species and to develop applicable avoidance and mitigation 

measures. 

7.4 Migratory Bird Treaty Act

The Migratory Bird Treaty Act prohibits the taking of any migratory birds, their parts, nests, or eggs, 

except as permitted by regulations. Consultation with the USFWS would be required if impacts to 

migratory birds are anticipated during construction activities.

7.5 Bald and Golden Eagle Protection Act 

The Bald and Golden Eagle Protection Act provides for the protection of bald and golden eagles by 

prohibiting, except under certain specified conditions, the taking, possession, and commerce of such 

birds. Consultation with the USFWS would be required if impacts to bald or golden eagles are 

anticipated during construction activities.

8.0 Recreational Resources

The OYTS corridor provides many opportunities for recreation, including, but not limited to, the 

following: fishing, hunting, hiking, rafting/kayaking, camping, wildlife viewing, ATV, horseback and 

bicycle riding, cross country skiing and snowshoeing. The Yellowstone River within the study area has 

been recognized as a blue-ribbon recreational fishery for wild trout and Yankee Jim Canyon includes 

world-class whitewater for rafting and kayaking. 

The OYTS study area currently includes approximately three boat launches, two picnic areas, one 

campground as well as several unimproved (non-formalized) campgrounds, and five trailheads. 

The proposed project is being developed to enhance recreational opportunities within the OYTS corridor 

without degradation of the natural environment. 

9.0 Traffic

The existing OYTS roadway is comprised of gravel surfacing, has a seasonal average daily traffic (SADT) 

of 100, and is maintained by Park County. The road is currently impassible by vehicles due to washout 

sections in Yankee Jim Canyon.

Improvements to the OYTS roadway and associated corridor would create the potential for the OYTS to 

be an alternate emergency route for Emergency Services in case of closures on U.S. Highway 89. Should 

U.S. Hwy 89 become inaccessible as a result of rock slides, accidents, wildfires, etc., OYTS would provide

the only ingress and egress to the community of Gardiner and the original and only year-round access to 

Yellowstone National Park.

In addition to providing emergency access for motor vehicles, improvements to the OYTS roadway may 

increase vehicle traffic within the study area as it would provide better access to public lands and 

potential recreation areas.
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10.0 Noise

The OYTS study area consists of park lands, recreation sites, and federally listed Canada lynx critical 

habitat. Short-term and minor noise impacts from construction-related activities (clearance of rockfall 

areas, culvert installation, etc.) would occur to soundscapes during the duration of each construction 

activity. Long-term impacts to soundscapes as a result of the project are not anticipated; however, an 

evaluation of noise impacts may be warranted in the future if improvements to the road/trail results in 

an appreciable increase in vehicle traffic. 

11.0 Visual Quality

The OYTS corridor is encompassed by the Yellowstone River and its tributaries, valleys, mountains, 

riparian areas, cultural and historic resources, and open spaces free of anthropogenic structures. 

Short-term visual impacts from construction-related activities may occur; however, long-term visual 

impacts to the landscape as a result of the project are not anticipated.

12.0 Air Quality

The OYTS corridor is not located within an EPA designated air quality maintenance or non-attainment 

area. A lack of dense population centers and large industrial facilities limit the likelihood for long-term 

and measurable impairment of air quality within the OYTS study area.

Heavy machinery used during construction activities would contribute to an increase in exhaust fumes 

and fugitive dust. These increases would be short-term, isolated, and minor. If necessary, dust emissions 

would be controlled by applying water to construction areas and access roads. It is not anticipated that 

the project, short-term or long-term, would result in an exceedance of air quality standards.

13.0 Hazardous Materials

No known EPA hazardous materials sites are within the OYTS corridor or project vicinity.

The Montana DEQ data mapper (http://svc.mt.gov/deq/wmadst/) shows verified locations of currently 

in-use and temporarily out-of-use regulated underground storage tanks (USTs) and locations of open cut 

mines that are present within the OYTS study area. Additional investigation of the precise locations of 

the USTs and mines may be warranted as the project progresses. However, it is not anticipated that the 

proposed project would affect hazardous materials or be a source of hazardous materials.

14.0 Cumulative and Indirect Impacts

In addition to an analysis of direct impacts to relevant environmental categories from a proposed 

project and its alternatives, cumulative and indirect impacts are also required to be addressed in NEPA 

documentation. 

14.1 Cumulative Impacts

Cumulative impacts are defined as:

“...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
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individually minor but collectively significant actions taking place over a period of time. (40 CFR §

1508.7)”

Other “past, present, and reasonably foreseeable future actions” that may be included as cumulative 

impacts are anthropogenic bank stabilizations and flood confinements on the upper Yellowstone River 

within or near the OYTS study area. 

14.2 Indirect Impacts

Indirect impacts are defined as:

...caused by the action and are later in time or farther removed in distance, but are still reasonably

foreseeable. Indirect effects may include growth inducing effects and other effects related to induced

changes in the pattern of land use, population density or growth rate, and related effects on air and

water and other natural systems, including ecosystems. (40 CFR § 1508.8)”

(https://www.environment.fhwa.dot.gov/nepa/QAimpact.aspx)

Indirect impacts that could be “reasonably foreseeable” as a result of the proposed project may include 

the following: impacts to wildlife as a result of increased human-wildlife interactions, theft of 

archaeological assets, and environmental degradation from increased recreation activities.

15.0 Summary of Permits and Clearances 

Below is a summary of Federal, State, and local agency permits and/or clearances that may be required 

as part of the project: 

U.S. Fish and Wildlife Service 

• Section 7 Consultation – Endangered Species Act

• Migratory Bird Treaty Act/Bald and Golden Eagle Protection Act Clearances

U.S. Army Corps of Engineers 

• Section 404 Permit – Clean Water Act

U.S. Coast Guard

• Section 9 Permit – Rivers and Harbors Act 

Federal Emergency Management Agency

• No-rise Certification

Montana Department of Natural Resources and Conservation 

• Montana Land-Use License or Easement on Navigable Waters

Montana State Historic Preservation Office 

• Section 106 Clearance – National Historic Preservation Act

• Archaeological Resources Protection Act (ARPA) Permit
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U.S. Department of Transportation

• Section 4(f) Clearance

Montana Department of Fish, Wildlife, and Parks 

• SPA 124 Permit – Montana Stream Protection Act

Montana Department of Environment Quality 

• MPDES “General Permit for Storm Water Discharges Associated with Construction Activities” 

including a Notice of Intent (NOI) and a Stormwater Pollution Prevention Plan (SWPPP). A soil 

erosion and sediment control plan and an Authorization for turbidity-related construction 

activities would also be required from the MDEQ. 

• Section 401 Water Quality permit if a Section 404 permit is required by the USACE

• Section 318 Water Quality permit (generally approved by the MFWP on behalf of the MDEQ)

Park County – Floodplain Administrator 

• Park County Floodplain Permit 

Department of Housing and Urban Development

• Uniform Relocation Assistance and Real Property Acquisition Act Clearance
Old Yellowstone Trail South Corridor Study

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Old Yellowstone Trail South Corridor Study

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Old Yellowstone Trail South Corridor Study

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Appendix C: Planning Cost Estimate

Provided as separate attachment
Old Yellowstone Trail South Corridor Study

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Old Yellowstone Trail South Corridor Study

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Appendix D: Cost by Improvement Option

Provided as separate attachment