Monitoring and Evaluation

Perhaps the greatest concern with CNF’s Monitoring Plan is that there seems to be no target or goal for the number of staff days per year for monitoring and law enforcement in the Pryors. A Travel Plan is just paper in a file unless it is enforced. After decades of neglect, people know there is little chance that they will see anyone from CNF in the Pryors. Compliance with, and enforcement of, the new Travel Plan depend on a regular and visible presence of CNF staff and Law Enforcement Officers throughout the Pryors. It appears from the Monitoring Plan that CNF expects that most monitoring and enforcement will be incidental to Beartooth District staff trips to the Pryors for other purposes. This will be inadequate both in frequency of trips, and in thorough and timely coverage of all parts of the Pryors. We suggest there should be several trips per week (both weekends and week days) dedicated to enforcement and monitoring – especially on Big Pryor Mountain. Regular trips should also be made to East Pryor and the Sage Creek area. An objective should be added to the Monitoring Plan of some minimum number of dedicated enforcement/monitoring days per season in the Pryors.

Another concern is route signing which CNF has identified as a high priority element of the Monitoring Plan. Legally people are responsible to follow the Motor Vehicle Use Map (MVUM) regardless of the existence, or absence, of signs on the ground. Nevertheless we endorse CNF’s objective that “All designated routes [be] signed with route number signs.” The courtesy of helping responsible recreationist by posting such signs is an important service to the public.

Unfortunately we find nothing in the Monitoring Plan about clearly indicating routes that are NOT designated for motorized use. This is a significant issue quite a few places in the Pryors because of the excess of user created two track routes which have been created over the years. Sometimes these form “Ys” with motor legal routes with no indication that one route is closed to motorized use. Responsible land management and courtesy to responsible motor recreationists require clearly indicating one fork is motor legal and the other is not. This would both serve the public and help protect the landscape.

CNF should add an objective of clearly indicating as closed tracks that are NOT designated for motorized use. This can be done in a variety of ways. The best option is to obliterate and rehabilitate the tracks. When this is not possible (or until it is) some sort of barrier should be should be installed. This could be something as simple as logs or rocks across the closed tracks. Such a barrier can be helpful information to responsible recreationists even when it might be easy to drive around it. In some cases signs may be the best option. Seasonal closures should also be signed at the point of the closure.

The Monitoring Plan mentions that Custer National Forest’s stated “Purpose and Need” for the Travel Plan included providing “non-motorized opportunities”, but nowhere in the Monitoring Plan does it address monitoring or evaluating whether the Travel Plan succeeds in providing such opportunities. (Of course it doesn’t since there is just over one mile of designated non-motorized route in the Pryors.)

We are glad that CNF included ”Use or User Conflicts” as an issue to be monitored, but are disappointed by the weak treatment of this important issue. USFS rules require Forest Travel Plans to minimize conflicts between uses. As succinctly stated in a U.S. Department of Interior document:

“It appears that most nonmotorized forms of outdoor recreation are disrupted or diminished in value by the operation of ORVs nearby. This is especially true for those visitors whose recreation goals include solitude, tranquility, relaxation, observation of wildlife, and appreciation of wildland environments. Where a significant level of ORV use is present, tranquility-seeking recreationists are often displaced altogether.” **

This is the “use conflict” that Executive Order 11644 charges the USFS to minimize with its Travel Plan. CNF does not to fully address the concept of “use conflict” and treats the issue as simply about individuals who might get into a conflicted interactions at “site specific locations.” If hikers (or other non-motorized users) simply do not go to the Pryors (or go less frequently) because there are no designated quiet hiking routes, that is a use conflict. The use conflicts are still very real even when hikers do go to the Pryors, but are polite and courteous and do not get into conflicts. The solution is to designate some routes for non-motorized recreationists. CNF has not done so.

**U.S. Dep’t of the Interior, Heritage Conservation and Recreation Service, Final Environmental Statement: Departmental Implementation of Executive Order 11,644, 30–31 (1978). As quoted in John C. Adams & Stephen F.McCool, Finite Recreation Opportunities: The Forest Service, the Bureau of Land Management, and Off-Road Vehicle Management, in Natural Resources Journal, Vol. 49, Winter 2009, page 52.

Finally we are concerned by CNF’s statement that “Funding to undertake the activities in this [monitoring] plan are subject to Forest Leadership Team (FLT) prioritization and available funds.” i.e. CNF might not even implement the Monitoring Plan, or do so erratically. We understand the realities of staff and budget limitations, but the Pryors must be protected. Without monitoring and enforcement the Travel Plan is nothing more than paper in a file. This problem is compounded given the Monitoring Plan standard that “potential corrective action” regarding violations of “motorized use compliance” will be considered only if there is evidence that violations “occur for three consecutive years or more” at a particular site or route. If monitoring and enforcement is done erratically due to inconsistent budget and priority decisions the “three consecutive years” evidence standard is likely never to be met – even if the violations are frequent.

Good intentions are not enough. Failure to fulfill the Monitoring Plan due to budget or priority decisions would indicate that the Travel Management Plan was not enforceable, a requirement for Forest for travel planning. If priorities and budget do not allow appropriate implementation and enforcement of the Travel Plan, then the authorized motorized road and trail system should be pared back until it is enforceable.