Custer Gallatin National Forest Management Plan

Forest Management Plan for the Pryors
Updated July 11, 2020

On July 9, 2020 Custer Gallatin National Forest (CGNF) released their Final 2020 Land Management Plan and Environmental Impact Statement (EIS). This Plan will guide management of the entire Custer Gallatin National Forest, including the Pryor Mountains, for the next 15 to 30 years.

Previously, in March 2019, CGNF had released a Draft of this Plan and EIS for public comments. The Pryors Coalition sent a letter to CGNF commenting on the Pryors portion of the Plan on June 1, 2019. Scroll down to see that letter under LETTERS to CGNF below.

We are very pleased that CGNF is designating a 10,366 acre Bear Canyon Recommended Wilderness Area that we had proposed. With this designation CGNF acknowledges that the very special ecological and cultural values of the Pryors merit the Wilderness classification to best preserve these values.

New Bear Canyon Recommended Wilderness Area (dw photo 7/13/20) New Bear Canyon Recommended Wilderness Area (dw photo 7/13/20)

The RWA includes most of the Bear Creek watershed on the south facing slope of Big Pryor and Red Pryor Mountains – including several forks of rugged limestone-cliffed Bear Canyon. With elevation varying from about 5,000 to 8,600 feet, this small area exhibits a wide range of ecological habitats including arid semi-desert, rare riparian areas, dense Douglas fir forest, and sub-alpine plateau.

The Bear Canyon RWA includes much of the Montana Audubon Society designated Important Bird Area (IBA), and part of the Montana Native Plant Society designated Pryor Mountain Important Plant Area (IPA).

We are disappointed that CGNF is not designating the Big Pryor and Punch Bowl RWAs we proposed. These areas also merit the best possible protection as landscapes unlike any other in the National Wilderness Preservation System.

July 2017
Custer Gallatin National Forest (CGNF) is in the process of revising the Forest Management Plan for the entire Forest. This includes the Pryor Mountains. The “current” Management Plan for the Pryors is seriously out of date having been completed in 1986. A lot has changed in 30 years! The new Management Plan will guide all future management decisions in the Pryors for many years. So this rather wonky and bureaucratic process is extremely important for the future of the Pryors.

In the 1986 Management Plan for the Pryors, protection of natural and cultural resources were a clearly secondary consideration at best. The Plan provided for and encouraged commercial activity like timber harvest and intensive cattle grazing. (The Pryors Coalition does not oppose cattle grazing in balance with other values of the land.) Public recreational activity in the Pryors was hardly mentioned in the 1986 Plan. This was:

• before drastic and increasing OHV/ATV use in the Pryors

• before there was much conflict between motorized and non-motorized recreation

• before there was enough motorized use to significantly effect wildlife and other ecological, natural and cultural resources.

A guiding principal for the Pryors Coalition is that the first goal of management should be to preserve and restore the natural and cultural resources of this fragile and unique landscape. A secondary goal is to provide a balance of recreational opportunities. But all forms of recreation must be managed within the limits that the landscape can sustain. The Pryor Mountain part of the new Forest Management Plan must provide guidance for future management decisions and actions consistent with these principals.

The Pryors Coalition and associated organizations have sent several substantive letters discussing changes we believe are necessary in the new Plan. These letters are accessible below.

Desired Future Condition
A key section of the Management Plan is the “Desired Future Conditions” for the area. The rest of the Management Plan should provide management direction to achieve and maintain those Desired Future Conditions (DFCs).

We have drafted an updated one-page summary of our Vision and Desired Future Conditions for the Pryors. We encourage the Forest Service to carefully consider this statement when drafting the DFCs for the new Management Plan. Read our statement here..

Recommended Wilderness:
In addition we have proposed that several Recommended Wilderness Areas be designated in the Pryors in the new Forest Plan. Our April 13, 2017 letter proposing these Wilderness areas can be seen here.


Our letters to CGNF are listed below in reverse chronological order. Click on each to open.

Pryors Coalition letter to CGNF: June 1, 2019. Comments by The Pryors Coalition and associated organizations in response to CGNF’s Draft Revised Forest Plan and Draft Environmental Impact Statement. Among other topics this letter describes inadequacies in CGNF’s Wilderness Analyses – including inaccurate and misleading statements.

Pryors Coalition letter to CGNF: February 28, 2018. Comments by The Pryors Coalition and associated organizations in response to CGNF’s proposed Management Plan revision. This letter is necessarily long and detailed, but includes many important points.

Wilderness Inventory:
The first step (of four) in the planning process which leads to possible designation of Recommended Wilderness Areas is a Wilderness Inventory. On July 24, 2017 CGNF released a Wilderness Inventory map based on a deeply flawed analysis. The resulting map excluded large area of potential wilderness on Big Pryor Mountain and a couple other smaller areas. With very considerable time and effort we sent several letters to CGNF critiquing the flawed Wilderness Inventory and reporting our own field study on Big Pryor. See letters dated August 9, August 25, and September 25, 2017.

Our effort paid off!! On November 6, 2017 CGNF released a Wilderness Inventory Report and map revising the July draft. This new Wilderness Inventory now includes almost all the areas on Big Pryor that we claimed it should include. But this is still just step #1. We need to keep encouraging CGNF to actually designate RWAs in the Pryors.

Pryors Coalition letter to CGNF: September 25, 2017. Going out to look at the landscape is sometimes better than a computer GIS analysis done in an office. We did a careful and systematic Field Study of the wilderness character of Big Pryor. This report of that study again challenges CGNF’s July draft Wilderness Inventory. (Contact us if you want copies of the photo record of this field study.)

Pryors Coalition letter to CGNF: August 25, 2017. We received a document explaining CGNF’s Geographic Information System (GIS) model used to generate the Wilderness Inventory. In this second letter we identify and explain the serious flaws in the GIS model that led to the flawed Wilderness Inventory map.

Pryors Coalition letter to CGNF: August 9, 2017. This is our first letter responding to the July draft Wilderness Inventory map. We identified areas that had been inappropriately excluded, and explained why the FS Planning Rule and facts on the ground both indicated thee areas should be added. At this point we had not seen the model that the CGNF used to generate the map.

Pryors Coalition letter to CGNF: April 13, 2017. In this letter the Coalition and several allied organizations present our proposals for Recommended Wilderness Areas in the Pryors.

Pryors Coalition letter to CGNF: January 5, 2017.
In this letter we respond to CGNF’s Draft Assessment of Existing Conditions Reports and their Draft Need to Change the Management Plan.

Pryors Coalition letter to CGNF: April 5, 2016.
In this letter we discuss ways the new Management Plan needs to differ from the 1986 Plan based on a comparison of:

• the 1986 Management Plan (parts that relate to the Pryors),

• the 2012 Planning Rule which describes Forest Service requirements for Plan revision,

• what we believe will be important to the public over the next 30 years.

Development of the new Management Plan will take several years. There will be opportunities for the Public to influence the new Plan. These opportunities include public meetings with CGNF Planners, and requests for public comment letters on various stages of the Planning process.

Information on the Forest Service planning schedule, their progress toward the new Plan, and opportunities for public comment can be found here.

Management of the public land in the Pryors is divided (fractured) among three federal agencies: Custer Gallatin National Forest (CGNF), the Bureau of Land Management (BLM), and the Bighorn Canyon National Recreation Area (BCNRA). But the Pryors are a single landscape including the north part of the Pryors on the Crow Reservation. Management of the Pryors should be holistic. The management agencies should have a unified vision of the Pryors and manage the Pryors as a single landscape. This should be clear in the new Management Plan.

CGNF currently has designated an abundance of motorized routes in the Pryors. But current management is deficient in providing protection for the ecological diversity, secure wildlife habitat, and opportunities for quiet recreation. In the new Management Plan CGNF has the opportunity to designate several motor-free areas to meet these needs.