Observations, Objections and Comments

on the Final Forest Plan!



To View GWA's Objections to the

2020 Custer Gallatin National Forest Plan

Check it Out Here!


GWA filed 3 Objections to the 2020 Custer Gallatin National Forest Plan; Species of Conservation Concern, Wilderness and Land Allocations and Climate Change. Those are below.










On July 9th, the Custer Gallatin National Forest (CGNF) released their 2020 Final Plan, a summation and guide of how the Forest Service (FS) plans to manage CGNF lands into the future. Needless to say, we didn’t expect much agreement with the position of GWA and our support for Alternative D. But we were hoping for better than what we saw. We urge everyone to read and digest as much of the information as you and your schedule have time for. To help in that effort, we have presented some of our own talking points and comments on the plan itself. To view the documents of the Forest Service, we urge you to click on this link here.




To warn you, the number of inclusive pages of all documents will well exceed 1,000 pages when you include the Plan and the Final Environmental Impact Statement (FEIS). We all can work together on this to be the loudest voice for wildlife.


NOTE: These observations and comments are complete at this time, but we allow flexibility to make changes and to make corrections as analysis and review take place. 


Wild Hollyhock along Bear Canyon Trail, MT.08102013 Photo taken by Clint Nagel.




Recommended Wilderness: GWA originally supported Alternative D of the Draft Revised Forest Plan. If you remember, that alternative recommended slightly more than 711,000 acres across the CGNF. The Proposed Plan recommends only 125,675 acres. This is a huge loss in overall wilderness; a shortfall of 585,325 acres of wilderness.


The final recommended wilderness proposed in the Final Plan concerning the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area is half of the original acreage recommended. Only 77,631 acres of the total 155,000 acres of the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area is being proposed as wilderness. We obviously find this unacceptable and object to how the Forest Service derived these numbers. GWA thinks it is unconscionable not to at least honor the original acreage as determined by Congress in 1977.



Geographic Area


Bear Canyon

Pryor Mountains


Lost Water Canyon

Pryor Mountains



Absaroka Beartooth Mountains


South Crazy Mountains

Bridger, Bangtail, Crazy Mountains


Gallatin Crest

Madison, Henrys Lake, Gallatin Mountains


Sawtooth Mountain

Madison, Henrys Lake, Gallatin Mountains


Taylor Hilgard

Madison, Henrys Lake, Gallatin Mountains


Total Acres

No data



For comparison:

GWA supported Alt. D which encompassed 711,425 acres of recommended wilderness.


Alternative C proposed 146,555 acres of recommended wilderness. The Final Plan is supporting even less wilderness than Alt. C.



The map below shows the problem with Alternative F. At the southern end of the Hyalite-Porcupine Buffalo Horn Wilderness Study Area lies a chokepoint manufactured by the removal of the proposed Porcupine-Buffalo Horn wilderness area. Wildlife moving northward out of Yellowstone National Park have a more narrow walk trying to strike connectivity to the north. What once was recommended as wilderness by several NGOs is now being recommended as the Buffalo Horn Backcountry Area, lands more likely to force wildlife to avoid noise and actions by both mechanized and motorized uses. At the north end of the original WSA lies the removal of the proposed Hyalite and West Pine wilderness areas. To replace them as designated by Alternative F are the Hyalite Recreation Emphasis Area and the West Pine Backcountry Area. Here wildlife will have to navigate the noise and activities of man even more so. What will add to their collective stress, is the fact that among these lands will be the potential logging and forest thinning of the Bozeman Municipal Watershed Fuel Reduction Project.



Backcountry Areas: Under the proposed Final Plan, the CGNF is proposing 208,957 acres set aside as Backcountry use areas. For your edification, here is the definition of Backcountry areas (page 125).


For comparison sake:

GWA supported Alternative D which designated 5,937 acres as Backcountry Areas.


Alternative C supported 252,896 acres.


“Backcountry areas are generally undeveloped or lightly developed. They are either are unroaded, or have few, primitive roads. Some are both unroaded and untrailed. Backcountry areas provide for more remote, semi-primitive recreation opportunities, both motorized and nonmotorized, depending on the area. Backcountry areas are listed in table 31 and are depicted in appendix B. Additional plan direction for each backcountry area is found in chapter 3 of the plan.”



Even under the suitability clause, it states this: Vegetation management, including timber harvest, is suitable for purposes such as fuels reduction, restoration, or wildlife habitat enhancement.” (page 126)



Geographic Area


Chalk Buttes



Cook Mountain



King Mountain



Tongue River Breaks



Big Pryor

Pryor Mountains


Punch Bowl

Pryor Mountains


Bad Canyon

Absaroka Beartooth Mountains


Blacktail Peak

Bridger, Bangtail, Crazy Mountains


Crazy Mountains

Bridger, Bangtail, Crazy Mountains


Buffalo Horn

Madison, Henrys Lake, Gallatin Mountains


Cowboy Heaven

Madison, Henrys Lake, Gallatin Mountains



Madison, Henrys Lake, Gallatin Mountains


West Pine

Madison, Henrys Lake, Gallatin Mountains


Total Acres

No data



Even here, you can see by the definition and suitability allowances, there is a tolerance for motorized use, for vegetation treatment and thinning on Backcountry Areas. As a result, there is no real protection, no real difference than what there is now.



Recreation Emphasis Areas: Under the proposed Final Plan of the CGNF, they are proposing 224,608 acres as public land devoted to recreation. The definition of Recreation Emphasis Areas is as stated. (page 126)


“Recreation emphasis areas typically offer a variety of quality recreation opportunities, including motorized and nonmotorized uses. The recreation opportunities are accessible to a wide range of users, in several seasons, and typically offer challenges to a wide range of skills. The areas may be regional, national, or international destinations, or may be close to higher population centers. Recreation emphasis areas close to population centers may offer opportunities for trail connections to communities.


Recreation emphasis areas may have a high density of human activities and associated structures. There may be roads, utilities, and trails as well as signs of past and ongoing activities of managed forest vegetation. Opportunities for solitude and a primitive experience may be limited near roads or trails due to frequent contact with other users. Recreation emphasis areas are listed in table 32 and are depicted in appendix B. Additional plan direction for each recreation emphasis area is found in chapter 3 of the plan.”


Table 32. Recreation emphasis areas by geographic area and acreage Recreation Emphasis Area


Geographic Area


Main Fork Rock Creek

Absaroka Beartooth Mountains


Cooke City Winter

Absaroka Beartooth Mountains


Boulder River

Absaroka Beartooth Mountains


Yellowstone River

Absaroka Beartooth and Madison, Henrys Lake, Gallatin Mountains



Bridger, Bangtail, Crazy Mountains



Madison, Henrys Lake, Gallatin Mountains


Storm Castle

Madison, Henrys Lake, Gallatin Mountains


Gallatin River

Madison, Henrys Lake, Gallatin Mountains


Hebgen Winter

Madison, Henrys Lake, Gallatin Mountains


Hebgen Lakeshore

Madison, Henrys Lake, Gallatin Mountains


Total Acres

No data




Between designated acreage of Backcountry areas and Recreation Emphasis areas, our question remains. Where is there room for wildlife in these scenarios? Both of these land-use designations allow activities not permitted in wilderness areas. They allow actions that are not supportive of wildlife.


For comparison sake:

GWA supported Alternative D which supported 34,649 acres of Recreation Emphasis Areas.


Alternative C supported 208,718 acres Recreation Emphasis Areas.


And we thought Alternative C was bad. We state this to prove the point this Final Plan is favoring the recreational emphasis of public lands over that of protection.


Timber Production and Land Allocation: GWA has commented on this provision of the draft plan of 2019 during our original submittal. Our concerns have not changed, only grown. From our understanding and from what was confirmed on a July 23rd webinar meeting with the Forest Service, they have divided up timber management into two camps: timber production and timber harvest. The former relates to the sole purpose of providing timber for the production industry while the latter relates to providing timber as a result of the multiple-use act, timber for other purposes. To simplify it even more; the former has the sole purpose for production and the latter for multiple purposes. We were told during that webinar that some of these lands do overlap, meaning the same land can be used for multiple purposes. According to the math, it appears that most of these lands do take on that characteristic.


First, we need to place in perspective the amount of logging. According to the FEIS on page 305, it states:


“The estimated treatment area for harvests and thinning under alternative F would average approximately 1,000 acres per year or about 0.04 percent of total forested area on the Custer Gallatin National Forest.”


We need to comment based upon this fact. Table 16, below states this in different terms.


Table 16. Timber production suitability classification (acres)

Land Classification Category


A. Total forest lands in the plan area


B. Lands not suited for timber production due to legal or technical reasons


C. Lands that may be suited for timber production (A−B)


D. Total lands suited for timber production because timber production is compatible with the desired conditions and objectives established by the plan; percent of forest


E. Lands not suited for timber production because timber production is not compatible with the desired conditions and objectives established by the plan (C–D)


F. Total lands not suited for timber production (B+E)


Page 75 of the Final Plan.


As one can see in Table 16 above, according to the FS, there are a little over 680,000 acres of land available for timber production or about 22.3% of the totality of the CGNF.  Of those 680,000+ acres, there are 114,500+ acres of land not suitable because the land is not compatible with the desired conditions on site. As said, category C computes out to 22.3% of the totality of CGNF land that has potential for timber production. But if you remove category E (those lands not suitable due to incompatibility, otherwise stated as category D) there is 18.6% of FS lands available for timber production and timber harvest.


Table 2. Forestwide comparison of issues by alternative

                                             Alt. A                 Alt. B                 Alt. C                  Alt. D                 Alt. E                    Alt. F  

Forested acres suitable for timber production; percent Custer Gallatin National Forest

664,628 (22%)

573,275 (19%)

549,115 (18%)

545,274 (18%)

593,735 (19%)

565,536 (19%)


Forested acres unsuitable for timber production but where timber harvest is suitable for other purposes; percent Custer Gallatin National Forest


517,195 (17%)


595,964 (20%)


577,591 (19%)


249,141 (8%)


610,629 (20%)


614,349 (20%)

Page 36, FEIS


Here in table 2 above you have the two types of timber cut, one for timber production and the one for timber harvest (the latter being the bottom line. According to the objectives on page 77 of the Final Plan and Table 2 on page 36 of the FEIS,  19% of CGNF lands would produce about 10 million board feet per year. According to the same references, 20% of additional and same lands would produce timber for multiple use at about 18 million board feet per year. This compares to the 8% of what GWA preferred in Alternative D. See Table 2 above. This does not include fuel treatments or other sorts of activities.


That was the breakdown forestwide. If we would like to confuse ourselves more, we can just talk about the Geographic area of the Madison, Henrys Lake, Gallatin Mountains. We can look at Table 5 below, found on page 137 of Appendix B. This table indicates that there are are 806,615 acres of CGNF lands descsribed as being located in the Madison, Henrys Lake, Gallatin Mountains Geographic Area. Of those 806,615 acres, Table 5 states that 216,714 of those acres may be suited for timber production or about 27% of those lands.


However, NOTICE: The discrepancy here between the totality of lands available for timber production in Table 5 and Table 8 below. Table 5 indicates there are 216,714 acres of potentially timber production lands, but Table 8 indicates 207,543 acres of land for the same purpose. We surmise that the difference of 9,171 acres (216,714 of Table 5  - 207,543 of Alt. F in Table 8) is most likely made up in lands that the FS classifies as unsuitable for the desired conditions as mentioned in Category E on Table 16 above. This needs verification. 


Table 5. Acres that may be suited for timber production, by geographic area*

Geographic Area

Total National Forest System Acres

May be suited acres

Percentage of Geographic area













Absoroka Beartooths




Bridgers, Bangtails and Crazies




Gallatin,Madison, Henrys 




Custer Gallatin 

National Forest




Page 137 Appendix B


Table 8. Madison, Henrys Lake, Gallatin Mountains Geographic Area (GA) comparison of issues by alternative.


                                     Alt. A                     Alt. B                   Alt. C                    Alt. D                    Alt. E                   Alt. F

Forested acres suitable for timber production; percent of GA



183,823 (23%)

167,239 (21%)

168,755 (21%)

183,538 (23%)




Forested acres unsuitable for timber production but where timber harvest is suitable for other purposes; percent of GA

Page 42, FEIS





188,432 (23%)


180,749 (22%)





219,016 (27%)





Land Allocation: So, we went through all of that to state and clarify the following land allocations on the CGNF based upon decision of Alternative F being the preferred alternative. Of the 3,045,965 acres of the CGNF, we are in the process of determining the remainder 1,138,955 remaining acres, or about 37% of the forest.


Of course, this in and of itself is in a state of question and/or flux as several hundred thousand acres could have been chosen for wilderness recommendation, but were not. GWA again, had chosen Alt. D which would have established 711,000 acres of additional wilderness, 585,325 acres more than Alternative F. See Table 3 below taken from page 136, Appendix B. After the removal of designated lands below, slightly less than 1,140,000 acres remain. 


Table 3. Designated areas that have been withdrawn from timber production. Because there is overlap in some designations, the total amount of a particular designation may exceed what is shown.

Designated Area


Rationale for Not being Suitable for Timber Production

Designated Wilderness


The Custer Gallatin National Forest manages portions of the Absaroka-Beartooth Wilderness and the Lee Metcalf Wilderness. Designated wilderness areas are excluded from timber production and harvest. Recommended wilderness is NOT excluded in this step because it is re-evaluated as a part of revision; it would be excluded in step 2 and may vary by alternative.

Wilderness Study Area


The Custer Gallatin National Forest manages one congressionally designated wilderness study area, the HyalitePorcupine-Buffalo Horn Wilderness Study Area. Per the Wilderness Study Act, these areas are to be managed as wilderness until Congress decides whether to designate them as wilderness.

Research Natural Areas


The Custer Gallatin National Forest has ten existing research natural areas. The designation of research natural areas precludes suitability for timber production.

Cabin Creek Recreation and Wildlife Management Area


The Cabin Creek Recreation and Wildlife Management Area was designated by the Lee Metcalf Wilderness Act in 1983. Public law 98-140, October 31, 1983, established the Cabin Creek area for the purpose of wildlife and recreation.

Additional Inventoried Roadless


The Roadless Area Conservation Rule does not allow for timber production to be a management objective.

Continental Divide Scenic Trail


The Continental Divide National Scenic Trail was designated by Congress in 1978. A half-mile buffer (one half-mile on either side) is not suitable for timber production.

Wild Horse Territory


The Wild Free-Roaming Horse and Burro Act of 1971 (P.L. 92- 195), as amended by the Federal Land Policy and Management Act of 1976 and the Public Rangelands Improvement Act of 1978, established wild free-roaming horses as a part of the natural system. This area is not suitable timber production.

National Natural Landmarks


The National Natural Landmarks Program was established in 1962 to encourage the preservation of sites illustrating the geological and ecological character of the United States, to enhance the scientific and educational value of sites thus preserved, to strengthen public appreciation of natural history, and to foster a greater concern for the conservation of the nation's natural heritage. Three national natural landmarks are located on the Custer Gallatin National Forest. These areas are not suitable timber production.

Total Acres



Page 136, Appendix B


GWA Table 1 based upon the land allocation of Alternative F.


  1. Total forest lands in the plan area                                                                                                3,045,965       (100%)
  2. Total Number of Allocated land in

Acres of removed from Timber

Production. (Reference page 136,

Table 3, Appendix B)                                                                                                              1,907,010        (62.6%)

  1. Remainder of acreage to be determined                                                                                     1,138,955         (38.2%)


(Percentages all based upon totality of CGNF lands.)

The breakdown of “C”: Remainder of acreage to be determined


  1. Backcountry Area acres                                                                     208,959      (  6.9%)
  2. Recreation Emphasis Area acres                                                      224,608      (  7.4%)
  3. Stillwater Complex acres                                                                   101,832       (  3.3%)
  4. Forested acres unsuitable for timber production but where timber harvest is suitable for other purposes; percent Custer Gallatin National Forest                                                                                     614,349      (20.2%)

                        Total                                                                                          1,149,748        (37.8%)


Totals don’t quite add up as some designations can overlap, with the same land allocated twice.


Notice, if you calculate the additional wilderness lands found in Alternative F, the FS is only recommending an additional increase of wilderness lands by 4.1%.


The Problem with Timber Production is Climate Change: Our problem is not necessarily with the amount of acreage set aside for timber production, but that it is occurring at all. On page 77 of the Final Plan, there is this statement.


“Timber production and harvest contribute to ecological sustainability and ecological integrity while contributing to economic sustainability, providing jobs, and income to local economies.”


We understand the need to satisfy the timber industry’s appetite in logging. But we also have to understand the science, the economics and the societal value in maintaining it in the 21st century. GWA disagrees with the premise that timber production and harvesting actually contributes to ecological sustainability and ecological integrity. Where is the science proving or stating that argument?


The FS states that all timber production and harvesting is done on sustainable lands, but those lands are changing in Montana due to climate change. A topic not addressed in this section. It should be as all parts of our environment are related. Even on unstainable lands, timber harvesting is not being ruled out as stated here on page 79 of the Final Plan.


“On lands not classified as suitable for timber production, regularly scheduled timber harvest should not occur and timber harvest should only be used as a tool to assist in achieving or maintaining one or more applicable desired conditions or objectives of the plan in order to protect other multiple-use values, and for salvage, sanitation, or public health or safety. Examples of using timber harvest to protect other multiple use values may include improving wildlife or fish habitat, thinning to reduce fire risk, or restoring meadow or savanna ecosystems where trees have invaded.”


Climate change has and will reduce the likelihood of sustainability. The science is clear that there will be ecological change across the west. Seedling regeneration will be increasingly difficult and unlikely at the warmest and driest margins of forests - low elevation / low-tree line forests will not regenerate at lower level elevations, and forest composition will change. We can't continue to log like this is 1899 or 1949. There will be more said on this and we invite the public to review GWA's previous comments from back in June 3, 2019.  



Connectivity: In the draft EIS and draft revision forest plan, alternatives B, C, and D had set aside areas known as “key linkage areas”. Fortunately, that premise along with the “set aside” of Forest Service lands remained and were carried over into the Final Plan. On page 30 of the Final Environmental Impact Statement, “key linkage areas” with the following language is stated below. 


In addition to forestwide plan components that address connectivity, key linkage areas with associated plan components would be included in the northern end of the Gallatin Mountains and in the western and southern Bridger Mountains. In key linkage areas, mountain biking would be suitable only on approved system mountain biking routes.”


These key linkage areas, one known as the Bridger Key Linkage Area and the other known as the Gallatin Key Linkage Area are shown on map files fseprd760100.pdf and fseprd760103.pdf respectively. While we applaud the idea of trying to enhance wildlife connectivity, we feel the current geographic layout of land use designations and the management of those designations will not have the efficacy desired or expected.


Nearly half of the Gallatin Key Linkage Area contains the Bozeman Creek Watershed, of which lies the Bozeman Municipal Watershed Fuel Reduction Project, a proposal between the CGNF and the City of Bozeman. Hyalite Recreation Emphasis Area lies to the west and the West Pine Backcountry Area to the east, all of which allow recreation, potential vegetation treatments and intrusions of man. We are fighting for the right of wildlife to make that outward connection to the north. 


On top of that issue, here is another. On page 53 of the Final Plan under Desired Conditions, Desired Condition #7 states this proposition.


“In key linkage areas, human disturbance does not limit habitat connectivity for wildlife, particularly wide-ranging species.”


With this premise, we don’t hold much hope for success of wildlife connectivity. While it may be true that not all species are sensitive to human activity, many are; such as grizzly bear, wolverine, lynx and moose to name a few. We find this attitude objectionable and one that undermines the goal of future connectivity of species naturally occurring on a large landscape.


We did observe language on two other occasions that give us pause. On page 54 under Guidelines, there is this statement. We are not sure what this means. Why is there a possibility of having new recreation developments within a “key linkage area”?


“New recreation developments may be constructed to address on-going or imminent ecological resource concerns within the key linkage area, including but not limited to, degradation of wildlife habitat connectivity.”



And then there is this quote on page 55, under Suitability 01;


Key linkage areas are suitable for mountain biking only on approved system mountain biking routes.”


With the reality on the ground according to maps drawn and designation of lands, with the series of quotes above; we are very disillusioned concerning the likelihood of wildlife connectivity ever being established in any meaningful way through this corridor.


Species of Conservation Concern: GWA has been pushing for an expanded listing of species of conservation concern for some time. We feel the current list of three species; the Western Pearlshell, Greater Sage Grouse and the White-tailed Prairie Dog are not fully representative of the species on the Custer Gallatin National Forest that face critical risk. The definition as it now stands of Species of Conservation Concern is the following.


“A species, other than federally recognized threatened, endangered, proposed, or candidate species, that is known to occur in the plan area and for which the regional forester forester has determined that the best available scientific information indicates substantial concern about the species’ capability to persist over the long-term in the plan area (36 Code of Federal Regulations 219.9(c)).”


In her June 30, 2020 letter, Leanne Marten Regional Forester for Region 1 added one more species of conservation concern to that list, that being the Western Cutthroat Trout. While we applaud this inclusion, we still feel that this no way represents the reality on the ground of those species that face critical losses in the upcoming future.


On page 30 of GWA’s original comments, we specifically state that we support the inclusion of bison, bighorn sheep, wolverine, moose and the swift fox as species that should also be considered and included on the list of SCC. We have the science in our comments to back those comments. We certainly object to the CGNF actions of not including these species. We have no way of knowing how seriously each of these were considered.


At the same time, in a June 30, 2020 letter from Leanne Marten, she states this about the inclusion of bison.


“I would also like to acknowledge the high level of public interest regarding management of bison on the Custer Gallatin National Forest. Although bison do not meet the criteria for species of conservation concern on the Forest, I appreciate how the plan recognizes that bison are of great importance to local, regional, and national visitors and the tribes.”


We disagree and object to this final decision. While we appreciate the acknowledgement of the public’s willingness to see bison on the public landscape, we disagree with the decision. Our position is that bison do not occur on the landscape to the degree necessary without being endanger of being shot.


If anything, we believe that the determination of species of conservation concern is inconsistent and highly subjective.


Habitat Fragmentation: This issue could easily be discussed under the topic of connectivity as they are intertwined and so closely related, but perhaps separating them might double the attention they both deserve. In the 2020 Final Plan, the phrase “habitat fragmentation” is used only 3 times, two of those in reference to sage grouse habitat and once referring to grassland and sagebrush community habitats which is also sage grouse habitat. Why is that? Habitat fragmentation occurs nearly in all species. We can’t think of one species that would not suffer from these effects. 


In GWA’s original comments, this was one of our critical concerns in regard to grizzly bears, big horn sheep and other species. Nearly all species requiring a large open landscape has, is and will suffer from habitat fragmentation.


One reason for GWA’s high concern over this issue is the fact that it is happening all the time over time. The integrity of our forests is being mutilated like our body would receive a thousand cuts. Likewise, our forest will become so dissected and fragmentated that the forest will lose it integrity, its biodiversity and its ability to function as an intact ecosystem. Every time there is a grazing allotment here, or a roadway or trail there, or a timber cut here or a fence line there, etc., etc., the forests loses its integrity and its character. As this is happening, wildlife connectivity becomes harder and harder to achieve. This is what’s happening on the Custer Gallatin National Forest. 


Wilderness is the best, most protective way to keep this integrity intact, to keep it whole and to preserve the wildness that exists. Alternative F, CGNF’s preferred plan, has just instilled the potential of a thousand cuts. Between the prescribed implementation of Recreation Emphasis areas, Backcountry Areas, timber harvesting, vegetative treatments and the allowances of uses in which are not conducive to Key Linkage Areas, the CGNF is in greater danger than ever before of losing its wild character and its integrity.


Between the lands that have been set aside for Recreation Emphasis Areas, Backcountry Areas, and forested lands suitable for timber harvesting, we are talking about nearly or over 1,000.000 acres of land that has the potential of being cut up fragmenting wildlife habitat and their connectivity!


Grizzly bears: Topics such as connectivity, habitat fragmentation, and the amount and location of wilderness are as relatable and connected as life itself. Grizzly bears and other wildlife species are part of that connection. One thing we know is that grizzlies and many other species are highly sensitive to actions of and by man. Outside of wilderness, there are no other land-use designations that can preserve the integrity and biodiversity of an intact ecosystem.


Alternative F, the preferred alternative, has removed thousands of acres of potential wilderness as prescribed in Alternative D, the alternative favored by GWA. The Buffalo Horn Backcountry Area and the Lionhead Backcountry Area need to be restored as part of the totality of wilderness. The former, the Buffalo Horn, was already included as part of the Hyalite Porcupine Buffalo Horn Wilderness Study Area ever since 1977. Did we have more sense then than we do now?


The Taylor Hilgard, Cabin Creek South, Cabin Creek North, Lionhead and the Buck Creek Recommended Wilderness Areas also need to be restored. The reason for us making that claim is because all of these areas are part of the Grizzly Bear Recovery Zone (GBRZ). Even the Key Linkage area specified as the Gallatin Key Linkage Area and the Bridger Key Linkage Area have the potential of being fragmented. This concerns us greatly. On page 159 of the Final Plan, there is this statement.


“The Bridger Mountains play an important role for wildlife connectivity, especially for wide-ranging dispersing species like grizzly bears.”


All of these current designations proposed in Alternative F as Backcountry Areas or Key Linkage Areas allow some sort of potential disturbance. This is even more true in the area designated as the Hebgen Lakeshore Recreation Emphasis Area. All of these areas serve as a problem for the Grizzly bear. All these areas will make allowances to use trails for motorized and mechanized use more likely and thus, more fragmented. This should not occur in the GBRZ. We recognize it is already true within this zone that so many acres contain these actions and so much more, but we strongly believe that we should not be increasing the likelihood or condone actions within the GBRZ that makes grizzly bear recovery even less likely. Even in the FEIS on page 403 says this.


“The basic premise of the conservation strategy is that habitat conditions inside the grizzly bear recovery zone should be maintained or improved relative to secure habitat levels, number and capacity of developed sites, and acres of permitted livestock grazing on public lands. Since the conservation strategy was first formally adopted into forest management plans in 2006, public visitation on federal lands in the Greater Yellowstone Ecosystem has increased dramatically. In Yellowstone National Park alone, annual visitor numbers increased by more than 40 percent from 2008 to 2018, surpassing 4 million visitors annually since 2016.”


So how is taking these designated wilderness lands from Alt. D going to improve the habitat of within the GBRZ? We feel wilderness is the best protection for the grizzly bear and should be part of the GBRZ. We strongly recommend the Final Plan must adhere and implement the totality of the Grizzly Bear Conservation Strategy. Part of our rationale comes down to once again habitat fragmentation. In a report brought to the attention of the Interagency Grizzly Bear Committee, was this statement.


"In 2018, U.S. Fish and Wildlife Service grizzly bear coordinator, Hillary Cooley told the Interagency Grizzly Bear Committee that conflict with humans is the main cause of grizzly bear mortality, accounting for 85% of known deaths in the GYE and the GYE and 91% in the Northern Continental Divide Ecosystem"


One reason for this high human causality of grizzly bear deaths is because of habitat fragmentation.


Bison:  For years there has seemed to be an actual bias against bison in the west with a policy based upon discrimination. Much of this was and still is based upon fear and unscientific beliefs held by thos who are trying to protect their livelihoods, the cattle industry. There has been some progress over the years as GWA and many other groups have been trying to get bison (free-roaming bison) on the natural landscape. The lands of the CGNF are key in this cause as bison of Yellowstone National Park want to search out lower elevation lands for their winter range. That has been the rub. Many of them trying to do so have either been hazed back or killed during tribal hunts, not allowing bison to make it to the ready-made habitat which exists on the CGNF lands.


The Final Plan and the FEIS both state encouraging words on bison and the hope that they will expand their range into the future. On page 58, under Desired Conditions, in the Final Plan, it states this:


“Bison are present year-round with enough numbers and adequate distribution to support a self-sustaining population on the Custer Gallatin National Forest in conjunction with bison herds in Yellowstone National Park.”


We at GWA do not believe that this is true. The habitat is there, but in reality, the numbers are not. Here again is where it appears that the actual plan and the environmental impact statement are not in agreement. In the FEIS, on page 541, there is this statement.


“Bison presence is currently limited to relatively small areas on the Custer Gallatin, primarily located within state-identified bison management zones west of Yellowstone Park in the Madison, Henrys Lake, and Gallatin Mountains Geographic Area and north of the park in the Madison, Henrys Lake, and Gallatin Mountains and Absaroka Beartooth Mountains geographic areas. There is suitable habitat for bison outside these management zones, and bison occasionally wander, but not far, outside the zones.”


Due to the relatively small number of bison occurring on the landscape outside Yellowstone National Park (YNP), GWA as well as many other groups have been trying to get our National Mammal declared as a species of conservation concern based upon trying to preserve the purity and genetics of the bison. GWA in their comments submitted to the Draft Plan said this on page 48.


“If there ever was an example of discrimination being practiced against a native species, this is it. As a result, free-roaming bison are not found on the CGNF landscape in any significant numbers. The few that are present only do so as they migrate out of YNP to reach winter feeding grounds and many of these end up getting killed. In reality, there is this fact about bison as presented by (Sanderson, E.W., et al. 2008)40


“Although more than 500,000 bison exist in North America today, we estimated they occupy <1% of their historical range and in no place express the full range of ecological and social values of previous times.”


With this fact and other scientific evidence, GWA fully believes that bison should be considered as a species of conservation concern. Leanne Marten, the Regional Forester, claimed in her letter of June 30, 2020 this statement.


“I would also like to acknowledge the high level of public interest regarding management of bison on the Custer Gallatin National Forest. Although bison do not meet the criteria for species of conservation concern on the Forest, I appreciate how the plan recognizes that bison are of great importance to local, regional, and national visitors and the tribes.”


They need to define bison migrations based upon bison habitat rather than man-made migration zones they established as the key here is free-roaming bison. We do not have that at this time.


And bison are not fully protected without being considered a species of conservation concern. It is the genetics that we are making this case. 


Bighorn Sheep: GWA’s concern over bighorn sheep was and is many fold. On page 57 of the Final Plan, there is this statement.


“Disease transmission from domestic animals, particularly domestic sheep and goats, is considered a primary threat to bighorn sheep populations. At the time this plan was written, there were no permitted grazing allotments on the Custer Gallatin stocked with domestic sheep or goats.”


While it is true there are currently no existing grazing allotments of domestic sheep in the Custer Gallatin National Forest, there are plans to use goats and sheep for weed control depending upon risk assessments. GWA had pages in our original comments as to why bighorn sheep are still at risk on the CGNF. Here is one excerpt from our argument.


“Even though “there are currently no sheep or goat-grazing allotments on the national forest(page 374 of the DEIS), that does not mean there are no threats of disease to bighorn sheep. In fact, just the opposite is true. In a paper entitled, “Modeling Risk of Pneumonia Epizootics in Bighorn Sheep”, published in The Journal of Wildlife Management, (Sells, S.N., et al. 2015)62; there is this distressing statement:


“This paper suggests the Upper Yellowstone and Hilgard bighorn sheep herds on the Custer Gallatin National Forest have an 80% and 85% chance, respectively, of a disease epizootic within 10 years of 2012 if levels of risk factors remain unchanged.


Risk of disease epizootic is estimated for each one of the 42 bighorn herds in Montana.””


You place that evidence with the usual suspects of wildlife threats such as:


1.disease-carrying domestic sheep and goats,

2.conifer encroachment,

3.noxious weeds,

4.human disturbance, and

5.habitat fragmentation from human development. 


GWA has been trying to get the Forest Service to consider Bighorn Sheep as a Species of Conservation Concern. Again in our original comments in June of 2019, we had this statement as to one of our demands.


GWA wants a full explanation as to how the final assessment of species for SCC was made and what criteria were used to disqualify those species not chosen.


GWA has not been given the respect of a response. Finally, there is this comment again from our original comments.


“Prior to this, the U.S. Forest Service used a list of “sensitive species” for identifying imperiled wildlife. GWA will refer back to a document submitted during the last comment period, a document by the U.S. Forest Service dated October of 2012 entitled Wilderness Character Monitoring Report Hyalite Porcupine Buffalo Horn Wilderness Study Area (Clark, Erin; Schlenker, Kimberly; Filardi, Catherine, 2012)17. On page 20, they define species of concern based upon 2011 baseline:


“In 2011, one new sensitive species was recognized for the region: bighorn sheep (Ovis canadensis). This brings the total to 31 known indigenous species that are listed as threatened, endangered, sensitive, or species of concern known or assumed to utilize habitat within the HPBH WSA, or, in the case of plants, known or suspected to be established on the Gallatin National Forest.”


Bald eagle

Bighorn sheep

Black-Back woodpecker

Canadian Lynx

Gray wolf

Grizzly bear

Peregrine falcon

Western big-eared bat



There is so much more science that we have provided in our original comments and that we could provide here, but this is just a few talking points of why we strongly object to the lack of attention to addressing the population decline of bighorn sheep.



Moose: Another species in poor-related health that GWA raised during our original comments is that of moose on the CGNF. In fact, GWA had sent in two addendums after the original deadline over this issue as new facts and science came to our attention. We complained in our original comments that moose were only mentioned once in the Draft Revision Plan. In this 2020 Final Plan, moose is only mentioned 5 times and those were mentioned mainly in topical headings, or of no consequence. This is unacceptable. It is better as we peruse the FEIS. But here they admit on page 187 this statement.


“and moose populations are declining in some areas.”


On page 524, there is this statement.


“With the exception of moose, these big game populations on the Custer Gallatin National Forest have generally increased in number and distribution since the original forest management plans were finalized in the mid-1980s.”


On page 525.


“With the exception of moose, these big game populations on the Custer Gallatin National Forest have generally increased in number and distribution since the original forest management plans were finalized in the mid-1980s.”


Finally, on page 526, there is this.


“Possible explanations for moose population declines include hunter harvest, increased predation, vegetation changes due to large-scale disturbances and natural succession, disease, parasite loads, and climate change (DeCesare et al. 2014).”


And there it is, there is the first mention of the threats and stressors that are affecting populations of moose. But the 2020 Final Plan doesn’t address the potential threat looming over the population or what the Forest Service intends to do to mitigate the issue. GWA again believes that this species deserves to be placed on the list of Species of Conservation Concern. And we object to the fact that the Forest Service is not listening to the science as it is.


As listed, climate change is one of the threats to moose populations forcing the larger issue to be considered among GWA membership. We feel that the Forest Service is not taking the decline in moose populations seriously enough. The FEIS honestly states the condition on the ground, but we feel the actual 2020 Forest Plan does not. GWA has presented several types of science and research in our original comments that we will draw upon to place an objection on the lack of consideration of moose as a species of conservation concern.



Climate Change, Carbon Sequestration, Forest Health and the Watershed: All of these facets of our environmental world are directly and indirectly related in simple and complicated ways. But because of that preordained relationship, it is these first three that will determine the quality of the watershed.


Our Watershed:

The final end product, our watersheds, reflect the workings of what has gone on before. With that said, we found this statement in the Final Environmental Impact Statement on page 119.



“Overall, alternative D would provide the greatest ecological benefit to aquatic species habitat, riparian areas, and watersheds.”


“Plan objectives that improve ecological conditions for aquatic species habitat, riparian areas, and watersheds are highest in alternative D and lowest in alternative E. Alternative D would move toward the watershed, aquatic, and riparian desired conditions faster than the other alternatives, and alternative E would move toward the watershed, aquatic, and riparian desired conditions slower than the other alternatives.”


This is of no surprise, of course, for it is one of the reasons GWA had preferred Alternative D in the beginning. Obviously, there are other considerations to be taken into account when the FS considers a Forest Plan, considerations other than just the quality of the watershed. But let’s face it; the protection of our watersheds is one of the reasons the Forest Reserve concept came into existence to begin with in the 1890s, even before the Forest Service was established.


And then there is this paragraph (divided into three here) found on page 111 in the FEIS under the title of “Effects of Land Allocations for Recommended Wilderness, Backcountry Areas, and Eligible Wild and Scenic Rivers”.



Many watersheds in the Absaroka Beartooth; Madison, Henrys Lake, and Gallatin Mountains; and Bridger, Bangtail, and Crazy Mountain geographic areas that support the healthiest populations of native trout and other aquatic species, currently have their headwaters protected through lands managed as Congressionally designated wilderness areas (Lee Metcalf and Absaroka Beartooth) or inventoried roadless areas.


These areas are the building blocks of a conservation network. Naturally functioning headwaters have a large influence on the function of downstream reaches (Vannote et al. 1980, Meyer et al. 2007) and would be particularly important as refuge habitat for cutthroat trout, and other species, in light of potential effects of climate change (Isaak et al. 2015).


The best remaining trout habitat conditions are found in wilderness and unroaded landscapes (Rhodes et al. 1994, Kershner et al. 1997). Across the west, roadless areas tend to contain many of the healthiest of the few remaining populations of native trout, and these are crucial to protect (Kessler et al. 2001). Roadless areas are a source of high-quality water essential to the protection and restoration of native trout. The high-quality habitats in roadless areas help native trout compete with non-native trout because degraded habitats can provide non-natives with a competitive advantage (Behnke 1992). Roadless areas tend to have the lowest degree of invasion of non-native salmonids (Huntington et al. 1996).” 


Alternative D was not chosen by the Forest Service and because of that, GWA believes that the CGNF watershed is poorer for it. The quality of a watersheds streams and waters are an indication of the quality of the watershed. The more impact from man, no matter what the source, will degrade the quality of the watershed and thus the quality of the watershed’s waters.


Of course, our watershed will not only be impacted by climate change but by further intrusions of man whether it be recreational, timber harvesting, road construction or grazing. All of these activities will have an impact on soil compaction, erosion, invasive weeds, and on and on. In our previous and original comments, GWA submitted a lengthy comment on the impact all of these actions will have on our watersheds. None of them are to be taken lightly.


GWA will provide a new piece of scientific research here from the U.S. Forest Service Rocky Mountain Research Station in Moscow, Idaho, there is this table and conclusion.


Reference provided here.


Elliot, J. William, Page-Dumroese, Deborah, Robichaud, Peter R, The Effects of Forest Management on Erosion and Soil Productivity, U.S. Forest Service RMRS, Moscow, Idaho.





TABLE 12.1
Typical Effects of Forest Disturbances on Productivity



Productivity response


Area removed from production

Up to 30% of forest area losta


Organic matter loss
Disease reduction

Long-term effects not measured; observed loss of organic matter leading to growth reduction from water and nutrient stressb


Reduced water availability and increased runoff

Height reduction of 50%c or more
Volume reduction up to 75%d

Tree harvest

Loss of organic matter and site disturbance

Up to 50% reduction if site is severely compactede

a Megahan and Kidd, 1972.
b Harvey et al., 1979.
c Reisinger et al., 1988.
d Froehlich, 1978.
e Amaranthus et al., 1996.


The first paragraph of the stated Conclusions states the following.



All these actions that will be talked about here will affect the quality of our watershed and forest health. They are intertwined.


Ecological Integrity:

One of the concerns and goals that GWA is striving for on the CGNF is to protect the ecological integrity which the forests currently possesses. Of course, one way to maintain that integrity is to hold on to inventoried roadless and wilderness areas when possible. It is that integrity that helps determine a forest’s health. On page 165 of the FEIS under the title of Ecological Integrity, there is this statement.


“Assumes that ecological systems that retain their native species and natural processes are more resistant and resilient to natural and anthropogenic stresses over time (including climate change).”


“Ecological integrity has emerged as a key component of ecological restoration and adaptation to climate change (Suding et al. 2015) and a useful framework to guide management of terrestrial ecosystems (Carter et al. 2019).”


This highlights our position. In order to mitigate the climate change affects upon our forests, we need to maintain the forests ecological integrity. An example of our concern can be found in the quote below, on page 119 of the FEIS. As this statement refers to problems pertaining to two species of conservation concern, GWA wonders why this explanation is not used for other species that may be considered in that regard. A stressor such as climate change will affect all other species if it hasn’t already. If the Forest Service is concerned about climate change reaching beyond their authority to manage, why not maintain the ecological integrity as much as possible?


“Due to the small size of the populations and their limited habitat on the Custer Gallatin the Westslope cutthroat trout and the western pearlshell mussel are vulnerable to stressors beyond the authority of the Forest Service to manage; most notably the risk of non-native trout and climate change effects. In this case, the plan must provide direction that will contribute to maintaining long term persistence of the species within their range.”



Along the same lines, when you talk about biological integrity, you are also referring to the biological diversity of the ecological system. You’re most likely not going to have one without the other. With that there is this statement found in page 106 of the FEIS.


“As climate change continues to increase air and water temperature, western pearlshell and westslope cutthroat trout would be negatively affected because increased temperatures would also limit the extent of the temperature sensitive westslope cutthroat trout thereby even further limiting the extent of the western pearlshell.”


This kind of logic can and should be applied to other species on the forest. Which is why GWA has asked for additional species of conservation concern to be considered and acted upon favorably.


The acknowledgement of Climate Change:

These following passages from the FEIS are simply stated here to showcase the point that the Forest Service is acknowledging the future effects of climate change upon the forest. Passage found on page 140 in section 3.5.3 Environmental Consequences – Effects Common to All Alternatives.



“Conservative future climate scenario models predict that the effects of warming trends result in a lengthened growing season, decreased number of days with snow on the ground, earlier peak snow occurrence, and increased water stress for all sites in the study, which represent temperature and precipitation spectrum in the forests of the Rocky Mountain Region (Boisvenue and Running 2010). Mountain ecosystems can shift upslope, reducing habitat for many subalpine and alpine tundra species. Mountain tree line is predicted to rise by roughly 350 feet for every degree Fahrenheit of warming (Environmental Protection U.S. Environmental Protection Agency 1997).



And then there is this found on page 167, Climate Change Considerations and Assumptions:


“In addition, to better understand the effects of climate change at a more local scale, the Custer Gallatin Plan Revision Team collaborated in a series of workshops with a diverse team of scientists and land managers from universities, government agencies and non-governmental agencies to specifically review and assess the revised plan’s approach to climate change. The results of this effort are discussed in more detail below and are also available at Hansen et al. (2018).” 



This is the admission that the Custer Gallatin Plan Revision Team has had training and scientific presentations to the effects of climate change. The question is: was this science biased? The litany of passages from the FEIS stated below appears to be a reasonable presentation of what most scientist would expect from climate change. GWA’s position is the science presented here seems to dictate a more active participation in mitigating these effects than what the actual 2020 Final Plan indicates.



Page 60 - Effects Common to all Alternatives


“Climate change would likely increase smoke emissions for each alternative. Higher temperatures are anticipated to result in decreased snowpack, earlier springtime snow melt, and longer fire seasons would increase the frequency and area burned by wildfires.”



Page 167 - Climate Change Considerations and Assumptions


“Climate change is expected to continue and have profound effects on the Earth’s ecosystems in the coming decades (IPCC 2007). Description and analysis of these effects relied on a broad array of recent scientific literature and in particular a recent meta-analysis of climate change and potential effects published for the Northern Region Adaptation Partnership (Halofsky et al. 2018c;a).”


Page 172 –


“While there is high uncertainty in projections of future climate and vegetation response, there is high agreement that some trends are likely, and these should be considered by management.”


Page 179 –


“Climate strongly influences fire regimes. Historically, extended periods of warm and/or dry conditions tended to be associated with larger, higher severity, and more widespread fires. Shade intolerant, fire resistant species may still have developed into mid and late successional stages where low severity regimes were maintained; as did shade tolerant species in areas spared from fire. Periods of cool or moist climatic conditions tended to be associated with smaller and less severe fires.”


Page 216 –


“The potential effects on intermittent stream ecologies from these aspects of climate change could decrease runoff with more perennial streams becoming intermittent streams, losing hydrologic connectivity and reducing habitat for species dependent on perennial flow.”



Page 289 –


“The effect may be due to direct climate-related factors, such as increased temperature and greater drying of forest fuels; or indirectly, related to potential changes in forest composition and structure due partly to climate change. These climate-induced changes in fire regimes could have substantial impacts on ecosystems, with associated effects to communities and economies (Littell et al. 2009b).”



All of these statements are profound in their own right and alarming as well. To think our forests are in danger of drastic change, to the point that we may not recognize them as we do now is perhaps life altering for some, simply just mind boggling for others and no doubt, some are in a state of denial. But we ask that Forest Service officials, other wildlife and land-management agencies, political leaders of the county, state and country to think of how all these climate change effects will impact wildlife. This should be the alarm.


Timber Harvesting and Forest Health:

Perhaps the following paragraph indicates the disconnect between the Forest Service’s rationale in their philosophy of timber management and forest health and the science which states some caution should be the guiding rule. This paragraph is found on page 304 of the FEIS.



“In general, management activities (such as timber harvest) would initially directly reduce carbon stocks on the national forest, though minimally. However, this initial effect would be mitigated or even reversed with time, reducing the potential for negative indirect and cumulative effects. These short-term losses and emissions are small relative to both the total carbon stocks on the forest and national and global emissions. Further, the proposed activities would generally maintain and improve forest health and supply wood for forest products, thus having positive indirect effects on carbon storage. The Custer Gallatin National Forest will continue to be managed to maintain forests as forests and the many ecosystem services and co-benefits the forests provide, including carbon uptake and storage. The following management strategies are available under all alternatives and influence carbon uptake and storage potential:”


This explanation seems to minimize or rationalize the negative effects of timber harvesting and forest health projects. Yet, the FEIS has laid out in fairly explicit terms some of the environmental damage which has already done and what is potentially yet to come. In addition, GWA has provided science in our original comments back in June of 2019 that contradicts this minimalization. As long as there is this attempt to accentuate the positive (as one-sided as it may be) of timber harvesting and forest health projects and ignore the science which counters those claims, we don’t see much progress being made in the attempts to counter climate change. For there will always be the impetus for timber harvesting and production. 


Then there is also this statement found toward the bottom of page 304.


“Decrease forest densities and fuel conditions to reduce the risk of large, stand-replacing disturbance from insect, disease, and fire. Although this strategy initially reduces carbon stocks, it can lower risk for greater carbon stock losses and emissions in the future (Wiedinmyer and Hurteau 2010).


This statement is also making the claim that it is better to do these treatments now rather than later because in the long run, over time, there will be greater reward in terms of carbon sequestration. The trouble is these policies are based upon some assumptions of the future and ignoring the realities of the present.


First, Climate change is a problem now. It will be in the future as well, but it is a problem now and if we are serious in mitigating climate change before the agency becomes (as the Forest Service claims) vulnerable to stressors beyond the authority of the Forest Service to manage; we should act now; not kick the can down the road.


Second, there will always be the push for more logging, whether it be for harvesting or for production. When is a good time to make a change? By reacting later than now, we are just pushing the problem for future generations.


Basically, what GWA is asking for is a change in the Forest Service’s premise; a change in the agencies’ philosophy. We know this will be a hard sell, but one that is needed in order for there to be a positive change in the management of the resource and for the health of the planet.


GWA makes this statement.


"If concerned citizens are wondering why there seems to be this disconnect between what the Forest Service does and what they say (Jin terms of climate change and the need for timber harvesting); I think that can be explained by excerpts from their own FEIS......The Forest Service is using their own science that allows them to rationalize their desired and traditional actions. Needless to say, these are different than the sources we rely upon. Their sources provide cover to the policies they proclaim."


We believe the following sentence best explains the Forest Service's position, a position found on page 304 in the FEIS.


“This approach to management of forests for purposes of contributing to climate change mitigation is supported by a number of scientific sources (Ruddell et al. 2006, Hurteau et al. 2008, Reinhardt and Holsinger 2010, Ryan et al. 2010, Wiedinmyer and Hurteau 2010, North and Hurteau 2011, Schaedel et al. 2017).”


They continue this line of thought on page 307 in the FEIS.


“Plan components in the action alternatives are designed to provide for ecological integrity and resiliency to disturbances. Potential negative effects may be mitigated and completely reversed with time as the forests regrow. Over the longer term, the activities allowed by the plan are likely to increase carbon storage and reduce emissions, by reducing disturbance risk and storing carbon in wood products. The management mechanisms applied in all plan alternatives are consistent with internationally recognized climate change adaptation and mitigation practices identified by the IPCC (Intergovernmental Panel on Climate Change 2007b).”


One More Thing:

GWA has presented many sources of scientific research on the subjects of climate change and carbon sequestration in our original comments. But we would like to add one more here and showcase an article captured in the Proceedings of the National Academy of Sciences (PNAS). The article published in the May 2, 2017, Vol. 114, no.18 edition entitled “Adapt to more wildfire in western North American forests as climate changes” by Schoennagel, Tania. Et al; tells us that we need to change our premise, change our paradigm when it comes to wildfires. A couple of passages from the article. 


Page 4583:


“Our key message is that wildfire policy and management require a new paradigm that hinges on the critical need to adapt to inevitably more fire in the West in the coming decades. Policy and management approaches to wildfire have focused primarily on resisting wildfire through fire suppression and on protecting forests through fuels reduction on federal lands. However, these approaches alone are inadequate to rectify past management practices or to address a new era of heightened wildfire activity in the West (1114).”


Page 4584:


“A paradigm shift now in approaches to WUI development and management of fire and fuels can yield tremendous benefits to society later.”


Page 4586:


“Managing forest fuels is often invoked in policy discussions as a means of minimizing the growing threat of wildfire to ecosystems and WUI communities across the West. However, the effectiveness of this approach at broad scales is limited. Mechanical fuels treatments on US federal lands over the last 15 y (2001–2015) totaled almost 7 million ha (Forests and Rangelands, https://www.forestsandrangelands.gov/), but the annual area burned has continued to set records. Regionally, the area treated has little relationship to trends in the area burned, which is influenced primarily by patterns of drought and warming (2, 3, 20).”


“Therefore, roughly 1% of US Forest Service forest treatments experience wildfire each year, on average. The effectiveness of forest treatments lasts about 10–20 y (75), suggesting that most treatments have little influence on wildfire.”


These statements highlight the need for the Forest Service to take a second look at how they and society view wildfires. Science is proving that perhaps there are alternatives in how land-use management agencies apply wildfire science on public land. The answer may not be the traditional application of those applied over the last century. 


Carbon Sequestration:

The FEIS, the heart and soul of the 2020 Final Forest Plan, mentions the climate-related topic of carbon sequestration 19 times out of a 594-page report. The term is only mentioned 5 times in the actual 2020 Forest Plan. In the Introduction of Section 3.8 on page 298 entitled Carbon Storage and Sequestration, the Forest Service makes this statement.


“The Forest Service recognizes the vital role that our nation’s forests and grasslands play in carbon sequestration. Accordingly, carbon storage and associated climate regulation has been identified as a key ecosystem service provided by the Custer Gallatin.”


Then in the paragraph below, there is this claim.


“Carbon sequestration is one way to mitigate greenhouse gas emissions by offsetting losses through capture and storage of carbon. The relationship between climate change and other resources is addressed throughout this analysis. In the context of global atmospheric carbon dioxide (CO2), even the maximum potential forest management levels described by the plan alternatives would have a negligible effect on global emissions and climate.”


It is interesting that the Forest Service is making the argument that whether the action be from fire and fuels management or from timber management, the effects on carbon sequestration would be minimal.  


On page 306 under the section “Effects from Fire and Fuels Management in the FEIS, there is this statement.



“Fire, (both natural and human ignitions) pose the greatest potential for short-term reductions in carbon sequestration by removing vegetation as well as causing carbon emissions. However, fire is also a primary mechanism for restoring and maintaining native vegetation with conditions consistent with the natural range of variation, thereby contributing to carbon sequestration potential over the long term.


On page 306, under “Effects from Timber Management”


“Plan components for timber management would allow for the short-term, localized reduction of carbon sequestration through the removal of living vegetation. The magnitude of this is greatest in alternative E and least in alternative D, but the difference between alternatives relative to effects on carbon is negligible.”


The Forest Service is basically saying that no matter what the alternative chosen for the CGNF, the effects of carbon sequestration upon the global climate is negligible. Perhaps this can best be reflected within the Conclusions on page 307 in the FEIS. 


“A large body of science agrees that future climate conditions will include increasing average annual temperatures over the coming decades, which will have impacts to natural resources.”


“Potential negative effects may be mitigated and completely reversed with time as the forests regrow. Over the longer term, the activities allowed by the plan are likely to increase carbon storage and reduce emissions, by reducing disturbance risk and storing carbon in wood products.”


“Carbon stocks on the Custer Gallatin National Forest would likely continue to increase or remain stable under all plan alternatives in the foreseeable future. Natural ecosystem processes, including forest growth (succession) and small-scale disturbances (for example fire, insects, harvests) would continue to influence carbon stocks and emissions, but they are not expected to substantially change current trends in carbon over the span of the plan.”


What the Forest Service is saying is that the best way to mitigate the negative effects of climate change upon the forest is to conduct business as usual and let the forest regrow. This literally changes nothing. The Desired Condition found on page 49 of the 2020 Final Plan basically sums it up best under the Carbon Storage and Sequestration element.


“Carbon storage and sequestration potential is sustained by biologically diverse and resilient forests, woodlands, shrublands, and grasslands that are adapted to natural disturbance processes and changing climates.”


To GWA, this sounds like a plan saying it is business as usual. It seems like the Forest Service is saying the forests are self-mitigating when it comes to carbon sequestration.


But this is not the complete science. GWA has presented several pieces of research in our original comments on this subject and we will mention a few of them here to counter this notion that the Forests will take care of themselves as long as man helps through prescribed burning, fuel reduction projects and timber harvesting or production.


First, we would like to highlight the fact that older trees sequester more carbon than younger growing trees. In a paper by Natural Resources Conservation Service: Alaska Forestry Technical Note 1 dated April 2008, Carbon Sequestration and Forest Land Thinning, there is this statement.


“An important consideration in the carbon sequestration abilities of forest is that forests composed of larger older trees sequester more carbon than younger forests composed of smaller trees, in healthy fully stocked forest stand conditions.”


And then there is this point. From GWA’s previous comments.


“In an article in Earth Island Journal, “Logging Is the Lead Driver of Carbon Emissions from U.S. Forest - If we want to effectively mitigate climate change, it’s time for bold action to protect forestlands.” (Smith, Danna; Hanson, Chad; and Koehler, Matthew, 2019)141 There are these outtakes:”


"But the promotion of logging to supposedly curb carbon emissions is just part of the Administration's ongoing alignment with industry and troubling pattern of climate science denial. Carbon emissions from logging in the US are ten times higher than the combined emissions from wildland fire and tree mortality from native bark beetles. Fire only consumes a minor percentage of forest carbon, while improving availablility  of key nutrients and stimulating rapid forest regeneration. Within a decade after a fire, more carbon has been pulled out of the atmosphere than was emitted. When trees die from drought and native bark beetles, no carbon is consumed or emitted initially, and carbon emissions from decay are extremely small, and slow, while decaying wood helps keeps soils productive, which enhances carbon sequestration capacity over time."


Consider this: About 28 percent of tree carbon is contained in branches, and this is emitted when they are burned after logging operations. An additional 53 percent of the carbon in trees removed from forests is emitted as waste in the manufacturing and milling process. Overall, about two-thirds of the carbon in trees that are logged for lumber quickly become greenhouse gas emissions.”


This is just the beginning, but it shows that there is science available negating the rationale that the Forest Service is employing. 



Other Considerations:

GWA has provided over 163 pages worth of comments during the original draft. Obviously, we cannot replicate all of those comments and concerns here during the Objection process. If time permits, more comments will be provided. Hopefully others will provide assistance.

Print Print | Sitemap
© Gallatin Wildlife Association