CURRENT CONDITION

The Wyoming Game and Fish Department has stated that wildlife in the Bighorns, elk in particular, are forced to private land sanctuaries diminishing hunting quality (more hunters, less wildlife, less money to communities). Timber sales, roads, overgrazing, riparian area erosion and pollution have noticeably impacted the health of elk and elk habitat. For wildlife in general, lack of predators and reduction in biodiversity of plant and wildlife species is creating a homogenous population.

As is well documented by scientists, writers, photographers and forest managers, the Bighorn Mountains are an isolated mountain range and have been isolated physically from other mountain regions for hundreds of thousands of years. Biologically, this situation has created genetically unique wildlife subspecies. Montane vole, American pika, snowshoe hare and least chipmunks have all maintained the Bighorns as their home, and are attributed a genetic uniqueness found only in the Bighorns. They are genetically distinct from the Wind River, Absaroka or Black Hills species by the same name. Even the black bear on the Big Horn Mountains has been found to be only distantly related to black bears on the Tetons and Snowy Ranges (D. McDonald, University of Wyoming, personal communication).

Beauvais (2000) states:

"These forest-adapted mammals (e.g., southern red-backed vole, snowshoe hare, American marten) have a strong affinity to coniferous forest, and because of this affinity, the species in this group are most influenced by forest management. At a regional scale, forest-adapted mammals are the most spatially restricted group of mammals in the Central and Southern Rocky Mountains. Where isolated, forest-adapted mammals occur in smaller populations than farther north and thus likely are subject to a suite of factors that increase the risk of local extinction. These include a loss of genetic variability through inbreeding and genetic drift, two of the main factors in the so-called extinction vortex (Gilpin and Soule 1986, Caughley and Gunn 1996). Other subspecies are restricted to only a few mountain ranges in the region, and truly insular ranges support several endemic subspecies. These include Lepus americanus seclusus, Ochotona princeps obscura, and Tamias minimus confinis in the Big Horn Mountains (Hall 1981)."

"Morphological, behavioral, and genetic analyses confirm the divergence among mountain ranges of populations of red squirrels (Lindsay 1987), Abert's squirrels (Lamb et al. 1997), American pikas (Hafner and Sullivan 1995), and least chipmunks (Sullivan 1985), and suggest that more subspecific designations may be warranted. Indeed, the U.S. Endangered Species Act grants special protection to threatened populations with unique genetic or morphological characters (Pennock and Dimmick 1997), raising the possibility that some small populations of forest-adapted mammals in the region could qualify for statutory protection."

"Species in this group strongly prefer undisturbed forest. Several species (e.g., southern red-backed vole, American marten) prefer forest and avoid dry and open patches, including clearcuts, at both the stand (Table 1) and landscape (Table 3) scales. Some of the same species are most abundant in late-seral stands with large trees and large and abundant coarse woody debris (Table 2). This association with later seral stages also is indicated by a preference for spruce-fir stands (Table 1) and landscapes dominated by spruce-fir (Table 3), because spruce-fir generally reaches a climax condition following pine on mesic sites in the region (Buttrey and Gillam 1984, Johnson and Fryer 1989)."

"We know the distribution of forest-adapted mammals is already fragmented on a regional scale; persistent clearcutting, and possibly road building, threaten to fragment them on a finer scale. In contrast, most open-country and generalist mammals form larger and more contiguous populations, and respond positively to the vegetation changes that accompany clearcutting. At a local scale, replacement of forest-adapted mammals by habitat generalists may not change species richness or diversity, but at a regional scale such replacement essentially makes rare species even rarer and common species more common (Beauvais 1997). Additionally, it may reduce or even eliminate genetically unique populations of forest-adapted mammals. Therefore, the most prudent conservation strategy is to bias management in favor of forest-adapted species" (Beauvais, "Mammal responses to forest fragmentation" 2002.)

Canada lynx, once found in the Bighorn Mountains, is now extinct from this range. Now, if lynx are sited in the Bighorns, they are passing through as spillover from another more northern range, and may end up dead. No breeding pairs have been found in the Bighorns in decades. Management activities have destroyed most of the sub alpine, open country in the Bighorns that lynx prefer. Suitable habitat available in the northern third and the eastern portion of the Forest has been heavily roaded and timbered. Where it still remains roadless, it is too steep for lynx to survive winter's deep snows. Roads and activities have encouraged other predators to dominate the habitat, to the detriment of potential lynx populations returning to the Bighorns.

Yellowstone cutthroat trout on the Big Horn Mountains are of conservation and management concern for three reasons: (1) at a regional scale, Big Horn Mountain populations are now isolated from adjacent populations on the Absaroka front by degraded stream habitats in the intervening lowlands; (2) at a local scale, natural stream barriers have prevented hybridization between some Big Horn Mountain populations (e.g., upper Paint Rock Creek, Deer Creek) and populations of exotic salmonids, resulting in genetically pure cutthroat populations that are critically important to the persistence of the subspecies (Kruse 1998); and (3) recent evidence indicates that most Yellowstone cutthroat populations are genetically pure and are considered as a sensitive species by G&FD and BNF. Some streams on the eastside of the Bighorns contain YCTT that are genetically pure and the populations maintained (Bradshaw, personal communication, 2002).

Years of extractive and destructive management practices have so altered the landscape and pre-settlement conditions of the Bighorns that we stand to lose the very unique species that have fought so hard to evolve into this landscape.

DESIRED CONDITION

The protection of sub alpine forests and lower mountain regions should be a top priority of the Forest Plan Revision. Wildlife refuges should be developed as off-limits to motorized activities, logging and mineral development. The northern third and eastern portion of the Bighorn Mountains should be protected from development and restored as wildlife refuges and wilderness.

Business as usual must stop. The Forest Management Plan should consider the reintroduction of lynx, fisher, river otters, grizzly bears, wolves and bison.

The CCA recommends that potential lynx habitat areas should be identified and protected for restoration of lynx habitat areas. Wilderness recommendation for the Littlehorn Roadless areas would prevent fragmentation, and protect the potential for lynx's return to the Bighorn Mountains.

Management Indicator Species (MIS) monitoring needs to maintain the original species list, and add species that truly determine the health of the habitat. Replacement of the MIS list with species that are "easy" to monitor will not ultimately help determine the health of the Forest. Moreover, protecting the habitat for specialized species should be the Standard for the Bighorn Forest Plan Revision, not merely a Guideline.

Special management plans should be in place for all genetically unique wildlife species to the Bighorns: red-backed vole, montane vole, red squirrel, American pine marten, American pika, and least chipmunks. Priority should be place on protecting native cutthroat trout by making grazing and road use off-limits in critical areas.

The following species are in need of special management and conservation measures (Beauvais 1999 attached as Appendix A; Beauvais 2001 attached as Appendix B):

Columbia spotted frog (Rana lutieventris; Bighorn Mountains population)
Wood frog (Rana sylvatica; Bighorn Mountains population)
Southern red-backed vole (Clethrionomys gapperi; Bighorn Mountains population)
Water vole (Microtus richardsoni; Bighorn Mountains population)
American marten (Martes americana; Bighorn Mountains population)

The CCA sites the following reference in support of the Bighorn National Forest Plan's revision to include strong Standards to protect habitat for the unique wildlife species listed (Beauvais, 2001, appendix attached):

CURRENT CONDITION

Overgrazing is a very big problem on the Bighorn. It has become the norm rather than the exception. The Forest Service's own monitoring reports show violation after violation. The 1990s Monitoring and Evaluation Report stated that 60 of the 90 allotments were out of compliance. The lack of enforcement of the existing Standards & Guidelines has far-reaching negative effects on wildlife, recreation use, and clean water. Livestock are destroying riparian areas and contributing heavily to fecal coliform bacteria concentrations in our domestic water supplies. This raises the cost to make our water useable. The riparian habitats and forage production are critical to many wildlife species.

Excessive grazing has negative impacts on people who visit the Forest. Livestock on the highway poses a public safety issue. Contaminated water can ruin an otherwise pleasant weekend hike. Habitat destruction from overgrazing can diminish the public's enjoyment of wildlife. The impacts on water quality from overgrazing threaten to exterminate a declining cutthroat trout population, upon which many fishermen rely.

DESIRED CONDITION

The CCA recommends:

1. Reducing grazing by 50% in both the number of animals and the time each spends on the Forest;
2. Designating large areas critical to wildlife as off-limits to grazing;
3. Identification of streams suspected of impairment, and prohibition of grazing in those watersheds.
4. The BNF should enforce existing rules and punish violators with reduction in permit privileges.
5. Livestock must be kept away from streams and highways.

CURRENT CONDITION

Travel management has fallen well behind the times. A tremendous increase in motorized ATV's, 4X4's, and mountain bikes has damaged roads and trails, while accelerating off-road impacts. This has also led to a decline in air and water quality. Any "C" areas open in the past have proven impossible to manage, resulting in destruction of land and watershed resources. Unfortunately, lack of enforcement or ignoring the problem has become the norm rather than the exception.

Winter travel has reduced the Bighorn Mountains to a speedway. While impacts from winter snowmobile abuse have not been studied, certainly the associated snow compaction, noise and air pollution pose risks to the environment, as well as to human health and safety. Many wildlife species, such as small mammals, moose and birds, winter in the Bighorns and are affected by heavy snowmobile use. Cross-country ski, snowboard and snowshoe areas have been markedly reduced, leading to user conflicts if these recreation users go outside the few ski-designated areas. Also, lack of enforcement, excessive speed and associated accidents occur regularly in the Bighorns, threatening the safety of all snowmobile users. Local citizen have done some work to provide for trails where dogs accompanying skiers will not conflict with track skiers.

DESIRED CONDITION

Keep motorized use to designated routes, and close areas where motor vehicles disrupt wildlife, damage riparian areas or serve no viable purpose. The Bighorn National Forest must make enforcement of motorized travel a major priority. Unrestricted off-road use destroys vegetation, harasses wildlife and livestock, contributes to stream pollution and disrupts more quiet forms of recreation. The areas on the BNF that currently allow unrestricted off-road use should be closed. All vehicles should be restricted to designated and classified motorized routes. Certain areas should be restricted to non-motorized use. These areas should be large enough to muffle, if not silence, the sound of motorized vehicles and obscure their physical presence. Special permits could be issued for specific needs. For example, single trip permits could be granted to hunters for removal of large game, but unrestricted use must stop.

Unrestricted use allows snowmobiles into some areas where cross-country skiing trails and backcountry snow boarding and skiing try to use. For reasons of safety and enjoyment, designated snowmobile and ski areas should be segregated. More areas that are accessible for handicapped winter use should be provided. Greater and more diverse areas such as open fields, slopes and climbs should be off-limits to snowmobiles, and designated for cross-country ski, snow shoeing and snow boarding recreation. Dogs accompanying skiers should not conflict with track skiers. Solutions to this conflict have emerged on a small scale, but more attention needs to be given to officially designating trails and areas to specific sport users.

CURRENT CONDITION

Logging at historical rates has proven unsustainable on the Bighorns, with 120 years needed to grow marketable size trees. The timber program is not economical with 90% of all timber sales showing a deficit. Too much lodge pole and too few spruce/fir forests characterize the BNF. The removal of trees, especially on the BNF where trees require 200 years to reach maturity, impacts the Forest significantly for at least the next 100 years. The BNF forests will take a century or more to regrow the smallest size tree currently being logged for commercial lumber. In addition, all of the groves of large, old growth trees (over 2 feet in diameter and 80-100 feet tall) are nearly gone. These have taken as long as 400 years to produce.

The CCA regards as unacceptable the historical strategy of using vegetative management, i.e. logging, to rationalize "treatments" of the Forest. More recently, with the forest management agencies flush with Federal fire protection monies, "fuel reduction" is leading into logging ventures without justification or assurance that the cutting of trees will save communities from fire danger.

The older forests, considered disease and insect ridden in the past, are now known to provide important and crucial habitat for many wildlife species. They are also important for the replenishment of quality soils, and protection of pure rivers. Silvacultural treatments, i.e. logging, through commercial timber sales have not been proven:

• To be sustainable at the rate specified in the 1985 Forest Plan; and
• To maintain a diverse tree species base (to the contrary, they are replacing the forest with the monocultural lodge pole pine).

To date, the BNF has not provided significant and scientific monitoring and evaluation data supporting the regeneration and sustainability of clear-cut forests. This throws into question the viability of logging as a sustainable component of the multiple use strategy. The CCA asserts that few areas remain to be logged that can attain the higher standards and guidelines that will protect wilderness, roadless and wildlife areas.

Logging creates even-aged timber stands. Even-aged stands are more susceptible to fire and disease and lack the diversity that old growth or multi-age and multi-species forests provide. Retention of snow cover from deep, diverse and shaded old growth forests is greater, thus water yield will increase. Even select cut logging creates many problems in the Bighorn's forests where second entry is planned 20-30 years later, as again more damage occurs to watersheds, more disturbance to wildlife, water and soils. Moreover, this second entry opens access to motorized vehicles so the area is never given the chance to recover from logging disturbance.

The Bighorn NF has admitted that the Timber Allowable Sale Quantity (ASQ) is vastly overstated. Studies were done to show the sustainable annual volume is closer to 2 million board feet (mmbf) than the stated 15 million. In 1990, over ten years ago, a Notice of Intent was published in the Federal Register that promised the ASQ would be corrected. Instead, an arbitrary figure was chosen to appease political pressures and timber sales continued. This figure has not been proven to provide for sustainable harvest and regeneration on into the future. Because of this arbitrary decision, the Bighorn NF is being sued to scientifically determine the exact effects of a timber sale on wildlife, recreation, water resources, and the timber industry itself. An unsustainable ASQ harms the general public, local governments, the timber industry, and the forest. Continuation of industry jobs for the long term requires equilibrium between timber harvest and regrowth.

DESIRED CONDITION

Old growth logging should be banned completely. The CCA calls for a plan to maintain heretofore undisturbed areas for as long as possible, and a schedule for other areas to be set aside until they can again make an important visual and ecological contribution to our forest. Timber sales can only be allowed if they:

• Offer any long-term protection for the environment or the communities;
• Provide a net economic benefit to the public; and
• Benefit wildlife (indeed, they have been clearly shown to harm many wildlife species and the biodiversity of the Forest).

The BNF needs to show scientific evidence of sustainable harvest within the Standards & Guidelines for all other resources and delineation of future old growth, adequately distributed throughout the Forest. The ASQ should take into consideration the past 17 years of timber harvest under the illegal ASQ of the 1985 Forest Plan. The Plan should pledge to build no new roads in an over-roaded forest -- then calculate an appropriate timber base. No logging should occur unless proven sustainable and beneficial to the ecological health of the forest. The best economic use should be determined over a 200-year period to promote long-range planning.

All spruce/fir trees should be off-limits to harvest. Spruce/fir provide excellent habitat for more diverse wildlife species. The BNF Plan Standard should be to work towards increasing old growth of spruce/fir. To that end, the CCA recommends that: fire be brought back into the ecosystem, protecting the spruce/fir; that plans be developed to increase the health and vitality of aspen forests; that healthy trees never be cut to protect them from insects or disease; and that beetles be recognized as natural cyclic infestations that provide a food base for birds and small mammals.

Beauvais (2000) suggests:

"Given the goal of protecting this group (of wildlife species), one approach would be to reduce clearcutting and rely more on harvest techniques with less impact on stand and landscape structure. The specific responses of forest-adapted mammals in the Rocky Mountains to alternative harvest techniques are poorly known, but most species prefer stands with at least some tree cover to clearcuts. Retaining downed logs and snags in harvested stands may be as important as retaining live trees; logs and snags are critical to species like American marten (Buskirk and Ruggiero 1994), Canada lynx (Koehler and Aubry 1994), and several bats (Rabe et al. 1998), and are recruited very slowly in Rocky Mountain forests. From the perspective of forest-adapted mammals, the most critical difference between stands regenerating after natural disturbances (e.g., fires, blowdowns) and stands regenerating after clearcutting may be the abundance of coarse woody debris in the former, and the lack of it in the latter." (Beauvais, "Mammal responses to forest fragmentation" 2002.)

"Because many forest-adapted mammals have strong associations with spruce-fir forest, managers should especially protect and enhance coverage of this forest type. At present, spruce-fir is rarely clearcut in the region. However, clearcutting stands of late-seral lodgepole pine with the potential to convert to spruce-fir obviously reduces future spruce-fir coverage. Again, partial harvesting techniques may allow timber extraction from late-seral stands without reducing the viability of emerging spruce and fir trees, and thus may maintain habitat quality for forest-adapted species." (Ibid)

CURRENT CONDITION

The condition of our Roadless Areas in the Bighorn NF has deteriorated over the last 17 years. Because of road construction and timber cutting, we have seen the dramatic loss of almost 40,000 acres of previously unspoiled public lands. Once lost to development these roadless areas can never be replaced, and such a dramatic loss in acreage in just nearly two decades does not bode well for the future of roadless lands on the Bighorn National Forest.

Increased population and recreation popularity impacts the quality of any forest user's experience. Excessive motorized use brings about a steady erosion of non-motorized primitive recreation areas and a very high road density. Too many roads fragment the forest, destroying habitat and extirpating wildlife from the forest.

Overuse by motorized vehicles has become more intense, more pervasive and more abusive, both in summer and winter. Winter snowmobiles have increased, and will continue to increase due to the projected YNP ban, close vicinity to eastern users and increased popularity. The noise, air pollution and enforcement challenge associated with snowmobiles is driving cross country skiers and quiet recreation users from a majority of the accessible forest.

The Roadless Area Conservation Initiative approved during the last administration was a Forest Service-devised-policy to preserve some of the few remaining backcountry areas in their present condition. There have never been enough funds to maintain roads already in existence. Although the Bighorn National Forest roadless areas are not designated Wilderness, many of the roadless areas that have survived the motorized onslaught, should be recommended for Wilderness protection in the Revision. Some candidate roadless areas already contain primitive roads and trails open to motorized vehicles.

DESIRED CONDITION

All roadless areas should be protected against motorized use. The Forest Plan should emphasize existing roads and trail maintenance. Many volunteers from organizations contributing to the CCA have helped the Forest Service inventory the Roadless Areas. In general, these studies have concluded that roadless areas should be maintained as such, in keeping with the original intent of the Initiative. The data collected from these inventories should be used to determine boundaries, wilderness qualities and management protections. The CCA urges the BNF to recognize and utilize the inventories in developing a new Forest Plan.

No new road construction should be allowed, as there is a more than adequate number of existing roads. No upgrades of road classification should be allowed. The BNF should implement a no-net road Standard, limiting road building and setting aside large blocks of undisturbed forest habitat for elk and other wildlife security. No development should be allowed in roadless areas. If the BNF finds it necessary to build roads, an equal number of roads (or more) should be closed down in areas important for expanding contiguous wildlife sanctuary. The road density Standard should be brought down to a number compatible with wildlife protection.

The CCA recommends that the roadless areas with motorized use be assessed and evaluated to determine if:

• The resource is damaged or abused to the point of environmental degradation;
• The roads provide no destination, are user-created byways, or are not part of the Forest Road System;
• The roads do not adhere to the definition of a classified road, i.e., demonstrate a level of regular maintenance, demonstrate purpose and use;
• The watersheds are suffering from erosion caused by motorized use;
• The fisheries are harmed from motorized use; or
• The motorized use is so minimal that the area should be restored to a non-motorized use area.

The time has come to make sure that the primitive and natural character of the Bighorn Mountains is protected for our children and grandchildren. The CCA is recommending an expansion of the lands protected as Wilderness in the Bighorns. Wilderness is a Congressional designation, which does not change with the policies of each incoming forest supervisor. It's a designation that protects these lands for the future.

The BNF is mandated to review the current condition of roadless areas during the Forest Plan Revision and make recommendations for wilderness protection. The BNF will determine if those roadless areas have retained their wilderness characteristics - i.e., essentially untrammeled by man, where man visits but does not remain, where solitude and unique geologic, or ecological characteristics can be found.

Many people feel that Wilderness is too restrictive and that the Forest Service should look at other ways to protect roadless areas. But the facts from the last decade show that Wilderness is the only way to protect environmentally sensitive roadless lands from logging and roading.

The CCA will provide more non-roaded, non-motorized recreation areas. Public demand warrants more wilderness and quiet recreation areas, values increasingly limited to our national forests. Habitat fragmentation by roads has devastated wildlife in the Bighorns. In order to halt this process for all the Bighorn's wildlife species, protect water and fisheries, and provide for quiet recreation opportunities, the Citizen's Conservation Alternative recommends the following Roadless Areas (with approximate acreage) for Wilderness Recommendation:

• Little Bighorn - 120,000 acres
• Devils Canyon - 32,000 acres
• Cloud Peak Contiguous - 90,000 acres
• Piney Creek/Penrose/Little Goose-71,000 acres
• Rock Creek - 40,000 acres
• Walker Prairie - 51,000 acres
• Leigh Creek Canyon - 23,000 acres
• Medicine Lodge Canyon - 6,400 acres

CCA WILDERNESS AREA RECOMMENDATION DESCRIPTIONS (Total approximate: 433,400 acres)

Little Bighorn (including Tongue River Canyon, Mann Creek and Dry Fork) Roadless Area - approximately 120,000 acres

The Little Bighorn includes two of the most spectacular canyons in the Northern Rocky Mountains: the Tongue and Little Bighorn. The RARE II analysis found 134,760 acres in 1984. These roadless areas receive some of the highest recreational use in the Bighorn Mountains due to their accessibility, providing superior primitive recreation experience, extraordinary geologic characteristics, and magnificent wildlife viewing opportunities. This roadless area deserves wilderness designation so that the primitive characteristics and backcountry recreation that now is so prevalent in the area will continue.

The Little Bighorn roadless area lost to logging over 14,500 acres, which is over a 10% loss of the total area of decade ago. The Mann Creek area contained within the Littlehorn Roadless Area has very special characteristics that add to the biodiversity and limestone canyon habitat. With Douglas fir, ponderosa and limber pine as well as grass and shrub habitats represented, in steep rough terrain with little access, represent a wilderness ecosystem as none other in the Bighorns. Keeping the Littlehorn ecosystems intact and including Mann Creek to Tongue River is the highest best use for the northern Bighorn Mountains region, and provides a possible reintroduction area for Canada lynx.

The Littlehorn to Tongue River roadless areas would contribute the largest wilderness addition to the Wyoming Wilderness Act if recommended for wilderness protection by the Bighorn National Forest. The public has shown time and again that they want these areas protected as primitive non-roaded recreation areas - i.e. wilderness. The Dry Fork Pumped Storage Project, the Coal Slurry Pipeline project, Gloom Creek timber sale, etc has shown opposition from the public. Time and again, proposals come forward threatening the pristine wilderness characteristics of these areas. Small research natural area status will not protect the intact ecosystems from further fragmentation. This huge roadless area is a sure-fire opportunity for the Bighorn National Forest to provide a unique and highly qualified roadless area wilderness protection, and provide the ultimate for dispersal of the wilderness recreation experience.

Devil's Canyon Roadless Area -- approximately 32,000 acres

The spectacular and bewitching Devil's Canyon of the western Bighorn Mountains lost over 2,000 acres of the roadless land that comprised the area just a decade ago. The remaining 32,000 acres of roadless lands need to be protected as wilderness. No one who has seen the majestic views of Devil's Canyon and the awe-inspiring sight of Bucking Mule Falls could deny that this area is deserving of wilderness designation.

The canyon is completely undisturbed, steep and rough country with a wide variety of ecosystem types such as spruce/fir, Douglas fir, limber pine, aspen, grassland and sage. Also in proximity is the Medicine Wheel National Historic Landmark, which is recommended for expansion by the BNF and many tribal nations. The CCA strongly urges the BNF to combine the wilderness recommendation of Devil's Canyon and the Medicine Wheel's NHL expansion to protect the history, archeology, geology, paleontology and recreation values and aspects of this amazingly unique treasure.

Cloud Peak Contiguous Roadless Areas - approximately 90,000 acres

The roadless areas still retaining wilderness characteristics that are adjacent to the Cloud Peak Wilderness Area (CPWA) should be added to the wilderness system. The CPWA is being loved to death, was too small to begin with from the 1984 Wilderness Act and needs to have its boundaries expanded. The Cloud Peak Contiguous roadless area at the RARE II inventory found 151,410 acres, now with roads, timber sales and fragmentation the roadless area has been dramatically reduced.

All-terrain vehicles and 4-wheel vehicles have made various inroads closer to the wilderness boundary destroying roadless characteristics, but many areas remain intact and should be protected for additional protection for the Cloud Peak Wilderness.

Cloud Peak, the crown jewel of the Bighorn Mountains has also been adversely affected by the Forest Service's timber policy of the last decade. Over 5,600 acres of roadless lands Cloud Peak Contiguous roadless areas adjacent to the Wilderness have been sacrificed to cutting.

These practices fragment wildlands and destroy the vistas that people seek in their wilderness experiences. Such spectacular areas as Paintrock Canyon and Lakes, Lost, Lily and Grace Lake have all been threatened by ATV abuse, and need to be added to the Cloud Peak Wilderness Area to expand the boundary. These adjacent areas include more diverse vegetative communities, areas with tremendous recreational interest, and would protect a contiguous band of wilderness from the western boundary of the Great Plains to desert steppes of the Bighorn Basin.

The Cloud Peak Contiguous Roadless Areas protect important watersheds for clean water that communities rely upon for their drinking water, and for the protection of important fisheries. Crazy Woman, Baby Wagon, Tensleep, Paintrock, Medicine Lodge, Trapper, Cross Creek, Little Goose watersheds all rely on the Cloud Peak Contiguous roadless areas for the protection of their clean water. The Story, Buffalo, Ten Sleep, Worland, Shell, Basin and Sheridan communities are dependent upon the clean water that flow through these critical roadless areas. Impairment (pollution/ sedimentation) of water is created by roads and overgrazing. The Yellowstone cutthroat trout is found streams in several Cloud Peak Contiguous roadless areas - the Paintrock, Medicine Lodge and possibly Trapper creeks, and the Story and Tensleep Fish Hatcheries will require that their water sources stay clean.

The CCA urges the adoption of this simple solution to a complex political problem of keeping our mountain streams pristine - protect roadless areas and keep them intact with wilderness designation.

Piney Creek / Penrose Ridge/Little Goose Roadless Areas - approximately 71,000 acres

The Little Goose/Penrose Ridge/Piney Creek Roadless Area consists of approximately 71,000 acres located entirely on the Tongue Ranger District within portions of Sheridan and Johnson counties. The area includes the Penrose, Little Goose and Piney Creek watersheds that are located approximately 10 miles southwest of Big Horn, Wyoming, and are contiguous to the Cloud Peak Wilderness Area. Prominent landmarks in the area include Little Goose Peak, Kenniwood Park, Telephone Park, Penrose Park, Penrose Guard Station, Little Goose Campground, Kearny Reservoir, Willow Park Reservoir, and Cloud Peak Reservoir. The elevation in the area ranges from a low of approximately 5,400 feet to a high of approximately 9,900 feet.

The Penrose Ridge Roadless Area is a logical addition of granite moraine drifts and some green fringe needed to skirt the high country above it. Included are the beautiful rapids of Kearny Creek. Cloud Peak Reservoir is not objectionable and is a previously existing private right. Important elk habitat - migration corridors, calving and security areas - are found in the Penrose Park area.

These roadless areas have not diminished significantly in the last 16 years since their release. The current motorized activity level has increased so the amount of ATV abuse and damage has increased. If the motorized use was strictly limited to designated trails, and signage and enforcement were stepped up, the Penrose Trail area, Moncrief Ridge area and Willow Park area could be reclaimed.

The CCA feels that the maintenance roads to Cloud Peak, Kearney and Willow Park Reservoirs could be included for that special use only and should be barricaded at the boundary at Willow Park Reservoir. The Wilderness Act specifically allows for management of special prior uses. A corridor for the road and reservoir would present far more management problems. The CCA recommends that an improved dead-end access road and campground facilities be located in the South Piney and/or Penrose Park area. This region, at present, is generally providing heavy motorized use through Story to Kearny Lake via the Penrose Trail. The 1985 Forest Plan never would have envisioned the amount of ATV abuse that is occurring without any enforcement in the area. In fact, the Penrose Trail has become so motorized that it is a single use area, and an area that the Forest Service has basically chosen to ignore the complaints of the non-motorized public. Motorized corridors can be left intact on the Penrose Trail between wilderness areas as long as enforcement is heavily provided to keep the use on designated trails. The Kearney Creek Trail that follows the creek to the point of actually going into a part of the creek should be off-limits to motorized use.

The Little Goose/Penrose Ridge/Piney Creek areas were previously three RARE II areas. A portion of the area was added to the Cloud Peak Wilderness Area while the remainder of the area was released for multiple uses with the passage of the Wyoming Wilderness Act of 1984. The BNF attempted to build a major road system into the area in 1986 and again in 1987 and again 1991 (Little Goose Road). The Forest received over 1000 letters, with approximately 95% being against the road project. There were several public meetings held in the Sheridan area that demonstrated that a united front had developed in the community in opposition to the road proposal and proposing protection of the area for primitive recreation. The wide expanse of parks and forest, Little Goose, Piney, Penrose, and Kearny Creek drainages offer ideal habitat for elk, deer, moose, black bear, lion, other small mammal species, avian species and fisheries. There are significant areas of old growth forest - some of the last remaining outside the Cloud Peak Wilderness Area.

Rock Creek Roadless Area - approximately 40,000 acres

On the East face of the Bighorn Mountains lays an area of immense beauty and wildness. This area held the Wyoming Wilderness Act of 1984 captive for years. The Rock Creek Roadless Area encompasses a complete alpine ecosystem. From the Cloud Peak Wilderness boundary where wild lakes abound to dense forested elk habitat to deep canyons laced with impressive rock spires, the Rock Creek addition is wilderness personified. Interspersed with small creeks, open parks, old growth aspen groves and dense conifer forests, it remains the most unusual, wild and rough of the remaining roadless areas outside the Cloud Peak WA. The Rock Creek addition to Cloud Peak WA would add a much-needed ecosystem of lower elevation forestlands -- vegetative and topographic diversity, plus protecting key watersheds and wildlife habitat. This area is very popular with big game hunters and fisherman, hikers and horse packers alike. The original RARE II proposal contained 51,200 acres. The Cloud Peak Wilderness Citizens Study Group (CPWSG) recommended nearly 40,000 acres. No timbering, fires, road building or oil or gas leasing has taken place in this pristine area. Although some ORV trails are intruding into the south end of the roadless area, reparation could be recommended to clean up the area from damage, or appropriate signage could emphasize the management for wilderness recommendation.

In the 10/2/1984 Congressional Record, Senator Malcolm Wallop of Wyoming expressed his support and reasons for the Wyoming Wilderness Act of 1984. He states,

"One area receiving considerable attention throughout negotiations was the Rock Creek drainage over on the Big Horn NF. I resisted inclusion of Rock Creek in the Cloud Peak Wilderness inasmuch as most of the drainage is covered with oil and gas leases. In addition, the drainage contains at least two potential reservoir sites. I am convinced water will eventually become on of Wyoming's most important resources and I feel very strongly that we must maintain options for its eventual development and management. I also believe it is important to maintain a transportation corridor between the wilderness boundary and the forest boundary. I would, however, hope that if the Forest Service finds it necessary to construct roads into the Rock Creek drainage for oil and gas exploration or timber management purposes that such roads can be closed and restored to a near-natural condition at the conclusion of the activity."

Rep. Sieberling on 10/2/84 (H10889) states,

"The substitute (Cloud Peak Wilderness Area Addition) adds approximately 37,000 acres to the Senate proposal. The bulk of the additions are located in the Shell Creek area on the northwest side of the Primitive Area and the Upper Penrose/Little Goose Creek Area on the Northeast. These additions generally comprise scenic lower elevation forested terrain which will help act as buffer to the fragile high country above timberline."

"Quite frankly, although the additions are meritorious, I would have preferred to see them in the Rock Creek area. The approximately 35,000 acre Rock Creek area runs all the way from alpine tundra down through scenic canyons to the edge of the prairie and represents the only real opportunity to have the proposed wilderness incorporate a vast spectrum of ecological systems. The Subcommittee toured the Rock Creek area in 1981, and I was very impressed with its rugged scenic terrain, dramatic rock spires, and beautiful canyons. Unfortunately, much of the area has been leased for oil and gas and the delegation was unwilling to designate it as wilderness or wilderness study at this time. It would be my hope, however, that if the area's oil and gas potential proves to be low that a future Congress would reconsider the wilderness option for this beautiful and fragile area. In the meanwhile we would ask that the Forest Service exercise special sensitivity in planning for management of the area and, that if all possible, any oil and gas exploration activities on the existing leases be conducted by helicopter or other nonsurface disturbing methods. The Subcommittee has received a great deal of input from Wyoming residents asking that the roadless nature of the Rock Creek area be protected, and we trust that the Forest Service will be sensitive to those concerns."

Walker Prairie - approximately 51,000 acres

Walker Prairie is a vast mountain high altitude prairie ecosystem that can be seen from 100 miles from the east. Likewise, views from Walker's Prairie to the plains of Sheridan and beyond are extraordinary. Hikers and horse packers have used Walker Prairie as a getaway from more populated recreation sites in the Bighorns. Spectacular water falls from Big Goose Creek and Rapid Creek provide delightful destinations for recreation users and anglers. The Nature Conservancy has protected many of the adjacent private lands of Walker Prairie through conservation easements, because the unique and rare ecosystems and transition zones that are found in area.

However, the Walker Prairie roadless area has lost over 9200 acres of the original roadless area from logging activities (62,530 acres - RARE II). The Forest Service chose to sacrifice the long-term recreational opportunities in this area for its limited and meager timber resources.

Backcounty recreationalists also extensively use Walker Prairie. Eaton's Guest Ranch, one of the West's oldest and most popular dude ranches, conducts numerous trail rides into the area. The huge outpouring of recreation users and hunters support for the maintenance of access through the PK Lane is indicative of the importance of the Walker Prairie Roadless Area. Wilderness designation would permanently solve the problem of protecting the recreation user's experience as well as protect the rancher's fear of motorized abuse of their private land access. The remaining intact roadless area of Walker Prairie needs to be protected as wilderness if its viability as a backcountry area is to be preserved.

Leigh Creek Canyon - approximately 23,000 acres

Leigh Creek Canyon is one of the most visible and deserving potential wilderness areas in the Bighorns. As a tributary to Ten Sleep Creek, the majestic beauty of Leigh Creek Canyon justly inspires everyone traveling U.S. Highway 16. The RARE II inventory found 25,320 acres as roadless. The Forest Service, however, has failed to realize the importance of protecting this amazing resource, and instead has logged almost 2,000 acres of the area in the last decade. If the natural legacy of Leigh Creek Canyon is to be enjoyed in the future, the Forest Service needs to recommend this area for wilderness designation.

Leigh Creek Canyon roadless area provides a unique ecosystem transition zone with Douglas fir and narrowleaf cottonwood down to the shrub/sage dotting the canyon walls. Many archeological prehistory sites are found in the area. Caves abound in the limestone walls. Although the Tensleep Canyon roaded area is impacted with heavy recreation use, the Leigh Creek Canyon is pristine and wild. The difficulty in accessing the area makes for a supreme solitary experience - a prime condition for wilderness recommendation.

Medicine Lodge Roadless Area - approximately 6,400 acres

The Medicine Lodge roadless area is one of the Bighorns best wilderness additions. Although cut off by road development from its original Cloud Peak Contiguous roadless area, the CCA has set the Medicine Lodge roadless area as an important wilderness to be preserved. The Medicine Lodge area sits between the Cloud Peak Wilderness area on its East (separated only by 4-WD road #344), and the BLM's Medicine Lodge Canyon Wilderness Study Area to the west. The Medicine Lodge roadless area includes Lower Medicine Lodge Lake and portions of Medicine Lodge Canyon, and provides opportunities to hike varied and picturesque terrain. The BLM has already recommended its portion of Medicine Lodge Canyon become Wilderness and the Forest Service should do the same. The agency boundary between these two biologically connected areas should not be used as a means of keeping the 6,400 acres of Forest Service lands from receiving the same level of protection as the adjoining BLM lands enjoy.

The topography and geology of the Bighorn Mountains is very spectacular and unique. The island mountain range is cut with many outstanding canyons and wild rivers. It is unfortunate and unwarranted that the Bighorn National Forest could only find two canyons that have merited Wild and Scenic River recommendations - the Littlehorn Canyon and the Tongue River Canyon. Both of these canyons should continue to be protected and the recommendations restated with Wild and Scenic protective status.

In order to further protect the integrity of our most scenic and ecologically important rivers and canyons, the Citizen's Conservation Alternative recommends for Wild and Scenic river corridors:

• Big Goose Canyon
• Little Goose Canyon
• Rock Creek Canyon
• Crazy Woman Canyon
• Tensleep Canyon
• Shell Canyon
• Medicine Lodge Canyon
• Paint Rock Canyon
• North and South Piney Creek Canyons

Roadless areas needing protection from further degradation due to logging, off-road vehicles, or from fragmentation to the point of needing restoration should be recommended for protective status such as Research Natural Areas. The Bighorn National Forest has identified eleven areas as potential Research Natural Areas. Some of these areas the CCA finds eligible for wilderness recommendation such as Leigh Creek Canyon, Tongue River Canyon, and Devil's Canyon. In addition to these, the Citizen's Conservation Alternative has identified former roadless areas that no longer retain their primitive characteristics, but still yield to the need for RNA protective status in order "to preserve a wide spectrum of pristine areas" representing "important forest…alpine…geological…situations that have special or unique characteristics" (Forest Service Manual 4063.02).

Forest Service Manual 4063.02 lists the objectives for establishing RNA's:

1. To preserve a wide spectrum of pristine areas that represent important forest, shrubland, grassland, alpine, aquatic, geological and similar natural situations that have special or unique characteristics;
2. To preserve and maintain genetic diversity;
3. To protect against serious environmental disruptions;
4. To serve as reference areas for the study of succession;
5. To provide on-site and extension educational activities;
6. To serve as baseline areas for measuring long-term ecological changes;
7. To serve as control areas for comparing results from manipulative research; and
8. To monitor effects of resource management techniques and practices.

There are currently two RNAs on the Bighorn National Forest. A more complete description of these RNAs, and others in Forest Service Region 2 can be found in Ryan, et al. (1994). Bull Elk Park was established in 1952, 200 acres, is known for its disjunct Palouse Prairie Climax ecosystem, and Shell Canyon, was established in 1987 for its intact Rocky Mountain juniper community.

The ecological evaluations of the Forest Service included field review by WYNDD botanists, ecologists, and/or wildlife biologists; interaction with Forest Service and Wyoming Game and Fish specialists; and, review of pertinent vegetation and animal databases. National Forest and Game and Fish specialists reviewed initial drafts of the ecological evaluations.

The Citizen's Conservation Alternative appreciates the efforts of the BNF on RNA research and strongly recommends that these areas receive RNA protection:

• Crazy Woman Canyon
• Elephant Head
• Mann Creek
• McClain Lake
• Pete's Hole
• Pheasant Creek
• Poison Creek
• Hazelton Peak/Doyle Peak
• Bear Rocks
• Hideout Creek
• Bruce Mountain
• Horse Creek Mesa
• Sibley Lake

Roadless areas that were encroached upon over the last 17 years since the passage of the Wilderness Act have lost some of their roadless characteristics. However, Hazelton and Doyle Peaks, Bear Rocks, Hideout Creek, Bruce Mountain and Horse Creek Mesa roadless areas still retain some genuine primitive qualities that would provide for excellent habitat for scientific research, non-motorized short hiking areas, proximity to paleontologic discoveries, unique geological formations, and plant ecosystems that are intact.

Sibley Lake Roadless Area

The Citizen's Conservation Alternative supports the nomination by the Bighorn National Forest of 18,000 acres of the Medicine Wheel and Medicine Mountain as a National Historic Landmark (NHL), and supports extended management protection of this important site under the existing Historic Preservation Plan (HPP). The Medicine Wheel NHL nomination culminates a fifteen-year effort by government agencies and American Indian advocacy organizations to document and protect all significant archeological sites and Native American traditional use areas in the vicinity of the Medicine Wheel. The document incorporates a large body of current archeological and ethnographic information.

The Bighorn NF Plan Revision should incorporate the recommendation to support the 18,000-acre "Area of Consultation" that the 1996 signed Historic Preservation Plan intended as a blueprint for management of the Medicine Wheel. The Area of Consultation provides for protective management of the Wheel and should continue to be honored, as efforts are underway to expand the boundaries.

Our National Forests should not be managed to benefit commercial interest at the expense of the unique characteristics and sacred values of the area. Evidence collected by Forest Service archeologists and ethnologists demonstrates that the Medicine Wheel is not merely an isolated archeological "relic", but part of a complex and unique concentration of associated sites and Native American traditional use areas that occupy 15,000 acres on the crest and slopes of Medicine Mountain.

Combining the wilderness recommendation of Devil's Canyon with the Medicine Mountain NHL designation would provide for a lasting and visionary legacy for many generations.