September 22, 2003

Gallatin National Forest
Attn: Steve Christiansen
PO Box 130
Bozeman, MT 59771

RE: COMMENTS ON THE GALLATIN NATIONAL FOREST TRAVEL MANAGEMENT PLAN AND FOREST PLAN AMENDMENT

Hello,

Native Ecosystems Council (NEC) and the Alliance for the Wild Rockies (AWR) would like to provide the following comments on the proposed Forest Plan Amendment and travel planning. Both groups would like to receive a hard copy of the draft plan and associated documents when these are released. Please send these to:

Sara Johnson, NEC
PO Box 125
Willow Creek, MT 59760

Michael Garrity, AWR
PO Box 505
Helena, MT 59624

1. The Gallatin Forest appears to be embedding a Forest Plan revision within your travel planning and a Forest Plan amendment. This process will make any future Forest Plan revision moot. In additional to the procedural flaws with this approach, you are misleading the public. It is unlikely that most of the public has any idea of the massive changes you are planning for the current Forest Plan.

2. It is unclear as to why this travel planning is being done as a Forest Plan amendment.Travel planning is a very specific process while Forest Plans are programmatic in nature. Although some of your travel plan decisions are general, there are many, many very specific decisions in this document. In addition to this conflict between site-specific and programmatic planning, you are making it essentially impossible for the public to provide meaningful input on travel management decisions. No single individual would be able to comprehend and evaluate the massive site-specific decisions you are making in this travel planning/Forest Plan amendment.

3. A Forest Plan amendment requires that existing standards be "amended" rather than deleted. This is not happening in your amendment. You are deleting standards without replacing them with anything. What you are really doing is revising the Forest Plan, not amending it.

4. You are not asking for public comments on all the hundreds of amendment (deletions) you are making to the current Forest Plan. How are you going to get public involvement on these changes if no public comment is sought?

5. Procedurally your amendment is very confusing. What will be the status of other previous Forest Plan amendments, such as amendment 19 for the grizzly bear (that was implemented as a settlement of a lawsuit) with this new Forest Plan?

6. If there are no specific management standards in the new Forest Plan, how will environmental impacts be measured? You will not be able to predict how natural resources, such as wildlife, will be managed. Therefore, you will not be able to measure impacts of management activities for the new Plan.

7. All of your travel management decisions are being made without the benefit of any current conservation strategies for management indicator species and sensitive wildlife species. This makes any travel planning decision arbitrary, since they are being made in a void (no wildlife direction or standards). Resource management issues, such as wildlife habitat, should drive travel planning, and this clearly is not happening.

8. It is not clear how this new planning direction fits in with current management area direction. You have not addressed this in your current analysis and description of travel planning.

9. The new planning direction refers repeatedly to "new access needs" without providing any rationale to the public why new access is needed, and for what.

10. As we mentioned previously, this new planning direction will significantly change the current direction for grizzly bear recovery habitat, in that the "current situation" will be maintained. If an area has too many roads or too little core habitat, there will be no objectives to improve conditions. This would appear to be a violation of the Endangered Species Act.

11. The proposed management of snowmobiles also appears to be a violation of the Endangered Species Act in regard to the lynx. The careful coordination that will be required between snowmobile use and preservation of the lynx appears absent from your planning.

12. It is not clear how snowmobile use and the wolverine have been coordinated in your planning.

13. Although you indicate that migration routes, security habitat, and grizzly bear core habitat will be managed, you have no specific standards provided, and you have not identified where or how much of these habitats will be provided. This information should be provided to the public, especially when you are already making many site-specific decisions regarding roads. If you are planning specific road use, this should include wildlife corridors, security and core habitat as well. You cannot plan one without the other.

14. You have not provided any maps or discussion of inventoried roadless lands.

15. This plan appears to allow established motorized uses, even if they violated Forest Plan direction, of becoming permanent without any consideration of resources.

16. You discuss desired future conditions without addressing current management area direction in the Gallatin Forest Plan. How are these two factors related?

17. You have some alternatives that do some mitigation for wildlife, while you have others that do little mitigation. How can you meet the viability requirements of the National Forest Management Act (NFMA) by implementing Forest Plan direction that severely impacts wildlife either across the Forest or in local areas? It does not appear that some of your alternatives will be viable as a result.

18. You have not discussed grizzly bear management situation areas 1 and 2 as per the current Forest Plan. What do you intend to do about these recovery lines?

19. Many of your alternatives will allow motorized use in wilderness study areas. These alternatives are not viable.

20. Why is it that all of your alternatives, except the current Forest Plan direction, will have the very same extensive deletions of current Forest Plan direction?

21. There are many other forest management activities, in addition to motorized and nonmotorized recreation (logging, mining, grazing) that will be affected to various degrees by your travel management planning. How are you going to address all these impacts, and explain them to the public. They have not been mentioned thus far in your analyses.

22. Why would you make thousands of site-specific travel management decisions as a Forest Plan amendment, when these decisions should be flexible and dynamic? Do you intend to amend the new Plan every time a site-specific travel plan decision needs to be changed? This is likely why there are usually two levels of planning which are kept separate, rather than muddled together as you are trying to do.

Regards.

Sara Jane Johnson, NEC

Michael Garrity, AWR