Medicine Wheel returns to forefront

After operating with few hiccups for some 30 years, the Historic Preservation Plan governing the Medicine Wheel National Historic Landmark in the Bighorn National Forest east of Lovell has lately come under increased scrutiny, with special interest groups seeking significant changes in the plan, Big Horn County Commissioner Bruce Jolley said last week.

One of the proposals is to expand the landmark boundary from the current 2½-mile radius around the wheel (roughly 12,556 acres) to 27,000 acres.

After many years of meetings and negotiations, the Medine Wheel HPP was signed in September of 1996, with seven signatories to the plan representing the Big Horn County Commissioners, the Advisory Council on Historic Preservation, the Medicine Wheel Coalition for Sacred Sites of North America, the Medicine Wheel Alliance, the Bighorn National Forest, the Wyoming State Historic Preservation Office and the Federal Aviation Administration, which operates the radar dome on Medicine Mountain.

Jolley said he has been attending semi-annual meetings of the HPP consulting parties as long as he’s been a commissioner, even a year before that when he was thinking of running, following in the footsteps of former commissioners Ray Peterson and Keith Grant.

“They were extremely enjoyable, and for the most part, everyone got along really well,” Jolley said. “There were a few times it might get a little bit cantankerous where they didn’t like what was going on up at the top, or too many four-wheelers had driven by. But all in all, it was good communication, and everyone got along.”

Things began to change a bit a couple of years ago, Jolley said, when a gentleman from Fremont County was quite upset when some grazing cattle got near the Medicine Wheel, but assurances were made regarding cattle, and the man was fine with the changes.

“We talked about, well, how do we fix that? How can we not let that happen again? And we made it through that,” Jolley said.

Soon after that issue, he said, a woman from Fort Peck, Montana, Dylan Youpee, a tribal historic preservation officer, began attending meetings questioning Forest Service management practices in what Jolley believes to be an unnecessarily aggressive manner. Conflicts increased at the meetings beyond what would be considered to be reasonable, he said, calling the meeting exchanges difficult.

“I mean, you couldn’t talk, you couldn’t communicate, and they wanted to argue,” he said. “As commissioners, our biggest concern was ‘Don’t shut down the road that goes up there, Forest Service Road 12,’ which Big Horn County built (improved) so that Big Horn County folks would have access for the hunting and the grazing. You’ve got (people) that have a place up there, and that’s how they get access to their private property. We improved it.”

Don’t close the road

Jolley said the commissioners sent a letter to Forest Supervisor Andrew Johnson on March 17, 2025, emphasizing that, as one of the seven signatories to the HPP and as a consulting party, Big Horn County would assert that the public Forest Service Road 12 remain open at all times.

“The intent of this letter is to clarify Big Horn County’s intent that this road remain open at all times to through traffic in accordance with the Historic Preservation Plan and its Addendum,” the commissioners wrote. “Big Horn County respects the ability afforded to entities to request closure of the Medicine Wheel site for planned ceremonies, however this closure does not include the road. As stipulated in the HPP section IX.D- Transportation and Access, ‘Travel is restricted to defined roads and/or trails without closure.’

“Big Horn County garnered the support of the local community, our U.S. Senators, our U.S. Representative and local government for the expanded Medicine Wheel/Medicine Mountain National Historic Landmark by promising Forest Service Road 12 would always be open for public access. … Continued access and road closure is not a negotiable item, and we are requesting that this group no longer waste efforts to readdress this topic at future meetings.”

During the summer of 2025 the commissioners received a request from Christine Varah, a tribal relations specialist with the Bighorn National Forest, to perform a study through the University of Wyoming to examine the HPP and update the agreement. The commissioners wrote to Varah objecting to the study as one of the seven consulting parties due to concerns they have regarding plan modification and language in the proposal.

“As a collective whole, we, as a board, would be adamantly opposed to any underlying groundwork that would make the HPP vulnerable to change,” the commission wrote. “We are concerned about some of the language contained in your proposal synopsis and what that would mean for the HPP going forward.

“We greatly appreciate the stakeholders involved with maintaining the integrity of the Medicine Wheel and believe in our duty to uphold and maintain the HPP as it is written. We will continue to collaborate and cooperate with stakeholders moving forward while balancing the requirements of the HPP for all involved.”

Jolley said the commissioners believed they had, essentially, veto power as one of the consulting parties but noted, “It didn’t do us any good. They’re right in the middle of this big grant thing. They did not listen to our letter.”

Plan changes

Tribal historic preservation officer Youpee has submitted a proposal to “update” the historic preservation plan and “seek some type of revision to reflect modern legal standards, expanded boundaries and evolving tribal sovereignty,” according to the proposal. The four priority areas stated in the proposal are as follows:

• Consultation – “Shift from ‘Consulting Parties” to formal government to government consultation with Tribal Historic Preservation Officers.”

• Land Base – “Incorporate the 4,080 acres added to the National Historic Landmark in 2011” and expand the landmark boundary to 27,000 acres.

• Board Structure – “Reorganize the Alliance/Coalition to ensure representation of the federally recognized tribes and THPOs (tribal historic preservation officers).”

• Compliance – “Integrate specific Inadvertent Discovery Plans for human remains and cultural items.

Among the specific recommendations, the proposal would amend the HPP so that the Big Horn County Commissioners consult only on local economic and access issues but hold no jurisdictional authority of the sacred integrity of the site. Cultural management decisions would be restricted to the Forest Service and tribal representatives, essentially removing Big Horn County as a consulting party. The county would no longer be an equal partner under the proposal.

Meanwhile, tribal historic preservation officers would be incorporated as full consulting parties with the state historic preservation officer, even though the national historic landmark is on federal and not tribal land.

And the proposal would implement a detailed Inadvertent Discovery Plan “to prioritize tribal authority over human remains and cultural items,” the proposal states. Archaeological Resources Protection Act citations would be updated to ensure that any “unauthorized articles” left at the site are handled according to contemporary tribal protocols rather than purely administrative removal.

The proposal also demands a “Stop-Protect-Notify” protocol through which, if any human remains or funerary objects are found, all activity including logging, grazing and construction must cease within 30 feet. Appropriate federal official and all affiliated tribes would have to be notified within 24 hours.

In addition, the proposal would prohibit commercial hauling on Forest Road 12 permanently rather than on the current case-by-case basis. The proposal would “prohibit any commercial timbering or vegetation manipulation that results in noise or visual intrusions detectable from the Medicine Wheel.” It would also “explicitly prohibit the use of retardant drops (during a fire) within the NHL (national historic landmark) boundary to prevent chemical damage to limestone features and sacred plant gathering areas.

Other recommended “crucial updates” include eventual mandatory removal of the FAA radar dome to “restore the sacred landscape,” permanent, year-round motorized vehicle (snowmobile) closure “for all areas off Forest Road 12 within the expanded boundary to protect sensitive tundra  and archaeological features” and moving from “standard oral presentations” by Forest Service staff at the site to having tribal historic preservation officers “design and lead all interpretive content to ensure Native American spiritual values are represented authentically.”

In light of the proposed changes to the HPP, Forest Supervisor Andrew Johnson in late February issued a request for comments and recommendations from the consulting parties with a deadline of March 30. The Forest Service would make a final decision on adoption of the recommendations to amend the HPP should the consulting parties concur with the proposal, but if one or more of the parties do not agree with the proposal, a dispute resolution process would kick in to include direct consultation with the Forest Service and resolution through the Advisory Council on Historic Preservation.

The comment period deadline was extended to April 30 and then May 15.

County response

On March 5, the county commissioners wrote a letter to U.S. Senators John Barrasso and Cynthia Lummis, U.S. Rep. Harriet Hageman asking a number of questions about process, the involvement of tribal historic preservation officers as a consulting party and the demotion of the commissioners’ input. The letter also questions the expansion of the historic landmark area to 27,000 acres, stating, “This land grab directly affects private land owners, area lodges, cabin owners and federal grazing lease holders and creates economic hardship that is nearly impossible to quantify due to the ever evolving regulations and requests to protect view sheds and any item an individual or group may determine to be sacred.”

The commissioners then met with Forest Supervisor Johnson on March 16 and sent in the county’s official comments on March 17. In their response, the commissioners stated that the county “recognizes the profound cultural, historic and spiritual significance of the Medicine Wheel landscape and supports efforts to ensure its management reflects applicable legal standards and meaningful tribal consultation,” adding, “We also value the collaborative relationships that have historically guided stewardship of this unique and nationally significant site and the public lands that encompass it.”

The county continues that for nearly 30 years the HPP has provided the guiding consulting framework for the site “through cooperative participation of the consulting parties,” adding that the Forest Service has worked successfully with the parties to address “important management issues affecting the landmark and its surrounding cultural landscape” through the consultation framework established under the National Historic Preservation Act while carrying out its duties as a multiple-use land management agency.

Given that framework, however, the county expressed numerous significant concerns with the proposal and detailed the concerns in a 12-page document. The document points out that the HPP, while establishing shared consultation, operates alongside existing federal law governing historic preservation, cultural resources and tribal consultation, adding that the HPP was never intended to function as a comprehensive land management plan or to establish operational direction for broader forest management activities.

Other concerns with the proposal addressed by the county include the requirement for the Forest Service to consult with tribal historic preservation offices at the same level as the state historic preservation office, the former assuming responsibilities on tribal lands but the latter holding the regulatory role off tribal lands under Section 106 of the NHPA. The county further points out that the Medicine Wheel Alliance and the Medicine Wheel Coalition already may designate individuals of their choosing including a THPO to participate in the process.

With the county having been an active participant in the stewardship of the Medicine Wheel landscape for decades and recognizing that the Section 106 process “explicitly recognizes local governments as consulting parties when undertakings may affect historic properties within their jurisdiction,” the county objects to the hierarchical framework of the proposal. Under that framework, the county’s role would be limited to economic impact and access issues, and the county would no longer be a full consulting party.

Among other issues, the county objects to expanding required historic preservation plan consultation to include the 4,080 acres of the enlarged national historic landmark boundary in 2011, pointing out that an NHL designation is a recognition of historic significance by the National Park Service but does not automatically modify land management policies, existing agreements like the HPP or the roles of consulting parties.

Jolley said the commissioners also strongly object to the expansion of the landmark boundary to 27,000 acres.

With the comment period ending Friday, the issue will now be in the hands of the U.S. Forest Service.