HUPC Comments on Preliminary Alternatives, Wasatch-Cache National Forest Plan Revision
19 September 2000
Bernie Weingardt Forrest Supervisor Wasatch-Cache National Forest Attn.: Revision Team 8236 Federal Building 125 S. State St. SLC, UT 84138
We want to provide you a brief comment on the Preliminary Alternatives, Wasatch-Cache National Forest Plan Revision.
First, again you and the Revision Planning Team deserve an immense amount of credit for opening this process to public review. The obvious test will be how comments will be utilized to "improve" or alter alternative outputs. Quite likely comments at this level will be indicative of comments on the DEIS since alternatives are the foundation of the DEIS.
What we can't tell from this document are outputs, allocations, other than roadless/wilderness and management standards and guidelines, which seem to be of some controversy on the forest. Thus, as is noted in the document, it is incomplete and thus any comments on it are incomplete as well. Nonetheless, since alternative formulation is so crucial to the forest plan process we have some observations.
We have distinct problems with Alternative 5. Let us preface this with the comment that we have no interest in an array of alternatives that is not really an array and fully understand, of course, the context of alternative formulation. I can recall on a couple of occasions discussing this process with you, Pam and Melissa and we all agreed that alternatives need to be realistic as well as reflective of particular themes.
The problem with this particular Alternative 5 is that it is not realistic nor reflective of the rural economies or livelihoods on this forest that it purports to serve. It is an alternative of a small sub-group of folks, obviously those screaming loudly and intimidatingly, who insist on an archaic and intolerant view of culture and custom. It is a dangerous thing for the forest to adopt because it suggests that those who do scream get results. The rest of us plod along with some degree of measuredness only to find those who rattle past dictums get attention. It raised this, specifically, with Melissa in our August meeting. Developing an alternative meeting rural concerns is valuable and meaningful but I urge you to look carefully and closely at the demographics of Cache and Box Elder Counties (even Rich County) or Uintah County, WY to assure the alternative is connected to those counties. For the most part, they are broad-based counties, both economically and socially (Rich County being a partial exception). Either alter Alternative 5 to reflect those of us living in those counties or add another alternative and re-define Alternative 5 as the grazing. logging and snowmobiling alternative.
As we've said from the outset of the proposed action, Alternative 3, we remain deeply concerned with the allocation of roadless areas/wilderness recommendations and the actual protection of roadless areas. Fortunately and thankfully, the National Roadless Area Conservation Policy (RACP) will absolve the Wasatch by formally protecting roadless areas. The fact that such protection must come from the Chief of the Forest Service and not an individual forest, one that bills itself as progressive, no less, is both telling and depressing.
The Wasatch-Cache still seems timid (and intimidated) when it comes to protecting roadless areas and making wilderness recommendations. The assurance that roadless areas will be protected comes in personal conversations or tangentially in alternative descriptions ("...generally would not be developed or would only be developed where it would be necessary for achieving habitat improvement or restoration.") Bernie, that is doublespeak! This is enhanced given the controversy around management prescriptions/desired future conditions--what you called "management direction" in your August 28 cover letter to the alternatives booklet. To say rest assured roadless areas will be protected, maybe, is unfair on your part and represents a snag in this process.
The matter of fact is the proposed action flies in the face of the context of its name, Need-for-Change. There is no doubt that roadless areas are of meaningful importance in forest management. There is no doubt protection of significant roadless acreage has been part and parcel of forest planning and nearly every project on the forest since the 1985 forest plan. The results of the RACP, both nationally and for this forest, along with the above noted historical concern over roadless area conservation, makes it even more clear the need-for-change has not been met in this alternative. Only a third of the roadless acreage is given some kind of formal protection on less than a third of the areas (this represents not a full roadless area, but small segments of roadless areas).
It seems the forest is willing to nod and wink that roadless areas will be protected but only write it in an alternative direction that is anything but clear. We've already discussed this at length in earlier comments and obviously have not connected. This will assure tension over expectations, and send confusing management direction to forest users, not to mention that it fragments roadless areas and fails to grab hold of the clear data which suggests roadless area protection is as important or more so than another contemporary management direction. For the Wasatch not to move forward on this is distressing.
The wilderness recommendations are even more stingy and backward looking in the supposed need-for-change proposed action. Less than 50,000 acres on the whole forest recommended as wilderness...less than 9%! That is timid. This is particularly true in light of the lucid and meaningful remarks to The Wilderness Society on September 9, 2000 by the Chief of the Forest Service where he acknowledged the Forest Service must be more forward-looking when it comes to recommending additional. This proposed action with a tiny recommendation on the Uintas and, surprisingly, no recommendation on the Lakes/Mt. Watson area( a major surprise given the earlier version of this proposed action shoed the Lakes as an either/or) was deafening.
And, of course, Alternative 4 and 5 showing no wilderness recommendations are utterly pointless. Alternative 4 is a "continuation of current management under direction of the 1985 Forest Plan..." Well, that plan, of course, noted that upon revision additional wilderness recommendations must be made. That was the management direction.
And to suggest that the rural residents envisioned in Alternative 5 want no wilderness is just not accurate. It is, no doubt, the wish of a small backward-looking group of people that apparently are dictating the construction of this alternative, but it is not representative of the theme as written in Alternative 5.
So, how to solve this so the alternatives provide a true array, respond to need for change and met the context of the alternatives?
Table 1. Suggested Roadless Disposition by Alternative
Table 2. Comparison of Proposed HUPC Alternatives and WCNF Preliminary Alternatives
The logic of these suggested changes is clear. Alternatives 1 and 2 do what their theme intends them to do and that is vigorously protect large, high quality blocks of land that add to the ecological integrity of the forest. They both focus on "rounding out" the extant designated wildernesses with meaningful additions, making those areas large, intact wild places. The only change in Alternative 1 is the Lakes/Mt. Watson area where we suggest ~65% of it recommended as wilderness rather than the 49% you recommend. This alternative recommends 48% of roadless lands, instead of 45%, as wilderness.
Alternative 2 increases the number of recommendations by only two but increases the acreage to encompass 38% of the roadless lands recommended as wilderness.
Alternative 3 accomplishes the same context of focusing the wilderness recommendations adjacent to the extant wildernesses in a much more measured manner, meeting the obvious need for change theme while being consistent with the proposed action and recent management direction on the Wasatch Front. It also makes a much more authoritative and equitable statement toward meeting the intent of Forest Service direction (and need-for-change) by recommending more wilderness. it only adds 2 small areas to your Alternative 3 while only proposing a mere 20% of roadless lands as wilderness.
Alternatives 4 and 5 are more consistent with the intent of, in the case of #4, the direction of the 1985 forest plan, the theme of the alternative and alternative 5 adopts the paltry 9% of roadless acreage recommended for wilderness in the extant Alternative 3.
This suggested alternative array keeps the focus of wilderness designation on adding high quality wildlands to the extant designated wildernesses rather than recommending often times small or disjunct areas. It is exceptionally consistent with providing a broad array of alternative acreages to be recommended as wilderness while being consistent with themes of each alternative. To this extent it differs only in degree, with the proposal in the Preliminary Alternatives booklet. With one exception. We find it biased and offensive that the proposals in the Preliminary Alternatives booklet reveal two of the 5 alternatives harbor NO WILDERNESS RECOMMENDATIONS. The Proposed Action makes a recommendation of just 9% of the roadless acreage as wilderness, Alternative 2 only 17% and Alternative 1, 45%.
While 45% is a lot of wilderness to some, no matter how you look at it, it really is not a high number. It is reasonable and based on high quality lands and a meaningful inventory and evaluation. ZERO, 0% (Alts. 4 and 5), no matter how you look at it and no matter how it fulfills the ego of a few users (we hope none in the Forest Service), is a small number! The same can be said of 9% (Alt. 3) and 17% (Alt 2) --they are paltry numbers that don't meet the intent of the alternatives or the obvious quality of the landscapes under discussion.
That is why ZERO, 0%, does not exist and certainly does not belong in a forest plan discussion. At least not if the forest plan revision is to meet a broad array of public and ecological concerns. But it shows an even deeper bias that concerns us--while two alternatives propose no roadless areas recommended for wilderness, no alternative recommends all roadless areas recommended as wilderness. I suspect you would argue and we would agree (this is more than a suspicion since we've had this discussion) that such an alternative is simply not realistic. NEITHER IS ZERO IN ONE OR TWO ALTERNATIVES!
Bernie, these suggestions are in the spirit of the alternatives booklet and not simply to be discarded. I provided the revision team suggestions for alternatives months ago when they were at the earliest stages without formal recommendations. I thought the themes/context were good and anticipated an array of wilderness recommendations more similar to this very broad and measured array of alternative we've provide. These changes are necessary to make the alternatives more responsive to the intent/theme of each alternative. They are realistic, consistent with the landscapes involved and broad-based versus the alternatives in your booklet which are simply too small and shallow compared to the impacts and value of the landscapes involved and far too reliant on the archaic NO or MINIMAL WILDERNESS view. The WCNF simply can't stay in that place.
There are numerous good components to this effort. The prime wilderness recommendations are in place in Alternatives 1-3 and only need to be adjusted in size, for the most part, not in number for all 5 alternatives as we've noted. The proposal's language to "discourage" non-native wildlife introductions is commendable but should be strengthened so as to not suffer from the expectation dilemma (we expect discourage to be vigorous and the WCNF may see it as benign). Allowing wildland fires and protection of wildlife corridors in some fashion across the first 3 alternatives is good. Timber harvesting excluded from roadless areas or to achieve historic conditions is meaningful. No ski area expansion is forward-looking. The openness of the process is to be commended.
We are deeply concerned with the recommendations on oil and gas leasing with the exception of Alternative 1. We suggest to meet the intent of Alternatives 1 and 2 that leasing NOT BE ALLOWED in roadless areas. Alternative 3 should see a NO SURFACE OCCUPANCY OR NO LEASE AREAS ON ALL ROADLESS AREAS AND LYNX HABITAT, for example.
Historic condition and forest health are an antithesis. Historic conditions have nothing to do with forest health. A thinning discussion is legitimate in the context of thinning around structures and campgrounds to assure safety, but not in a forest harvesting context. Forest health will simply become an excuse to log outside of the historic condition process.
Reliance on forest watershed structural improvements in Alternatives 2-3 is wrong-headed. The only long lasting answer to these kind of problems is limitations on the uses that cause watershed damage. The data is clear, convincing and long term. Alternatives 1-3 should have a snowmobile prohibition in all roadless areas (#1) and all roadless areas adjacent to designated wilderness (2 & 3). This is more consistent with the theme of these two alternatives and represents a bit of proactive management since we all know snowmobile use will only increase until roadless values are lost or significantly diminished.
The fact that the Preliminary Alternatives booklet lacked actual output/allocation projections, maps (we feel very frustrated that maps are not readily available other than off the Internet since maps are so important and functional to the understanding of these alternatives--this should be rectified promptly!) and standards and guidelines renders it a bit disordered. Thus we look forward to a discussion and briefing along these lines and hope to hear from you as to the resolution of management prescriptions.
Thanks very much. We also, of course, look forward to hearing from you with respect to these suggestions and how they will be used in this process.