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HUPC Comments on Wasatch-Cache National Forest Draft Environmental Impact Statement

26 October 2001

Genuine politics-politics worthy of the name, and the only politics I am willing to devote myself to-is simply a matter of serving those around us: serving the community, and serving those who will come after us. Its deepest roots are moral because it is a responsibility, expressed through action, to and for the whole, a responsibility that is what it is-a "higher" responsibility-only because it has a metaphysical grounding: that is it grows out of a conscious or subconscious certainty that our death ends nothing, because everything is forever being recorded and evaluated somewhere else, somewhere "above us," in what I have called "the memory of being."

If we want a better world than that now in prospect, we must-as humanity, as people, as conscious beings with spirit, mind, and a sense of responsibility- somehow come to our senses."

Vaclav Havel Summer Meditations

Tom Tidwell
Forest Supervisor
Wasatch-Cache National Forest
Salt Lake City, Utah

Dear Tom:

An unusual way to start a forest plan comment by drawing our collective attention to genuine politics and serving our community, some might argue. It will be the only way to make this plan work--not a plan of ideology, but a serving plan based on the profound ecological knowledge we know to be true and the decency of all of us who care about our forests.

You have challenged all of us to find solutions and engagement of all of the issues. We have done that and hope this is not shoved aside because of less than genuine politics.

I want to add a bit on this point. As you know I attended the Logan and Evanston oral comment hearings. We were dumbfounded by portions of the Logan hearing-- the reference to conservationists being part of a terrorist network. I'm sure you folks were stunned by those silly allegations as well. Almost exclusively conservationists in the meeting stood up and relayed specific suggestions as to how to make the Mt. Naomi Wilderness a better wilderness by recommending specific portion of the Mt. Naomi Roadless Area as wilderness. A few conservationists spoke only in general terms--most spoke specifically to areas on the larger roadless area that should be considered for wilderness.

The other set of speakers that was represented in the meeting spoke to one point-- general in nature: don't take my rights away by closing a single road, restricting snowmobiles or protecting a single acre of roadless area. The oral record will be clear on this point as you know.

Much the same happened in Evanston sans the terrorism allegations. One speaker after another spoke to: close no roads, designate no wilderness and protect no roadless areas. On the other hand HUPC, again, got up and spoke to specific portions or roadless areas needing wilderness recommendation.

I did not appreciate your closing Evanston remarks, that this was a productive and helpful meeting, Tom. I suppose there was nothing else you could say, but we await a decision by the Forest Service by way of your recommendation based on the general opposition to all preservation as heard by some in Logan and most in Evanston or whether your challenge of specificity will be met. Literally, it is a challenge of genuine politics versus disingenuous. Tom, after the Evanston meeting I was accused of living in a rock house, a worm hole and was actually grabbed and spun around by a woman who said, "Listen, Mr., connect the dots, you are trying to destroy us and we aren't going to let you."

Please accept these comments on the Proposed Forest Plan and Draft Environmental Impact Statement for the Wasatch-Cache National Forest. While we would very much like to address every geographic region within the forest plan, we are sure you understand that our comments must focus on the High Uintas, even though many of the broader policy issues can be easily transplanted within every geographic region (and issue) on the forest.

Throughout the process, long before you arrived as the Forest Supervisor in spring of 2001 we were involved in the preparation of this plan. We have attended almost every public open house, briefing and meeting dating back to the preliminary version of the AMS, 1999, proposed alternatives, scoping meetings, and DEIS open houses. We've met with you, Pam Gardiner, Deputy Forest Supervisor (and previously Acting Forest Supervisor), Melissa Blackwell, Planning Group Leader and her staff of planers, Steve Ryberg and Jane Cottrell, District Rangers and the former Forest Supervisor Bernie Weingardt numerous times. Our written comments on each of these stages have been detailed and measured. They have always started with a strong support for the openness of the process initiated by the Wasatch-Cache National Forest and often with the support and commendation of much of the planning direction as we've seen it evolve at each stage.

We stand by those comments and repeat them here!

But there is much that is of deep and profound concern and may leave the plan reeling. At almost every meeting dealing with the forest plan the equivalent of the statement that 'we wanted to do so much more' is offered. While that is true and is often actually a positive statement, in this case it seems to be a warning to lower expectations to the point that the forest plan may not actually address the real issues facing the forest. We are deeply sympathetic to the constraints placed on this process but this is not the place or time to lower expectations and quality of the plan!

The formal allegiance by way of a Cooperating Agency status with Uinta County, Wyoming, which we have personally conversed with you about, is a roaring, to the point of deafening, statement that a bias exists in the planning process. This bias is seen clearly within the social/economic analysis and review in the DEIS.

When the forest extended the comment period, as a result of a request from Uinta County, from early September to early November, although appreciated by everybody, the forest sent a signal--an expectation--that Uinta County will likely be heard with more vigor and distinction than the rest of us.

There are other deep issues of concern and we will raise them throughout this comment.

For now, we also want to raise the issue of how public comments will be utilized during this process. Many of us within the conservation community will continue to provide detailed comments, often backed up by references and citations, and have already done so across the whole planning process. Already many of our concerns and issues raised have not been responded to or utilized. This is an issue, particularly given the status of the Uinta County, WY Resource Committee. It is imperative that a clear, objective and measurable standard and process be identified to explain why a comment or suggestion will be heard or discarded.

Roadless Areas

Of course, this is probably the key issue facing the forest plan, but not only from the perspective of actual resource conflicts, because the forest plan notes for the most part roadless areas do not harbor consequential resources that seriously affect either forest outputs or economic or social valuations of the forest. Clearly, there is an issue over roadless areas at both the personal level or the broader and harder-to-grasp context "culture and custom," expressed by Uinta County, WY.

The issue write-up in the DEIS portrays this level of concern in some detail but in only a sentence of two does it discuss the real and broader issues dealing with roadless areas-- ecological integrity and value of protecting roadless areas as roadless areas. This needs to be rectified in the DEIS and forest plan because it affects the analysis of the issue in Chapters 3 and 4 which is largely a recreational based discussion.

Having said that we must acknowledge and strenuously support the forest plan's decision to implement the structure of the Roadless Area Conservation Rule (RACR) in the Preferred Alternative and the request to forest plan reviewers from the Wasatch-Cache National Forest to recognize that the roadless issue is an issue regardless of the final resting position of the RACR. While we would like to see the issue resolved at the broader policy level as per the RACR, we have always felt and said that it will be resolved at the forest plan level. Thus the importance of the forest plan. It can either be "solved,' by protecting roadless areas in the context of the RACR, via this forest plan, although probably not through a consensus, or allowed to fester. It goes without saying that disposing the roadless issue through some planning fiat is not possible and one which we would not expect to come from the WCNF. Thus the wisdom in the DEIS and forest plan of protecting roadless areas, independent of the RACR. While some would argue protecting roadless areas threatens resource outputs or custom and culture, it is imperative the burden must be on that allegation and specificity must reign. A simple allegation, although probably sincere, that 'our western Bridger Valley-way-of-life is threatened by roadless areas' certainly can be categorized but not utilized to determine a policy/planning decision since one can't see any connection. Roadless areas are and have always been part of a way of life.

Roadless areas are a limited portion of the forest, the last of their kind on this forest and have been recognized for decades now as crucial to maintaining ecological integrity of forested systems. To meet both the need for change and the Ecosystem Management Framework and the Forest Plan Model, it is obviously crucial that roadless areas be protected to assure both contexts are met. Protecting a roadless area here and one over there as isolated tracts of land renders them to the concept of real estate rather than ecological systems and simply fails to meet in any way the recognized need for change, the driving force behind issue identification and revised forest planning.

Maybe this is best shown within a Forest Service document. The Key Findings in the Columbia River Basin's Landscape Ecology Assessment (Nov. '95) states that:

"Across BLM and Forest Service lands of the basin, as well as on other ownerships, there has been a substantial decrease from historic to current of: net primary productivity, native grasslands, shrublands, riparian channel and bank conditions, old forest multi-layer, old forest single layer, scattered residual large trees, large snags, and tree species that are resistant to insects, disease, stress, and fire mortality. In contrast, there has been a substantial increase from historic to current conditions of: water balance stress, exotic and noxious plants, range, woodlands, mid -seral forests, forest canopy closure/density, small diameter trees, small snags, tree species susceptible to insect and disease, fire intensity, costs of fire suppression, fatalities and accidents related to fire suppression hazards, bare soil, and erosion rates. The decreases and increases are highest in human influenced management classes (areas w/roads and time/grazing emphasis) as compared to naturally influenced management classes (areas w/o roads and wilderness/semi-primitive emphasis)."

The last sentence, of course, is critical in the understanding of the values of roadless areas. This excerpt is the crucial one.

These values are documented over and over again, including, of course, within the Roadless Area Conservation Final Rule and Record of Decision and Final Environmental Impact Statement. The list of references below, which harbor literally hundreds of additional references specific to protection of undeveloped landscapes, speak directly to two key concerns with respect to roadless area conservation and protection: 1) the need to protect roadless landscapes for a variety of ecological reasons, and 2) the particular importance of large roadless areas conservation or the clustering of individual roadless areas to mimic large protected landscapes and minimize ecosystem fragmentation.

  • Forest Service Roads: A Synthesis of Scientific Information, USFS 1999. · Applying Ecological Principles to Management of the U.S. National Forests, Issues in Ecology, Spring 2000.
  • Principles for the Conservation of Wild Living Resources, Ecological Applications, V. 6, #2, 1996.
  • Ecological Effects of Roads, Special Section, Conservation Biology Feb., 2000.
  • Contribution of Roads to Forest Fragmentation in the Rocky Mountains, Conservation Biology, August 1996.
  • Importance of Roadless Areas in Biodiversity, Conservation Biology Institute, 1999.
  • Saving Nature's Legacy, Island Press, 1994.
  • Ghost Bears. Exploring the Biodiversity Crisis. Island Press. 1992.
  • Conservation Biology. Michael Soule', Ed. Sinauer Associates. 1986.
  • Unmanaged Landscapes, Island Press, 1999.
  • Using Focal Species in the Design of Nature Reserve Networks, Wild Earth, Winter 1998.
  • Application of Conservation Biology to Wilderness Recovery, Wild Earth, 1999.
  • End of the Road, Natural Resources Defense Council, 1999.
  • Letter from the Ecological Society of America, 9/2001.
  • A Citizens Guide to Ecosystem Management. Reed Noss. 1999. Biodiversity Legal Foundation.
  • Continental Conservation: Scientific Foundation of Regional Reserve Networks. Michael Soule and John Terbogh, eds. Island Press. 1999
  • From Aldo Leopold to the Wildlands Project. Environmental Ethics. Fall 2001.

As to the roadless areas associated with the Uintas, they meet every criterion of importance and not marginally! They are the largest roadless areas on National Forest lands in Utah and both are adjacent to extant wilderness and clustered together (the Lakes Roadless Area (LRA) is over 120,000 acres in size and separated from the main block of the Uintas by the Mirror Lake Highway.)

As to the High Uintas Roadless Area (HURA), the proposed forest plan and DEIS note the area is some 104,000 acres in size and adjacent along its entire east-west border of nearly 45 straight line miles to the High Uintas Wilderness (HUW). But that misses the point entirely. Both the Wasatch-Cache and Ashley National Forests promised us that the analysis of issues would transcend forest borders. And here it doesn't and is a serious error. The High Uintas Roadless area is not confined to the WCNF. It runs east-west across the entire North and South Slope of the Uintas for 45-70 straight-line miles in both directions, most of it contiguous to the HUW. The acreage is more like triple the 104,000 acres. While we recognize the WCNF plan can only make recommendations on its portion of the roadless landscape, it is essential for the proposed forest plan and DEIS to analyze the value of the roadless area as one huge roadless area, most of it contiguous to the HUW.

It is not two roadless areas of distinct acres and landtypes on two National Forests. While it is a hugely diverse area, it is distinctly one huge roadless area--one of the largest on National Forest lands in the lower '48!

The roadless areas on the Uintas are eminently manageable as roadless areas because of their connection the extant HUW and/or massive size and configuration--notable on the Lakes Roadless Area. On the Uintas there is the "forest" that is largely roaded, usually heavily roaded, and can be generally described as north of the North Slope Road, and the "forest" that is unroaded and generally described as south of the North Slope Road and the massive Lakes Roadless Area. This is a real, not imaginary, difference and, when described in this context, management directions seem very clear. Thus the logic of our concerns are, and we think the proposed forest plan and DEIS should be, based on this profound distinction: A significant portion of the North Slope is defined by extensive roading and human-based management-- resource outputs with a clear management direction of continued human definition of the system. It is a forest interlaced with roads. It is defined by a motorized access context. The other "forest," if you will, speaks-- sings-- to another design. It is a place where wildness, an absence of human, cultural-based fabric, defines the system.

Using this obvious and simple design--which exists--ought to determine the kind of management layered on the real ground. It is not a map. It is real, wild Earth.

The DEIS simply fails to adequately describe and note this loss if roadless areas are not preserved.

Preserving these roadless areas (HURA, LRA and Widdops Mt., although the smallest of the Uintas roadless areas, it is part and parcel with the HURA, part of the same system and shoulder of the Uintas, separated only by a rarely used dirt road ) without the obvious, roads, and activities dependent upon roads, is the common sense management design. And for the most part this preservation design should include "without motors."

(This seems to be an issue only in the context of winter recreation--the forest plan tiers, if you will, to existing travel plans but tiers future travel plans to the winter recreation decision in the forest plan. While this is understandable in some ways and recognizes a growing problem, it is not clearly stated as to why a bifurcated analysis is needed and how travel plans will be reviewed in the future. The obvious question arises-- will travel plans be updated with this split personality? Summer travel planning analyzed using the "normal" travel planning process with winter travel planning having a special persona-- the forest plan-- and not reviewed for the life of this revision... This represents an issue of consequence and needs clarification.)

But "without motors" is the essential point. Snowmobiles are the equivalent of motorized road access in the winter. They are the incongruity, the discord, in a roadless area. The literal context, the fabric from which a roadless area is woven, is profoundly altered. It is now motorized and thus roaded--the road being anywhere a snowmobile can go. Thus, in general we opposed the use of snowmobiles within these 3 Uintas roadless areas-- not because we oppose snowmobiles or want to diminish any particular user group's fun but because the literal meaning and value of a roadless areas is not just tempered, it is eliminated.

To this extent we are enclosing our Evanston/Mt. View Ranger District Proposed Travel Plan comments as Appendix 1 and a formal part of our comments. We have highlighted (yellow) the pertinent snowmobile/roadless recommendations We are doing this because it is clear that the preferred alternatives in the travel plan EA and the proposed forest plan and DEIS are identical and tiered/tied to one another. Please refer to those comments in Appendix 1 to see an analysis of this situation as it pertains to the North Slope HURA.

We also want to draw your attention, Tom and Planning Team, to the modified solution we offered originally in those comments and now in this comment. It does not recommend all of the HURA be closed to snowmobiling. Far from it! We propose to maintain the Travel Plan's Proposed Action open-to-snowmobile allocations while closing the roadless areas south of the North Slope Road on the areas where snowmobiling does not presently occur or is limited by terrain, primarily Bear River, Henrys' Fork and Beaver Creek. This approach does not alter the Proposed Action's snowmobile allocations of the currently used lands, but more vigorously meets the analysis in both the proposed Travel Plan EA and Forest Plan and DEIS of resource protection and snowmobile use areas. This focuses closures on areas adjacent to the HUW and helps resolve the issues of incursions into the HUW. Rather than simply closing all roadless areas, this suggested approach addresses the issues, the alternatives, the HUW and would still allow for considerable unused, but open roadless snowmobile acres (see map, Appendix 1.)

We raise this, Tom and Planning Team, because it was a significant part of a discussion at the September WCNF monthly breakfast meeting where we raised the concern of hearing specific proposals and you raised the concern of finding common ground and solutions. This is just that. Almost everything the snowmobile community wants and uses on the North Slope HURA remains open in this alternative. At the same time, crucial areas that are not used and are important for other values we propose to close. While it is easy to fall into the knee-jerk reaction of 'close everything because we have lost so much' or 'leave everything open because we have lost so much', same jabber, opposite side of the coin, this is far more genuine and we hope you meet your challenge to provide meaningful solutions!

As to the LRA we will provide the snowmobile analysis within our review and discussion of proposed wilderness issues.

There are 31 roadless areas that are being evaluated for wilderness recommendations (App. C, proposed Forest Plan and DEIS) on the WCNF. These three (HURA/WMRA and LRA) WCNF roadless areas account for 40% of the roadless acres on the forest! The next largest roadless area (Mt. Naomi) is 45,000 acres, considerably less than half the size of either roadless area. These are unique places in any context-- and profoundly unique on the Wasatch, within Utah and the West! And even more so as we've noted when the actual HURA is considered to be many hundreds of thousands of acres in size, most of it adjacent and all of it contiguous to the 460,000 HUW. And when the 122,000 acres LRA is considered as part of this complex, which it is, then the High Uintas roadless/designated wilderness complex becomes one of the largest undeveloped regions in the lower '48!

The proposed forest plan makes one powerful statement which must put the preservation of large, intact, integral roadless areas such as the High Uintas roadless areas at the forefront of forest planning: "One of the primary forces affecting forest plan revisions as "needs for changes" is the focus on ecosystem management and sustainability as the over-arching objective of National Forest stewardship." No matter how one tries, utilizing the concepts of ecosystem management, which implies a degree of ecological integrity as the guiding principle(s), preserving roadless areas at the scale presented by the High Uintas roadless area complex is a MUST! Discounting those roadless areas with some flimsy management direction would simply render the entire context of the forest plan and the WCNF moot and without integrity. This is the cornerstone of the planning process, at least in the case of these massive and wild roadless areas.

The issue of roadlessness has been THE driving factor in national forest management (it literally led us into the National Forest Management Act and Federal Land Policy Management Act in 1976) since the mid 1950's and long before that, in fact. The first formal Forest Service roadless inventory occurred in 1926 and has been an ongoing process since! Let's hope on areas as magnificent as this and based on the data available that this forest plan puts it to rest with a vigorous preservation direction.

As to management prescriptions, the DEIS is not clear as to why some roadless areas receive a management prescription 2.6 and some a 4.1. The prescription direction is for all intents and purposes the same. Both prescriptions speak to maintaining the natural and undeveloped environment while allowing existing uses and focusing on backcountry non-motorized recreation. Timber harvesting is not allowed, road building is not allowed, vegetation management, consistent with the intent, is allowed, including prescribed fires. The difference, if one exists, is the operative context of undeveloped areas versus recreation backcountry/ undeveloped areas.

Early on in the process we recommended the undeveloped area prescription and appreciate its inclusions in the planning process. And to allay future expectation-problems we suggest the DEIS and forest plan do one of two things:

  1. Clearly define the difference for each landscape across each alternative. Over the life of the plan it should be abundantly clear what one should expect in terms of management/ allocation actions. For example, under the Preferred Alternative, the Middle Fork Blacks Fork is 4.1/3.1 and under Alt. 2, for example, it is 2.6/3.1. Why is not clear and the difference in future actions is what is important.
  2. Or, in the alternative, and this makes more sense on the Uintas, simply put all roadless areas under the Undeveloped Area prescription because of the context and size of the roadless areas being more than double the size of the next largest roadless area on the WCNF. This would not preclude any activity different than envisioned under 4.1 with the exception of some vague recreation developments consistent with the backcountry/undeveloped nature of the area. After all these are undeveloped areas of prime note.

Any proposals to harden sites would likely be budget busters given the relatively low recreational use received in these areas as compared to other roadless areas on the forest. It appears to us that this may be a way to allow additional special use permitted actions such as yurts and the like to be utilized. This is an underhanded way to accomplish this activity, if it is so, and needs to be plainly noted in the DEIS and management prescription analysis. It also seems that since the RACR is in limbo it may well be that a supplement to the DEIS needs to be released explaining the new roadless directives pending the conclusion of legal challenges to the RACR.

Wilderness Recommendations

And, of course, roadless issues led us to the Wilderness Act, a profound and powerful piece of legislation that has easily withstood every test of time and politics! So let's not dance around that symbolic little word! While the roadless discussion/inventory is not about wilderness designation per se under the Wilderness Act of 1964, it is tied by a sound knot to that issue.

And with respect to the High Uintas roadless area complex, much of the same logic of size, shape, connection, and wildness should prompt the required wilderness recommendations. The ultimate value of the National Wilderness Preservation System, created by the 1964 Wilderness Act, is not a series of fragmented and isolated wildernesses spread across the landscape but large intact and connected ecosystems (see references noted on page 4 as they also related directly to the wilderness issue). And once again, the Uintas stand exceptionally high as already noted.

It is virtually impossible to discern the rationale utilized in the proposed Forest Plan and DEIS to make wilderness recommendations. This is a meaningful problem because we can't see the assumptions or logic attached to a recommendation, or more important, in almost every case, a no-recommendation. It is the latter that, unfortunately, defines this proposed Forest Plan and DEIS.

The DEIS states a theme(s) for each alternative and the proposed Forest Plan, of course, lays out a Desired Future Condition(s) for the Preferred Alternative but nowhere in either case is there a set of assumptions of any sort that can guide us to understand how the alternatives that make wilderness recommendations actually made them. Why were a paltry 70,000 acres, a tiny 12% of the roadless areas on the forest, recommended as wilderness? Why and how did the 26,000 acre Lakes recommendation evolve? We have heard over and over again that the proposal represents what the Kamas District thinks is manageable and what snowmobilers can live with. Tragically enough, our concerns were not consulted in such a direct fashion and that further enhances the problems with the wilderness recommendations across the forest in the Preferred Alternative, in particular!

We fully understand there is a bit of objectivity involved in making wilderness recommendations-- all the more for a clear set of assumptions and concepts that guide the actual boundary drawing process. Do these areas represent the highest of the high wilderness quality within particular roadless areas? Do they represent acres that have the least tradeoffs with some other particular set of resource needs consistent with the theme of the alternative? This is very important. Do they represent particular ecological/biological standards? Do they enhance extant wilderness? Do they meet the increasingly accepted context of protecting wilderness as large integral blocks of land able to preserve landscape systems and systemic processes?

It is here we want to interject the references on page 4 of this comment-- as you peruse those references and the dozens of citations they reference, the importance of large wilderness landscapes becomes self evident-- even more so than in the roadless discussion because wilderness has attached to it a remarkable and vigorous social and political history. It is a secure and vibrant land allocation system that has not only survived but mushroomed into a metaphysic of land preservation. It is a system that started with some 88 areas and 14.5 million acres of wilderness and primitive areas to be studied for wilderness and in a short 3 1/2 decades now consists of well over 600 areas and 105 million acres! Do they protect wilderness recreational (solitude and primitive recreation) resources-- trailheads? This is a meaningful manageability issue as well and is now fully recognized by most wilderness managers. Making a wilderness island does not make a wilderness manageable. The flow of the wilderness from the top of its drainages to the trailheads that access those places is crucial. Wilderness is not a moment or a place, even from a recreational standpoint-- it is experiential, a process of immersing oneself into the wilderness environment.

The DEIS and proposed Forest Plan miss the boat in this instance. What is the wilderness theme in the Preferred Alternative? What theme would suggest 12%? What is the difference between that theme and the Alternative 3 theme of 9% or the Alternative 4 and 5 themes of 0%? We don't pose these questions as cynical or picky-- we don't understand the context of the recommendations. While this is true for the DEIS and proposed Forest Plan as a whole, it is particularly true for the High Uintas.

While the DEIS notes the final wilderness recommendations will be made by the Regional Forester in a Record of Decision, it is imperative that the rationale for wilderness recommendations be placed forward. And that simply can't be determined in this DEIS.

Thus we make some specific recommendations as to how to (1) improve the wilderness recommendations to make them more manageable; (2) make them more consistent with the high quality roadless land involved; and (3) improve the quality of the DEIS.

Lakes Roadless Area (LRA)

What is so frustrating here is the failure of the alternatives to catch the meaning and value of this area, one of the largest intact roadless areas in Utah and the Intermountain West, for that matter. It is unusual in that it is large, "fully" shaped, adjacent to a huge designated wilderness and as remarkably diverse in topography and biology as any area in the roadless inventory.

To suggest that it is too close to an identical High Uintas Wilderness and offers only the same kind of landscape and experience misses the point in every context. First, IT IS the High Uintas as it "flows" directly from the slopes of Hayden Peak, down through the Hayden Fork and its forested slopes, up into Hayden Lake and Cutthroat Lake and over the ridge to Mt. Marsell above Cuberant Lakes and down the steep timbered slopes of the Weber, over into the Middle Fork of the Weber, much of it rarely seeing human feet, through the treacherous country of Hells Kitchen and the untrailed forests and parklands of the Jean Lake country into Smith Morehouse and over the top into Shingle Creek, the North Fork Provo and the nearly unknown Hidden Lake to Island and Long Lake and cross country through the dense forests of the upper Provo to Reids Lake, and through the spruce forests and rugged pass between Reids and Bald Mt. back into the upper Hayden Fork. One place.

So if looked at in this context--the only real view since it is the same place--the LRA is deeply enhanced as a potential wilderness, not an island of wilderness separated from its main block, if you will, but part of the weave of the High Uintas Wilderness and roadless ecosystem. This context, a science based context (see the references noted earlier), is belittled by the Preferred Alternative's treatment of the roadless areas-- an isolated, cut-off, island of 26,000 acres, a mere 21% of what is recognized, even by the Forest Service in the DEIS, as a premier, massive and diverse roadless area.

Suggesting it is 'too much like the High Uintas Wilderness' also equally misses the point. The Uinta Mountain Ecosystem Management Project, Ashley, Wasatch-Cache, and Uinta National Forests, notes just how distinct this area is by placing it in a subsection of its own, the West Flank Uintas. This ecological subsection, of course, correlates directly with the LRA. What makes it so unique is a combination of sage, oak, aspen, cottonwood and mt. brush vegetation types along with the more traditional lodgepole pine and spruce/fir communities. This is one of the few places in Utah where large areas of unroaded and undeveloped lower-mid elevation, diverse forests exist. Associated with these landscapes and part of and resulting from them are unique wildlife populations and ecological processes. They also add to the sense of wilderness (which we talked about above) in that they provide the flow of an experience in a truly wild region--not just a high elevation coniferous forest, but a whole system of landscape types are encountered with a hike up Shingle Creek or Red Pine or Yellow Pine.

The DEIS (App. C) belittles the supporters and the value of the LRA with a constant suggestion that snowmobiling is the primary constraint against wilderness designation, going so far as to suggest snowmobiling is very popular in the area, particularly in the outer "42%" portion of the area.

Not surprisingly, no data is offered to suggest how heavy or where this mysterious 42% of the area is harbored. Interestingly, the DEIS section(s) on winter recreation makes no mention of this conflict and particularly no mention of the 42% figure--if we read this correctly about 51,240 acres. The proposed Forest Plan makes no such distinction either. Incredibly important allocations are being proposed without the slightest bit of information and without a disclosure as to where, what and how this 42% figure came into existence. In numerous discussions with the District Ranger on this issue specifically, we've never heard or encountered this reference in spite of direct discussions and questioning as to the extent of snowmobiling in the LRA. Consistently the answer has been snowmobiling is limited at best and focused on the Mirror Lake Highway, Soapstone and Whitney areas--all roaded.

As to the core of the area being rugged and thus available to the "highly skilled and adventuresome snowmobiler," the same set of questions exist. How much use is occurring? What and where is the interior that is discussed here? Is this backcountry area the only region available to that kind of snowmobiling use? What makes the Kamas Ranger District feel this use must be encountered and met in the interior of the area? What will be the actual impacts to the "highly skilled and adventuresome snowmobiler" if this particular area is not made available to that kind of use? What is a "highly skilled and adventuresome snowmobiler" anyway? Does that kind of use/user have to be associated with the LRA? Why isn't' it available in Soapstone or Current Creek or Wolf Creek or Hardware or Whitney? Other than the statement apparently made to the Wasatch by some snowmobiler(s) that the core of the LRA is needed for this kind of use/user, what and why is this important for that use/user?

All of these are factors that should have gone into the analysis in the DEIS but are seemingly invisible. There is no comparison between alternatives that is helpful or meaningful to show lost snowmobile opportunities including the skilled and adventuresome type. In reality, how much less snowmobiling will there be between the Alt. 2 LRA wilderness recommendation than Alt. 6 for example?

The truth is there is very limited snowmobiling terrain on the roadless portions of the North Fork Provo or Shingle Creek, Box Canyon, Red Pine or Dry Fork. On the other hand there is considerable highly skilled (and less skilled) use on and around the clear cuts in the Spring Canyon/semi-primitive roaded developed lakes area. This makes perfect sense actually and meets the developed roaded motorized context while protecting the highest quality backcountry.

And, of course, there exists the broader issue-- the purpose of a forest plan that is missed in this instance-- just how long, given the discussion of projected snowmobile increases will this backcountry skilled snowmobile use remain light and thus offering the rationale for the activity? Fifteen years ago a trip up the Mirror Lake Highway would have qualified for this kind of event! While we have been promised a monitoring/winter recreation analysis as per the Mirror Lake Snowmobiling SUP appeal resolution, nothing exits now and will exist for at least two years. On the other hand, there exists a Lakes Backcountry Management Plan and a HUW Management Plan to analyze/monitor summer recreation use. At the minimum, prior to completing the plan the Wasatch should not formally authorize this kind of use.

Unless the Wasatch can show why this laissez-fare (or laissez-passer) attitude toward snowmobiling is the appropriate approach to planning, then the agency should do what its forest planning suggests--plan and positively state that the LRA backcountry is either the appropriate place of this kind of long term use or isn't. We've laid out a powerful rationale why it isn't.

While the area is recognized as potential lynx habitat and it is noted (DEIS App. C) this is an issue with winter recreation, there is ZERO analysis. NEPA is not met by simply saying there is a meaningful and documented potential impact and leaving it at that. Whether lynx are present or not is irrelevant--the issue is habitat. If this weren't potential lynx habitat there would be no issue. Furthermore, it is not the Mirror Lake Highway or Soapstone or Whitney where this quality habitat exists and where lynx are likely to survive--it is the backcountry. And without a doubt, based on the literature, the marginality of anthropogenic impacts of even small proportions increases hugely in areas where there is little or no anthropogenic disturbance to lynx. Thus the likelihood of negatively effecting lynx habitat along the Mirror Lake Highway and small corridor alongside the highway is considerably less than 1/2 mile off that corridor within the LRA. So the question becomes, and was clearly begged off in the DEIS, what is the best way to assure lynx habitat (and wildlife habitat)? Is it allowing snowmobiling use to grow and grow in an area which has none or very little right now or to protect the viable ecological values inherent to the area and not in any need of snowmobiling?

We are also interested in the assertion in the DEIS, Appendix C, that leaving the area as a backcountry area, specifically not designated as wilderness, is less expensive and more economically efficient to manage than a designated wilderness. This has been a myth perpetuated by the Forest Service and some of its old time wilderness opponents for years. We would like to see documentation of this statement. Is this true if the LRA backcountry is open and actively managed as a snowmobile area? Areas pinpointed by the snowmobile community and acquiesced to by the Forest Service will not remain hidden-- they will require an immense management cost to administer the snowmobile use. To even suggest the Mirror Lake Highway and its campgrounds are less of a burden to the Kamas District than the Naturalist Basin within the HUW is absurd. If the backcountry is "hardened" as is suggested in the DEIS and if snowmobiling becomes a major winter past time within the area, an economic stress will certainly be created--one which at least the Wasatch agrees isn't needed. It is just that the analysis seems to be fabricated!

We also noted that there are some suitable timber acres found within the LRA. Yet no map is offered to show where they are. We will discuss this in more detail in a later section of this comment but it only makes sense to document with a map the suitable timber acres. Back in September 2000 we provided a detailed comment on the Preliminary Alternatives for the Forest Plan revision. In that letter we suggested a much more realistic and fair allocation of roadless acres recommended for wilderness based on clear principles of recommending wildernesses that add to the extant National Wilderness Preservation System (NWPS) areas and more equitably meet the themes of each alternative. Our suggestions were, not surprisingly, ignored and we've never heard a response to that comment. While we will focus on the LRA and HURA we also want to again recommend a similar proposal for the forest's roadless areas/ wilderness recommendations which we will provide as a table in our comment/discussion surrounding the HURA analysis.

As to the LRA wilderness recommendations per alternative, we suggest a more rational and meaningful distribution:

Table 1
Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt 5 Alt 6
119,041 a. 71,896 a. 0 0 26,253 a. ~57,222 a.

The logic is clear. Alt. 3 represents the original proposed action--why that alternative is carried forward is beyond us! Alt 4 is the current direction which says the plan must be revised but is being used as the no action comparison-- an ironic and odd twist, to say the least! Alt. 5 is the development proposal.

The only changes we propose are within Alts. 5 and 6. The Alt. 5 recommendation represents the extant Alt. 6 proposal--we categorically reject and ask you to reconsider the development rural lifestyle alternative's no-wilderness-recommendations across the board. I live in a rural area and in no way, shape or form are all rural residents categorically opposed to all wilderness, LRA or others! The alternative represents a bias that is not found in reality and does not belong in a forest plan. It is an alternative meant to appease Uintah County, WY-- your supposed working partners-- who have been anything but partners. You wouldn't even consider an all-wilderness alternative, nor would we, and therefore an action-based alternative of no-wilderness has no place in this process!

The Preferred Alternative is altered to reflect the direction contemplated in 1984-- the preservation of a conflict-free, large, integral roadless landscape. Of course, this area represents the former semi-primitive non-motorized area designated in the 1985 Forest Plan and considered for the extant Lakes Backcountry Management Plan. With the exception of the absence of Shingle Creek, it represents the highest of the high quality roadless lands within the LRA. It is a highly manageable area, large (50,000+ acres), making it an imprint addition to the NWPS and much needed logical progression from the previous forest plan. This history of the roadless area needs to be understood by this version Wasatch-Cache National Forest. In the 1972 Roadless Area Review Evaluation (RARE), it received the highest quality index rating in the Utah. In RARE II it then received the highest Wilderness Attribute Rating (WAR) in Utah and the nation. The anti-wilderness position by the Forest Service, in spite of its own clear rating of the area as being one of he most eminently qualified areas in the lower '48, has always been dubious. We finally arrive at the point where the agency can step out from under those old cultural traditions, and for that we are grateful, but the step is small, timid and still counter to the value of protecting as wilderness under the NWPS meaningfully large, integral wildernesses. The 26,000 acres proposal is just over 20% of the roadless acreage and is smaller than the Lone Peak Wilderness. It is an opportunity lost and in need of fixing!

Obviously we fully support the proposed wilderness recommendation in Alternative 2 as it represents years of work by HUPC (and, before that, the Utah Wilderness Association). It stands out for a variety of reasons: 1) it is large enough to encompass the flow of complete watersheds from trailhead to headwaters on Shingle Creek, Yellowpine, Slate Creek, North Fork Provo, both major Weber drainages, Dry Fork and Smith Morehouse; 2) it is manageable a wilderness for much the same reason--it is an integral wild system; 3) it maximizes the biological diversity within the area by protecting the broad U shaped glacial high elevation valleys and landscapes on the east end, the dense forests at mid elevations as the area dips to the West along with the sage, oak and aspen landscapes of Yellowpine, Shingle Creek, So. Fork Weber and Red Pine; 4) it encompasses the majority of the backcountry recreation trails that provide access through the wildness of the region; 5) and it does all of this on about 60% of the roadless acreage (~72,000 a. of the 122,000 a. roadless area)-- the undeniably roadless portion of the area. The western and northwestern portions of the roadless area are excluded from this wilderness recommendation as they possess a number of long standing conflicts dealing with access, thus avoiding a number of cherrystem issues which admittedly denigrate the manageability of the wilderness.

This proposal, again, reflects and meets the challenge posed by the Forest Service to seek resolutions rather than ideologies. Over 50,000 acres of the roadless area are not recommended as wilderness to meet a variety of other resource and public concerns while seeking to preserve as wilderness the highest value and most wild backcountry of the roadless area. Rather than being an island of tiny wilderness--serving no recreational or biological purpose, as the extant Alt., 6 suggests--this concept/context preserves the highest value wilderness while still meeting the access issues that have been identified as important.

We want to be clear on one point; while we have suggested a different presentation of alternatives to make the DEIS and eventually FEIS more reflective of public concerns and broad resource allocations, we fully support and hope the inclusion of the ~72,000 acre proposed wilderness on the LRA will be reflected in the preferred and chosen alternative in the FEIS!

At the minimum whatever wilderness recommendation is made on the LRA the boundary on the Weber River (Main and Middle Fork) must be brought to the trailheads that access those places--Pass Lake, Bald Mt. and Crystal Lake Trailheads. We have noted the importance of the flow of wilderness as a recreational, management and ecological resource and of necessity that entails the protection of both access and full drainages. The spectacular North Fork Provo drainage must be included. This drainage is remote, rarely visited and presents some of the most stunning and wild country on the LRA. The canyon is deep, rugged, timbered. The canyon bottom is filled with aspen, cottonwoods and small meadowlands adjacent to the river itself. A climb out of the canyon is over one bench after the next and if you are coming out in the right place you are greeted with one of the least visited little lakes in the Uintas--an elongated unnamed lake of immense solitude. Golden eagles are common in the canyon. The Provo drainage's Hidden Lake is found here--rarely ever visited. Dense forests of lodgepole pine, intermixed with aspen and some spruce, grace this large valley and low pass.

This, of course, includes the high lakes within the Provo River Drainage, notably the reser- voired lakes now stabilized, acting as the natural lakes that they are, and clearly meeting the definition of wilderness. Long, Island, Duck, Fire, Weir, and Pot Lakes are all stunning reminders of just how wild and beautiful this country is at over 10,000 feet in elevation, shadowed by dense pine and spruce forests, small meadow complexes and streams and a series of low passes dotted with numerous bogs and potholes all drifting toward the headwaters of the North Fork of the Provo River and its long isolated descent through the heart of the most wild of the LRA down to the Mirror Lake Highway.

On the other hand the much less rugged and steep Shingle Creek is a must addition as well. In this case because it represents the epitome of the lower elevation drainages. While it flows up into the glacial Erickson Basin, much of it a picturesque drainage of aspen forest, some cottonwoods, a vibrant riparian system, potholes, bogs Doug-fir, blue spruce, mt. shrubs and sagebrush parklands. It is a remarkable journey and holds together the ecological integrity of the LRA as it connects the lower reaches with Erickson Basin, over into Smith Morehouse and the broad densely forested passes dropping into the North for Provo. An isolated island of the LRA does not deserve wilderness recommendation. That is a timid response out of an old fear of wilderness designation. It keeps wilderness in the rocks, if you will, and doesn't allow it to be the ecological entity the NWPS envisioned. And then with a terrible irony the Forest Service says, 'see, wilderness isn't an ecological resource.' The 26,000 floating acres perpetuates the idea that wilderness is difficult to manage and at best is a recreational resource of high elevation glacial basins. It is not and it is quite surprising to see this forest, this Kamas District, in fact, hold so tightly to those archaic cultural values.

Snowmobiles and roadless (wilderness also, of course) areas are an anathema. If snowmobiles roam and run on roadless landscapes, it is not roadless because snowmobiles are the roads! The change the fundamental character of the area in the same manner a road changes the character of a roadless area. We re-emphasize, the logic of the FEIS and Proposed Forest Plan should be based on the profound distinction between the roaded and unroaded forest. A significant portion of the North Slope and Kamas Ranger district is defined by extensive roading and human-based management-- resource outputs with a clear management direction of continued human definition of the system. It is a forest interlaced with roads. It is defined by a motorized access context. The other "forest," if you will, speaks-- sings-- to another design. It is a place where wildness, an absence of human, cultural-based fabric, defines the system. Placing motors in this system completely changes the place. Its definition is remade, whether humans hear or see the snowmobiles, for example. Using this obvious and simple design--which exists--ought to determine the kind of management layered on the real ground. It is not a map. It is real, wild Earth.

High Uintas Roadless Area (HURA)

While we have made many of our points in the above related discussion dealing with snowmobile access and roadless area protection, we do want to focus a vigorous argument for additional wilderness recommendations on the North Slope.

First and foremost, unlike the tiny, fragmented, island wilderness recommendation on the LRA, we find the proposal on the North Slope within Alt. 6 to be far more strategic, albeit every bit as timid and fearful of wilderness as the LRA. And because of that we are perplexed. The DEIS and Proposed Forest Plan simply don't, as we've noted, adequately explain the rationale or assumptions that were used to explain wilderness recommendations. The falling back to tiny wilderness recommendations (22% of the HURA on this forest) representing only small segments of large roadless areas simply makes no ecological sense and is not representative of your public who care deeply about wilderness.

As to the HURA wilderness recommendations per alternative we again suggest a more rational and meaningful distribution:

Table 2
Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt 5 Alt 6
98,226 a. ~85,000a. 18,165 a. 0 20,116 a. 29,303 a.

The logic is clear. Alt. 3 represents the original proposed action--why that alternative is carried forward is beyond us!; Alt 4 is the current direction which says the plan must be revised but is being used as the no action comparison--an ironic an odd twist too say the least!; Alt. 5 is the development proposal.

The changes we suggest are within Alts. 2, 5 and 6. The Alt. 5 recommendation represents the extant Alt. 6 proposal--we categorically reject and ask you to reconsider the development rural lifestyle alternative's no-wilderness-recommendations across the board. I live in a rural area and in no way shape or form are all rural residents categorically opposed to all wilderness, HURA or others! The alternative represents a bias that is not found in reality and does not belong in a forest plan. It is an alternative meant to appease Uintah County, WY--your supposed working partners--who have been anything but partners. You wouldn't even consider an all-wilderness alternative, nor would we, and therefore an action-based alternative of no-wilderness has no place in this process!

The proposed revised Alt. 2 (see Appendix 2 map) is more consistent with the theme and context of Alternative 2, large protected wildernesses, and the approach taken with the LRA--it is basically the acreage proposed by the High Uintas Preservation Council as wilderness on the North Slope--about 82% of the roadless acreage. This recommendation enhances the wilderness values by proposing to designate large contiguous areas that are highly manageable, undeniably roadless, and harbor trailhead to headwaters. This alternative array makes for a much more defensible set of alternatives and represents a true array, from the Alt. 1 wilderness recommendation of 95%, Alt. 2, 82%, Alt. 3, 17%, Alt. 4, 0, Alt. 5, 19% and Alt. 6, 28%.

The Preferred Alternative is altered to reflect what seems to be the theme of the alternative--protection of high quality, conflict-free wilderness. Almost everything in this revised set of alternatives is protected under the extant Alt. 6 as management prescription 2.6 or 4.1, noting plainly that no meaningful resource conflicts exist. This proposed change would show the Wasatch is not quite so timid about wilderness recommendations and understands the need to protect the flow of wilderness values, not simply isolate them.

This history of the roadless area also needs to be understood by this version of the Wasatch- Cache National Forest. In the 1972 Roadless Area Review Evaluation (RARE) the HURA was intentionally divided into two contiguous and wholly adjacent roadless areas, Bald Mt. and the North Slope. Under that process, the larger an area the higher its total quality index rating. The effort to undermine this rating process, by making one roadless area into two separate roadless areas, was exposed and, in part, led to the demise of RARE. In RARE II this single roadless areas received the highest Wilderness Attribute Rating (WAR) in Utah and the nation. We finally arrive at the point where the agency step out from under old cultural traditions and recognize the remarkable value of this roadless country and its undeniable potential and value to the HUW and the NWPS and what we see, unfortunately, is a step too small. It is an opportunity lost and in need of fixing!

We want to be clear one point: while we have suggested a different presentation of alternatives to make the DEIS and eventually FEIS more reflective of public concerns and broad resource allocations, we fully support and hope the inclusion of the ~85,000 acre proposed wilderness on the HURA will be reflected in the preferred and chosen alternative in the FEIS!

This alternative represents years of work by HUPC (and before that the Utah Wilderness Association). It stands out for a variety of reasons: 1) it is large enough to encompass the flow of complete watersheds from trailhead to headwaters; 2) it is manageable as wilderness for much the same reason-- it is an integral wild system; 3) it maximizes the biological diversity within the area by protecting the higher quality undeveloped forested systems leading into the higher elevations; 4) it encompasses the majority of the backcountry recreation trails that provide access through the wildness of the region; 5) and it does all of this on about 82% of the roadless acreage-- the undeniably roadless portion of the area. It avoids the long fingers on portions of the Bear River, W. Fork Smiths Fork and E. Fork Smiths Fork drainages along with the small strips of roadless land adjacent to heavily developed and harvested areas including the intermingled ownership on the Blacks Fork as well as areas where controversies exist with roads and access.

This proposal, again, reflects and meets the challenge posed by the Forest Service to seek resolutions rather than ideologies. Over ~18,000 acres of the roadless area are not recommended as wilderness to meet a variety of other resource and public concerns while seeking to preserve as wilderness the highest value and most wild backcountry of the HURA. The recommendation we've made enhances the viability of the proposed wilderness in every context, expanding the northern border to be consistent with trailheads, high wilderness values and adding meaningful ecological diversity to the HUW. It does all of this without impacting other non-roadless resources with the exception of minor concerns on the far eastern end of the proposal. Almost all of the proposed recommendation comes from lands in the extant alternative that would be protected under Management Prescriptions 2.6 and 4.1!

And certainly this recommendation is far more reflective and responsive to your stakeholders, or whatever we are called nowadays, who are deeply concerned with wilderness values!

At the minimum, whatever wilderness recommendation is made on the HURA, the recommendation needs to include:

Middle Fork Blacks Fork

From hundreds of tiny rivulets melting from late-summer snowfields on the shoulder of Tokewanna Peak to its confluence with the West Fork, the Middle Fork Blacks Fork is the least disturbed major drainage on the Uintas' North Slope. Recent studies show the Middle Fork and its Brush Creek tributary harbor one of the few remaining essentially pure populations of Colorado cutthroat trout, perhaps the rarest of all the inland cutthroats. They have found refuge in this remote drainage, free from the damage caused by road building and easy angler access that plagues most of their range.

A hike up the Middle Fork is a hike through a quiet drainage. Sprawling wet and dry meadows offer striking views of Tokewanna Peak. Beaver dams, built almost entirely of lodgepole pine, form quiet pools for native cutthroats. But it is a good day's walk with a light load to reach the Wilderness boundary from the trailhead-- the wildest, yet least protected, of the Uintas drainages.

Many users of the Uintas, from hunters and anglers to backpackers and wilderness enthusiasts, consider the Middle Fork of the Blacks Fork one of the most wild rivers and drainages on the Uintas. About two miles is within the HUW and the rest is adjacent. It is a large meandering river from its inception. Working up the drainage it is river dominated by huge forested slopes with portions of the river forested to its banks. Other portions open into wide expansive meadows where the river meanders and flows quietly and deeply. Beaver are noticeable. Pine marten are seen. The great gray owl is tucked in these deep old growth forests. Moose roam throughout the drainage. Coyotes, black bear and even cougar are seen here. At least two species of woodpeckers are found in these forests. There are a couple of huge rock slides. Like the West Fork Blacks Fork, hikers are in touch with this river since they must cross it back and forth, working their way up through lodgepole pine forest to classic subalpine parklands and spruce fir forests. The river circles in and about these meadows and the base of 13,000 foot Tokewanna Peak. Literally the Middle Fork starts on the shoulder of this massif. Early in the summer I've seen sandhill cranes and listened and watched common loons stop over here as they migrate north. A hike up here on a hit and miss trail is a hike in wildness, from trailhead to headwaters.

This omission is mysterious because in every aspect and every category the values are concomitant with the East Fork and the West Fork of the Blacks Fork, maybe more so. The drainage is certainly wilder.

The proposed inclusion consists of about 5,200 acres and is represented by Management Prescription 4.1 and 3.1 on the Alt. 6 map.

West Fork Beaver Creek

The proposed wilderness recommendation in Alts. 2, 3 and the Preferred Alternative on the West Fork Beaver Creek is strategic and to be commended, but it is a half step. Instead of bringing the boundary back to a manageable area at the trailhead and road, the boundary cuts across the heart, the very middle of the drainage, adding about a mile of the river to the wilderness recommendation and still leaving almost three miles of the drainage, all spectacular and undeniably roadless country, between the proposed wilderness boundary and the trailhead! What sense is there to this recommendation? None offered by the DEIS for any of these alternatives, particularly the Preferred Alternative. It misses the point made in this comment some pages back about the need to protect the small portion of the forest that remains undeveloped-- that demarcation provides so much common sense to management and allocation that it is silly and frustrating that it is not seen by the Wasatch in this DEIS. The acreage we are talking about on the West Fork Beaver Creek is less than 3,000 acres!

This portion of the West Fork of Beaver Creek contains some of the most wild and least impacted roadless lands on the North Slope. This area is typified by lush forested riparian areas and scattered meadows. Potholes are frequent and resting ducks are a common sight during the summer months. The West Fork is a unique drainage of acre after acre of forests inhabiting a wide and gently sloping valley. Rather than the deep canyons of the Bear or the wide open glacial remnants of the Blacks Fork this drainage is neatly tucked in dense forests that give way to easy slopes and steppes and sort of drift to the Henrys Fork on the west and the Middle Fork the Beaver on the east. It is the literal center of the most expansive forested ecosystems on the Uintas. We have watched goshawks, seen pine marten and this is the habitat where the lynx stalks snowshoe hares (snowshoe hares are commonly seen, if searched for, in this and the Middle Fork drainages) and where the wolverine can still find real refuge. Early in the summer on both the Middle Fork and West Fork of the Beaver Creek we have watched the visiting common loon rest on many of the larger ponds prior to its magnificent trek northward. Both drainages receive very limited human use notching the wildness factor up even a bit more. We have seen bear tracks commonly on this portion of the West Fork.

This again is large country adjacent to the HUW, taking its headwaters from the Wilderness and inseparable in its wildness.

And in an interesting twist, the Forest Service Wild and Scenic River Eligibility Report found the entire length of the West Fork of Beaver Creek, from headwaters to forest boundary, some 10+ miles, as free flowing and containing numerous outstandingly remarkable values so as to qualify as eligible for a Wild classification under the Wild and Scenic Rivers Act. Ironically, the wilderness recommendation leaves, as noted, a meaningful ribbon of this river, around 3 miles, out of the proposed wilderness recommendation!

Burnt Fork/Thompson Fork/Kabell Creek

Probably the most disappointing set of wilderness recommendations on the North Slope is this region on the eastern end of the Uintas. Unlike the western end of the Uintas, which receives a great deal of wilderness use, this area receives limited use and much of this country is as wild as anywhere on the Uintas.

Of course, in this case Alt. 1 best catches the value of these areas--all of them high quality roadless landscapes and undeniably roadless. There are few conflicts--no oil and gas, limited timber resources (primarily on the lower Kabell and Beaver Meadow Reservoir area), light recreational use and prohibitive snowmobile terrain (see proposed Alternative for the Evanston/Mt. View Travel Plan). The value of this small 9,600 acre area is the fact that it represents a remarkable ecological diversity and extends the wilderness down to the trailhead and road boundary.

The recently reintroduced bighorn sheep find both summer and winter range in this area of open north/south ridges like Burnt Ridge and Kabell Ridge and on the numerous east/west hogbacks. These east west hogbacks are found in roaded terrain but are critical for bighorn sheep; most of the remaining reaches are roadless. This area is unique as the alpine and open subalpine ridges extend further north than anywhere in the Uintas, offering a vast panorama of wild land.

The roadless portion of Thompson Creek runs through rolling forested terrain with the rare Colorado Cutthroat and drains the open flanks of Thompson Peak and Burnt Ridge, habitat for bighorn sheep. The roadless upper portion of Kabell Creek, a tributary to Thompson Creek, drains the lush Kabell Meadows in the wilderness. Burnt Fork flows through a remarkably steep, narrow, forested canyon. This roadless canyon reportedly contains Colorado cutthroat trout. The huge meadows of Big and McCoy Parks and the wet meadows on the ridge to the north form roadless headwaters of Beaver Meadows Reservoir.

This is wonderful subalpine country with lots of classic spruce stands. Numerous high elevation potholes make for rich wetlands and numerous species of resting ducks, moose and pine marten. The feel of the place is entirely different than the Uintas to the west, including the neighboring drainages of Beaver Creek. This is high country which elevates distinctly, but not steeply, and offers unmatched vistas into and out of this high country. Traversing across Thompson Creek or Kabell Creek, one is simply spellbound by the high peaks as a backdrop and the undulating drainages of spruce, fir, open wet meadows and potholes. The peaks are different-- they have become rounded and separate peaks, almost plateaus--the beginning of the bollies.

Again, this is large country adjacent to the Wilderness, taking its headwaters from the Wilderness and inseparable in its wildness, is lightly visited country and extreme in its naturalness and isolation.

In an interesting twist, the Forest Service Wild and Scenic River Eligibility Report found the entire length of Thompson Creek, from headwaters to the Hoop Lake diversion, some 5+ miles, as free flowing and containing numerous outstandingly remarkable values so as to qualify as eligible for a Wild classification under the Wild and Scenic Rivers Act. Ironically, the wilderness recommendation leaves the entire drainage out of the proposed wilderness recommendation!

Hayden Fork/Main Fork/Stillwater/Boundary Creek

The best way to describe the country, in the context of this priority minimum wilderness recommendation, would be to use the Preferred Alternative management prescriptions, 2.5 and 2.6 on the Hayden Fork and Main Fork drainages and the 4.1 and 3.1 on the Stillwater and Boundary Creek drainages, south of the Bear River Smiths Fork Trail and adjacent to the extant HUW and recommended wilderness, management prescription 1.5. This represents only about 12,000 acres.

Hayden Fork/Upper Main Fork

The spectacular descent of Hayden Fork from its sources in the Hayden Peak springs and broad meadows near the Highline Trailhead constitutes the classic scenic view along the Mirror Lake Scenic Byway. Moose, a myriad bird species, deer, elk, mammals... all frequent this panoramic river course. It resembles a living museum as one travels the route from the Stillwater turnoff up to Hayden Pass. This country, a wild drainage visually so close but in walking quite rugged to reach (and therefore essentially unvisited by humans except those who tackle a route into Kermsuh/West Basin up and over the Kletting/ Hayden ridge from the highway), is pristine in its gorgeous forested descent and sheer mountain walls. To imagine oil/gas trappings in this "viewshed" is to imagine the destruction of a familiar wild monument countless Wyoming, Utah and regional visitors have taken for granted in their visit to the High Uintas Wilderness. The canyon beckons, "Here lies wild country."

Over the ridge to the east of Hayden Fork is an untrailed drainage that joins the Hayden at the highway and Hayden Fork Campground. It is part of this entire ecosystem of wild country and hosts the most elusive of wildlife species ... here one can imagine wolverine, pine marten, goshawk, lynx are finding refuge. It is this breadth of wildness that gives the Uintas its rich character. These are not places humans have defined or sung. These are places integral to the survival of the wild inhabitants and vegetation and health of the range. These are the places, these unnamed drainages, that compose the music of the Uintas, the wind, the rain, the snow, the bark and blossom and birdsong of the range.

Hayden Fork is literally a wilderness trailhead experience assuring wildness from trailhead to wilderness and flows right from the HUW down A-1, Kletting and Hayden Peaks--the massif western wilderness boundary first visible from Bald Mt. Pass. It is wilderness!

Stillwater

A tangle of aspen clutters the bumpy, twisted terrain along the road up Stillwater Fork. To the west in a shaded ravine the river races to join the Hayden Fork. Patches of sky, canopy of aspen, dotting of pine...then that breathtaking view of Ostler and LaMott Peaks high above the sweeping meadows of this riverine valley. The meadows demand a stop, a welcome annual survey of the great tilting world of mountains, forest and meadow. On one forested flank of the river nestle summer homes, on the other a steep incline of forest leading east across the flank of the Uintas into the roadless country of the East Fork Bear and beyond to the Wilderness. The naming of the river becomes apparent: the luxuriant grasses of the Stillwater Basin invite exploration of deep, clear potholes and crystalline waters. Trout skim along the shadowy banks; did you see the moose in the aspen, there, among those rocks? And that nest... could it belong to a goshawk? Time to count the wildflowers: spring beauty first, paintbrush, gilia, shooting star, yarrow, and late blooming purple gentian. A dash of watercolor, a sketch of pastel blooms, an ink outline of pines... Stillwater: the dream of artists and birders and other seekers of wild beauty.

Here are the spectacular narrows of a canyon, rich in birds and mammals and sunshine on traveling days, rain on nourishing days. The Stillwater Canyon is a deep canyon showing signs of numerous snow slides, thus dotted with aspen showing the power of natural disturbance regime. About 2 miles from the trailhead one enters the High Uintas Wilderness on a small unnamed and untrailed drainage, that if followed to the west, crosses a number of avalanche paths on open slopes of aspen and into a small and delicate basin forested with spruce and lodgepole, a few small untouched meadows and two tiny ponds, vibrant with aquatic wildlife. I have seen bear tracks here and spent a few of the quietest nights ever! Dense cover, isolated, open aspen slopes make for a vibrant riverine system.

And it meets, also with ease, the roadless characteristics. It is large, contiguous and in conjunction it its sub-drainages, the Hayden and Main Forks, and the neighboring Boundary Creek and East Fork of the Bear River, possesses remarkable isolation and natural integrity. Furthermore the protection of the Stillwater is crucial to the manageability of the High Uintas Wilderness since it is the access to the High Uintas Wilderness and the popular Amethyst and upper Stillwater Basins. It is a fundamental piece of the wilderness concept. The soul of the Stillwater starts within the designated wilderness and flows through wildness. Isolating the lower reaches off the Stillwater's wilderness and wildness from the designated Wilderness is administratively and biologically dishonest.

Boundary Creek

Boundary Creek is a small isolated drainage with its headwaters at Baker Lake. In many ways it is a refuge. For years it has not been grazed. There is no formal trailhead and the trail into the area is unmarked and rarely visited. It is a like a drainage enveloped and surrounded by the much larger and visible East Fork and Stillwater. The river bottom is unique in that it is a densely forested drainage. From the wetlands of Baker Lake, where the visitor can bask in the beauty of stunning peaks at the headlands of the basin, the creek gently flows through a forested wood of pine, spruce and fir with aspen dotting some of the open avalanche chutes. Meandering through willows where moose snip tips off the budding plants, where pine marten run the limbs of dark pines in search of squirrels and birds, where ouzel dips along splashed rocks, Boundary Creek is spectacular in its simplicity, its offering of life as the forest has always offered it. A rugged, forested trek from the springs and ponds half a mile below Baker Lake leads to Scow Lake in a marvelous hidden saddle between the Stillwater and Boundary Creek. The forests are old, harboring numerous interior forest birds such as flickers and three-toed woodpeckers. We've seen pine marten and bear tracks along the small creek.

Its ultimate value is that while it is connected and in the heart of the wild country on the western end of the Uintas, it is wholly composed of a mid-elevation lodgepole pine forest with its headwaters not in a alpine basin, but in a stunning small open forest parkland.

And in an interesting set of twist and turns, the Wasatch-Cache Wild and Scenic River Eligibility Report found the entire lengths of the Hayden Fork, Boundary Creek and the Stillwater, from headwaters to mouth, over 18 miles, as free flowing and containing numerous outstandingly remarkable values so as to qualify as eligible for a Wild or Scenic classification under the Wild and Scenic Rivers Act. Ironically, the Preferred Alternative wilderness recommendation leaves, as noted, most of these drainages out of the proposed wilderness.

A significant portion of the North Slope is defined by extensive roading and human-based management--resource outputs with a clear management direction of continued human definition of the system. It is a forest interlaced with roads. It is defined by a motorized access context. The other "forest," if you will, speaks--sings--to another design. It is a place where wildness, an absence of human, cultural-based fabric, defines the system. Placing motors and their counterparts in this system completely changes the place. Its definition is remade. Using this obvious and simple design--which exists--ought to determine the kind of management layered on the real ground. It is not a map. It is real, wild Earth.

Such a powerful and profound opportunity exists in this plan to actually move forward on this issue. If it is missed we know the consequences--more irreversible loss and more incessant conflict. If it is engaged as we have suggested, while some will be upset on the short term, the long term management will be stabilized and the issues of the day met. Resource impacts will not be sacrificed, that is obviously made clear by the DEIS and proposed forest plan; snowmobiles will continue to have the run of the forest-- that, too, is obviously made clear by the DEIS and forest plan. And the challenge the Forest Service has made--find specific solutions that are not unilateral in context--has been met. It will be up to the Wasatch-Cache to show all of us that challenge has been met!

Oil and Gas Leasing

We applaud the DEIS and proposed forest plan for the context and direction with respect to oil and gas leasing. Given the fact that 148,000 acres of the North Slope are under lease or proposed for leasing and that all of the lands in this analysis are roadless landscapes (North Flank Fault) with a proven track record of no discoveries and an RFD suggesting that discovery potential is very limited on the North Flank Fault and far less limited on the Moxa Arch, the recommendation to limit leasing is one of obvious common sense based on the best available data! The question is whether the lands should come under an NSO or NL recommendation. We will address that shortly.

But first, the DEIS suggests that one of the reasons for limited drilling has been unavailable lands that create a "financial risk." While source is cited (a personal communication), this needs some considerable explanation. The financial risk is inherent in the leasing/development process, as we've been told ad nauseam, by the oil and gas interests and now by the Forest Service (Burkhardt's personal communication cited in the EIS). Of course, there is no financial risk at all associated with lands not under lease--only the lands leased present a challenge to the industry. Thus the issue is how much less financial risk is associated with additional leasing. Of course, this is linked to the Table Top Unit where small tracts of land are not leased. Simply because the industry contends a financial burden exists if those small tracts are not leased does not mean there is a financial risk or threat to the industry. This is a meaningful issue and analysis if it is the point on which this issue turns...and that appears to be the case. The difference in risk matters and not simply because the industry threatens that we will not drill unless leased.

It is also noted in the DEIS and attributed to Burkhardt (2001) that a NSO stipulation may lead to limited exploratory wells due to the complex geology and other factors and "the uncertainty of being able to develop a field due to surface constraints, should one be developed." This is downright disingenuous, maybe even dishonest. The industry constantly reminds us that directional drilling has become relatively easy and sure-footed, first, and second, remember the RFD suggests there is no chance of a field within the North Flank Fault, just the likelihood of an exploratory well over the RFD scenario. And third, the connection between the constraints of an exploratory well and "the uncertainty of being able to develop a field due to surface constraints, should one be developed" is plain bogus. Once a field has been discovered there are no surface constraints. There is no connection between the surface constraints associated with exploratory drilling and surface constraints of a new field. NONE!

If the allegation is that NSO may constrain the identification of a field, then analyze that with more than what the DEIS says--it will be harder. That is not adequate. Provide some rationale, particularly in the context of the DEIS RFD, which suggests that a field is not going to occur on the North Flank Fault, but along with up to 5 exploratory wells may occur on the areas north of the North Flank Fault.

The DEIS also desperately tries to show the issue of oil and gas leasing is an access issue with roads translated into acres of development. The DEIS fails to catch the significance and permanence of the real issue--allocation. That is what needs to be discussed to make the NEPA analysis adequate, thorough and honest! Once an area is leased for oil and gas the consequences of management permanently change in that the lease prerogatives holds ultimate sway when the lease is activated. While an exploratory well or even a small field, which is all that is proposed under this scenario, may constitute a reasonably small discrete acreage, the impacts of the development scenario far exceed that acreage. It is that context that needs analysis--roadless turned to roaded, semi-primitive turned to "concentrated development."

The DEIS notes that not-leasing may preclude the opportunity to develop an oil and gas field, access reservoirs from adjacent leased lands and recover financial resources related to federal returns to counties or states. While these stand alone statements are true and, to some, ominous sounding, they are as out of context as suggesting the far side of the Universe is as close as a worm hole. If the likelihood of oil and gas discovery is low, as the DEIS and proposed forest plan's RFD note, then not-leasing precludes any losses of any sort. If there were any known adjacent fields to the areas not-leased that could not be accessed from within the extant field or somewhere else then this is an issue. But it is not the case. Context of an analysis matters as the DEIS and proposed forest plan suggest in the early chapters by way of topics needing revision, issues and utilizing an adaptive planning process.

We feel it is imperative now that RACR is in limbo to maintain the same logic in the DEIS and proposed forest plan This is a sound and common sense approach to leasing. As we understand the DEIS and proposed forest plan, it applies to at least Alternatives 1, 2 and 6, for example. Alt. 1 precludes leasing unleased areas within Table Top and prescribes a NL category for leases as they expire. Alt. 2, like Alt. 6 provides for a NSO on the Table Top area. The Preferred Alternative would allow a CSU lease option on that portion of the roadless area allocated to a "non roadless" prescription when leases would expire.

But from an analytical standpoint we don't understand the pronouncements, made as irrefutable, that directional drilling can't occur in Alts. 2 or 6, for example. The implication is the exploratory seismic work can't be read in a directional context. That is simply contrary to geophysical review. This must be explained in more detail.

While we have some concerns as expressed about the difference and the intent of management prescriptions 2.6 and 4.1, we also have concerns over why both prescriptions in Alt. 2 and 6, just for example, have the same lease terms--NSO. It would seem the intent of the prescriptions is that 2.6 harbors a greater ecological/undeveloped/roadless integrity component and that it should receive an across the board NL category within the appeal settlement zone.

More importantly and thoroughly, the lease category ought to have a deep connection to the RFD. We believe the appeal settlement zone is contained almost exclusively within the North Flank Fault where field development is not predicted or likely and even where only one exploratory well is proposed over any given period of time. Given this, the lease category should be a NL, since the value of the roadless area is so high. Where roadless landscapes are found within the other two faults, particularly the Moxa Arch, an NSO for either prescription 2.6 or 4.1 is more appropriate.

The cumulative effects section fails to catch the concern that if additional leasing is allowed, even NSO, that may lead to field development. This changes the allocation context of the landscape, regardless of the management prescription. This change in allocation is much more meaningful that a few acres or miles of roads--the entire forest landscape changes from a semi-primitive or primitive landscape to a "concentrated development landscape." That is not a minor change. The impacts upon wildlife (there is no discussion of lynx or lynx management units, for example) and natural processes are of even greater import in that the landscapes under consideration for leasing or continued leasing and potential development are landscapes that bear minimal human/anthropogenic impacts so the footprint, if you will, is even more shocking. It is abundantly clear this is quite unlikely, we agree, given the RFD for the appeal settlement zone roadless areas within the North Flank Fault. That makes it even more important that the DEIS and proposed forest plan recommend a NL for these lands in order to make a clear and concise set of land management expectations based on the best information and value of these wild landscapes.

Timber Suitability

Let us start where we started back in the early to mid 1980s with respect to the "first" forest plan which is now being revised. Then and now we do not see a map of "tentatively suited" lands or the "suitable timber" lands. It does not appear they are harbored within a particular management prescription and are thus seen through a prescription.

This is important for obvious reasons--it is where, theoretically, the forest harvesting will occur or has been precluded due to other prescription direction. It must be clearly mapped by regulation and therefore should be easily portrayed. It wasn't in the" "first" forest plan, it isn't now and we've asked for such a map on many occasions over the years and have not yet seen it.

Having made that point, let us note the direction in this section of the DEIS and proposed forest plan, like that of the Oil and Gas Leasing section, is noteworthy and positive.

The DEIS notes that while some of the WCNF may be predisposed toward insect activity... "because of fire suppression," mt. pine beetle infestations are at low endemic levels. The two statements seem contradictory and need clarification.

The DEIS also notes that the ASQ is associated only with suitable lands but that in some cases timber harvest could come from lands that are not tentatively suited or from roadless areas. The DEIS does not quantify those volumes or the time frames associated with this harvest, opting to suggest volumes could be substantial but not offered on a regular basis. This is simply not an adequate analysis for a DEIS. If the timber resource is going to be regulated, it is imperative that there be a more firm discussion about how this timber resource will be harvested. The indication is that offerings would be based on "opportunities and funding availability" -- neither of which are explained, nor is the meaning of substantial. Managing a forest to meet long term sustained yield requires a significant degree of predicable and known timing of growth and removal that can't simply be tuned to "opportunities" or funding. What happens if the funding is available and the opportunities are not? Or the opportunities, whatever they are--they need much more clarity-- available and funding not? There are clearly no opportunities in that case. Funding, really, seems to be the issue, in this case. Not opportunities based on some vague concept of restoration. If this is not the case then it is imperative to understand what triggers a timber sale that is outside of the timber prescription or suitable base. This needs far more review if it is to be carried forward.

And therein lies a great deal of confusion. The DEIS states that "tentatively suited lands are the same for all alternatives." But in no table is that indicated. Furthermore, the Preferred Alternative notes that 28,900 "total suited acres" would allow timber harvesting on the Uinta Mts., producing an ASQ of 1.5 mmbf. However, Table 2.1 shows that for the Preferred Alternative management prescription 5.2, the specific timber harvest prescription to be 34,800 acres. Table TM-2 shows that "total acres" for the Preferred Alternative is 101,000 acres-what is that? We can add numbers up easily enough but we can't understand the intent or categories they represent.

The DEIS has a short discussion on the impacts of lynx upon timber harvesting but shows nothing with respect to lynx management units or any other wildlife species on an alternative by alternative basis. It notes impacts will be meaningful on lynx if timber harvesting occurs, but that is as far as the DEIS goes. That is not far enough. It is one thing to have large areas of suitable timber and high ASQs as a theoretical context (alt. 5, for example) but no specific discussion as to how lynx and lynx management units (no discussion of lynx management units are found in the DEIS--an error that seems consequential to say the least) will be negatively impacted and thus reduce timber harvesting potential. In other words, the connection between the acres, ASQ and the constraining resources does not seem to exist.

Although very inexact analyses exist in the DEIS for resource values along with a cumulative effects section, it is simply too loose to mean anything. The analysis is so qualitative as to verge on unedifying. The question isn't that Alt.1 may increase bug mortality more than Alt. 5 and Alt. 5 decreases bug mortality more than Alt. 6--what does that tell a reviewer? The question is does Alt. 1 or Alt. 2 create a situation that allows bugs to exceed a historical ecological variability? And, if so, how can that be when the alternatives basically allow the natural processes not to be mimicked but to operate? If bugs are out of an ecological historical variability then the obvious source has to be the tinkering of humans in these forested environments--exclusion of fire or creation of forest structure that is beyond what the system is designed to tolerate.

In the cumulative effects section it is noted that a no harvest option, Alt. 1, for example, will create the least resistance to uncharacteristic wildfire and some undefined level of insect and disease. There is no definition as to what uncharacteristic wildfire means. Earlier in this section of the DEIS it is noted disease and insects are part and parcel of a forest yet here is a suggestion that insects and disease are a function of not logging a forest. Maybe it was possible to get away with such loose concepts 30, 40, or 50 years ago, but not today. The question is will Alt. 1 create a condition that makes the forest less integral or less functioning, than, for example, Alts. 2 or 5 or 6?

Hiding behind the fear of an uncharacteristic fire in the day and age of ecological literacy isn't a helpful direction. No matter where you look on the Uintas, where regulated, active timber harvest will and can take place, the elevation, the short summers, and the incredibly varied topography and land type/diversity with short spatial regions will limit the uncharacteristic fire. These are the kind of issues that need to be addressed and analyzed.

The Cumulative Effects section of the DEIS brings in an issue of impacts to adjacent non- Forest Service lands as a possible concern, yet it is not raised anywhere else in the Timber Suitability chapter to give it context and then only with respect to Alt. 1!

Combined with the changing timber demand, which to the credit of the DEIS is noted, and the clear discussion in the socioeconomic section, it is obvious timber harvesting is not an issue of consequence on the forest. It is equally clear whatever state of dysfunction exists within forest systems on the Uintas it has been woven by past timber harvesting and fire exclusion which have drastically changed the structure and components of native forests. Additional timber harvesting in largely unharvested areas will not address these problems and will add to them.

To that extent we have a very difficult time understanding why any timber/forest vegetation management prescription is allocated for any of the roadless lands on the North Slope. (The DEIS should show, because of the long standing importance of the roadless issue, the amount of the 1.5 mmbf ASQ that will come from the roadless area as well as the predicted non- regulated harvest.)

This issue is part and parcel of the deepest discussion surrounding the WCNF--the value and importance of allowing undisturbed landscapes to stay in that condition--to be woven and unraveled by the miraculous and inherent ecological forces. While the DEIS touches the issues of roadlessness, it simply does not negotiate the waters very well--the loss after timber harvesting is injected is not just a loss of a roadless area on a map. It is the loss of the function characteristics of the process called roadless. That has become the fundamental issue of the 20th century and now the 21 century with respect to forest management, not because of recreation or aesthetics, though both play a powerful role in the discussion of the issue, but because of the inherent value of these systems at providing refuge for the ecological processes that sustain life systems. The references we provided back in the roadless and wilderness discussion of this comment speak directly and clearly to this issue.

For the most part the Preferred Alternative grasps this and portrays it! But it holds steadfastly to old proposals on the eastern end of the Uintas in the Kabell/Burnt Fork and Thompson/Beaver Meadows Reservoir. All of this over a perfectly natural pine beetle infestation, "Condition Red," which has now left a few hundred acres of standing dead trees, not all dead and standing for a number of years now. The fear expressed is they will fall at once and a conflagration will ensue. So be it, but it won't be a conflagration and the question is just how much the fuel loading will increase over time and whether that will alter the fire sensitivity of the system. That has not been addressed!

Neither have issues surrounding the very premise of this forest plan--ecosystem management-- as it pertains to impacts upon avian species, soil /organic matter decomposition, nutrient retention, all of which are crucial to today's timber harvesting issues. The literature is clear--forests that are functioning as inherently intended are integral and healthy--those that are on the receiving end of roads, culverts, saws and the like are where the forest management problems exist. Given that we support the effort to achieve restoration and mimic historical variability on those areas already harvested--generally north of the North Slope Road and within heavily roaded and developed landscapes. Other than that there is no point to timber harvesting simply because the problems created will far exceed the philosophical discomfort and ecological illiteracy associated with a forest doing what it does--grow old, get sick and die over an exceptionally diverse spatial and temporal framework.

And one last point of which we mean not to be picky but to bring to your collective conscience the deep bias the agency still has with the timber folks. The DEIS notes, "Our interviews with processors..." Obviously these interviews were more than meetings but direct formal interviews with the timber industry to help determine the status of the industry and the supply of logs from the WCNF.

In all of the years I've been involved in these kind of issues I've never been formally interviewed about the value, location, quality, priority, context of a roadless area, or a wilderness management issue! At best, I would say that we have had to fight to get the Forest Service to acknowledge a preservation, conservation or wilderness management issue. Yes, we submit maps and comments and, yes, you read them, but the intent is very different. I look forward to the day that the Forest Service formally asks other "experts" for their best information and suggestions as to the value of a host of other resources--not just range or timber or oil and gas or snowmobile concerns.

Wilderness Management

We just don't know what to say anymore. There is no place where the double speak, intentional, I'm afraid, is so profound. On the one hand, the DEIS and Proposed Forest Plan speak properly and hopefully to the concepts of ecological values of wilderness, not just recreational values--in fact, it is stated clearly in the alternatives' discussions, the forest plan goals, even in the early parts of the issues analyses.

Then it all falls apart. The analysis on non-native mt. goat introductions is missing in spite of clear policy statements by the Forest Service that mt. goats are not native and do not belong and should not be introduced into designated wilderness landscapes. There is no discussion of introducing mt. goats into landscapes directly or immediately adjacent to designated wilderness and the obvious impacts of movement into designated wilderness. There is no discussion of the reams of data and sources we and others have provided to the Forest Service raising this issue(s) and showing, beyond a doubt, that mt. goats are not native to this part of the world and can't be introduced into designated wilderness environments under law and regulation (see Appendix 3)--a position supported by the Forest Service The issue is barely even glossed over, despite the clear directional statement in the DEIS and Proposed Forest Plan that it needs to be analyzed. (The WCNF has been provided a copy of "Utah's Rocky Mountain Goats: A Crisis in Management," Oct. 2000, Pete Hovingh.)

There was no discussion of impacts to goats to the context of wilderness and the likely long term physical impacts of mt. goats on those high elevation designated wilderness environments. There was no discussion as to how to deal with the hundreds of mt. goats that now reside in the High Uintas Wilderness and the immediately adjacent LRA.

In part the rationale seems to be a blatant decision to not address this concern because of "politics," less than genuine, we might add, and in part due to conflicting direction from within the Forest Service. However, conflicting direction does and should not translate into an intentional paralysis. The purpose of a forest plan is to address those conflicts in the context of the best scientific information in the context of the archway of this plan--ecosystem management.

The same concerns exist with respect to non-native recreational based fish stocking within designated wilderness. The plan is silent on the single scientific/ecological/ecosystem direction-- fish stocking in high mountain wilderness lakes where fish were not native is having serious impacts upon those lake ecosystems (see Table 3) below for just a few of the most recent studies detailing fish stocking in issues). The plan simply notes fishing is important to some users--there is not even an analysis how that value has changed dramatically over the years and is documented for portions of the High Uintas Wilderness. The irony is the cutting down of green trees for pine bow beds or lean-to shelters was and is important to some visitors yet the agency has moved aggressively to halt that behavior. But not with respect to a clearly documented ecological/ecosystem threats posed by a traditional practice.

Table 3
  • The Introduction of Nonnative Fish into Wilderness Lakes: Good Intentions, Conflicting Mandates, and Unintended Consequences; Wilderness Fish Stocking: History and Perspective; The Wilderness Act and Fish Stocking: An Overview of Legislation, Judicial Interpretation, and Agency Implementation; Geography of Invasion in Mountain Streams: Consequences of Headwater Lake Fish Introductions; Alteration of Nutrient Cycles and Algal Production Resulting from Fish Introductions into Mountain Lakes; Local and Landscape Effects of Introduced Trout on Amphibians in Historically Fishless Watersheds; The Effects of Stocking and Removal of a Nonnative Salmonid on the Plankton of an Alpine Lake. Ecosystems (2001) 4: 279-286
  • Resistance and Resilience. Ecological Monographs, 71, 401 (2001)
  • An Evaluation of Restoration Efforts in Fishless Lakes Stocked with Exotic Trout. Conservation Biology. December 2000.
  • Non-Native Fish Introduction and the Decline of the Mountain Yellow-Legged Frog from within Protected Areas. Conservation Biology, April 2000.
  • The Status of Fish Populations and Management of High Mountain Lakes in the Western United States. Northwest Science.1992.
  • A Study of High Mountain Lake Fish Stocking Effects in the U.S. Sierra Nevada Wilderness. International Journal of Wilderness. April 1999

The reason? Disingenuous politics. The DEIS Proposed Forest Plan direction is clear--the analysis and response isn't. The DEIS and Proposed Forest Plan doesn't discuss the fact there is no required memorandum of agreement between UDWR and the WCNF with respect to fish stocking in the HUW. These wilderness management issues are simply glossed over. While the skeletal direction in the DEIS and Proposed Forest Plan is meaningful and we support it, the necessary analysis is profoundly lacking and makes us, again, question whether we really are going to be heard. There is no other direction for this plan to take but set up a phase-out process for fish stocking in wilderness until and as part of the required but not yet extant memorandum of agreement--we have discussed this with you ad nauseam.

And clearly, direction in the DEIS and Proposed Forest Plan must be clear with respect to non-native mt. goat introduction in and adjacent to wilderness where the likelihood or intent is to get mt. goats into the HUW--no more. It is a simple standard and it is simply disingenuous and dishonest to do anything else.

The discussion about grazing effects on wilderness is horribly amiss. Of course there are impacts on wilderness and it matters not an iota that grazing is allowed in wilderness. Impacts on users, wildlife, predators are all worthy of analysis. Furthermore, the DEIS is confused about the impacts of wilderness on grazing levels and privileges. What the law states plainly is that grazing cannot be terminated solely because of the wilderness designation. That is all. Resource impacts, and by definition resources in designated wilderness are wilderness resources, will be the determinates, not the wilderness designation. Furthermore, disposition of vacant allotments certainly can be made based on wilderness resources and wilderness itself. The fact that they are vacant is the standard--an active allotment certainly can't be vacated or grazing terminated/reduced solely because of the wilderness designation. Those actions can be accomplished based on impact to the wilderness resources. Since a vacant allotment is not actively grazed or allocated to any grazing management practices, it can and should be terminated based on wilderness!

The section on recreational impacts is awfully lightweight as well! We were glad to see the issue of fish stocking is recognized as an impact to some lake basins in that it increases possible recreational use and thus physical impacts at campsites and in the lake area. What the Proposed Forest Plan and DEIS fail to do, however, is to analyze that concern in something more than the most broad, generic, qualitative language--a problem with the entire recreation impacts on wilderness analysis.

It is noted in the DEIS that to meet the intent of the Wilderness Act and improve ecosystem health the Proposed Forest Plan provides direction for wildland fire within designated wildernesses. But only in the most minimalist and broadest terms imaginable is such direction provided. Unfortunately neither the DEIS or Proposed Forest Plan provide direction when and how that broad direction will be turned into specific wildland fire direction. Only the HUW presently has a wildland fire plan and it is, at best, nearly meaningless and was not even subject to any public review!

Finally the Proposed Forest Plan provides a guide as to when wilderness management plans, presumably the place where a wildland fire plan would be developed(?), will be prepared or updated. Unbelievably enough what the schedule calls for is the better part of a decade of time to pass before many wildernesses get a wilderness management plan! Mt. Naomi has one, in theory (I doubt anybody can actually pinpoint a completion date!!), although it has never been implemented or monitored and it will not be updated until 2006(!). Deseret Peak has been a wilderness since 1984 and won't have a wilderness management plan until 2008, the Wellsvilles not until 2010, even the Wasatch Front areas, designated since 1984, won't see a plan until 2004. If anything ever suggests NEGLECT and a deep lack of concern for wilderness it is this schedule. It is shameful. Decades have gone by and the Proposed Forest Plan and DEIS suggest even more time should float by before doing what should have been done decades back! Although we have made this point many times and most of those on the WCNF privately agree, the concern is registered by the WCNF like the proverbial water off a duck's back--so what...

And, of course, most troubling is the HUW Management Plan. While the skeleton of it was completed in 1997, a mere 13 years after designation as wilderness, the implementation of the plan, which includes the all-important and all-crucial monitoring plan, HAS NOT BEEN COMPLETED! That has been a 4 year effort and is still not done, with no indication from either forest as to when it will be completed.

We suggest the Proposed Forest Plan adopt a streamlined plan completion process:

  • W Front Areas-2004
  • Deseret Peak-2005
  • Naomi/Wellsvilles-2006-7
  • HUW-2007-8

This is not an impossible time line. And it is the only right thing to do given the neglect offered up for so long. Each plan could easily build from the previous plan and considerable work has been done on many of these areas for an updated plan to hook onto! Furthermore, at numerous WCNF breakfast meetings we have discussed, for example, growing use problems on Deseret Peak ,which has not received attention, additional use problems on the Uintas, including frequent snowmobile and mt. bike trespass, and at the Logan forest plan oral hearing it was noted by a number of snowmobilers, some intentional and defiantly and some unintentional, that snowmobile trespass into the Mt. Naomi is anything but infrequent! Same stuff we've provided to the WCNF on many occasions!

Those represent issues also ignored, improperly, in the DEIS. The documentation has been made and is clear and made clearer at the above referenced Logan hearing.

Rangeland Capability and Suitability

The DEIS notes capable rangelands do not change per alternative and account for some 27%, 340,992 acres, of the WCNF. This should make them easy to map and display, yet like the timber suitability acres there appears to be no such map or direct connection with a particular management prescription. There should be and we urge and request that you incorporate it into the forest plan maps. In particular a map of capable lands within each allotment is essential.

And therein lies a problem. The DEIS notes capable lands are oftentimes unevenly scattered and separated. What this means, of course, is (1) that sheep and cattle, in particular (although it may be true to a lesser degree for recreational horse use), utilize more lands than the capable rangelands. This is obvious and has been recognized but not dealt with in a professional manner due to what is obviously a special relationship between the Forest Service and livestock interests. Livestock may not eat what has been determined to be capable and are likely eating and impacting lands that have clearly been determined not to be capable. Furthermore, they walk and rest oftentimes on lands deemed not capable. Thus the impacts of grazing are far outside of the lands determined to be capable for livestock grazing. Thus grazing capacities, especially the way they are determined in the DEIS and Proposed Forest Plan, represent, at best, a rough estimate of AUMs determined by grazing levels and forage production on these unevenly and separated capable lands for the decade of the 1990s. Again, this has been recognized but not dealt with simply because of the disingenuous politics surrounding grazing. As the DEIS notes this is the only way to justify/rationalize a grazing program on much of the WCNF because if grazing output were done professionally, scienti- fically and honestly, as noted in the DEIS, there would be such a small potential output that grazing would be exceptionally limited or ended all together.

The proof is in this corrupt and weak process and the fact that the DEIS notes that NOT one management area on the WCNF has even 50% of its acres as capable lands for grazing! Two of the lowest are the two Uintas management areas at 21% and 24%.

What this really shows is that the vast majority of the forest is not capable of sustaining domestic grazing--the DEIS notes that only 27% of its land has been found suitable rangeland and that only 23 % of the land on the two Uinta management areas is capable rangeland!

Yet grazing goes on with a wink and a nod impacting a huge piece of land that is connected and unscattered. What an irony-- outside of the suitable rangelands. And this is not even discussed in the DEIS. That is inappropriate and improper even though it has gone on for a long, long time.

The DEIS notes that demand is below the permitted grazing levels for a number of reasons, including voluntary and involuntary reductions, limited budgets by the WCNF to implement capital improvements, and range developments, among others. The implication seems to be an attempt to cover up the fact that, as the DEIS notes, "The extent to which the overall demand for livestock forage is being met has not been determined." There is evidence noted above that the supply of forage for grazing far exceeds the land's capacity to provide grazing. Furthermore, the actual use is meaningfully below the term permitted use suggesting the WCNF has set grazing numbers too high.

What the DEIS seems to try to say is that neither is the case and these discrepancies really are "our fault" in that we don't have the money to pay for range permittee improvements or that we have forced grazers to give up numbers. The DEIS is at fault for making assertions attributed to "range conservationists who work directly with permit holders..." and not providing an iota of data that explains that assertion. For example, an involuntary reeducation is solely a function of the grazer exceeding capacity for some reason--a deeply legitimate reason for authorized use being less than permitted! We are curious as to what kind of improvements would have allowed authorized use to meet permitted use?

Of course, the problem with condition and trend is that very small areas have actually been analyzed. Estimations run the day. And while this is understandable to some degree, the vast majority of the acres are either undetermined or estimated to be moving toward objectives and that isn't good enough in that grazing numbers have not been altered or reduced or seasons meaningfully altered until ground truthing can be achieved. That is the wise and prudent professional approach that is needed for forest planning, particularly given the fact that the DEIS notes the required and necessary Riparian Value Rating system is not in place. Until that occurs and additional ground truthing actually verifies trend and condition movement in a statistically significant manner, grazing must be minimized to be appropriately cautious.

The DEIS notes a number of allotments are vacant and in various alternatives proposes to close all or some of them to grazing. However, the DEIS errs by not providing names or maps of those allotments so reviewers can see whether the proposed analysis in the DEIS as to impacts from closing those allotments is consistent with the location of the allotments. Thus we urge and request that you provide a map of the forest allotments, vacant and used, as well as the three sheep allotments that if voluntarily waived without preference would benefit bighorn sheep.

The DEIS notes that closing the 13 vacant allotments would have positive effects on all non-grazing resources but only chooses to close 3 allotments in the Proposed Forest Plan and DEIS Preferred Alternative. The primary reasons offered not to take advantage of this remarkable opportunity are:

  1. Suitable rangelands acres would be reduced.
  2. Estimated grazing outputs would be reduced.
  3. Reduce grazing flexibility by eliminating allotments that could alternate forage to resolve allotment.
  4. These allotments offer alternative forage in drought years.
  5. Closing these vacant allotments may affect management of private lands surrounding the forest. This represents spurious rationale at the very best, does not belong in the DEIS analysis, and if offered these arguments should be clarified and properly analyzed.

The DEIS does note that each of the reasons above depends upon site specific conditions, thus the obvious concerns:

  1. How much additional grazing and to what benefit would the lost suitable acres and allotments provide? They are vacant now so they are providing no "grazing benefits." In other words, there are no losses. The issues of costs, both ecologically and financially, must, in that case, be weighed before filling any of those allotments. And with the recognized budget problems that the DEIS notes that has already prevented a proper and full range management program, why would a prudent and professional public resource management add to that dilemma by opening a vacant allotment? Lost suitable acres mean nothing by themselves. This analysis is missing in the DEIS.
  2. By how much would estimated grazing outputs be reduced? Because they are vacant now there are no outputs associated with the allotments so, in fact, they are no reductions. The reduction is a theoretical, non existent reduction dependent upon site specific conditions which may include other resource conflicts, limitations, drought or economic constraints. Adding grazing pressure would likely create impacts to these vacant allotments and this must be considered and isn't!
  3. The flexibility argument is particularly bogus and misleading. The assumption seems to be that if Allotment A develops problems with grazing capacity then the AUMs could be moved to Allotment B, C, D.... This assumes they are the appropriate allotments (cattle or sheep), have the same capacity, are in the same condition and trend, assuming that is positive, meeting management objectives, in the same vicinity and land type and harbor no other site specific conditions that would create additional conflicts. The simple assertion in the DEIS isn't appropriate!
  4. This argument is a variation on the theme above. If drought conditions menace an allotment then the grazing capacity, if these allotments are not closed, may be moved to another allotment. Of course, this assumes they are the appropriate allotments (cattle or sheep), have the same capacity, are in the same condition and trend, assuming that is positive, meeting management objectives, in the same vicinity and land type and harbor no other site specific conditions that would create additional conflicts. And the big assumption is that drought conditions would be very geographically specific, affecting only Allotment A and not B. The chances of that are very slim unless the intent is to simply stress Allotment B, C, D... in the same manner that Allotment A was stressed due to drought. If that is the case, then the whole purpose of range management has been subverted, not to mention the context and integrity of the forest plan and planning process! Of course, none of this is analyzed or raised in the DEIS.
  5. We are having a difficult time understanding the strawman arguments in this section of the DEIS. We fully recognize that some forest users are more equal than others-- Forest Service grazing permittees are at the top of that list, thus the weak arguments raised to rationalize grazing where there is no rationale with respect to closed allotments. The mere assertion that private land may be affected by closing vacant allotments needs to be critically addressed, not just offered up as a generic concern. The particular allotments obviously must have some physical connection to surrounding private lands as well as similar rangeland capabilities and use patterns. In other words, the arguments here are much the same as those in the above discussion. The simple indistinct qualitative statements need a bit of definition and clarity to assure the arguments are specific to the particular private lands and specific, particular allotments in question.

It is obvious that all 13 allotments could be, SHOULD BE, closed under the Preferred Alternative without any but theoretical ramifications. Only benefits would accrue--riparian, soils, wildlife, recreation, WCNF budget. Range conservationists' WCNF rangeland direction would be consolidated and focused on the true grazing issues on the forest.

The DEIS states that access for grazing management in wildernesses may have historically used unclassified roads and that this may, the DEIS implies, have some kind of an impact on grazing outputs. There is nothing specific that is noted, only implied, with the conclusion that these unclassified roads "may have to be authorized specifically" or closed, requiring non-motorized access.

This is a misleading statement in that it is used as a threat against wilderness. As the WCNF knows, this issue was addressed on the West Fork Blacks Fork cattle gazing permit. The Wilderness Act and regulations prohibit the use of motorized access for grazing purposes unless a regular historical record of motorized access predated the wilderness designation, is necessary for continued grazing, and has been thoroughly documented. Occasional use or use not recognized and authorized specifically by the Forest Service in the grazing permit literally doesn't count! A theoretical standard of may-have-used and now may have to be authorized also doesn't count!

The DEIS suggests an interesting solution to one particular grazing conflict--the HUW sheep versus bighorn sheep grazing issue-- by suggesting 3 permits would be closed to grazing to protect bighorn sheep if these permits were waived by the permittee without preference. Fat chance-- at least as the DEIS and Proposed Forest Plan is set up with respect to maintaining the extant grazing outputs. While we believe the Desired Future Conditions and Alternative Direction in most of the alternatives, and particularly within Alts 1, 2 and 6, for example, plainly directs the FS to do just this; there is no connection--a major problem with the DEIS.

To meet the alternative direction and DFC it makes far more sense to initiate the phase out of these 3 allotments by simply noting in the Preferred Alternative and Proposed Forest Plan that these allotments are essential to recovery of a native species, wilderness and roadless integrity, maintenance of wildlife corridors, species viability and that they represent special habitats. To that extent the allotments should be phased out over a 10 year period. This will give the permittee adequate time to respond and assure the planning direction and expectations are met. If this isn't done, the whole planning effort and all of its direction and DFC remain hollow. The plan has given a special formal status to Uinta County, WY and, from the statements made at the Evanston forest plan hearing (10/17), it is clear their interests coincide with snowmobile, road access and grazing, anything but a full spectrum of multiple uses, and anything but fair. And now the direction in the Proposed Forest Plan states rather clearly that grazing is the other special status (actually it joins snowmobile access, particularly on the Kamas and Logan Ranger Districts) as the proposed decisions simply do not match up with the impacts, need for change and proposed management direction. A simple and cursory look at the suitable rangeland as a percent of capable rangelands per alternative tells this story, as well: from Alternative 1 to 6 it reads, 83%, 83%, 92%, 92%, 92%, 86%! Talk about sameness and special status!

Social and Economic Analysis

There is much left dangling in this section and while the bottom line of the whole chapter is that the forest is not singularly economically important to any particular segment of the broader society, the WCNF is important to all segments of that broader social context. The only problem is the DEIS and Proposed Forest Plan bends and contorts itself in such an obvious and biased manner to assure local communities, a definition that is suspect from the start, that they matter more, have more weight and are better defined and thus more influential.

That is an unfortunate state of affairs because from the outset the DEIS and Proposed Forest Plan imply that "local" means an attitude that opposes wilderness, fears roadless protection, and wants to graze, timber, snowmobile, and develop the forest's "resources." That is what makes this chapter so unfortunate.

This unfortunate state of affairs starts with the DEIS noting that local communities are the basis for analysis and that local communities are composed of long time residents that want to know resources will be developed. Because local communities have only minimal ties to the forest based on later analysis in the DEIS, they are given their own study area status in order to highlight them. While the latter can be understood, the former is without basis-- the DEIS presents no formal surveys that suggest local communities, long time residents and development of resources are in any way connected! It is the myth of rural versus urban attitudes.

We've already commented upon the formal status offered Uinta County, WY and in combination with the analysis in this section that starts from the premise that certain users (local communities) advocating traditional resource development (grazing, timber, motorized access) are of heightened importance and one can only sit back and recognize the analysis is biased from the inception. From a professional planning process the bias in unfair and thus is the analysis! There exists a further bias-- to simply tag "local communities" as a monolithic body typical of resource development is not established. The entire analysis seems built to appease the Uinta County, WY resources group which later became the foundation for the Uinta County Cooperating Agency.

The essence of the analysis is that at a statewide level the WCNF has a limited effect upon any economy analysis factor. The same holds true for a regional view and almost exclusively is true (grazing seems to be the only exception and that is really associated with only one Utah county) at even the local community level. That is because, as the DEIS notes, local communities with the exception of Rich County, UT have grown dramatically in every analytical facet and have thus seen a tremendous diversification of economies. This diversification has resulted in delimiting the traditional resource related economies and in some case those economies have shrunk considerably as a result of the diversification.

What is so frustrating is that while the DEIS notes all of this rather plainly, the analysis continues to come back to the old adage of resource outputs (the triumvirate of grazing, timber and motorized access) are important to the local community identity and of economic value to the individuals involved in the outputs.

While the latter is true, there is powerful evidence in the DEIS analysis that the value of one particular job is of no greater relative import than another job and the local economies are generally very elastic.

Furthermore, the DEIS notes that "relatively large numbers of people" have grazing permits but does not provide that number. We beg to differ and urge the DEIS to disclose the number of permittees--no name or places, just the number-- that graze the Uintas as part of the WCNF! This is a blatant mis-statement, not from the Forest Service we hope, but from the Uinta County Cooperating Agency and its puppeteer, the local Resource Committee.

We find it not the least bit amusing that under the Recreation and Tourism portion of this chapter there is no mention of wilderness or roadless in the context of "wildlife viewing." Furthermore no attempt is even made to note the financial value, since that all this section is associated with backpacking, hiking, and backcountry recreation of any sort. There are outputs associated with hiking, wilderness and backcountry recreation and they are simply shoved aside without even a mention of their relative importance and the value to the individual users.

There is a benefit/cost discussion. But for a benefit/cost analysis to be meaningful from a public policy standpoint, there must be a full accounting of benefits and costs. The DEIS notes that because some "nonuse" benefits are difficult to analyze, they were not utilized in the B:C analysis. That is convenient, but not good or acceptable public policy in the context of professional planning process. This is augmented by the fact that the DEIS offers no accounting for "nonuse" values using any recognized for economic valuation. The DEIS simply says it is too complicated and assures the reader that there are, no doubt, nonuse or non- consumptive values associated with the WCNF!

That is both unfair and unprofessional. Complex it is but not impossible--in fact, it is a routine analytical context.

The PNV for grazing notes that grazing output would remain constant for the 50 year time frame. Yet the EIS notes that grazing output has altered dramatically within this time frame. This is a deep bias which maintains grazing at undoubtedly high levels. At the minimum grazing outputs over the future half century should be reduced by as much as they have been reduced over the last half century! Certainly the restrictions, though few they may be, will have reduction-impacts over the next half century!

The same holds true for the mining analysis. The frustration here is the DEIS even notes the 50 year PNV output is unlikely and unreal but goes right on forward anyway! If it is an absurd or dull analysis, remove it!

Once again the DEIS notes in the alternative comparisons with respect to the "Distribution Analysis" that impacts are minor and almost the same across the breadth of alternatives, again showing the small economic impact the forest has on local communities, but continues to assist the impacts, as minor and minuscule as they are, are important to individuals, some businesses and families. The bias is so damn clear. If the WCNF DEIS and Proposed Forest Plan is going to continue to insist on this kind of analysis then it is absolutely imperative, proper, correct analysis and only fair to assure those folks, families, communities, individuals and some businesses who care about the ecological, aesthetic, biological, wild values of the Uintas be on the receiving end of a proper economic, financial and social analysis. The uni-direction of this section is violate of professional planning, regulation and common sense.

Although the DEIS insists there is a social valuation section within the broader Social and Economic Analysis, there really isn't. There is no discussion of the immense social values people place on the wild environment, on protection of roadless areas, wilderness recommendations, non-consumptive wildlife, aesthetic, scientific or ecological values. All of these have long been recognized as legitimate social and economic indicators--every bit as important to understand, document, relay and analyze as PNV, financial transactions or economic indicators. These values are found in local communities and widen in a continuous circle through regional, sate and national importance. The DEIS references none of the many recognized opinion and behavioral polls that have been done both in Utah and on a broader scale that relate to this specific set of circumstances. Nor does the DEIS cite any of the numerous refineries within the Forest Service itself that speak to the value of natural environments and wild areas as both social and economic indicators.

The federal government formally recognizes two methods of capturing recreation non-consumptive and preservation values--the Travel Cost Method and Contingent Valuation Method (themselves leading to numerous sub-valuations such as willingness to pay, passive use benefits, ecological services, biological conservation benefits, etc.). The Forest Service utilizes these all of the time in analyses such as this one. The literature is replete with these kinds of studies dating back to Krutilla and Fisher's profound book, Economics of Natural Environments, 1975. Since then the field of preservation and natural environment economic valuation has simply exploded. Work by Kellert ( Yale), Loomis (Colorado State University), Power (University of Montana), Pope (BYU), to mention but a tiny few of the most recognized economic researchers, has moved these analyses to the forefront. If not utilized the DEIS should acknowledge them and draw from their conclusions to show a similarity of possible economic and social valuations associated with preserving this magnificent wild and largely (and huge expanse) intact mountainous ecosystem--a rarity in and of itself!

Biodiversity and Viability

While recognized as a key issue it is hard to see any direction in the DEIS and Proposed Forest Plan specific to the principles of biodiversity. A good example is the tall forb community in the Uintas. It is recognized as a community at moderate to high risk, high risk on the Kamas Ranger District, and due to one reason--loss of topsoil associated with extensive grazing. Instead of ending the grazing permit, the DEIS and Proposed Forest Plan place a bandaid on the problem by restricting grazing with a complete recognition that will not likely help.

The DEIS does acknowledge where deviation from Historic Range of Variability (HRV) exists as determined through the Properly Functioning Condition Report (PFC) it is a result of one factor--past Forest Service management, whether it be grazing, fire exclusion, past timber harvesting that occurred outside of the ecological constraints of a particular forested system, road building, oil and gas development and loss of large connected wild landscapes.

And while recognized as a major issue, the DEIS and Proposed Forest Plan have selected an alternative that simply fails to aggressively restore HRV. This makes little sense in the context of the importance of the issue and the framework of the Proposed Forest Plan--ecosystem management.

And therein lies a significant set of concerns with respect to this particular issue. While it is the overriding issue, its foundation and formation is found within the context of the other issues--protecting roadless areas, recommendation of wilderness, the penultimate manner in which to protect functional ecosystems and achieve the goals harbored in the chapter on biodiversity, minimizing anthropogenic impacts such as grazing or timber harvesting, particularly within undeveloped landscapes.

And, unfortunately, the alternatives with respect to this issue represent a very jumbled and juxtaposed direction toward the plethora of issues that come under the heading of biodiversity. Ironically, the DEIS predicts under the alternative that restricts anthropogenic impacts the most, Alternative 1, that it will be most out of line with HRV! It does this without rationale, by simply suggesting human management inputs/impacts are needed to flush the systems already impacted and speed up recovery to the continuum of HRV. It does this without proposing to build any roads into undeveloped landscapes, as do Alts. 1 and 6, for example, thus making it clear that it is not the undeveloped landscapes that are contributing to the forest systems being out of HRV. To that extent the DEIS is positive and helpful/hopeful. It should state this very clearly.

The problems, of course, are primarily, but not exclusively, within the areas where active human/Forest Service management has been ongoing and is proposed to continue to go on and on. Thus the DEIS, to make the Biodiversity and Viability section whole and meaningful, needs to show and discuss the value of allowing natural disturbance regimes to operate as freely as possible within the undeveloped landscapes. The idea of mimicking natural processes is an oxymoron where natural systems can (and should) operate with limited human input. Given the huge array of literature dealing with ecological processes we can understand the concepts of mimicking natural processes to restore or rehabilitate already altered landscapes back to within some boundary consistent with the HRA. The emphasis, though, clearly can't be on production of resources, although they may occur; the emphasis must be on an adaptive management context that seeks to bring a harvested forest, for example, back to within the structure, function(s) and component(s) of that forest pre-management!

Where the intent is to harvest timber for yield there is no biodiversity goal to achieve. For the most part there is no biodiversity goal to achieve within the framework of livestock grazing, although we think, again based on the literature, that with low enough grazing rates, short seasons, and minimal structures it is possible to find rangelands that are not seriously impeded by grazing.

Thus Alt. 1 is misrepresented and Alts. 2 and 6 highly overstated in their value to biodiversity as an issue in the Proposed Forest Plan and DEIS. The literature is crystal clear in this respect, and we've posted some of that clearest and most definable literature below (Table 4), where natural disturbance regimes are allowed freedom, if you will, the integrity and health of an ecosystems is enhanced. The jury is still out on whether a system can be restored--so it can't be said as plainly as the DEIS and Proposed Forest Plan say it! It is not at all clear that mimicking a series of natural, inherent, ecological disturbances will put a system back within the HRV, thus approaching some concept of health or integrity.

Nor is it crystal clear that simply allowing natural processes to occur, particularly within systems that have been already altered, will produce a system within its HRV.

To this extent the DEIS and the discussion/impacts on biodiversity isn't really adequate and lacks serious discussion on disturbance ecology and ecosystem resiliency.

But given all of this, what can be said with authority and what the DEIS misses with the Preferred Alternative the way it is authored is that the best way to achieve the biodiversity and viability goals set forth in the DEIS and Proposed Forest Plan is to assure:

  1. Undeveloped (roadless) landscapes remain undeveloped and inherent ecological disturbance processes should be allowed to operate freely.
  2. Roadless and undeveloped landscapes should be connected and clustered to provide as large an area as possible.
  3. Wilderness recommendations should be large, intact systems, with the primary recommendations being large adjacent and/or adjacent and connected to extant wilderness system.
  4. Within the broader undeveloped landscapes it is crucial to end the anthropogenic impacts such as intensive range management, non-indigenous wildlife introductions and motorized access. In this context we go back to the rangeland discussion and note the allotments that are now vacant best serve the broader ecosystem and biodiversity goals by remaining vacant.

What this does is to assure resiliency and redundancy are inherent in the system(s), thus minimizing the potential for major shifts in ecosystem structure and function. This concern is one of the most profound now being analyzed in the ecosystem/biodiversity management literature. Numerous stochastic events can shift ecosystems to altered states but this often occurs actually as a result of human induced changes in ecosystems that have reduced the resiliency of ecosystems, often undetected until a major or catastrophic shift occurs. We don't see a deep discussion, review or analysis on Canada lynx (or anything about the proverbial lynx management units-- maps of which we received from the Forest Service a year before the DEIS was released but are found nowhere in the DEIS) or gray wolf, wolverine, pine marten and other top level predators, for example. These species are of great concern, dependent upon wild ecosystems, in fact, considered as indicators of wild and integral systems.

As to evaluating viability it is clear that both the science and the courts are still searching for clarity. But whether selecting management indicator species, umbrella or keystone species, which should have been analyzed and discussed in this section of the DEIS to make it a viable and up-to-date review, one overriding concern is agreed upon-- caution in the context of preservation of species and habitat must be the guiding principle. Literally, there would be no endangered species that still persist if it were not, first, for preservation of habitat, often times unoccupied or sparsely occupied and, second, protection of the population members. Thus the fact the wolves are not yet permanent here, though sightings continue of individual transient wolves on both the North Slope and Bear River Mts. or lynx/wolverine not yet formally confirmed, there exists profound and superb habitat on the Uintas--the whole Uintas, not just the WCNF North Slope. That is what must be considered in a cumulative context--close to a million acres of undeveloped lands exist on the Uintas and for this plan to be true to its context and the statements made by both the WCNF and the Ashley National Forest that the Uintas are being planned and looked upon as one continuous huge wildland!

Just recently, the U.S. District Court of New Mexico, Forest Guardians , et al. vs. USFS, concluded the Forest Service, after being challenged as a result of a timber sale, failed to evaluate population trend data as required by the National Forest Management Act, opting only to look at habitat evaluations.

This DEIS and Proposed Forest Plan looks only at a habitat model without any population trend data of management indicator species or any other species for that matter. Thus our suggestion that the DEIS and Proposed Forest Plan implement the strictest concept of the precautionary principle as noted throughout this comment and summarized in the above four primary points.

Table 4
  • Causes, consequences and ethics of biodiversity; Getting the measure of biodiversity; Global patterns in biodiversity; The diversity- stability debate; Consequences of changing biodiversity; Systematic conservation planning. Nature. 11 May 2000
  • Catastrophic shifts in ecosystems. Nature 11 October 2001.
  • Selecting Effective Umbrella Species. Conservation Biology in Practice. Spring 2001.
  • Applying Ecological Principles to Management of the U.S. National Forests, Issues in Ecology, Spring 2000.
  • Conservation Biology. Michael Soule, Ed. Sinauer Associates. 1986.
  • Using Focal Species in the Design of Nature Reserve Networks, Wild Earth, Winter 1998.
  • Large Carnivore Conservation in the Rocky Mountains of the United States and Canada. Conservation Biology, August 1996
  • Do Habitat Corridors Provide Connectivity? Conservation Biology. December 1998.
  • Conserving Biological Diversity through Ecosystem Resilience. Conservation Biology. August 1995.
  • A Citizens Guide to Ecosystem Management. Reed Noss. 1999. Biodiversity Legal Foundation.
  • Continental Conservation: Scientific Foundation of Regional Reserve Networks. Michael Soule and John Terbogh, eds. Island Press. 1999
  • Principles for the Conservation of Wild Living Resources, Ecological Applications, V.6,#2, 1996.

Much of this DEIS and Proposed Forest Plan provides the data and rationale for the kind of approach we've suggested. For reasons that we can't entirely follow, the Preferred Alternative simply don't connect to the Need for Change and the issues identified. An opportunity awaits the WCNF to take that step.

We look forward to hearing from you.

Best,
Dick Carter

"The importance of this immense task is greater than it has ever been because of the drastic changes in the functioning of ecosystems caused by humans. Through continued, unrestrained economic development, we may push ecosystems beyond a critical threshold, beyond which they are unable to sustain themselves and, ultimately, us." Jeff Harvey. The natural economy. Nature. 4 October 2001.


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