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26 July 2006
Mr. Kevin Elliott
Forest Supervisor
Ashley National Forest
355 N. Vernal Ave.
Vernal, UT 84078

Dear Mr. Elliott:

We have a number of comments on the “Evaluation of Undeveloped Area For Potential Wilderness Draft Information Packet.”

It remains a bit of a mystery as to what exactly this document represents; it is noted in your 23 June letter that a draft version of this document will be released on 1 September with a comment period to 29 September, less than 30 days. Given the obvious importance of this issue (that can’t be disputed), we urge you to allow for a minimum 60 day comment period, provide all of the information for each roadless area, not just the Forest Service defined high capability areas, and a forest-wide map of all areas as a companion to each individual map.

As to the concern over information provided in this document, we were stunned and appalled that only the five areas given high ratings by the Ashley harbored all of the data to help determine how that rating was made. It is hubris to assure us that this document was released “in the spirit of maintaining a transparent and open process” (Elliott letter, 6/23/06) and then the Ashley casually and arbitrarily dismisses as crucial information. It is virtually impossible to tell us the process is transparent and that decisions haven’t already been made independent of public concerns and issues. The process precludes all but five areas as having high capability and then prohibits a full review of the information to determine the merit of that recommendation.

It just doesn’t make sense. If the desire is to be open, transparent and seek public comment on the crucial issue, then provide the time frame to analyze the document, clarify the context of this “Draft Information Packet” with the draft document that will be released in September, and provide all of the information that went into the Ashley’s analysis.

In this light we also wonder, in the context of the broader forest planning process, as to whether alternatives will be considered dealing with other areas that might be considered high capability or whether the five areas thus far selected will have specific portions considered high capability and other areas not considered having a high rating?

We provided a detailed map of our proposed High Uintas Wilderness during the Desired Conditions comment and are submitting it again during this comment period. We would like it to be considered as a formal alternative within the forest planning context (at the appropriate time). Please promptly help us determine when that would be. We would also like to provide an HUPC alternative--a conservation alternative, if you will--which would deal not only with wilderness but the full breadth of forest planning. We look forward to hearing from you soon!

As to the specific areas in the evaluation, we want to first, again, commend the Ashley for a good roadless inventory. While the Forest Service has adopted new language for roadless areas (undeveloped), we will still refer to these areas as roadless areas. And frankly, the areas defined in this evaluation as having high capability are certainly meritorious. In most instances, they have followed the context of the logic we have suggested for decades--adding large roadless areas to existing designated wilderness should be an absolute priority and will, without disputation, enhance the extant wilderness system from every perspective, ecological to recreational.

Nonetheless, we were shocked to see a single roadless area fragmented into numerous units that do not reflect the extent, the size and the ecological diversity of the roadless landscape. The fragmentation of single roadless areas into smaller multiple units was clearly debunked in RARE I, some three decades ago. Size and ecological diversity are clear indicators of uniqueness--capability, if you will--and it has been recognized, again without dispute, that the more diverse and large a roadless area is, the more value it has, particularly within the context of ecosystem (landscape) management (see, for example, “Conservation Science and Forest Service Policy for Roadless Areas.” Conservation Biology, June 2006, V. 20, No. 3, 713-722. James Morton Turner). For the last couple of decades the movement to understand landscapes in this broader context has been the norm and, on more than one occasion, I have heard Ashley planners, rangers and biologists, even Forest Supervisors, brag that the Ashley has always recognized this concern.

But in this case it all seems to have been brushed aside with the distinct impression that the intent was to diminish the value of roadless areas adjacent to the High Uintas Wilderness. While we understand the need to often discuss roadlessness within a more specific geographic context (we recognize, for example, a single roadless area that envelopes the High Uintas Wilderness, and there is no doubt that this is the case, we discuss roadlessness within a broad drainage by drainage context), none of us should ever lose sight of what makes the Uintas a remarkable landscape/ecosystem--the core of the range is protected as wilderness and surrounding that wilderness is a single uninterrupted roadless landscape that literally envelopes the Uintas east to west, North and South Slopes, literally rolling off and flowing from the extant High Uintas Wilderness.

Specifically, the

  • North Slope High Country (40,574 a.)
  • South Slope High Country (85,024 a.)
  • High Uintas B (46,413 a.)
  • Lower Whiterocks (32,610 a)
  • Roadshed (37,805 a.)
    (242,426 a.)

are indisputably contiguous/adjacent to one another (Roadshed is only partially “bisected” from the North Slope High Country by the Carter Creek portion of the Sheep Creek Canal) and represent ONE massive and incredibly diverse roadless area--all of it adjacent and contiguous to the High Uintas Wilderness.

It is within this context that this preliminary evaluation also errs in specific analysis content. From a “capability” perspective, size is a crucial indicator of roadless landscape quality/capability. This has long been recognized both from a roadless quality concept as well as potential wilderness value and, in fact, has been a long standing argument noted by the Forest Service.

This is notably enhanced when exceptionally large roadless landscapes emanate from and are adjacent and contiguous to existing designated wilderness and even more so when that designated wilderness is large itself (the High Uintas Wilderness is the 24th largest designated wilderness of the 680 Wilderness Areas, excluding the 48 Alaskan Wilderness Areas). This needs to be noted plainly and distinctly in the capability analysis for the roadless landscape adjacent to the High Uintas Wilderness.

All of this is even further enhanced when looking at the units referred to as High Uintas A and C (we can’t help but wonder why units High Uintas A, B and C weren’t given geographical namesakes--the only units referred to only as single letters of the alphabet even though the areas harbor notably and clearly distinct geographic values). Again, these are not two units! They are distinctly ONE, contiguous and adjacent to one another and to the High Uintas Wilderness for dozens of miles!

  • High Uintas A (21,669 a.)
  • High Uintas C (48,851 a.)
    (70,520 a.)

The irony here is that tucked away in the analysis narrative for these seven units is a tacit admission that each of these areas, in fact, harbors a common boundary with another. But the analysis still insists they are all separate units. This is either a serious error, oversight or a disingenuous attempt to diminish the value of these units.

If you pretend the High Uintas Wilderness doesn’t exist and draw/map the roadless boundary that surrounds the High Uintas Wilderness, both forests (of course, I realize the Wasatch would never do that on the Ashley nor the Ashley ever do that on the Wasatch--old fashioned self-aggrandizing turf dominates, but try it anyway; sort of a mind game, if you will), you will find ONE roadless unit, not completely bisected/separated by a single road or other anthropomorphic insult.

On the Ashley this single roadless landscape consists of just a few acres shy of 313,000! There is more wildly diverse, high quality, connected, contiguous, adjacent roadless acreage flowing off the High Uintas Wilderness, if you will, than the High Uintas Wilderness acreage on the Ashley National Forest.

Even more remarkable is the high quality of the acreage as noted in the Ashley inventory and the incredible ecological diversity harbored within this single massive unit. Elevations range from above 12,000 feet and alpine habitats to elevations around 6,000 feet dominated by grass/sagebrush communities and aspen. In between are the classic high elevation habitats, glacial dominated geology and forests from spruce, lodgepole pine, ponderosa and douglas fir, aspen to sagebrush, and stream-bed geology, with forests of cottonwood and birch/alder confined to stream channels flowing though low elevation, deeply incised dry gullies and canyons. It is a remarkable landscape in and of itself, stunning that so much of it has been left largely undeveloped, to use your new vernacular, and that it is “contained” in a single, massive roadless/undeveloped region--probably none other like it in the Intermountain Region in terms of its size and diversity (and certainly nothing like it in Utah).

Remove the artificial boundaries that have been placed on this single unit--to not do that would be a lie--and this roadless landscape is singular along with its value as wilderness, whether viewed from a recreational perspective or, more importantly, from a conservation/ biodiversity/ ecological perspective.

The capability analysis rating system should harbor a standard and evaluator dealing with size or roadless unit and whether the unit is contiguous to an existing designated wilderness (or other identified preservation-based classifications such as a RNA).

The analysis also wanders aimlessly with respect to the first availability criteria:

"Is the area vitally needed for increased water protection and storage?”

This is answered in the affirmative for each of the “roadless/undeveloped areas” but High Uintas B (we still don’t understand why this unit is not given a name like the others) with the statement “...drainages in the area provide water for domestic and irrigation uses off forest.” The “yes” answer suggests wilderness character is offset by “current/future resource value(s) or uses.” The implication, of course, is that deep in these high country drainages the Ashley National Forest has proposed water storage facilities...without any analysis in the document as to where they might be located, when, why, or how. Simplistic broad future statements with no merit should not be utilized as a bias, to extant wilderness characteristics. What the analysis seems to be saying is, because there are streams in the area, they are capable of holding dams at some undefined point in time. Ironically, this comes at a time when the Ashley is bragging about removing dams from within the High Uintas Wilderness and on the heels of the much touted decision by the Ashley to reject the Blanchett Park dam within the very country being discussed!

The Ashley’s analysis could just as easily have noted potential major highway projects are possible or even trans-mountain power line rights of way. They have all the likelihood of reservoir or storage projects--it is just that water projects provide a more immediate level of fear and hysteria surrounding potential wilderness designation and set up a debate that doesn't exist. If there are proposals and projects, they should be clearly noted, where and when.
While the analysis asks whether the area is “vitally needed for increased water protection...,” one of the long recognized values of wilderness designation, even by the Forest Service, is the absolute protection of water and watersheds.

Thus, there are really two questions:

  • increased water protection of which there is no doubt wilderness enhances
  • increased water storage of which purely hypothetical project ideas have no place in this or future documents.

Furthermore, it is incumbent upon this analysis to also note that wilderness characteristics/values would be seriously hampered by such water storage facilities. The singular direction of impact--potential wilderness preservation would hamper water storage and thus wilderness values are offset by non-wilderness resource values--makes it only too clear just how deep the bias against wilderness is on the Ashley National Forest. For a true and meaningful evaluation, it is important the analysis go “both ways,” if you will, to show clearly that water storage values would hamper important wilderness values.

The same concerns exist for the utterly absurd and unprofessional analysis (similar in context to the water storage discussion) dealing with the “availability question” associated with restricting “important terrestrial and aquatic wildlife management measures” answered in the affirmative for Roadshed, South Slope High Country and High Uintas B. Once again the report or analysis referenced or suggested is not documented or provided. There is no time-line or location referenced for these projects and the assumption seems to be (nowadays a common one in the Forest Service) that analysis and public comments serve no purpose to alter any such projects or offer any accountability. Rather biblical in nature, the WORD from the Ashley is designated wilderness will hamper other resource values and thus designated wilderness is BAD as it “offsets” these resources, even though projects are not defined and public discussion not engaged.

It is equally valid to note, as above, that such projects may have negative impacts upon wilderness values and characteristics and should be reconsidered in light of the powerfully recognized values of allowing mother nature to dance her dance with grace and eloquence and never with harm to inherently natural ecological processes or humans. In other words, the analysis can’t simply go in one direction--that being wilderness as a constraint rather than an opportunity.

Similarly troubling is that we are not even allowed to see any these analyses for any of the roadless areas outside of the “five” determined to have high capability because the forest refuses to disclose all of the relevant information for all roadless areas.

Being asked to “trust us” with an issue of such magnitude and as faulty as presented is a bit much. The history and deep bias on the Ashley and throughout the Forest Service with respect to a measured and systematic analysis of wilderness characteristics and values suggests full disclosure of all of the relevant information is a must. We challenge you to at least do that.

It is within this same context that the Ashley evaluation automatically analyzes in a single direction that of tradeoffs with respect to ATV and snowmobile conflicts. The deeply biased and stated assumption is that wilderness hampers and inhibits such uses and is thus a conflict which lowers the status of wilderness values/characteristics. It is equally true, more so actually, that ATV/snowmobile use precludes wilderness values/characteristics. A fair, measured and meaningful analysis must consider a much broader evaluation and valuation.

Scattered throughout the evaluation is the phrase, “Encounters with humans is infrequent, but common.” Come now. It is not our habit to provide the full definition of “infrequent” from the 11th edition (2004) of Merriam-
Webster’s Collegiate Dictionary
, but we are compelled to do so because this phrase is used commonly in the undeveloped area evaluation to note, in a large part, wilderness values and characteristics are diminished. The definition of infrequent:

  1. : seldom happening or occurring: RARE
  2. : placed or occurring at wide intervals in space or time *a slope scattered with infrequent pines* *infrequent visits*

Synonyms INFREQUENT, UNCOMMON, SCARCE, RARE, SPORADIC mean not common or abundant. INFREQUENT implies occurrence at wide intervals in space or time *infrequent family visits*. UNCOMMON suggests a frequency below normal expectation...

The point is obvious: encounters are either common, and that is not the case in these places, or they are infrequent and that is the case.

Also, scattered throughout the analysis is the very old and ancient “sights and sounds” argument, about the same era of fragmenting large roadless areas into smaller ones to diminish their value, which suggests that sights and sounds outside of an area reduce its sense of naturalness. This might be true for a very, very small unit. Walk a few hundred feet and sight and sounds disappear (or just turn your head). Even on the “edges” of the nine million acre Wrangell-St. Elias Wilderness there are “sights and sounds” of civilization. It is a silly and outdated concept and belongs nowhere in this evaluation.

The evaluation commonly notes, “Natural processes are sporadically altered by human management activities.” This phrase is used to drop the rating of “natural integrity to low or moderate and reduce the wilderness capability. The evaluation never defines how natural processes have been altered and by what management activities within the roadless area. Again, the evaluation employs a word, “sporadic,” which has a very specific meaning--this time, from the Oxford American Dictionary:

“Sporadically altered” simply does not suggest in any manner that natural processes have been diminished within a specific roadless/undeveloped area by actions within that area. Again, this is found without the evaluation and simply does not belong as it does not accurately disclose information pertinent to the routine, systematic biased denigration of natural values.

The evaluation also is notably deficient in that no forest-wide map of roadless/undeveloped areas is provided and thus one is left to a good imagination as to how the roadless areas fit across the forest. When looking at the Ashley roadless areas, less than 50% of the total acreage on the forest, one faces a startling revelation--with few exceptions, roadless areas on the Ashley are clumped together and separated from one another almost always by primitive roads. Even though severely reduced by past Ashley management that has focused almost solely on a singular vision of roading and developing the forest at the expense of its natural/wild character, the distinguishing characteristic is that these landscapes dominate in landscape patches that are noticeable and notable. They are not isolated, meaningless, roadless areas, severed from other functioning roadless landscapes. Thus their ecological/wild/wilderness value is enhanced as they are clustered together dominating geographical areas. This also should be a measurement of capability and value. The concept of numerous areas (small or large) clustered and tied together enhances the value of each area, even though fragmented from neighboring areas. This is particularly true when the separation consists of primitive, lightly-used, backcountry roads.

We urge the Ashley to do this evaluation with the deepest integrity and honesty as it is such a crucial portion of the forest plan. Speeding it along, not providing the information, biasing the results by splitting single massive roadless areas into smaller units and thus not accounting for the remarkable size, ecological and wild diversity of those roadless areas, and by attempting to diminish the natural integrity and the simply stunning opportunities for solitude in these wildly diverse and large and clustered sets of roadless is not right.


Dick Carter

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