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HUPC Appeal of Forest Plan

26 June 2003

USDA Forest Service-Appeals Group
Attn: EMC Staff
Stop 1104
1400 Independence Ave. SW
Washington, DC 20250-1104

Dear Appeals Group, EMC Staff:

Enclosed is the High Uintas Preservation Council's appeal pursuant to 36CFR 219.7 of the Final Environmental Impact Statement, Wasatch-Cache National Forest Revised Forest Plan and Record of Decision signed by Jack Troyer, Regional Forester, Intermountain Region, March 19, 2003 and appearing as a legal notice in the Salt Lake Tribune, April 4, 2003.

We, of course, have participated throughout the lengthy process of revising the Wasatch-Cache National Forest plan, including numerous comments during the scoping process, preparation of the AMS and alternatives, attending hearings, meetings and open houses, much of this dating back to the early 1990s.

While we have deep and troubling concerns with the Wasatch-Cache National Forest plan, far beyond even what we've appealed, we do want to acknowledge the openness and effort the forest utilized in the long process of preparing the forest plan.

I also want to acknowledge High Uintas Preservation Council (HUPC) board members, Margaret Pettis, Connie Bullis and Mark Mckeough along with HUPC members Wayne McCormack, Jim Thompson and Lynette Brook for their assistance in preparing this appeal.

Sincerely,

Dick Carter

cc Intermountain Regional Forester

Forest Plan Appeal

26 June 2003

Introduction

This is an appeal pursuant to 36CFR 219.7 of the Final Environmental Impact Statement, Wasatch-Cache National Forest Revised Forest Plan and Record of Decision signed by Jack Troyer, Regional Forester, Intermountain Region, March 19, 2003 and appearing as a legal notice in the Salt Lake Tribune, April 4, 2003.

The High Uintas Preservation Council appeal challenges the incoherence of decisions in the Final Environmental Impact Statement, Wasatch-Cache National Forest Revised Forest Plan and Record of Decision, hereafter referred to as the forest plan, on the Uinta Mountains as they relate to the Western Uintas Management Area and Eastern Uintas Management Area, in particular, on the Lakes Roadless Area (LRA) and the High Uintas Roadless Area (HURA), focusing on two principal inconsistencies. First, it is impossible to determine why so much of the Lakes Roadless Area and the High Uintas Roadless Areas were not recommended for wilderness designation. The second inconsistency has to do with allowing snowmobiling to occur essentially throughout the Lakes Roadless Area and parts of the High Uintas Roadless Area without regard to whether the management prescription (mp) is 1.5, 2.6, or 3.2 and, in particular, within the forest plan proposed wildernesses on the LRA and HURA.

1.a. Management Prescription 1.5 (Recommended Wilderness Designation) is inconsistently applied and should be expanded to include more of the Lakes and High Uintas Roadless Areas.

MP 1.5 admittedly is a discretionary decision. Discretion, however, cannot be applied arbitrarily. It would not be sensible to recommend wilderness designation for land occupied by a ski resort. At the other extreme, it would probably be an abuse of discretion for a forest to make no wilderness recommendation if it contained large roadless areas and no formal wilderness as yet designated. Admittedly, the Western Uintas decisions do not fall at either of these two extremes, but the point remains that it is an abuse of discretion to make formal wilderness recommendations incoherently.

What we hope to demonstrate is that the small allocation of MP 1.5 in the Lakes Roadless Area is incoherent for two reasons. First, there are no sensible differences between the area that is placed in 1.5 and the contiguous areas that are placed in 2.6 or 3.2. The values to be preserved in all three types of allocation are virtually identical and there are no sensible boundaries to delineate these areas. The only reason for making such fine distinctions must be the thought that there should be other methods of protecting an area without taking on the politics of formal wilderness designation. The problem with that approach is that it is incoherent from a planning perspective. It takes away Congress' ability to manage the political issues by pre-screening the politics at the agency level.

We do not mean to be arguing that the Service must recommend all roadless areas as wilderness. What we are trying to point out is simply that there must be some rational distinctions that trigger the drawing of boundaries for non-wilderness management. As the courts said in both Parker v. United States, 448 F.2d 793 (10th Cir. 1971) and California v. Block, 690 F.2d 753 (9th Cir. 1982), the agency is required to protect an opportunity for Congress to consider the adding of suitable areas to the wilderness system. Allowing any other uses that could "destroy the wilderness value" would be contrary to the congressional mandate. Thus, as we look at what uses will be allowed on the adjacent lands in other categories, we need to be mindful of what uses occur on those lands, what reasons exist for allowing those uses, and what the effects of those uses could be. All of this must be considered in light of the Ninth Circuit's admonition in California v. Block that a planning cycle of 15 years (minimum) itself is a decision to remove an area from congressional consideration for an extended period, and that decision must be subjected to careful scrutiny.

There is no rationale provided in the forest plan as to why and how the 38,000 acre proposed LRA Wilderness was defined. This alone is a significant error. It is impossible to tell how and why it meets the context of the selected alternative other than a self-defined "core" of the LRA should be designated as wilderness. This self defined "core" is hardly a core. A better description is half a mountain. Only the "North Slopes" (Weber River drainage) of the LRA are recommended as wilderness without any explanation as to why none of the Provo River drainages were excluded from wilderness consideration. Ironically, the forest plan (App C1 and C2) shows that under the selected alternative 65,500 acres have their wilderness character protected as a result of a combination of MP 1.5 (recommended wilderness) and 2.6. The simple point, though, is made clear in Appendices C1 and C2-under alternative 7 the wilderness character, at the minimum, includes over 65,000 acres! It is incumbent on the forest plan to explain why under 60% of that acreage received a wilderness recommendation. MP 2.6 was never intended (and isn't a replacement) for wilderness character-it is to augment wilderness recommendations. In this case it attempts to hijack forest plan-defined high quality wilderness character.

Thus we arrive at the real issue of "coreness." The entire roadless area is some 122,000 acres. It is noted in the forest plan that the western portions of the roadless area have more surrounding impacts in the way of cherrystems and have higher impacts upon naturalness because of past admitted heavy grazing, but ironically, this is not addressed! Thus, within the selected alternative context the forest plan identified a core of the area, about 53% of the inventoried roadless area (IRA), as having wilderness character (MP 1.5 and 2.6), but chose, without explanation or rationale, to place only 58% of that in MP 1.5, recommended wilderness.

There is no disputation about wilderness character or values, other than the failure of the forest plan to explain why/how the decision was made. A wilderness recommendation should have been made on the lands identified as having undisputed wilderness characteristics with the remaining portion of the IRA being subjected, properly, to other undeveloped-oriented prescriptions (2.6, 2.4, 3.2.u, 4.1).

Appendices C1 and C2 provide a compelling analysis and review of the character of the roadless landscape. Of profound importance is the context of size which dramatically influences its overall values dealing with wildlife habitat, naturalness, solitude, primitive recreation and, in fact, results in the forest plan noting this is a "very significant" roadless area. Thus it is intuitive that what makes the LRA significant as a wilderness is its large roadless landscape. To diminish that context with a wilderness recommendation that trivializes the very value/significance of the area is counterintuitive. It doesn't fit the context of the selected alternative.

North Fork Provo
To rectify this planning error the Forest Service must consider the high value wilderness lands as recommended wilderness. At the minimum 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, and timbered. The canyon bottom is filled with aspen, cottonwoods and small meadowlands adjacent to the river itself-values deemed by the Forest Service to be important in wilderness needs assessments, yet ignored! 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 is unique and undeniably wild country that adds to the biodiversity and ecological uniqueness of the LRA because of its mid-elevational forests, and riparian/riverine habitat unmatched in the LRA.

The headwaters of this drainage are found, of course, in the high lakes of the Provo River Drainage, notably the reservoired lakes now stabilized, acting as the natural lakes that they are, and, as the forest plan now notes, "complements the undeveloped character of the land." The area clearly meets 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.

By including the North Fork Provo, in particular, both sides of the proverbial mountain are recognized as a flowing wilderness resource and the sense of an unconnected island wilderness is resolved. One of the issues is manageability and there is no doubt that wilderness manageability is enhanced when trailheads are at wilderness boundaries. This makes for easier out-of-wilderness-educational contacts by wilderness managers and from the outset "controls" the use of the area by minimizing the distinction between wilderness and non-wilderness travel and behavioral expectations. It is important to recognize that most of the MP 2.6 and 1.5, the areas of wilderness character noted in the forest plan, would bring the wilderness boundary out to the primary trailheads associated with the highest wilderness character consistent with the selected alternative context.

Requested Relief:
The LRA Wilderness recommendation should reflect the noted and clearly stated highest quality wildlands particularly as evidenced by MP 1.5 and 2.6, and the North Fork Provo drainage. (See HUPC appendix 1.)

1.b. The LRA proposed wilderness and snowmobiling

The only discernible argument against a larger wilderness recommendation by the Forest Service is the apparent or implied use of snowmobiles. Ironically, the forest plan notes that the vast majority of snowmobile use in the area is on the Mirror Lake Highway and that only the outer 42% of the LRA receives any measurable or notable snowmobile use. The "core" of the LRA, presumably this includes the core proposed for wilderness (although the outer 42% of the LRA consists of just over 51,000 acres, leaving nearly 71,000 acres as a "different core") offers minor snowmobile opportunities only for the "highly skilled" or "adventuresome" snowmobiler.

Not surprisingly, the forest plan offers no data or maps to suggest how heavy the use or where this mysterious 42% of the area is located, a notable and convenient omission.

As to the core of the area being rugged and thus available to the "highly skilled" or "adventuresome" snowmobiler, a meaningful set of concerns exist, but are not addressed. 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 will be the actual impacts to the "highly skilled" or "adventuresome" snowmobiler if this particular area is not made available to that kind of use? What constitutes a "highly skilled and adventuresome snowmobiler?" Does that kind of use/user have to be associated with the LRA? Why isn't this use available in Soapstone, Current Creek, Wolf Creek, 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, why is this portion of the LRA important for that use/user within a land planning context and Forest Service analysis?

All of these are factors that should have gone into the analysis in the forest plan 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 if the LRA was not open to snowmobiling, particularly any area proposed for wilderness?

The truth is there is very limited snowmobiling terrain on the roadless portions of the North Fork Provo, Shingle Creek, Box Canyon, Red Pine and Dry Fork. There are considerable highly skilled (and less skilled) snowmobile areas on and around the clear cuts in the Spring Canyon/semi-primitive roaded developed "Lakes" area. This makes perfect sense and meets the developed roaded motorized context while protecting the highest quality wilderness context. All of this was ignored as an analysis context within the forest plan.

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 in the forest plan, will this backcountry skilled snowmobile use remain light, 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! The forest plan promises not to "advertise" this use or do anything to increase the use. That is patently misleading and plainly disingenuous. The mere fact that the limited, nearly invisible use seemingly restricted wilderness recommendation acreage advertises and encourages the activity that is so inconsistent with the land base, land allocation and use patterns.

There is a clear suggestion, as well, in the forest plan that snowmobile restrictions on the LRA, including the "core" area open to the very small and limited "highly skilled" or "adventuresome" snowmobiler, may have negative economic impacts on the local Kamas economy. Of course, the forest plan shows no such evidence and can't. It is a silly out-of-the-hat trick. Remember, it is the agency's own assertion that very little snowmobile use occurs in the core area anyway, nothing will be done to enhance, augment or increase that use, and the vast majority of snowmobile use occurs within the roaded portion of the Kamas and Evanston Ranger Districts (where it belongs). Since nobody is challenging the Mirror Lake/Whitney snowmobile corridor, there will be no impact upon any local economies from snowmobile restrictions. It is inconceivable such an argument can be made or utilized by the Forest Service.

Finally, the fundamental and foundational error is the recommendation to leave the formally proposed wilderness, MP 1.5, open to snowmobile use. This is a profoundly egregious and hubris error in the forest plan and contrary to policy, guidance, context, and decent common sense. Chapter 4 of the forest plan, Forestwide Desired Future Conditions, states plainly, "Recommended wilderness areas are managed to maintain wilderness qualities. Activities allowed in recommended wilderness do not compromise wilderness values or reduce the area's potential for wilderness designation." This is a restatement, in essence, of formal Service-wide policy and direction.

The disconnect between the forest plan direction, the formal policy, the intent of recommending wilderness through the forest planning process, and the arrogance of then concluding that an action clearly violative of wilderness, snowmobile access, is one of deep cynicism and mischief. The issue is not necessarily one of particular sustained impacts to the biophysical wilderness resources but one of clear legal intent. Wilderness qualities, by definition, can't be maintained if snowmobiles use the area! Furthermore, the clear intent here is to dismiss wilderness character/qualities by allowing an action incongruent to wilderness, at the proverbial right angle to the very context of wilderness, and then have the audacity to say there are no impacts-WITHOUT A SHRED OF EVIDENCE OR EVEN ANALYSIS-and that Forest Service support of snowmobiling in a wilderness recommendation will not hinder future wilderness consideration! The agency speaks out of both sides of its mouth. This is deceitful, disingenuous and egregiously in error!

The irony of all of this is further noted by the forest plan management direction for the proposed wilderness within the LRA that even prohibits "mountain bike trail use and other mechanized use…" Allowing snowmobile use is capricious and incoherent.

Requested Relief: MP 1.5 should be closed to snowmobiling to meet the clear intent and policy of maintaining wilderness values/character of proposed wildernesses.

1.c. The High Uintas Roadless Area

There is no rationale provided in the forest plan as to why and how the 20,600 acre proposed HURA Wilderness was defined. This alone is a significant error. It is impossible to tell how and why it meets the context of the selected alternative. Of more importance, it is impossible to understand why many areas of the HURA did not receive a MP 1.5.

Some of this confusion is found in the roadless area write-ups within Appendix C. Just a few examples:

1. While there is no dispute about the significance of the area's naturalness and size, the forest plan intentionally downplays the fact that the HURA is a huge contiguous region, almost exclusively adjacent to the extant High Uintas Wilderness, HUW). When looked at in the proper context, the area includes the large 103,000+ acre roadless area adjacent to the HUW on the Wasatch-Cache National Forest AND additional hundreds of thousands of acres of roadless lands on the Ashley National Forest which extend east dozens of miles and then curve south and west to encompass the entire HUW. These roadless acres are as wild and diverse as any in the lower'48. The Appendix C2 acknowledges the size dwarfs any Forest Service roadless land in Utah and easily represents some of the most extensive roadless landscape in the lower '48. Yet it ignores this value in the analysis of wilderness capability! Alone, this context would suggest its potential wilderness value would be enormous. Instead of another small, hard to manage, isolated wilderness, this area is massive-an area worthy of special attention on that basis alone-when seen as a single roadless area of hundreds of thousands of acres adjacent to the 460,000 acre HUW! This context is ignored in the decision of a paltry 20,600 acre wilderness recommendation in the forest plan. If the LRA is a "very significant" roadless area, the HURA is hyper-significant!

2. Appendix C1 (App C1) write-up notes the area is lower in value because several old timber sales are directly outside of the area. Irrelevant!

3. App C1 suggests ATV use along with firewood gathering and harvesting occurs in some concentrations in Wolverine, Broadhead Meadows and Murdock Basin-all areas not part of the formal inventoried roadless area, thus irrelevant.

We could go on but these show the bias toward trying to delimit the value of the roadless area as potential wilderness.

On the other hand, App C1 does acknowledge that naturalness is high, solitude and primitive recreation almost exclusively outstanding, size, diversity and context unmatched…yet given this recognition, the forest plan unbelievably concludes that only 20% of the Wasatch-Cache portion of the HURA deserved a wilderness recommendation, MP1.5.

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 in the context of a wilderness recommendation was missed (an error) in the forest plan. For example, in the context of the selected alternative, an additional 10,800 acres of MP 2.6 were identified, primarily in small blocks that can't, even by the most jaded eye, be differentiated from the MP 1.5. The same is true for the MP 4.1, Backcountry Non-motorized, primarily on the Middle Fork of the Blacks Fork, Boundary Fork and the middle reaches of the Stillwater-all of these areas are contiguous to the HUW. These three prescriptions account for some 54,000+ acres of the highest quality roadless lands within the HURA. Interestingly enough, almost all of this MP 4.1 is within the areas the forest plan notes as the "most pristine and remote areas" in the HURA! Furthermore, and this is distinctly notable, the forest plan identifies 66,700 acres of the HURA in the Recreation Opportunity Spectrum of semi-primitive non-motorized-this follows the context of roaded versus clearly unroaded, wild terrain-the highest quality unroaded and wild lands on the HURA. On few forests is the distinction so plain and clear and, unfortunately, missed so profoundly in the forest plan!

To rectify this planning error the Forest Service must consider the high value wilderness lands as recommended wilderness:

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 and 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 still a good half day's walk with a light load to reach the proposed 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 evident. 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.

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.

West Fork Beaver Creek

The proposed wilderness recommendation is strategic and to be commended, but it is less than half a 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!

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. Goshawk and pine are common 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). Early in the summer on both the Middle Fork and West Fork of the Beaver Creek loons 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.

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 plan Wild and Scenic River Eligibility determination 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 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.

These drainages are high quality roadless landscape. 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. These drainages represent remarkable ecological diversity and extend 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 plan's Wild and Scenic River Eligibility determination 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!

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.

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 an alpine basin, but in a stunning small open forest parkland.

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 two 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 and isolated, open aspen slopes make for a vibrant riverine system.

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.

And in an interesting set of twist and turns, the forest plan's Scenic River Eligibility determination 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 forest plan wilderness recommendation leaves most of these drainages out of the proposed wilderness.

The disconnect between the high quality roadless lands and the resultant tiny wilderness recommendation does not meet Forest Service policy or common sense and misses the true value of this largest roadless area on Forest Service lands in Utah, likely within the Intermountain Region and one of the largest areas in the lower '48.

Requested Relief: The HURA Wilderness recommendation should reflect the noted and clearly stated highest quality wildlands, particularly as evidenced by MP 1.5, 2.6, 3.2u, and 4.1 in the Middle Fork Blacks Fork, Boundary Creek, Stillwater, Kabell, Thompson and Burnt Fork drainages and additional high quality roadless wildlands in the latter three drainages and the West Fork Beaver Creek. (See HUPC appendix 2.)

1.d. The HURA proposed wilderness and snowmobiling

Although at a much smaller level than in the LRA, the fundamental and foundational error is the recommendation to leave a portion of the formally proposed HURA wilderness, MP 1.5, open to snowmobile use. This is a profoundly egregious and hubris error in the forest plan and contrary to policy, guidance and context, not to mention decent common sense. Chapter 4 of the forest plan, Forestwide Desired Future Conditions, states plainly, "Recommended wilderness areas are managed to maintain wilderness qualities. Activities allowed in recommended wilderness do not compromise wilderness values or reduce the area's potential for wilderness designation." This is a restatement, in essence, of formal Service-wide policy and direction.

The disconnect between the forest plan direction, the formal policy, the intent of recommending wilderness through the forest planning process and the arrogance of then concluding that an action clearly violative of wilderness, snowmobile access, is one of deep cynicism and mischief. The issue is not necessarily one of particular sustained impacts to the biophysical wilderness resources but one of clear legal intent. Wilderness qualities can't be maintained if snowmobiles use the area by definition! Furthermore, the clear intent here is to dismiss wilderness character/qualities by allowing an action incongruent to wilderness, at the proverbial right angle to the very context of wilderness, and then have the audacity to say there are no impacts-WITHOUT A SHRED OF EVIDENCE OR EVEN ANALYSIS-and that Forest Service support of snowmobiling in a wilderness recommendation will not hinder future wilderness consideration! If there is ever a clear picture of an agency speaking out of both sides of its mouth it is here. It is deceitful, disingenuous and egregiously in error!

Requested Relief: MP 1.5 should be closed to snowmobiling to meet clear intent and policy of maintaining wilderness values/character of proposed wildernesses.

1.e. LRA/HURA and snowmobiling

The forest plan purports to be the winter travel plan decision, but harbors far less analysis of impacts to resources and land character than any traditional travel planning process. It remains unclear as to how future travel planning will be moved from this bifurcated process of summer travel plans done in the "normal" travel planning process and winter travel plans completed in the forest planning process. Will travel plans be updated with this split personality? In essence the vast majority of the forest is left open to snowmobile use without even a pretense of any quantitative or even qualitative review of impacts from this allocation.

With respect to roadless areas, particularly the high quality roadless landscapes of MP 1.5, 2.6, 4.1, 3.2u, and roadless areas adjacent/contiguous to the High Uintas Wilderness, for example, roadlessness 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.

While most of the HURA and LRA are recognized as potential lynx habitat and thus an issue with respect to winter recreation, there is minimal 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. So the question becomes, and was clearly begged off in the forest plan, 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?

Snowmobiles and roadlessness are an anathema. If snowmobiles roam and run on roadless landscapes, it is not roadless because snowmobiles are the roads! They 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 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.

Furthermore, the forest plan, acting as a travel plan, fails to discuss any meaningful issues with respect to snowmobiling and wildlife impacts. Because of their high noise levels and extreme speed, particularly overlaid on the roadlessness discussed above, snowmobiles harass wildlife, causing increased metabolic rates and stress responses (Creel, et al., 2002). A plethora of research and evidence shows meaningful and serious winter recreation-snowmobiling-impacts face many species specific to the Uintas, moose, lynx, bighorn sheep and gray wolves, as a few examples, when superimposed on the roadless values and characteristics of the LRA and HURA (Olliff, T., et al., 1999). During the winter months, wildlife are especially vulnerable to this harassment because they are already burdened by increased levels of stress. Snowmobile use can also cause disruption in movement patterns, making it more difficult to locate reliable food sources. These impacts are best understood and documented for ungulates (Greer 1979, Moen, et al. 1982, Parker, et al. 1984, Severinghaus and Tullar 1975); nevertheless, many other wildlife species suffer the same sorts of direct impacts from exposure to and harassment by snowmobiles. It is virtually certain, noted above, that lynx, snowshoe hare, and other wildlife within the range of snowmobile use will be harassed by noise and visual impacts. Accumulation of snowmobile exposures over the course of a winter or several seasons can result in significant long-term wildlife displacement and expanded home ranges, increasing winter stresses and energy expenditures. As a consequence, wildlife often suffer increased winter mortality in areas where snowmobiles are used, even in low intensities (Berwick 1968, Bury 1978, Dorrance, et al. 1975, Neumann and Merriam 1972).

In winter, snowmobile use can cause significant damage to exposed and unexposed vegetation. Abrasion and breakage of seedlings, shrubs, and other exposed vegetation is common (Neumann and Merriam 1972, Rongstad 1980, Ryerson, et al. 1977). Repeated snowmobile use can lead to changes in plant density and species composition (Aasheim 1980, Wanek and Schumacher 1975) and the associated loss of vegetative cover generally leads to increased soil erosion (Montana Fish, Wildlife and Parks 1993).

Snowmobile-induced snow compaction is implicated in numerous, often overlooked environmental impacts. For instance, snow compaction can cause considerable below-surface vegetation damage (Neumann and Merriam 1972). Significant reductions in soil temperatures may also result from snow compaction (Aasheim 1980, Rongstad 1980), retarding both soil microbial activity and seed germination (Keddy, et al. 1979), and these impacts may be exacerbated by compaction of the underlying soil layers. Compaction lowers temperatures in subnivean spaces, which in turn leads to increased metabolic rates, and thus, increased mortality. Finally, because most of the snow compaction occurs on the first snowmobile pass, even minimal use of any area can cause considerable damage (Aasheim 1980; Gabrielson and Smith 1995; Keddy, et al. 1979).

LITERATURE CITED -Aasheim, R. 1980. Snowmobiles impacts on the natural environment. Pages 191-200 IN R. Andrews and P. Nowak (eds.). Off-road Vehicle Use A Management Challenge. USDA - Office of Environmental Quality. Washington, DC. 348 pages. -Berwick, S. H. 1968. Observations on the decline of the Rock Creek, Montana, population of bighorn sheep. M.S. thesis, Univ. Montana. Missoula, MT. -Bury, R. L. 1978. Impacts of snowmobiles on wildlife. Trans. North Amer. Wildl. Natur. Res. Conf. 43 149-156. -Creel, S., et al.. Snowmobile activity and glucocorticoid stress response in wolves and elk. Conservation Biologuy. 16 (3) 809-814. -Dorrance, M. J., P. J. Savage, D. E. Huff. 1975. Effects of snowmobiles on white-tailed deer. J. Wildl. Manage. 39(4) 987. -Gabrielson, G. W. and E. N. Smith. 1995. Physiological responses of wildlife to disturbance IN R. L. Knight and H. K. Cordell (eds.). Wildlife and Recreation Coexistence through Management and Research. Island Press. Washington, DC. -Keddy, P. A., A. J. Spavold, C. J. Keddy. 1979. Snowmobile impact on old field and marsh vegetation in Nova Scotia, Canada an experimental study. Environmental Mgmt 88(10) 409-415. Dalhousie University. Nova Scotia, Canada. -Moen, A. N., S. Whittemore, B. Buxton. 1992. Effects of disturbance by snowmobiles on heart rate of captive white-tailed deer Odocoileus virginianus. New York Fish & Game J. 29(2) 176-183. -Montana Dept. Fish, Wildlife and Parks. 1993. Programmatic environmental impact statement, Montana Snowmobile Grant Program. Statewide Trails Program Coordinator, Montana Dept. Fish, Wildlife and Parks. -Neumann, P. W. and H. G. Merriam. 1972. Ecological effects of snowmobiles. Can. Field Natur. 86(3) 207-212. -Parker, K. L., C. T. Robbins, T. A. Hanley. 1984. Energy expenditures for locomotion by mule deer and elk. J. Wildlife Management 48 474. -Olliff, T., K. Legg, and B. Kaeding, editors. 1999. Effects of winter recreation on wildlife of the Greater Yellowstone Area: a literature review and assessment. Report to the Greater Yellowstone Coordinating Committee. Yellowstone National Park, Wyoming. 315 pages. -Rongstad, O. J. 1980. Research needs on environmental impacts of snowmobiles. Pages 220-227 IN R. Andrews and P. Nowak (eds.). Off-road Vehicle Use A Management Challenge. USDA - Office of Environmental Quality. Washington, DC. 348 pages. -Ryerson, D. K., D. A. Schlough, C. L. Foreman, [et al.]. 1977. Effects of snowmobile traffic on several forage species and winter wheat. Agron. J. 69(5) 769-772. -Severinghaus, C. W. and B. F. Tullar. 1975. Wintering deer versus snowmobiles. Conservationist 29(6) 31.Sheridan, D. 1979. Off-Road Vehicles on Public Lands. Council on Environmental Quality. US GPO. Washington, DC. 84 pages. -Wanek, W. J. and L. H. Schumacher. 1975. A continuing study of the ecological impact of snowmobiling in northern Minnesota. Final Research Report for 1974-1975. Bemidji State College. Bemidji, MN.

Requested Relief: -Properly analyze snowmobile effects upon both HURA and LRA biophysical resources and roadless characteristics. -Close to snowmobiles all MPs that emphasize preserving or mostly preserving roadless characteristics, MPs 1.5, 2.6, 3.2u, 4.1, on the LRA and the HURA south of the North Slope Road and contiguous to the High Uintas Wilderness.

2. Roadless Area Management/Direction

On 14 June the Forest Service formally acknowledged the RACR was in effect for all roadless areas on Forest Service lands. While the forest plan harbors language automatically implementing the rule where it made direction contrary to the rule while it was enjoined by the Court, it is imperative that the Forest Service promptly note the selected alternative in the forest plan is now subject to the RACR and that prescriptions be altered to reflect the status of that rule. The forest plan, under RACR, can not maintain any other prescription for roadless areas than a 1.5, 2.6, 4.1, or 3.2u for the LRA and HURA. When and if a new roadless rule is concocted, the forest plan will then have to be appropriately amended or altered to meet any new rule.

Requested Relief: Roadless areas must be allocated in the forest plan to appropriate roadless/undeveloped management prescriptions.

3.a. Wilderness management

The forest plan dismisses significant wilderness management-related issues by continuing the misleading argument that it is the state wildlife agency that solely manages wildlife, not the Forest Service even though the forest plan concedes a cooperative working relationship where the Forest Service, "often makes recommendations for management in those instances where national forest resources are affected by its actions." That suggests, in fact, the Wasatch-Cache does deal with wildlife/wilderness management making this misleading argument even more incoherent. Since wildlife and fisheries don't survive without habitat, the role the Forest Service plays is crucial! The issues we are concerned with, of course, are fish stocking in lakes within designated wilderness (the required MOU for fish stocking in wilderness lakes is still absent, for example) and introduction of non-native mountain goats in designated wilderness or in areas adjacent to designated wilderness.

The forest plan then notes in the Forestwide Desired Future Conditions for Designated Wilderness these future conditions: -Natural ecological processes are dominant. -Ecosystems are influenced by natural process with little or no intervention. -Native fish and wildlife species are featured… -…unique values of wilderness in providing diverse fish and wildlife habitats… -Exotic wildlife…are not considered for introduction in wilderness even if desirable for recreational purposes. -Exotic fish species…will not be stocked in wilderness waters.

Of course, all of these desired future conditions are built and rest solidly on Forest Service policy! Yet the issues have been dismissed within the forest plan. The disconnect is so wide that it is beyond comprehension. It is not possible to have and maintain desired future conditions without the adequate issues raised, addressed and engaged in the planning process without proposals, actions, analysis, management direction and standards and guidelines.

Furthermore, the forest plan, Forestwide Goals and Subgoals, notes in Forestwide Goal 3-Biodiveristy and Viability: -Maintain communities within their historic range of variation that sustains habits for viable population of species.

It is simply not ecologically possible (and completely disingenuous to suggest otherwise) to maintain non-native wildlife and fisheries (including native fisheries in historically fishless lakes as most of the High Uintas Wilderness lakes have been plainly recognized), particularly in a Wilderness landscape, and meet any standard, ecologically-based definition of historic range of variation.

Finally, the forest plan, Forestwide Goals and Subgoals, notes in Forestwide Goal 13-Designated Wilderness:
-Manage wilderness to sustain wild ecosystems for values other than those directly related to human uses.

The exclusive reason for non-native wildlife transplants, mountain goats, and non-native or native fisheries transplants into historically fishless lakes in designated wilderness is directly and completely related to human uses. The use of wilderness by humans, a crucial and important goal of wilderness management is not in the slightest dependent upon non-native wildlife transplants into wilderness or non-native fisheries (this includes native fisheries in ecological/historically fishless lakes).

The analysis of non-native mountain goat introductions is missing in spite of clear policy statements by the Forest Service (Utah Division of Wildlife Resources, Central Regional Advisory Council, March 22, 2001) that mountain goats are not native, do not belong, and should not be introduced into designated wilderness landscapes. There is no longer a dispute over this issue. There is no discussion of introducing mountain 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 mountain goats are not native to this part of the world and can't be introduced into designated wilderness environments under law and regulation-a position now clearly supported by the Forest Service

There was no discussion of impacts to goats to the context of wilderness and the likely long term physical impacts of mountain goats on those high elevation designated wilderness environments. There was no discussion as to how to deal with the hundreds of mountain goats that now reside in the High Uintas Wilderness and the immediately adjacent LRA. These are not state hunting issues-they are plain and simple habitat and policy issues! They can't be dismissed or run from any longer!

The same concerns exist with respect to non-native, recreational-based fish stocking within designated wilderness. The forest 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 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.

-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.

These wilderness management issues are simply glossed over. And clearly, direction in the forest plan must be clear with respect to non-native mountain goat introduction in and adjacent to wilderness where the likelihood or intent is to get mountain goats into the HUW. No more. It is a simple standard and it is simply disingenuous and dishonest to do anything else.

Finally, the DEIS and Proposed Forest Plan provided a guide as to when wilderness management plans will be prepared or updated. Without explanation, that guidance has disappeared in the forest plan. While it was notoriously slow and unresponsive to the plethora of issues facing Utah's wilderness designated as far back as 1978, most in 1984, at least it existed. Only one wilderness, the High Uintas Wilderness, has a formally prepared wilderness management plan, now 6 years old, and still not being implemented properly because a fundamental requirement of the plan-the monitoring proposal-is still not yet completed in spite of promise after promise from both forests managing the High Uintas Wilderness!

The forest plan simply chose to employ a set of very general standards and guidelines, none of them subject to any analysis or pubic comment/review. They just appeared out of the proverbial ether! There is no rationale for the standards and guidelines-they are not even wilderness specific-sort of a cookbook recipe to fit all and thus not fitting anything.

Requested Relief: -Analyze fisheries and non-native wildlife issues in the context of wilderness management and wilderness planning policy. -Specify and require the forest plan to adopt meaningful timeframes (i.e. those time lines provided in our comment on the DEIS and proposed forest plan) to prepare and update wilderness management plans.

3.b. Forestwide Subgoal-Wilderness Subgoal

The subgoal is counter to the Forestwide Goal 13-Designated Wilderness, which notes the proper direction for wilderness administration and management. The subgoal then notes it is incumbent to manage wilderness differently, based on proximity to populations and the "consequent role in providing wilderness experiences for more people." Not in statue, Forest Service regulation or policy can one find such a direction. Wilderness is designated under one and the same law and there is no explicit or implicit suggestion that wilderness management should be different in any context based on proximity to population centers. Many wildernesses distant from population centers receive exceptionally heavy use and some wilderness more proximate to population centers receive lighter use. Sometimes wilderness size is a factor, and sometimes it is not. Wilderness and the preservation of wilderness qualities and character must be consistent throughout the National Wilderness Preservation System (NWPS) with the sole intent of managing wilderness to meet the definitional and management contexts of the Wilderness Act. There is no need or direction to denigrate wilderness values/character to any degree "in providing wilderness experiences for more people." The simple goal of wilderness administration/management is to preserve wilderness quality in the process of meeting the dictates of the Wilderness Act.

Requested Relief: Remove Wilderness Subgoal.

4. Unsuitable Timber

In essence there is no unsuitable timber base in this forest plan-all lands are suitable! Forestwide standards and guidelines are so broad that they provide no management direction as to determine when and how unsuitable timber lands will be used for timber harvesting. There is no trigger to determine when unsuitable lands will be used other than overwhelmingly broad direction such as "salvage, fuels management, insect and disease mitigation…consistent with other management direction." Of course, all timber harvesting is done "consistent with other management direction or the Forest Service would be in violation of the Multiple Use Sustained Yield Act. The broader issue is the lack of triggers that define when and under what conditions it is important to use unsuitable lands for timber harvesting treatments. Unsuitable lands are deemed unsuitable for a reason. To simply paint them as useable for salvage, sanitation, recreational management or insect/disease mitigation is to categorize them as suitable. To truly be unsuitable but necessary for some purpose is to define the purpose as outside of the suitable timber base. If it is a salvage operation, for example, to be completed on unsuitable lands, it is the trigger that differentiates suitable from unsuitable lands that is so important. Either specific triggers must be defined in the Forestwide Standards and Guidelines-they might be that there would be no commercial logging or no road building-or unsuitable timber lands should remain just that-unsuitable-for timber management. That is, after all the purpose of the unsuitable timber base. The definition and standards and guidelines in the forest plan are deeply cynical and plainly dishonest.

There is also a situation of regulation. By definition the suitable timber base is "regulated" or "managed." The unsuitable timber base isn't. The Forestwide Desired Future Condition states simply that "managed" (suitable) forest land (at some point) will be "dominated by seral tree species" and that other land (unsuitable, etc.) will move through the "successional stages toward climax conditions…" The unsuitable base is certainly not moving through successional stages under direction in the forest plan if it is being harvested for undifferentiated reasons but at the same time is not being regulated.

Requested Relief: The unsuitable timber base is unsuitable for any commercial timber harvesting.

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