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The Real Deal

Folks, here is the real deal.

Some will accuse me of being far too gloomy. For that, I apologize. Some will wonder why we continue this seemingly hopeless battle. That answer comes only from within our hearts. Some will wonder if this isn't just another effort to tease a few extra dollars into our always nearly empty coffers. Nonsense! We do only one fundraising effort - membership - and we send out a total of two reminders. That's it. No foundations. No special fundraising events. No fundraising letters. We are always profoundly grateful and humbled by your kindness.

Let's start with the old and never ending story about the protection of ROADLESS AREAS. (See LYNX 10/03, 12/03, 2/04.)

Not a bit surprising, the Bush Administration and the Forest Service have dropped the roadless rule adopted during the last days of the Clinton Administration and supplanted it with a new rule-making process that allows state governors to petition the Forest Service to establish or adjust management requirements for roadless areas. In other words, roadless area protection will be determined through the formal Forest Service planning process, a dismal history, to say the least, allowing a governor to petition the Forest Service and ask that the "management requirements" for roadless area protection be increased (more likely decreased), for example, within 18 months of the final date of this rule. The Forest Service can either reject or accept a petition and initiate a state specific rule-making and public involvement process.

Remember, just recently the Wasatch-Cache National Forest Plan could only muster formal protection of the North Slope Uintas roadless area on about 30% of the acreage, with barely half the acreage on the Lakes Roadless Area being formally protected as roadless (and 94% of this roadless area was opened to snowmobiles.) And not to be forgotten, the Wasatch recommended a miniscule 35,000 acres of the 122,000 acre Lakes Roadless Area as wilderness but allowed snowmobile use even on this acreage!

Hopefully, the Ashley National Forest will respond with more vision and vigor than the Wasatch to protect the crucial roadless areas on the forest, most of which are contiguous and surround the High Uintas Wilderness.

So backward we go, defying all of the rhetoric of how much the Forest Service is committed to protecting roadless areas (for the next 18 months, most decisions to actually develop a roadless area will be in the Chief's hands.) Never mind the scientific literature, which is now deep and replete with meaningful review and analysis over and over again as to why and how important the last roadless areas are to protection of wildness, wildlife, water quality, and natural ecological processes.

Someday there may be a national roadless rule that will survive the divisive and hate-filled politics of this era, but more likely we are going to have to come to grips with the simple reality the roadless areas will be protected on a forest by forest basis and with passion for places, not for proposals. Your voice is fundamental. If it is vigorous and distinct, roadless areas will not fade. The Forest Service has made it clear it simply canít assemble the institutional commitment or ethics to protect wild and roadless landscapes.

If you want to comment on this backward-looking roadless rule and remind the Forest Service that they are a National Forest Service, beholden to ecological principles and public land policy/ management, not custodians to the 39 governors whose states harbor roadless areas, send your comments by September 14 to:
Content Analysis Team,
Attn: Roadless State Petitions
USDA Forest Service
P. O. Box 221090
SLC, UT 84122
or by email to

And now regarding OFF ROAD VEHICLE (ORV) use. (See HUPC LYNX, 2/04.)

The U.S. Forest Service has also proposed a new national rule concerning use of all off road vehicle (ORV) use. Although this represents a small step forward, with the Chief of the Forest Service at least recognizing unmanaged off-road vehicle use as one of the four greatest threats to America's National Forests, it falls short of what is needed to address such a great threat!

Last April the Chief catalogued the negative impacts caused by uncontrolled off-road vehicle use: "We're seeing more and more erosion, water degradation and habitat destruction. We're seeing more and more conflicts between users. We're seeing more damage to cultural sites and more violation of sites sacred to American Indians. And those are just some of the impacts."

Unfortunately the rules are at best tentative and set only the most benign policy. They do include some policy changes that would be beneficial, if effectively implemented on the ground, including:

  • Prohibiting cross-country, motorized travel across entire forests;
  • Authorizing ATV and dirt bike use only on roads and off-road vehicle routes specifically designated as open for such use.

But the weaknesses are glaring. While the Chief of the Forest Service acknowledged the need to act "now:"

  • The proposed rule does not include a timeframe for starting or completing the process of studying and designating roads and routes appropriate for ATVs and dirt bikes. It will be up to each District and Forest and the ongoing travel management planning.
  • The proposed rule is largely silent on the preeminent problem unauthorized, renegade routes.
  • Having enough law enforcement people and other resources to monitor impacts and enforce basic rules is essential to successful management, but the proposal does nothing to boost on-the-ground management and enforcement capability.
  • And, believe it or not, snowmobiles are not considered in this rule making!

If compelled to take action, you can comment to the Forest Service by September 13. Remember, when it comes to travel planning, it is crucial that you participate in the individual travel and forest planning processes.
Urge the Forest Service to:

  • Complete off-road vehicle route designations within two years of the effective date of that rule.
  • Immediately end use of all unauthorized, renegade routes.
  • Insist that the agency properly monitor ORV use.
  • Since snowmobiles are one of the prime off-road uses and act, literally, as both the vehicle and the road in that they can go anywhere, they should be part of this rule.
  • Insist all roadless areas be closed to all vehicle use.

Comments are due by September 13 to:
Proposed Rule for Designated Routes and
Areas for Motor Vehicle Use
c/o Content Analysis Team
P.O. Box 221150
Salt Lake City, Utah 84122-1150
Email: To view this:

For a superb review of on-the-ground ORV management, check out the Ogden Sierra Club website and take a look at the analysis of the Ogden Ranger District's troubles at meaningful ORV management -

And then there is forest planning itself.

New rules being promulgated and soon to be released by the Forest Service will, among other things, likely eliminate the requirement that each forest produce a formal Environmental Impact Statement or even an Environmental Assessment with each forest plan! There will also very likely be major denigration in the importance of maintaining viability of wildlife species and a greater emphasis on economic outputs rather than ecosystem integrity.

The Wasatch-Cache National Forest continues to pursue timber harvesting with the release of the Final EIS for the East Fork (Bear River) Salvage Timber Sale. (See HUPC LYNX, 2/04.)

The FEIS makes minor changes but continues to note the primary purpose of the sale is to provide timber for commercial harvest to local communities supposedly affected by the 2002 East Fork Fire started by the Boy Scouts on the East Fork Bear River. Over four miles of temporary roads will be constructed, trees important for wildlife habitat will be harvested, and none of it is needed to address any resource issue. Resource concerns dealing with the fire itself are minimal and easily addressed by non-harvesting treatments, notably no road building and actions already commenced shortly after the fire was controlled.

We are grateful the sale does not enter any of the roadless lands adjacent to the High Uintas Wilderness! But by connecting the timber sale so plainly and clearly to the goal of appeasing supposedly local communities and timber mills and not starting with meeting the other broader ecologically based goals in the revised forest plan, it is clear the forest excluded our collective voices from the beginning. If you don't harvest timber and don't live in Evanston or Bridger Valley, WY, too bad!

We were honored to join, as co-appellants, the Utah Environmental Congress appeal of the East Fork Timber Sale EIS. But it doesn't end there...

There are three other small timber sales also proposed on the Evanston/Mt. View Ranger District. One is proposed to harvest conifers in order to initiate prescribed fire in aspen to regenerate the aspen. The only problem with the proposal is the conifers don't need to be harvested to initiate and complete the project!

Another has been requested by private land owners asking the Forest Service to salvage trees adjacent to their property to create a fuel break. The Forest Service notes this would not "fireproof" the forest and that future harvests will be likely.

All of the ecological data suggests that such drastic timber harvesting has little impact on fire intensity. What matters is assuring structures are adequately protected with proper construction to lessen ignitability, the primary reason structures catch fire, and removal of small fire prone vegetation within 100-200 feet of a structure. Wildland logging serves little or no purpose to lessen ignitability of structures and is virtually impossible to create a fire break.

Yet another recent proposal calls for removing small patches of pine beetle- infested trees along the North Slope on the premise that this could slow pine beetle infestation. Of course, the Forest Service admits they don't know by how much or if the problem is even worth the effort. The real reason is noted in the last sentence of the scoping document: "Removal of these trees would also supply wood products to local industry." The data is replete and without disputation, produced by Forest Service researchers themselves, stating that, in this kind of forest, pine beetle infestations at all levels from minor to epidemic are normal and logging efforts simply compound ecological disruptions. Interestingly, the Forest Service didn't even offer a comment reply date and just noted that the whole project may be excluded from the preparation of any formal environmental analysis and public review!

So if forests mean something to you, start a logging operation...

Meanwhile, the Wasatch-Cache N. F. forest plan revision date allowed leasing on the last few acres of unleased land on the North Slope within the roadless country... thus opening the Main Fork (see HUPC LYNX 6/04) adjacent to the High Uintas Wilderness to oil drilling.

A pro forma Supplemental Environmental Impact Statement is being produced and will be released this summer, authorizing the oil company to access a drilling site just north of the High Uintas Wilderness in what was once a wild drainage on the North Slope of the Uintas. The irony? The Forest Service could have easily said NO to leasing in the forest plan and the issue would have vanished. The ultimate irony is the data in the forest plan showed that this area is well south of the oil producing structures with a very small possibility of any discovery.

Fox and Crescent Lake Reservoirs (see HUPC LYNX 6/04) within the High Uintas Wilderness are now private easements held by Dry Gulch Irrigation Company.

The Ashley National Forest and the Regional Forester signed a decision allowing Dry Gulch Irrigation Company a private easement within the High Uintas Wilderness on Fox and Crescent Lake Reservoirs and allowing them to access the reservoirs with helicopters and assorted heavy industrial machinery to maintain the reservoirs.

The irony? The agency did not even consider a primitive tools alternative, making the decision to allow a private easement even though the enabling legislation specifically prohibits this from happening in Wilderness. More irony? The Forest Service for nearly 20 years knew this issue was in the wings and did nothing to require Dry Gulch to seek alternative water storage. Instead of a special use permit, which grants the Forest Service full control over the reservoirs, a private easement transfers primary responsibility to Dry Gulch and offers no incentive to find water sources outside of the Wilderness.

With the help of Western Resource Advocates, we have appealed this decision.

Stating it doesn't need to recognize Management Indicator Species (MIS), the Ashley National Forest has identified only two-- native cutthroat trout and goshawk. (See HUPC LYNX, 2/04.)

While these species are good selections, the decision is woefully inadequate and runs counter to clear and concise legal obligations, regulations and prevailing ecological discourse. While it is true the idea of MIS, as it has been used, has come under scrutiny, the context of identifying species that are indicators of ecological conditions within specific habitats or groups of habitats and that are sensitive to management actions has become more pronounced in the ecological literature. The rationale is undeniable - this kind of monitoring requires managers to look at forests, not age classes, stand conditions and potential yields. It becomes a system-based monitoring process rather than resource-based monitoring. More and more ecologists are noting the value of keystone species, for example, habitat specific species and wide-ranging predators as indicators of broad system integrity, connectivity and diversity.

One portion of the Ashley analysis is of merit as they note so many species are hunted or trapped and fished so as to be indicators more of human recreation than ecological indicators. Precisely why we have called for wildlife and fisheries preserves to assure not all wildlife is simply counted as yield! Someday, the Forest Service will perhaps join this endeavor.

We joined with Red Rock Forests and Western Resource Advocates in appealing this decision.

The Ashley National Forest, Vernal Ranger District, recently release the Trout Slope West Timber Project FEIS. (See HUPC LYNX, 4/04.)

While better than it was originally proposed, this timber sale still creates deep suspicion. Plainly stated, the timber sale serves no resource function and is offered for one single purpose - to provide timber to local mills, much like the East Fork Salvage timber sale on the Wasatch-Cache N. F. What happened to those days of yesteryear and promise from the Forest Service that timber sales would be built first and foremost around ecosystem values and principles? Another wink and a nod...

The positive aspects are no new roads will be constructed and no roadless areas entered. The extant roads used for the sale will be closed and allowed to re-vegetate. An interesting and ironic note here, the Forest Service argues it is better to simply gate the roads and allow them to rehabilitate themselves, rather than go in and scarify the roads because of concerns over soil erosion and disturbance. Ironically, this issue is not raised as a serious concern with actual logging activity!

But not all is bleak. The Ashley National Forest has completed an eligibility analysis for potential Wild and Scenic Rivers (see HUPC Newsletter, 8/98) in the forest planning process (see HUPC LYNX, 6/04). About 30 rivers and segments were identified -some 350 miles. The Ashley's draft roadless inventory looks very hopeful. The real questions will be answered during the formal planning process - will the rivers be recommended as suitable and protected under the Wild and Scenic Rivers Act? Will roadless areas receive protection by the forest with meaningful wilderness recommendations?

And not as an antidote to the bad decision on Fox Lake, we remind all that the decision to remove the 13 small reservoir lakes in the High Uintas Wilderness on the Lake Fork and Yellowstone Rivers (see HUPC LYNX 12/01) is a decision that wilderness advocates, water users/managers, and the Forest Service ought to hold high and proud.

Should we throw in the towel?

It is clear there is no hope with the Forest Service - there are remarkably good, adept and hopeful folks in the agency, many as frustrated as we are with a clear swing back to the past. But the hope isn't with more roads, endlessly more ORVs and snowmobiles, more timber sales, more nonsensical oil and gas leasing to grub another tiny half barrel of oil, private easements in wilderness just to appease local officials and water managers, less public involvement in public issues, hopeless battles with mother nature's tiny little pine beetle and its exquisite dance with lodgepole pine forests.

No. The hope is with wildness, the wonder it embraces, the future it offers, and the humility it plainly presents. All of this will come from a simple, plain and vital wild voice. Close your eyes and dream of the life that is right now moving through time on Oweep Creek high in the Uintas. We are but a part of that mystery. It is not our world - and wild places tell us that, if we are listening. That is why we donít throw the towel in and why we will move on. The hopelessness of these empty decisions offers only more emptiness. Our full wild voice, each time it is raised, hungers for the bob and weave of a pine marten or the sense of goshawk merging with the forest.

So we urge you to join with us in this celebration at our annual Rendezvous at Mirror Lake at noon on September 11. It will be a chance to share in the hope we find.

Dick Carter

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