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Going back at least two district rangers, we have worked with the Kamas Ranger District on the concepts of their recently released Backcountry Semi-Primitive Non-Motorized Recreation Plan. Mead Hargis and other KRD staff have shown the utmost professionalism and encouraged meaningful public participation on this effort for the last five years. And from the outset we want to heartily express our appreciation and support of the process and effort that has gone into this plan to manage the area encompassing our proposed Mt. Watson Wilderness (see The Lynx, Dec. 1998 and the HUPC Newsletter, March/April ‘97.)

While some have suggested this effort is too restrictive and others call for an EIS, we want to suggest the planning process is responsive and contextual. It is crucial that a plan be in place sooner than later and we’d suggest sooner is upon us.

But it was not as responsive to the identified issues as we’d hoped. Without changes, we fear the plan will be more paper tiger than backcountry recreation plan.

The plan presupposes the need for outfitting and guiding. We strenuously suggest an analysis in the EA in the form of an alternative that discusses a no outfitting and guiding option. This analysis should/ must include a discussion as to whether the Forest Service missions/goals can be met without the use of formal outfitting and guiding. The EA makes an assumption because some goals and missions are partially met by outfitting, then outfitting and guiding inherently meets that test. Thus another indicator that needs a more detailed and meaningful analysis must be whether outfitting and guiding will advance the sustainability of the physical, primitive recreation and biological resources the plan proposes to protect. To judge outfitting and guiding against administrative or citizen need criteria, rather than against environmental impacts, is an action that must be rectified.

We still believe the idea of beating hearts is a creative and imaginative concept.The Kamas District should be commended for thinking holistically. But allowing 25 beating hearts per group as a standard in the upper Provo River does no good since the EA admits that only 1% of the present users exceed the standard. An indicator that is so far out and beyond the present use levels, which are deemed at the margin now, according to the EA, actually becomes a threat to the context of the plan. Under this indicator it would be possible to have 12 people and 13 horses-- can anyone honestly imagine anywhere such a group could meet the values associated with the upper Provo River backcountry?

It is true that this standard is less than the standards adopted in the High Uintas Wilderness Management Plan (see HUPC Newsletter Aug. and Dec. 1997 ). The Kamas District deserves kudos for its courage and vision. But this only shows how derelict the Wasatch and Ashley Forest Supervisors and the Regional Forester were when they constructed and authorized a 15 person, 14 horse restriction.

We suggest standards of 10-15 beating hearts for the entire area. The literature is replete with one general theme-- smaller groups leave fewer physical impacts and create fewer social impacts. The larger the group, the lower the expectations, which becomes an insidious, self-replicating cycle. As the expectations of quality backcountry drop so does the quality of the users. Soon a cultural/institutional problem exists (to some degree it exists now) where users believe it is okay to tolerate more and more conflicts and biophysical impacts. Crawling out of that spiral is very frustrating; look at Granddaddy Basin in the High Uintas Wilderness in Granddaddy Basin. Everybody admits such a problem exits but the agency steadfastly stands behind a low quality wilderness experience and value because that’s the way it’s always been!

We fully and enthusiastically support the standards employed to guide recreational livestock use. We are also very supportive of the restrictions on mountain bike use. More and more anecdotal and research-based evidence exists that mountain biking and non-mechanical recreation activities collide, sometimes literally! Furthermore, the intent of the forest plan and of this document is to maintain the primitive nature of this backcountry which can only occur under conditions where mechanical use does not exist. Both the sense of wildness and the actual wildness is lost if transport through the area is by aluminum alloy, rubber-tired, multi-geared, high-tech, manufactured bicycles.

Unfortunately, this plan is meaningfully wrong in two places. First is the fact that snowmobiling is not re-evaluated across most of this area. We urged and urged this in the travel plan and, while it received an analysis, the decision was not based on a broadly envisioned review. It failed to recognize, as we have consistently suggested, that snowmobile technology would continually improve until all the backcountry is accessible. That is now the case. Sooner than later snowmobile use in this country will become a significant biophysical and recreational conflict.

But the most obvious reason to close this country to snowmobiles is the impact upon the undeveloped nature of the landscape. Snowmobiles don’t belong, especially given the fact that huge acreages exist for snowmobile playgrounds on landscapes where maintenance of an undeveloped nature is not the driving motive.

The other serious error in the document is the fact that the analysis refuses to even address or analyze the issues of stocking non-native fisheries. It is an issue of consequence and has been raised within the rules set out by this very planning process. To ignore it is mischievous.

Fishing for non-native trout in lakes that were fishless prior to fish stocking programs is a significant use in this country and one of the primary activities that has created the recreational impacts and conflicts this EA is attempting to address. Without analyzing the reasons for the identified problems the decisions will be shallow at best.

We realize this issue is of deep controversy-- even to some degree within our own organization. The Forest Service has become terrified of state wildlife agencies and their rogue threats. But the agency, including the Kamas District, must be able to honestly and objectively deal with the issues it faces. If not, the agency creeps backward quickly and is less than honest as it touts "ecosystem management" language!

The EA insists on looking only at recreational impacts without realizing it is the wild, undeveloped nature of the landscape that creates these highly valued recreational opportunities. Thus it only makes sense and is required by law to analyze the impacts of recreation upon the natural environment where the recreation is occuring. There are numerous sensitive species in the area, including the likelihood of lynx which could also be impacted by snowmobile use.

Rather than setting camp fire site designation standards for heavy use areas we would suggest simply prohibiting camp fires in these areas since we already know that use will increase and the likelihood of firewood availability will diminish. Of course, the campfire prohibition would need to be phased in, but it is clearly the only long term option for the areas identified in the EA as needing campfire site designation. We strenuously suggest adding both Clyde Lake and Cuberant Lake to that immediate list.

There just seems to be too much of a disconnect between the issues and the actions identified to correct the issues. The need and purpose of the document is clearly noted. The direction moved in this EA is hopeful. Even though many of the standards and indicators are good, as we’ve noted, the distance moved is not connected as powerfully as it should be to the problems identified, which will leave far too many gaps in managing this incredible area.

Dick Carter

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