Late in April the Evanston/Mt. View Ranger District released a proposal to re-authorize grazing on the Red Castle, East Fork Blacks Fork, Middle Fork Blacks Fork, Lyman Lake, Little West Fork Blacks Fork and Elizabeth Mt. grazing allotments utilizing a categorical exclusion (CE). A CE is a super-abbreviated analytical process, as we have noted over and over in these pages, meant to diminish public involvement and minimize environmental analysis. It is also crucial to understand the Forest Service does not have to use this process—it is voluntary!
In this case, the Forest Service failed to note in the scoping/proposal letter that the Red Castle and East Fork Blacks Fork allotments are entirely, or nearly so, within the High Uintas Wilderness (HUW.) The Middle Fork Blacks Fork allotment is also within the HUW and primarily within the roadless country adjacent to the HUW. This was not an oversight, but intentional so as to deflect public concerns from the obvious wilderness issues and to rationalize the minimum analysis the Forest Service proposes to utilize to re-authorize grazing. We raised this same concern in September 2005 in the previous batch of HUW grazing allotments. (See HUPC LYNX 10/05.)
This proposal to re-authorize grazing harbors no information except that the Forest Service intends to re-authorize grazing. No studies, no analysis, no overview, no background, no descriptions, no history, no alternatives. Nothing. It is plain tomfoolery!
While we are dumbfounded, we are not surprised by this proposal. The Wasatch has had over a decade to initiate the necessary environmental analyses, properly group allotments and provide full public comment and review. They dumped that process in favor of simply amassing clutches of allotments, notably different in nature, incorporate meaningless broad stroke guidelines and categorically exclude them from environmental review and public involvement. It is a disingenuous and dishonest policy!
It is obvious that a CE for these allotments has a simple purpose— to prevent meaningful public participation and the decision to authorize grazing can continue unimpeded at the expense of public and environmental concerns.
The word wilderness does not exist in the proposal even though wilderness is the dominating resource value on the East Fork Blacks, Red Castle and Middle Fork Blacks Fork allotments. To suggest there are no impacts is silly. The impacts are undeniable, broad and deep. By its nature, grazing confounds wilderness. Grazing is not foundational to the meaningful and context of wilderness. Just because grazing is allowed in wilderness does not mean impacts do not occur. They must be analyzed and documented. The law is clear.
An analysis of issues ranging from wilderness to roadless to water quality, soil stability, biodiversity, plan succession, endangered species along with a plethora of recreational and other wildlife related issues have been shoved aside by this process!
On projects with impacts upon tens of thousands of acres of public national forest land, much of it in designated wilderness and contiguous roadless landscapes, it is imperative that a full scale environmental review be implemented.
Unfortunately, the Evanston/Mt. View Ranger District has selected a process to send an undeniable statement that public concerns are to be minimized and grazing interests maximized. Again.
This is hardly the context of public interest, professional forestry.