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The Forest Service has finally agreed native fisheries, Colorado River cutthroat trout (CRCT) have a role in wilderness-- only a few decades longer to come to this realization than the rest of us and, of course, not without a twist! The Ashley National Forest is proposing to use a poison, rotenone, to kill extant fish populations (and macro-invertebrates and am- phibians) applied within the High Uintas Wilderness (HUW) utilizing motorized boats flown in by a helicopter.

Do we really need to say more?

There is an equally stupid idea--just go to the Chief of the Forest Service (FS) and ask him to go to Congress and undesignate the High Uintas Wilderness (HUW) so all of this can be done in perfectly good conscience. It is inconceivable that the Roosevelt/ Duchesne Ranger District and Ashley National Forest can be proposing this in good conscience. It is anything but a necessary wilderness management project. Helicopters, motor boats and poison are obviously counter to the very context of wilderness. Can there be a disputation on this point?

The areas involve numerous lakes and streams in Garfield Basin, Swasey Hole, Toquer Lake, Ottoson Basin, Oweep Creek and Fall Creek.

Because the project is in a designated wilderness and proposes the use of motorized boats/rafts lifted into the wilderness by helicopters, it is obviously a Regional Forester decision and, if it proceeds, clearly should be analyzed in a full scale Environmental Impact Statement.

According to the scoping letter, numerous applications of poison may be required to achieve whatever desired results are expected-- and that is entirely unclear. This assumes motorized rafts will be left in the HUW for a prolonged term or that numerous helicopter invasions will be necessary.

The project would be monitored for several years to determine the success of the project. That could mean, we assume, more helicopters, motorized rafts and poison in the future if non-natives reappear. Or it could mean, we presume, that after the helicopters, motors and poisons, the project is determined to be unsuccessful. Either way it slams the idea of wilderness.

Thus the end product--the desired condition--must be fully and completely defined. What is success? And what if it fails? The literature is fairly conclusive on the problems with use of rotenone on high elevation lakes and streams, exacerbated by small springs, beaver and muskrat habitat. In high elevations amphibian and macro-invertebrate assemblages are obviously slow to recover. What is an acceptable recovery time? And what if it is not met? Doing all the pre-project inventory work is good but that does not help in recovery after poisoning which is an equally and crucially important concern in very high elevation ecosystems.

What will happen if non-natives reappear? That certainly will occur as long as traditional recreational fish stocking programs continue down (or up) stream.

While we fully support the return of native fisheries in the Uintas and have advocated it for decades, we can’t see the rationale for this intensive non-wilderness approach being used in the High Uintas Wilderness. This project will not meaningfully assure that CRCT will eventually be listed under the ESA. It certainly emphasizes deep human manipulation and influence rather than a reliance upon natural forces. It is anything but a minimal impact upon wilderness values. It steals the uniqueness of the wilderness resource. There are alternatives which assure wilderness values dominate. It accomplishes the management activity with motorized and mechanical equipment in a monstrous manner. It is not necessary to enhance wilderness values or management. It is not an emergency. It is not essential to meet wilderness management goals or administrative needs.

Ironically, all of these concerns come directly from the Forest Service Manual on wilderness management.

For decades (Forest Service files are stuffed with concerns from HUPC and, before that, the Utah Wilderness Associa- tion), we have argued the best way to handle this issue is to work with the Utah Division of Wildlife Resources (UDWR) to eliminate recreational-based fish stocking programs wilderness-wide. Anything short of that is piecemeal and will eventually result in this project being conducted over and over.

If the Forest Service and UDWR are actually serious about native fisheries and wilderness values/management such a systematic approach is essential. It is the only way to achieve a process whereby non- native recreational based fish stocking will be supplanted by “natural-wild-wilderness” forces. Thus the effort that should be engaged is a broad systematic analysis to determine how to end fish stocking, over what period of time, followed by a systemic analysis of how to reintroduce native fisheries and where they originally existed and how to assure they will survive.

This assures wilderness values are met and “natural-wild-wilderness” forces are allowed to determine ecological integrity.
Fish stocking is not a fish or wildlife activity. It is clearly an alteration of habitat-- and solely Forest Service responsibility. The Ashley should use it, at least once!

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