Well, your comments are written (thank you, thank you!) on the Utah National Forest Wild and Scenic River Draft Environmental Impact Statement (DEIS) and you sent them, of all places, to a Forest Service analysis team in Sacramento. Why our comments did not go to Ogden or SLC, Vernal, Richfield, Provo, Price or Cedar City adds to the intrigue and certainly lends a bit of suspicion to the entire process.
As we have said in the past, it is a lame DEIS (see The LYNX, 12/07 and special HUPC Alert, 2/08) intended to minimize the number of river segments that should be recommended for inclusion in the National Wild and Scenic River System (NW&SRS) rather than analyze what should be found suitable. Let’s start with the alternatives in the DEIS.
Of the six alternatives in the DEIS, two of them reject any suitability determinations. Two of the remaining four alternatives recommend barely a quarter of the river segments and mileage as suitable. One alternative recommended 63% of the mileage as suitable and 58% of the river segments. The sixth alternative was offered by a group of conservation organizations led by the Utah Rivers Council and recom-mends about half of the river segments and mileage.
Not surprisingly, the alternative that would recommend all of the eligible river segments as suitable is missing from the analysis. This alternative is essential as it provides a more realistic measure of both positive and negative impacts from suitability designations--it is the ceiling, if you will, as compared to the two lower baseline alternatives. It offers a true and broad array of alternatives as required by National Environmental Policy Act (NEPA).
But it gets even worse. The preferred alternative (24 rivers and 212 miles statewide, 11 rivers and 131 miles on the Uintas) makes a decision, seemingly without analysis, that, in all cases, no matter how minor the conflict might be, development potential trumps outstandingly remarkable values and river segment suitability. This assumption needs a clear analysis as to why it is purported to be true. Why is it that any development potential automatically and without review has notably greater weight than the preservation context of outstandingly remarkable river values? On its face this is absurd and clearly reveals a bias in analysis. Nowhere in any formal language associated with the W&SRS is the direction set forth to assure development trumps all river values.
It is even suggested in the DEIS that it is the cost of river management plans that precludes the incorporation of an all river segments suitable alternative. This is utter nonsense!
Because many of these river segments on the Uintas are within the High Uintas Wilderness (HUW), or mostly within roadless areas, and many contiguous to the HUW, river management plans would not be nearly as “expensive” to prepare since formal statutory guidance (Wilderness) exists or broad regulatory guidance (roadless areas) is in place.
However, the problems in this DEIS are even greater than a failure of alternatives. Within alternatives the river selection makes little sense, at best appears to be arbitrary, and nowhere within the DEIS is there a clear rationale provided for why one river is in and another out. Of course, this is most notable with the preferred alternative. Why isn’t the Middle Fork of the Weber River in Alt. 3? It certainly meets the characteristics and criteria. The same with the Main Fork of the Weber River or the Yellowstone River, Rock Creek or Lake Fork, Middle Whiterocks, Lower Dry Fork, Ashley Gorge, Stillwater, Little East Fork Blacks Fork, East Fork Blacks Fork or Left, Right and East Forks Bear. It is not possible to determine why these rivers don’t meet the foundational criteria within Alt. 3. There appears to be no systematic manner in which rivers were included or excluded within the preferred alternative other than decisions made by Forest Supervisors. That is not good enough, to say the least. River segments that meet the context need to be in Alternative 3.
The DEIS presents another notably disturbing analysis in the effort to exclude suitability determination for many of the eligible rivers. Throughout the DEIS it is noted that many rivers have potential dam sites associated with river segments, most times upstream or downstream, sometimes the actual segment under consideration.
As one example it is noted that a conflict exists on the Lower Dry Fork because of the proposed upstream Blanchett Park reservoir proposal. It is not noted, however, and it is as devious an omission as we’ve seen, that in November 1995 the Ashley National Forest prepared an EIS and rejected the Blanchett Park Dam proposal.
A similar situation is noted for many rivers--Stillwater, Hayden Fork, East Fork Bear, Ashley Gorge, East and Middle Fork Whiterocks, South Fork Ashley, and the Yellowstone River. It is noted that reservoir potentials exist...even though they were identified in reports dating back to 1940, some 67 years ago, or a report dating back to 1958, nearly five decades back! In some cases a 2001 Wyoming Water Plan report shows potential alternative dams sites (developed from studies in 1985) on some North Slope Uinta river segments under suitability consideration. It is important to recognize in every single instance these proposals are not only from outdated reports, but have no narrative history associated with them and have never seen the proverbial light of day. None of these proposals has been forwarded to the Forest Service, for example, in even a pre-NEPA context, let alone in a formal NEPA proposal with the exception of Blanchett Park, which was rejected. These proposals are fabrications, on paper at best, almost all dating back many decades, with no formal proposals being contemporary or even remotely considered!
Clearly, even within the strangled context of Alternative 3, the preferred alternative, a number of Ashley and Wasatch-Cache National Forest river segments harbor outstandingly remarkable values, many have received notable public support and have no impact upon “reasonably foreseeable future water resources projects....” At the minimum they include these segments within or mostly within the High Uintas Wilderness:
And, in particular, the following primarily roadless river segments harbor outstandingly remarkable values and have no impact upon “reasonably foreseeable future water resources projects....”
Let’s hope for a bit of honesty, professional evaluation and that the context of preservation has not been lost from the Forest Service institutional vernacular!