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The Preliminary Alternatives, Wasatch-Cache National Forest Plan Revision has finally been released. THIS IS NOT THE DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS), but represents the 5 alternatives that will be evaluated in the DEIS that will follow this document sometime later in the fall.

To the credit of the Wasatch, they again opened this process to public comment. The test will be how comments will be utilized to improve or alter alternative outputs.

The five alternatives represent various themes: #1- Conservation Biology, or nature-takes-its-course; #2- Biodiversity; #3-Need for Change and Proposed Action; #4-No action, or continue-the-1985-plan; #5 Development, or traditional- rural- economy- culture. This alert will focus primarily on the disposition of roadless areas.

While we recognize and support the need for a distinct array of alternatives, we have severe problems with Alternative 5. It is not realistic nor reflective of the rural economies or livelihoods on this forest, but is an alternative of a small sub-group of folks, obviously those screaming loudly and intimidatingly, who insist on an archaic and intolerant view of culture and custom. It is a dangerous thing for the forest to adopt because it suggests that those who do scream get results. The rest of us plod along with some degree of measuredness only to find those who rattle past dictums get attention. Meeting rural concerns is meaningful but the forest must look closely at the demographics of Cache, Rich, Box Elder and Uintah (WY) Counties to assure the alternative is connected to those counties. For the most part, they are broad-based counties, both economically and socially (Rich County being a partial exception).

As we've said from the outset of the FS proposed action, Alternative 3, we remain deeply concerned with the allocation of roadless areas/wilderness recommendations and the actual protection of roadless areas. Fortunately and thankfully, the National Roadless Area Conservation Policy (RACP) will absolve the Wasatch by formally protecting roadless areas. The fact that such protection must come from the Chief and not an individual forest, one that bills itself as progressive, no less, is depressing.

The Wasatch-Cache still seems timid when it comes to protecting roadless areas and making wilderness recommendations. The assurance that roadless areas will be protected comes in personal conversations or tangentially in alternative descriptions ("...generally would not be developed or would only be developed where it would be necessary for achieving habitat improvement or restoration.") That is doublespeak!

The matter of fact is the proposed action flies in the face of the context of its name, Need-for-Change. There is no doubt that roadless areas are of meaningful importance in forest management and that protection of significant roadless acreage has been part and parcel of forest planning and nearly every project on the forest since the 1985 forest plan. Yet only a third of the roadless acreage is given some kind of formal protection on less than a third of the areas. This is classic forest fragmentation and most distressing!

The forest states that roadless areas will be protected but only writes it in a vague alternative direction that assures tension over expectations and will send confusing management direction to forest users.

The wilderness recommendations are even more stingy in the supposed need-for-change proposed action. Less than 50,000 acres on the whole forest is timidly recommended as wilderness...less than 9%! Contrast that with the September 9, 2000 remarks by the Chief of the Forest Service to The Wilderness Society wherein he acknowledged the Forest Service must be more forward-looking when it comes to recommending additional wilderness. This proposed action with a tiny recommendation on the Uintas and, surprisingly, no recommendation on the Lakes/Mt. Watson area (a major surprise, given that the earlier version of this proposed action showed the Lakes as an either/or) was deafening.

And to suggest that the rural residents envisioned in Alternative 5 want no wilderness is just not accurate. It is, no doubt, the wish of a small backward-looking group of people that apparently are dictating the construction of this alternative , but it is not representative of the alternative's theme.

How can this be improved so the alternatives provide a true array and respond to need for change? Table 1 (please see charts on facing page) represents HUPC s wilderness proposals by percentage of roadless area recommended as wilderness, using the Forest Service format in the Preliminary Alternatives Booklet. Alternative 1 is the same as the Forest Service alternative with the exception that the Lakes/Mt. Watson area is larger. All other areas in Alt. 1 are the same as the Wasatch NF proposal. In the chart, the second set of parentheses represents the FS wilderness recommendations in each alternative.

Table 1. Suggested Roadless Disposition by Alternative

1 2 3 4 5
HU (69%) HUW(69%)(28) HUW(28%)(20) HUW(18%) HUW(20%)
Lakes (~65%)(49) Lakes (60%)(35) Lakes(35%) Lakes (35%)  
LPeak(56%) LPeak(56%) LP(56%)    
Mt. Aire(71%)     Mt.Aire(49%)  
MNaomi(85%) MNaomi(85%)(20) MNaomi(20%)(10) MNaomi(31%) MNaomi(10%)
MOly (93%) MOly(93%)(21) MOly(21%)(22) MOly(94%) MOly(22%)
SMts(88%) SMts(88%)(43) SMts(43%)(13)   SMts.(13%)
TPeaks(83%) TPeaks(83%)(8) TPeaks(8%) TPeaks(53%) TPeaks(8%)
USFork(100%)   USFork(100%)(100) USF(92%) USF(100%)
WMts(94%) WMts(94%) WMts(94%)    
WPine(95%) WPine(95%)(95)   WPine(95%) WPine(95%)
Wid Mt(100%)        

Table 2. Comparison of Wilderness Recommendations (recs.) proposed by HUPC versus the WCNF.

Percentages reflect the amount of roadless area recommended as wilderness as per WCNF format.


1 2 3


WCNF 13 recs. WCNF 7 recs. WCNF 6 recs. WCNF 0 WCNF 0
HUPC  13 recs. HUPC  9 recs. HUPC  9 recs. HUPC  8 recs. HUPC  6 recs
WCNF ~45% WCNF ~17% WCNF ~9% WCNF  0% WCNF  0%
HUPC ~48% HUPC ~38% HUPC ~20% HUPC ~22% HUPC ~9%

The logic of these suggested changes is clear. Alternatives 1 and 2 do what their theme intends them to do-- vigorously protect large, high quality blocks of land that add to the ecological integrity of the forest. They both focus on "rounding out" the extant designated wildernesses with meaningful additions, making those areas large, intact wild places. The only change in Alternative 1 is the Lakes/Mt. Watson area where we suggest ~65% recommended as wilderness.

Alternative 2 increases the number of recommendations by only two but increases the acreage to 38% of the roadless lands recommended as wilderness.

Alternative 3 accomplishes the same context of focusing the wilderness recommendations adjacent to the extant wildernesses in a much more measured manner, meeting the obvious need for change theme while being consistent with the proposed action and recent management direction on the Wasatch Front. It also makes a much more authoritative and equitable statement toward meeting the intent of Forest Service direction and need-for-change by recommending more wilderness.

This suggested alternative array keeps the focus of wilderness designation on adding high quality wildlands to the extant designated wildernesses rather than recommending oftentimes small or disjunct areas. It is exceptionally consistent with providing a broad array of alternative acreages to be recommended as wilderness while preserving their themes. To this extent it differs only in degree with the proposal in the Preliminary Alternatives booklet with one exception: the proposals in the Preliminary Alternatives booklet reveal two of the five alternatives harbor NO WILDERNESS RECOMMENDATIONS.

While 45% is a lot of wilderness to some, it really is not a high number. It is reasonable and based on high quality lands and a meaningful inventory and evaluation. No matter how it fulfills the ego of a few users (we hope none in the Forest Service), the ZERO % of Alts. 4 and 5 is unacceptable. It does not belong in a forest plan discussion that purports to meet a broad array of public and ecological concerns. But it shows an even deeper bias that concerns us-- NO ALTERNATIVE RECOMMENDS A LL ROADLES AREAS RECOMMENDED AS WILDERNESS. Neither all or none is realistic!

These changes are necessary to make the alternatives more responsive to the intent/theme of each alternative. They are realistic, consistent with the landscapes involved and broad-based. The WCNF simply can't maintain its archaic NO or MINIMAL WILDERNESS view.

There are numerous good components to this effort. The prime wilderness recommendations are in place in Alternatives 1-3 and only need to be adjusted in size. The proposal s language to discourage non-native wildlife introductions is commendable but should be strengthened so as not to suffer from the expectation dilemma. We expect discourage to be vigorous. Allowing wildland fires and protection of wildlife corridors in some fashion across the first 3 alternatives is good. Timber harvesting excluded from roadless areas or to achieve historic conditions is meaningful. No ski area expansion is forward-looking.

We are deeply concerned with the recommendations on oil and gas leasing with the exception of Alternative 1. The intent of Alts. 1 and 2 should FORBID leasing in roadless areas. Alternative 3 should include, for example, NO SURFACE OCCUPANCY OR NO LEASING ON ALL ROADLESS AREAS AND LYNX HABITAT.

Reliance on forest watershed structural improvements in Alts. 2-3 is wrong-headed. What is needed is limitations on the uses that cause watershed damage.

Alternatives 1-3 should have a snowmobile prohibition in all roadless areas (#1) and all roadless areas adjacent to designated wilderness (#2 & 3). This is more consistent with the alternatives themes and offers proactive management since we all know snowmobile use will only in crease until roadless values are significantly diminished or lost.

Dick Carter

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