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The Kamas and Evanston Districts of the Wasatch-Cache National Forest have proposed to allow outfitter/guided snowmobiling for 800 user-days per year along the Mirror Lake Corridor. This corridor includes off-highway use and use around and on Mirror Lake. Outfitter/ guiding will increase use in this already heavily used area; increase the demand for more parking; increase user conflicts; and increase effects to wildlife, water and air quality. The proposal also sets the precedence for increased snowmobile use and increased commercialization of the Kamas and Evanston Ranger Districts. As use on these districts increases because of increasing population, ways must be found to accommodate some of this use by the general public while protecting the environment. Allowing priority days for people who pay defies true public use of these lands.

The Draft EA for the above project has almost no environmental analysis, no economic analysis, ignores the concern that Forest Service partnerships with commercial activities will lead to a conflict of interest, and appears to be a blatant approval for snowmobile outfitter guiding and increased snowmobiling in the project area. A public need for outfitter/guides is not documented, every analysis is a qualitative description of something that might happen, and an outfitter/guide is assumed to solve a myriad of problems which also are not documented.

In reality, this project is proposed not from the Forest Service, but from outfitter/ guides who expect the Forest Service to do their bidding. Unfortunately, judging from this bad EA, the Forest Service seems perfectly willing to subject the forest and other users to the economic concerns of one or two outfitters. The EA claims that a major reason to permit an outfitter guide is to reduce illegal guiding. In essence, 'They are already doing it, so let's make it legal and then we can say we have reduced illegal outfitter guiding'. The EA does not discuss other methods to reduce illegal guiding such as limiting group size; reducing snowmobiling; and educating the public that guiding is not allowed, is illegal, and that the public could be getting duped by unauthorized, unsafe, uninsured guides.

In pushing this project, the Forest Service falls back on the trite and overused rural economy argument, but refuses to recognize the diverse economies of Summit County, Utah or Uintah County, Wyoming. It is embarrassing for the Forest Service to assert this project will assist in rural development. It will assist one outfitter! The EA never gives an economic analysis, either in terms of the boon to the rural economy, the cost of this EA, or the cost of administering the program. It is likely the cost of the program far exceeds the supposed cost savings of having the road plowed and bathrooms cleaned by the permittee.

The Forest Service doesn't even have minimum standards of work that must be met before any outfitter would be given the permit. They said they would pick the best one, although previous illegal guiding doesn't disqualify an applicant. In fact, this is hardly counted at all in the decision. This flies in the face of fairness to the public. The purpose of the proposal is to protect the public from illegal guides. How can we be protected by illegal guides who are now legal only because the Forest Service changed the policy?

In summary, the Forest Service decided to approve this project before doing the EA. The EA was done as a legal formality--and poorly, at that. The Forest Service is caving to the demands of one or two outfitters and short-changing the Uintas and other forest users in the process.

Lynette Brooks, Board Member

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