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Ah, it’s almost Halloween… celebrated in different ways by different cultures, but across cultures always dominated by a bit of mischief. A slight frisson grips almost all of us in this season.

It will be no surprise then that we update more Forest Service mischief than normal—too much of it on the Evanston/Mt. View Ranger District this time. Unfortunately, we shudder less with pleasure and excitement than with simple downright frustration.

I. The West Bear Timber Sale

(See HUPC LYNX, 6/02 and action alert September 2005), after well over a decade of fits and starts, finally made it onto the pages of a Draft Environmental Impact Statement (DEIS). The first mask, if you will, is that the Forest Service insists on spinning it as the “West Bear Vegetation Management Project” rather than the timber sale it is.

Within the 16,000 acre West Fork Bear River landscape (Humpy Creek/Whitney Reservoir on the west to the Mirror Lake Highway on the east), the Forest Service proposes to:

  1. Harvest over 1,600 acres in 38 units of old growth and mature spruce, fir, aspen and lodgepole pine to achieve “properly functioning condition;”
  2. Burn over 500 acres of aspen, most of it after conifers have been harvested; and
  3. Construct 7.8 miles of new, “temporary” roads to be open for the duration of the project and then rehabilitated.

This proposal, a multi-year project that could extend for well over a decade, would occur in a Lynx Analysis Unit. (Lynx are a threatened species under the Endangered Species Act.) The DEIS concedes wildlife habitat for lynx, woodpeckers, and many other species would be denigrated.

While no roadless areas are involved in the harvesting proposal—and that is the positive element of the proposal—almost all of the forests to be harvested would require temporary road construction to access them. The West Bear landscape is composed of discontinuous forest stands broken by massive sagebrush/grass/forbs and parklands with elevations of about 9,000-10,000 feet. The area is a roaded landscape and a primary snowmobile and ATV recreational destination.

The DEIS notes the Purpose and Need for this timber sale is to bring the forests into Properly Functioning Condition (PFC), largely because Forest Service mismanagement for decades prevented naturally occurring forest fires, which literally define this forest system. Of course, a timber sale is not needed to meet the Purpose and Need and thus, with great irony, such an alternative was not even presented or analyzed in the DEIS. A non-timber sale alternative with no road construction, focusing on prescribed fire and natural processes, should have been analyzed as the proposed action.

It is plainly stated that this project will not meet properly functioning condition. The second Halloween trick. It is also noted that PFC is a long term endeavor and, if approached from a timber sale perspective, would require multiple timber entries and roads over decades, only to exacerbate and enhance the environmental impacts and disturb the ecological process that, in fact, contributes to and defines PFC. Unmask this project and PFC is not the driving factor; it is nothing but good old “get-out-the-cut” forestry—something long ago banished to the back of the file cabinet because it was wrong-headed.

Simply removing old trees from a stand of timber does not in the slightest reflect, mimic or move an area to or toward PFC. It is widely recognized that timber harvesting in no way reflects the natural processes inherent in a forest ecosystem. PFC isn’t going to be reached by timber harvesting. The landscape is not functioning properly because of Forest Service mismanagement, not natural ecological conditions. Applying those old management practices will not result in PFC—it will result in driving the dysfunctional wedge even deeper, making PFC even more unreachable.

While the DEIS notes the area has important wildlife value, it also whispers, with a haunting smile, that these values will be notably denigrated by the project as proposed. Without any supporting data or basis, the DEIS then concludes that wildlife species will just simply alter their movement through the ecosystem. Road densities exceed one mile of road per square mile of land and there are few areas of 250 acres or more that are further than one-half mile from a road—a distance most wildlife research notes is needed for effective habitat for many species of wildlife. Adding another eight miles of roads for 10-30 years shouldn’t be so easily ignored and dismissed.

Furthermore, impacts to wildlife are not simply a matter of alternative habitat, which is scarce, but a function of a particular species’ behavioral patterns. More and more research shows with little disputation that wild critters make choices based on a much deeper context than what we show on a map as the place where they will go as an alternative to what we are developing. Territories, home ranges, familiarity, presence of other species, and different human interactions all determine wildlife behavior, making it abundantly obvious that additional development of undeveloped or lightly-developed landscapes must be halted.

The question is whether the Forest Service will replace the horrifying yet familiar “get-out-the-cut” mask with a visage and heart befitting an agency invested in public interest and ecologically based “management....”

Beaver Track by M. Pettis

II. …But the tomfoolery continues with the proposal to “authorize continued grazing on Gilbert Peak, Hessie Lake/Henrys Fork, Poison Mountain and Red Mountain allotments.”

About 68,000 acres of public national forest land on the Evanston/Mt. View Ranger District are involved in this proposal, including well over 25,000 acres on the Gilbert Peak, and Hessie Lake/Henrys Fork Allotments within the High Uintas Wilderness (HUW) and many thousands of acres in inventoried roadless areas. Each allotment harbors well over 1,000 ewe/lamb pairs!

The Forest Service proposed to exclude these allotments from an environmental analysis. A Categorical Exclusion (CE) allows the Forest Service to avoid preparing a proposal, analyzing alternatives and subjecting the analysis to public comment and appeal—its singular purpose is to prevent deep, meaningful public participation in this process, to assure the accountability is dismissed, and the decision to authorize grazing can continue unimpeded at the expense of public/environmental concerns and a broad valuation of our unique and sensitive public lands.

A word on Categorical Exclusions: Earlier this fall, the Courts ruled that CEs could not be exempted from appeals and has instructed the Forest Service nationally to re-do CEs like these to allow for full public input and appeal of the decisions. The Forest Service just recently appealed this decision.

It is amazing that the word wilderness didn’t exist in the proposal document nor is there a map delineating the High Uintas Wilderness, EVEN THOUGH IT IS THE DOMINATING RESOURCE VALUE ON THE GILBERT/HESSIE ALLOTMENTS. Ironically, Forest Service policy actually prohibits preparing Categorical Exclusions for projects in designated wilderness if the impacts affect wilderness values. The Forest Service jumped through this hoop by simply stating 1,000s of sheep have no impacts! It is almost unbelievable.

Sheep grazing brings thousands and thousands of non-native species into these drainages for a lengthy time frame and with them comes the concomitant plethora of disturbances of non-native species—stink of sheep, water pollution, predator control, salt troughs, herders, herder camps, displacement of wildlife and alteration of wilderness recreational values. The sense of solitude/isolation, the dominance of “mother nature,” primitive forms of recreation—all are keenly disrupted.

Even though grazing is allowed in wilderness, these issues must be analyzed to determine whether the effects are so great as to trigger a decision to remove all or some of the grazing within the HUW. Grazing by its nature confounds wilderness as it is solely a human introduced/ induced impact outside the very meaning of wilderness.

Furthermore, the proposal cites numerous trend and vegetation “studies” to show grazing has no impact on these high elevation ecosystems. On Gilbert Peak twenty-seven “studies” are proffered up, not one having lasted longer than four years and eighteen lasting only one year! Only one was last monitored in 2001, with the rest monitored in 1998-99, 1995, 1963, and 1960! Eleven represent “estimates.” Four note ground cover has increased since 1972 without explanation. This reveals anything but contemporary monitoring and certainly is not a TREND.

Hessie Lake shows twenty-two “studies”—only one longer than four years. Seventeen have lasted all of one year! Nine are estimates, four only note “increase indicated,” and two indicate inherent, natural low ground cover, but fail to note any impacts of sheep grazing. It does not matter what the inherent ground cover is; what matters is the impact of sheep grazing on the system! Three “studies” were last monitored in 2002, two in 2000, and twelve in the previous two decades.

The Forest Service has an obligation to meet ethical and professional standards; in no way do these studies indicate that any professional standards have been met. The vast majority of the relied- upon “studies” have only one year of monitoring and most of that monitoring occurred five or more years ago. The data is unreliable, based on estimates and speculation, and the duration of analysis is absurdly far too short to reveal any trends.

We have urged the Forest Service to prepare a fully disclosed Environmental Impact Statement for these two wilderness allotments…

III. …But the Halloween season is long and haunting and the Forest Service costume grows only more bizarre with the release of the decade-long awaited DEIS for the West Fork Blacks Fork (WFBF) Allotment Management Plan.

(See HUPC Review and LYNX, 6/98, 4/99 and 8/99, 4/00, 8/00 and 12/00, 12/01, 8/02 and 10/02, 4/03, 4/04). It remains a dubious process with an Environmental Assessment (EA) released six years back and withdrawn before a Decision Notice (DN) was finalized. Considerable discussion focused on monitoring and implementing high elevation grazing, with the Forest Service conceding that meeting forest grazing standards could take up to four decades.

At that time we were hopeful the Evanston Ranger District (ERD) and Wasatch-Cache National Forest (WCNF) would reconsider this grazing.

It became clear that hope was false as exorbitant amounts of time and excuse-making went by without the release of a DEIS until this summer.

The DEIS is almost obsessive in its effort to dismiss crucial issues. An analysis of grazing impacts upon wilderness values and resources is rejected, unbelievably, because grazing is allowed in wilderness and thus, the DEIS argues, can’t impact wilderness values. Suffice it to say, we raised the issues noted above in the Gilbert Peak and Hessie Lake grazing discussion and noted that wilderness grazing can be terminated if wilderness values, resources and attributes are negatively impacted by continued grazing.

The DEIS does analyze wilderness recreation in the context of hiking up the drainage as though each grazing unit is an independent, isolated region disconnected from the other units. The DEIS argues it is possible to be in a “unit” of the wilderness when the sheep are not in that unit and thus impacts to the wilderness experience are minimized.

Obviously, this fragmenting and compartmentalizing of the wilderness experience within the WFBF misses the entire context of the wilderness experience.

The DEIS section dealing with Economic/Social Values is as meager as the section on Wilderness and only analyzes the specific financial impacts to the permittee. Not one other socioeconomic value is even recognized.

The DEIS harbors a number of damning statements and concepts which render it hopeless. The most notable,
directly from the document: “It is impossible to determine what percentage of the disturbance to natural integrity is resulting from the management of grazing activities.”

The simple purpose of the DEIS is to determine the impacts of grazing on the natural/ wilderness environment/ resources on the WFBF. While it may be a difficult thing to do, this is the reason and purpose of the DEIS. Admitting that it wasn’t done because it is it difficult to do is not an acceptable conclusion. This is an excuse to allow grazing and the resultant impacts to continue without the analysis intended by the DEIS. In fact, from a professional and ethical perspective, the only conclusion that can be drawn is that grazing must be further restricted or phased out to assure no resource damage is occurring. The well established and accepted ecological precautionary principle must guide decision making under these conditions.

The DEIS dismisses stream bank erosion not because it does not exist but because the DEIS argues that natural geomorphic processes—an avalanche that occurred in the mid ‘80s and the inherent instability of a particular shale formation—have created high sediment and debris loads that have altered stream banks.

This appears to be true, but is irrelevant as it fails to analyze the effects of sheep grazing on stream banks. The fact that all of this occurs within the HUW delimits the concerns over impacts to stream banks: it is naturally occurring and it is wilderness, thus there is no problem or “impact.” What is missing is the analysis of impacts of domestic sheep grazing on stream banks.

The DEIS implies that because these natural processes occur and domestic grazing impacts are of a similar nature, then the domestic grazing impacts are of no concern, even if they are layered on the already fragile areas most affected by natural inherent processes.

This logic is highly flawed and inappropriate. Because of the fragility of the stream banks created by natural processes, domestic sheep grazing impacts are far more disruptive and simply can’t be deemed meaningless.

The DEIS notes that not all alpine areas that would be rated as impaired are necessarily due to sheep grazing. Some are a function of natural low productivity due to persistent and late-melting snow beds or burrowing of pocket gophers. Again, the concern is not natural or inherent low productivity, but the impacts of sheep grazing on areas of low productivity. Repeatedly, the DEIS incorrectly suggests that, because of the low inherent productivity, it is impossible to tell what impacts have been created by domestic sheep. The DEIS argues that, because there are areas of bare soil due to low natural productivity, it is appropriate to exceed detrimental disturbance thresholds by domestic sheep grazing.

This is utter nonsense. The issue is what kind of impacts and how many sheep over what period of time can and should graze areas of low productivity, slow growth, high elevation and harsh conditions.

It is noteworthy that this DEIS has documented numerous important ecological and geomorphic processes. But it has failed and even admitted that it has not analyzed the impacts of sheep grazing throughout these fragile areas. It does not matter how long naturally occurring bare soil sites resulting from inherent natural ecological or geomorphic processes last within designated wilderness. What matters is the impact on those and other sites by domestic sheep grazing.

Simply put, just because native fauna such as pocket gophers and inherent geomorphic or climatic processes “create” or enhance bare ground or sediment loads in wilderness environments does not mean it is tolerable for sheep to do the same or that it is acceptable to ignore domestic sheep grazing impacts upon those sensitive areas.

The DEIS suggests that native wild critters—specifically, the pocket gopher, which weighs in at less than half a pound (compared to a hundred pound ewe)— create disproportionate impacts within native landscapes with which they have evolved, while non-native sheep create no or only minor impacts. We wonder whether the Forest Service even hears what it says?

With respect to wildlife, the DEIS makes the same tired and worn statement that sheep grazing has limited impact upon most wildlife species simply because wildlife can move and avoid the impacts of grazing. The argument is specious at best in that many wildlife species are highly territorial with adjacent habitat being occupied and thus marginal. Furthermore, domestic sheep grazing permeates most of the drainages surrounding the WFBF. Thus, dispersal habitat within and without the WFBF is minimal. The DEIS simply can’t dismiss this issue.

Predator control is again dismissed even though it does not meet the standards, guidelines, goals and desired future conditions in the revised forest. Important issues dealing with native bighorn sheep are capriciously dismissed.

Now for the final and deepest ironies.

From the DEIS: “However, certain aspects of sheep grazing (trailing and bedding) are believed to be adding to the amount of bare ground.” End of discussion. Grazing is dismissed as insignificant.

From the DEIS: “Watering spots receive some trampling resulting in exposure to some bare soil. If located next to live water, some sediment enters into streams, however this is minor compared to natural processes and historical management practices.”

Again, the impact is dismissed simply by comparison to natural processes. What kind of logic is that? The natural processes in a wilderness are not negative impacts as we have noted over and over. Domestic sheep grazing impacts are negative and profound. But they are again dismissed in an effort to satisfy the permittee rather than perform the required public analysis.

From the DEIS: “…the direct impacts of manure, smell and multiple trails are still quite evident.” Still quite evident… but ignored, dismissed and not analyzed!

When the DEIS does note that there are two areas where sheep “have caused stream bank degradation,” that impact is largely rendered as insignificant when compared to natural processes.

Notably, the DEIS concedes the phase-out/ no grazing alternative enhances every aspect of the environment. Yet somehow, the DEIS then concludes that domestic sheep grazing impacts are, if not “impossible to determine,” so minor as to be inconsequential or unnoticeable. The problem is simple—the DEIS has met the whim of the grazing permittee, and the public interest be damned.

The grazing impacts are real and they occur to wilderness values and resources. There is one direction the data points—phase out this grazing.

The tricks of this season are many.

Dick Carter

Mountain Lion by Margaret Pettis

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