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ACTION ALERT #1: COMMENTS NEEDED BY NOVEMBER 1 ON THE DRAFT EIS AND FOREST PLAN FOR THE WASATCH-CACHE NATIONAL FOREST

Over 50 years ago ecologist Aldo Leopold first spoke to the principle of allowing land to speak of its capabilities rather than land managers simply forcing inappropriate activities onto every segment of land. The Uintas are the place to implement this principle. The Uintas are defined in two ways: the portion of the forest heavily roaded, with road densities as high as 2 miles /sq. mile of land--defined by a human-based context; and the portion of the forest utterly undeveloped where natural process dominate. It is a relatively clear line--roaded, motored, developed vs. un-roaded, un-motored and un-developed. Using Leopold's principles and the context identified by ecologist Ian McHarg over 30 years ago in Design with Nature, the North Slope roadless country is best left as is.

It sings for such treatment.

After nearly two years of meetings and comment periods, we now have the Proposed Forest Plan and Draft Environmental Impact Statement (DEIS) for the Wasatch-Cache National Forest -- three volumes of text and a couple dozen maps!

We have written over a dozen major articles in The LYNX on forest planning since 1997. Way back in February 1999 we said, and say it again today, "THERE WILL BE NO ISSUE MORE IMPORTANT THAN FOREST PLANNING." The forest plan will guide every decision, every allocation, every issue on the forest for the next 15 years. And the next 15 years will likely determine the fabric of the Uintas, the most wild and endangered ecosystem on the forest.

We've heard some criticism that HUPC provides TOO MUCH information, that short, simple directions are best. Frankly, these issues are complex. A brief layout isn't what the context of the issue or the context of the wild Uintas merit. We believe that meaningful concerns require meaningful delivery. So with that apology, we again present the issues in full.

YOUR WILD VOICE must be transferred to pen and paper. Every HUPC voice must be heard with distinction and vigor. This is the place, the time, for the seasoned activist, the cynical and tired, the freshness of new members. There is no room for di stance-- we must engage this plan! And we have some time--

COMMENTS ARE DUE ON NOVEMBER 1 to the Wasatch-Cache National Forest Planning Team 8226 Federal Bldg., 125 S. State, SLC, UT 84138

Three oral comment meetings are scheduled to be held from 5-8 each night: Skyline High School (10/16), Evanston - Beeman-Cashin Building in Depot Square (10/17), and Logan High School Auditorium(10/11).

BUT FIRST, WHILE WE HAVE SOME CONCERNS WITH THIS PLAN AND DEIS, THE WASATCH DESERVES MUCH CREDIT FOR ITS PAST OPENNESS, WILLINGNESS TO ENGAGE THE PUBLIC(S), AND FOR MANY OF THE MEANINGFUL CHANGES FROM PAST DIRECTION. THIS IS A MEANINGFUL PLAN AND, WITH A FEW CHANGES, CAN BE AN EXCELLENT FOREST PLAN. IT IS NO EASY PROCESS TO PUT SOMETHING OF THIS MAGNITUDE TOGETHER, ONLY TO HAVE IT PICKED AT. BUT THAT IS THE PROCESS. IT DOES NOT, HOWEVER, DEMEAN THE VALUABLE EFFORT LED BY THE WASATCH PLANNING TEAM.

So What Exactly Does A Forest Plan/Draft EIS Do?

Forest plans set goals and objectives, standards and guidelines management area prescriptions, identify lands not suited for timber, determine monitoring and make wilderness recommendations. This is all done in the context of issues and a need for change identified by the Forest Service and earlier public involvement processes. The plan defines Desired Future Conditions and identifies six issues: (1) recreation use conflicts, (2) roadless/wilderness, (3) diversity and species viability, ( 4) traditional economic contributions from the forest, (5) environmental, social and economic impacts of uses, and (6) facility development on the forest. These issues are responsive to the needs for change which deal with watershed health, grazing and timber suitability, wilderness and roadless area management, oil and gas leasing, road access and recreation management.

This is accomplished in different ways through the six alternatives in the DEIS: Alts. 1 and 2 are natural processes and preservation alternatives; Alt 3, 4, 5 and 6 represent various levels of resource production.

A bias is clear, huh? Alt. 6 is the preferred alternative-- sort of a middle ground, if you will, with Alt. 5 being the rural UT/WY dig it, lease it, graze it, road it, roar around on it, log it ALTERNATIVE.

WHAT DOES THIS PREFERRED ALTERNATIVE 6 DO?

WILDERNESS: This is a major disappointment in the forest plan. Forest-wide, only a scant 70,000 acres of roadless land is recommended as wilderness-- 12% of the roadless lands. On the up-side, 46,369 acres is on the Uintas with a little over 20,000 acres, good, strategic acres, on the North Slope of the Uintas adjacent to the extant High Uintas Wilderness (HUW) and a newly proposed 26,000 acre Lakes Wilderness. The 20,000 acres on the North Slope run east from the East Fork of the Bear River to the East Fork of the Blacks Fork putting the proposed wilderness boundary at the trailheads (with one major exception being the exclusion of the Middle Fork of the Blacks Fork north of the Bear River Smiths Fork Trail.) The only addition to the HUW on the east end of the Uintas is a small section on West Fork Beaver Creek.

The proposed Lakes Wilderness (the Forest Service refuses to adopt our proposed name, Mt. Watson Wilderness) includes only 26,000 acres, smaller than the Lone Peak Wilderness, and includes only the Middle Fork/Main Fork Weber and Smith Morehouse drainages.

Alt. 1 proposes a 119,000 acres Lake Wilderness and includes about 100,000 acres on the North Slope--in both cases about 95% of the roadless area. Alt. 2 includes the HUPC Mt. Watson proposed wilderness acreage of about 72,000 acres and 29,000 acres across the North Slope-- the same as the Preferred Alt. with additions on lower Kabell, Burnt Fork and the Round Park area south of Beaver Meadows Reservoir.

The Problem: Even the Wasatch still sees wilderness as a threat to the Forest Service culture and only begrudgingly proposes wilderness protection on the highest quality roadless/wild landscapes in Utah. The proposed Lakes Wilderness is a tiny floating wilderness amidst a wild forestscape. It is an afterthought rather than a recognition of the size and the wildness of the region.

HUPC'S RECOMMENDATION: (1) Wilderness designation is the penultimate commitment to protecting wildness. At the minimum a wilderness system should include large, intact, contiguous and adjacent roadless landscapes to assure the vitality of wilderness resources. The HUW and proposed Lakes (Mt. Watson) areas are the two highest quality and largest such places in Utah. Together they offer and give us the opportunity and challenge to protect nearly a million acres of wild mountainous terrain. (2) Across the North Slope the wilderness boundary should go back to the trailhead on every drainage. This is particularly true on the Middle Fork of the Blacks Fork, probably the wildest drainage on the North Slope. The lower elevation is a patchwork of dense forests and wide open riparian, willow-covered valleys. The same holds for the West Fork Beaver Creek--this is an exceptional drainage in that the lower portion is exclusively a wild forest of old lodgepole pine mixed intermittently with potholes. Bringing the boundary back to Hoop Lake assures the entire Burnt Fork, Thompson and Kabell Creek drainages are included within the wilderness. (3) On the Lakes area the Forest Service should adopt the 72,000 HUPC proposed wilderness boundary which includes the rugged and high quality wild landscapes of the Weber, Provo, North Fork Provo, Smith Morehouse, Shingle Creek, South Fork of the Weber and Red Pine drainages. This represents the high elevation subalpine country on the east end and the lower elevation deep canyons harboring aspen and doug-fir on the west.

Click here to view map of HUPC's proposed North Slope Wilderness:HUPC Proposed North Slope Wilderness thumbnail.gif (1222 bytes)

Click here to view map of Mt. Watson Wilderness Proposal:Mt Watson Wilderness Proposal thumbnail.gif (2210 bytes)

ROADLESS: All 600,000 acres of roadless areas on the forest are protected under the National Roadless Conservation Rule in this alternative and Alts 1 and 2. On the Uintas (over 30 roadless areas were identified on the Wasatch) this is the entire 104,000 acres of North Slope and 122,000 acres of Lakes roadless area--these two roadless areas account for nearly 40% of the roadless acreage on the forest. These areas would be protected from road building, timber harvesting and surface disturbing oil and gas leasing.

The roadless rule is subject to possible change (see Roadless Rule Changes), making the point we have made from the inception--roadless areas will be protected, ultimately, at the local level, right here on the High Uintas. This can only be accomplished if our voice is distinct, vigorous and with a multitude!

The science based literature is singular--protect roadless areas and the most sensitive wildlife-- pine marten, wolverine, lynx, cutthroat trout, boreal owl, great gray owl, goshawk-- will all be protected as will wildlife with broader habitat requirements. Protect roadless areas and watersheds heal and receive less damage. Biodiversity and species viability are all enhanced when roadless areas are protected.

The Problem: The preferred alternative, while protecting roadless areas, insists on placing many roadless landscapes in management prescriptions other than the Undeveloped Area prescription, 2.6, or Backcountry, Non-motorized, 4.1.

The preferred alternative leaves much of the roadless country on the Lakes Roadless Area and the eastern North Slope roadless areas open to snowmobile use.

HUPC'S RECOMMENDATION: (1) To avoid confusion, and future expectation problems, the Forest Plan and DEIS should allocate all roadless areas to management prescriptions which clearly highlight the undeveloped and roadless characteristics-- 2.6, Undeveloped Areas, or 4.1, Backcountry, Non-motorized. (2) All roadless areas south of the North Slope Road and the Lakes Roadless Area should be closed to snowmobile use.

Click here to view map of HUPC's preferred North Slope Uintas Alternative:Preferred North Slope Alternative Thumbnail.gif (1634 bytes)

OIL AND GAS LEASING: Virtually every acre of the North Slope of the Uintas outside of the roadless country is leased and open to oil and gas leasing. In 1994 we appealed the Forest Service decision to open even the roadless areas to leasing and won that decision, pending revision of the forest plan. And here we are. The Roadless Conservation Rule prohibits surface disturbance on these roadless lands except where valid leases exist. All new leases would have to be consistent with the Roadless Rule. Unfortunately Alt. 6 proposes to allow a no surface occupancy (NSO) lease on these roadless lands rather than a no lease (NL) decision. The exception is the lands recommended for wilderness which are proposed, of course, for a NL decision.

The complication is that some 17,600 acres are under lease within the Table Top Unit and include roadless areas on the Main Fork, Stillwater and a portion of the E. Fork Bear River. Within this leasing unit there exists a number of segments of land that are still not leased and now protected by the Roadless Rule (though the Bush Administration has proposed to alter the rule with the likelihood that the primary changes would be to open the restrictions on leasing).

The proposed forest plan and DEIS note that the potential for oil occurrence is high on portions of the North Slope but not within the roadless portions of the forest, the North Flank Fault. The highest potential is on the Moxa Arch and Hogsback Thrust to the north. The forest holds two small oil producing fields and shares three small fields with BLM, all on the northern edge of the forest. The potential for development is almost nonexistent on the North Flank Fault. So far, all of the wells and development have been on the Moxa Arch and Hogsback Thrust. The USGS projects that 1-2 wells would be drilled per 15 years on the N. Flank Fault. The forest plan and DEIS redefine that potential to 7 exploration wells and one active oil field! Since the l960s the single oil and gas field on the North Slope has produced about a day s worth of oil at present consumption rates!

The Problem: Leasing is not a paper transaction. With every lease goes the right to industrial development even though the potential for oil production is low! Each exploratory well pad requires 4 acres, almost 2 miles of road and a field that would likely consume 10 square miles! 250,000 acres of the North Slope is already leased-- that is the area with oil and gas potential and the extant Bridger Oil Field!

HUPC'S RECOMMENDATION: (1) Because the production potential is low, evidenced by an actual history of drilling, and the quality of the roadless lands so high and important to the integrity of the HUW, wildlife habitat for so many unique species and a heritage unmatched, all of the roadless lands, including those already leased when they expire, should be allocated to a NL category!

Click to view Table Top Lease map:Table Top Lease Thumbnail.gif (2371 bytes)

TIMBER: About 29,000 acres have been identified as suitable for timber harvesting, all of it on the Uintas. This would produce an annual sales quantity (ASQ) of 1.5 million board feet (mmbf). Both are late but huge improvements over past allocations. The ASQ volume comes from the suitable land base and is scheduled on an annual basis. Another figure used in the DEIS is the total sale program quantity (TSPQ), 3.9 mmbf, and is figured from the suitable and non-suitable land base. You read it correctly. Under management prescription, the Forest Service can harvest trees that do not count toward the ASQ and come from non-suitable lands! However, the TSPQ is not regularly scheduled and would likely be an exception on this forest. Under the Roadless Rule no timber road construction could occur in roadless areas and timber harvesting would be prohibited-- unlikely and very restricted in roadless areas.

Alternative 1 allows no timber harvest at all; Alt. 2 programs no ASQ and only a small TSPQ from non-suited lands.

The Problem: The preferred alternative identifies roadless lands on the West Fork Smiths Fork, Gilbert Creek and Burnt Fork/Kabell Creek/Beaver Meadows Reservoir (Round Park) as timber yield prescriptions (5.1, 5.2), even though they are roadless lands and are prohibited from road construction and timber harvesting. Even on the Lakes Roadless area in the Whiskey Creek and Gold Hill area the plan calls for a timber prescription.

HUPC'S RECOMMENDATION: (1) There should be no timber prescriptions on any roadless landscapes and (2) all roadless areas should be categorized as non-suitable for any commercial timber/vegetation treatments. The data is distinct -- the value of unharvested, unroaded wild landscapes, particularly in larger contiguous chunks of land, is incomparable in its values to wildlife, particularly those requiring sensitive old growth habitats and isolation from human disturbances.

WILDERNESS MANAGEMENT: The forest plan notes the HUW Management Plan was completed in 1997 and proposes it be updated in 2012!

The Problem: What the plan fails to mention is that the all important monitoring protocol for the 1997 plan, which was appealed and roundly slammed by the conservation community, has no set time frame for completion. The HUW Management Plan can't be implemented without the monitoring protocol!

HUPC'S RECOMMENDATION: (1) It took the Forest Service 13 years from designation of the HUW to completing a wilderness management plan. Now, 4 yrs. later, it is still nowhere near completion. It is time to do it right. Urge the Forest Service to scrap the old plan and within two years of the completion of the forest plan prepare and finalize a wilderness management plan for the largest and most wild wilderness managed by the Forest Service in Utah!

RANGE MANAGEMENT: The plan and DEIS determine that 292,000 acres of land on the forest are suitable for grazing. On the positive side the plan proposes to close three vacant allotments on the North Slope-- Burro, West Beaver and Thompson. These are allotments necessary for bighorn sheep. The plan also proposes to close 3 allotments on the North Slope that are now grazed-- Gilbert Creek, Henry's Fork and Red Castle-- IF permits are voluntarily waived by the permittee! These allotments are essential to the survival of bighorn sheep.

The Problem: IF, voluntarily waived by the permittee.

HUPC's RECOMMENDATION: (1) Support the forest plan recommendations of closing the three vacant allotments. (2) Initiate a phase out over the next ten years for the three other active allotments. These allotments, as the plan and draft EIS note, threaten the survival and viability of the growing bighorn sheep population on the HUW. A voluntary closure simply will not work!

EPILOGUE: So what does all of this mean?

  1. By adopting HUPC s recommendations, the forest plan assures, according the DEIS itself, the safest, healthiest watersheds, the greatest potential for biodiversity and species viability for the most sensitive species on the forest, from cutthroat trout to pine marten, goshawk, lynx, wolverine, big-horn sheep, great gray owl, and boreal owl, and meets the forest objective of protecting large undeveloped landscapes.
  2. It does all of this, according to the DEIS, with almost no economic impacts to local communities. The fact is the forest has no meaningful economic impact on local communities. We have a remarkable chance to enhance the inherent wild character of the Uintas. But WE ALL must speak of and for that character!

Dick Carter

COMMENTS ARE DUE NOVEMBER 1 to the Wasatch-Cache N. F. Planning Team 8226 Federal Building 125 South State Street SLC, Utah 84138


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