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Wasatch-Cache Forest Plan - What The Future Holds

    "Genuine politics-- politics worthy of the name, and the only politics I am willing to devote myself to-- is simply a matter of serving those around us: serving the community, and serving those who will come after us. Its deepest roots are moral be cause it is a responsibility, expressed through action, to and for the whole, a responsibility that is-- what it is "higher" responsibility only because it has a metaphysical grounding: that is it grows out of a conscious or subconscious certainty that our death ends nothing, because everything is forever being recorded and evaluated somewhere else, somewhere "above us," in what I have called the "memory of being."
    If we want a better world than that now in prospect, we must-- as humanity, as people, as conscious beings with spirit, mind, and a sense of responsibility-- somehow come to our senses."

Vaclav Havel, Summer Meditations

An unusual way to start a forest plan comment, but that is what we did, by drawing our collective attention to genuine politics and serving our community. It will be the only way to make this plan work-- not a plan of ideology, but a serving plan based on the profound ecological knowledge we know to be true and the decency of all of us who care about our forests.

The Forest Service challenged all of us to find solutions and engagement of all of the issues. We have done that and hope this is not shoved aside due to less than genuine politics.

Far too much of the Logan and Evanston oral comment hearings demonstrated the epitome of less than genuine politics. We were dumbfounded by the references to conservationists as being part of a terrorist network. On the other hand, almost exclusively conservationists in the meeting stood up to relay specific suggestions on how to make the Mt. Naomi Wilderness a better wilderness by recommending specific portions of the Mt. Naomi Roadless Area as wilderness. Only a few spoke generally.

The other set of speakers that were represented in the meeting spoke to one point-- general in nature: don't take my rights away by closing a single road, restricting snowmobiles or protecting a single acre of roadless area.

Much the same happened in Evanston sans the terrorism allegations. One speaker after another spoke to: close no roads, designate no wilderness, and protect no roadless areas. Hardly specific!

Throughout the process we were involved in the preparation of this plan. We have attended almost every public open house, briefing and meeting dating back to the preliminary version of the AMS, 1999, proposed alternatives, scoping meetings, and DEIS open houses. We've met with Forest Supervisor Tom Tidwell, Deputy Forest Supervisor (and previously Acting Forest Supervisor) Pam Gardiner, Planning Group Leader Melissa Blackwell and her staff of planners, District Rangers Steve Ryberg and Jane Cottrell (as well as former Forest Supervisor Bernie Weingardt, of course) numerous times, most recently on 19 November to discuss our comments in detail. Our comments have been detailed and measured. They have always started with a strong support for the openness of the process initiated by the Wasatch-Cache National Forest and often with the support and commendation of much of the planning direction as we've seen it evolve at each stage.

We stand by those comments--there is much that is good in this draft plan!

But there is much that is of deep and profound concern and may leave the plan reeling. At almost every meeting dealing with the forest plan, the equivalent of the statement that 'we wanted to do so much more' is offered. While that is true and is often actually a positive statement, in this case it seems to be a warning to lower expectations to the point that the forest plan may not actually address the real issues facing the forest. We are deeply sympathetic to the constraints placed on thi s process but this is not the place or time to lower expectations and the quality of the plan!

From here, our 42 page comment-- you can see it on our web site, www.hupc.org(DEIS Comments)-- along with maps, appendices and literature citations, dealt with these specific issues:

Roadless Areas

Of course, this is probably the key issue facing the forest plan. We provided specific data on key Uintas roadless areas. There are 31 roadless areas that are being evaluated for wilderness recommendations on the WCNF. The High Uintas Roadless Area (HURA) and Lakes Roadless Area account for 40% or roadless acreage on the forest! (The next largest roadless area, Mt. Naomi, is 45,000 acres, considerably less than half the size of either roadless area.) But even that does not take into account the fullness of HURA which is one roadless area surrounding the High Uintas Wilderness on both the Wasatch and Ashley National Forest and is really well over half a million acres in size! We discussed how it should be managed and provided a classification scheme to prioritize roadless areas on the forest as a whole. The basis was that all roadless areas should be protected as roadless but that management scenarios should be consistent with the importance of large roadless adjacent to wilderness or in large clusters of roadless areas.

Wilderness Recommendations

Of course, roadless issues led to the Wilderness Act, a profound and powerful piece of legislation that has easily withstood every test of time and politics! While the roadless discussion/inventory is not about wilderness designation per se, under the Wilderness Act of 1964 it is tied by a sound knot to that issue.

Lightning Strike by Margaret Pettis Lightning Strike by Margaret Pettis
Lightning Strike by Margaret Pettis Lightning Strike by Margaret Pettis

Thus, we provided maps and detailed analysis of our wilderness recommendations for both the North Slope and the Lakes Roadless Area (LRA). We focused, in particular, on the plan's poor wilderness recommendation on the Lakes Roadless Area. We again focused on the need to include both Shingle Creek and the North Fork Provo River in the LRA proposed wilderness. On the North Slope we provided detailed data on why the Middle Fork, Boundary Fork, West Fork Beaver, Stillwater, Hayden and the lower reaches of Thompson, Kabell and Burnt Forks need to be included in any wilderness recommendation.

Oil and Gas Leasing

We applaud the DEIS and Proposed Forest Plan for the context and direction with respect to oil and gas leasing. Given the fact that 148,000 acres of the North Slope are under lease or proposed for leasing and that all of the lands in this analysis are roadless landscapes within the North Flank Fault which has a proven track record of no discoveries and a reasonably foreseeable development (RFD) scenario suggesting that discovery potential is very limited, the recommendation to limit leasing to a No Surface Occupancy (NSO) is one of obvious common sense based on the best available data! Nonetheless, the lands should come under a No Lease (NL) recommendation because the lease category has a deep connection to the RFD and the roadless values are so high!

Timber Suitability

On balance the recommendations here are noteworthy and positive.

The two problems we addressed in detail deal with a hidden proposal to harvest timber outside of timber management prescriptions and in a few instances within roadless areas on the eastern end of the Uintas due to a concern over pine beetles, a perfectly natural component of all pine forests!

Wilderness Management

We just don't know what to say anymore. There is no place where the doublespeak is so profound. On the one hand, the DEIS and Proposed Forest Plan speak properly and hopefully to the concepts of ecological values of wilderness, not just recreational values-- in fact, it is stated clearly in the alternatives discussions, the forest plan goals, even in the early parts of the issues analyses.

Then it all falls apart. The analysis on non-native mt. goat introductions is missing in spite of clear policy statements by the Forest Service that mt. goats are not native, do not belong and should not be introduced into designated wilderness landscapes.

The same concerns exist with respect to non-native recreational based fish stocking within designated wilderness. The plan is silent on the single scientific/ecological/ecosystem direction-- fish stocking in high mountain wilderness lakes where fish were not native is having serious impacts upon those lake ecosystems.

Disingenuous politics is at work here!

We also focused on concerns over grazing and recreational use and suggested that wilderness management planning must be made a priority and moved up in time in dramatic fashion!

Rangeland Capability and Suitability

Interestingly the DEIS notes that 27%, only a small portion of the whole forest, is suitable for grazing and of that the two Uintas management areas have only between 21-24% of their lands as suitable. More amazingly, of that land only 23% has been found suitable for grazing. Grazing lands are largely fragmented and found in small isolated patches. Furthermore, the actual use is meaningfully below the term permitted use, suggesting the WCNF has set grazing numbers too high. Yet grazing goes on with a wink and a nod.

Social and Economic Analysis

There is much left dangling in this section. While the bottom line of the whole chapter is that the forest is not singularly economically important to any particular segment of the broader society, the WCNF is important to all segments of that broader social context. The only problem is the DEIS and Proposed Forest Plan bends and contorts itself in such an obvious and biased manner to assure local communities, a definition that is suspect from the start, that they matter more, have more weight and are better defined and thus more influential. Furthermore, nonconsumptive and ecological values are hardly even analyzed.

That is not good or acceptable public policy in the context of professional planning process. This is augmented by the fact that the DEIS offers no accounting for nonuse values using any recognized formal economic valuation. The DEIS simply says it is too complicated and assures the reader that there are, no doubt, nonuse or nonconsumptive values associated with the WCNF!

Biodiversity and Viability

While recognized as the key issue, it is hard to see clear, vigorous direction, although there is considerable hope in this section of the DEIS and Proposed Forest Plan.

We suggested the best way to achieve the biodiversity and viability goals of the DEIS and Proposed Forest Plan is to assure:

  1. Undeveloped (roadless) landscapes remain undeveloped and inherent ecological disturbance processes should be allowed to operate freely.
  2. Roadless and undeveloped landscapes should be connected and clustered to provide as large an area as possible.
  3. Wilderness recommendations should be large, intact systems with the primary recommendations being large, adjacent and/or adjacent and connected to an extant wilderness system.
  4. Within the broader undeveloped landscapes, it is crucial to end the anthropogenic impacts such as intensive range management, non-indigenous wildlife introductions and motorized access. In this context we go back to the rangeland discussion and note the allotments that are now vacant best serve the broader ecosystem and biodiversity goals by remaining vacant.

Dick Carter 


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