I find the objection process under the 2012 Planning Rule to be quite interesting. Some folks say that it’s turned out like “another comment period.” The idea was (which was also incorporated in the 2005 Rule) was that people would focus on specific concrete things in the plan, and not so much “you violated ESA” or “you did not consider the full range of alternatives.”
I’ve looked at some of the objection letters for the Colville National Forest Plan and found a number of interesting ones. Today I’d like to focus on this section of one on recommended Wilderness, part of a 20 page letter by the Northeast Washington Forest Coalition.
RWAs should be managed as wilderness. Pg 150 of LRMP – MA-STD-RW-02: allows mountain bikes & chainsaws in recommended wilderness. This management is inconsistent with recommended wilderness standards on other National Forests. Current levels of existing activities (such as mountain biking and use of chainsaws) will continue to occur until Congress moves to designate these areas as wilderness.
The 2006 USFS Handbook provides that “[a]ny inventoried roadless area recommended for wilderness … is not available for any use that may reduce the wilderness potential of an area. Activities currently permitted may continue, pending designation, if the activities do not compromise wilderness values of the area.” (2006 USFS Manual § 1923.03(1)).
However, the existing use of chainsaws, mountain bikes, and other mechanized vehicles is impacting the wilderness potential, including impacts on soils, wildlife, and aesthetics. Standards and guidelines are at the heart of a forest plan and serve as the basis for future decisions. Maintaining wilderness values is a responsibility the agency has under the Wilderness Act and is not discretionary.
I’ve always found some Wilderness discussions confusing, as they are part preservation of historic landscapes and uses (kind of a historic park idea) and sometimes protecting nature from humans, and sometimes touted as sources of recreation economic spending (obviously assuming that there is lots of human use). Sometimes the distinctions feel more ideological than other land designations, which are simply “you can do this and you can’t do that.”
What I don’t get about the chainsaw and mountain bikes, is that if those two things are bad for wilderness values, then if they are going on now, should the area not be recommended wilderness because these values have already impacted the wilderness potential?
I guess it’s just confusing to me that areas can become recommended for Wilderness with these ongoing activities, but the same activities between time t=(when recommended) to t=(when designated) would have such an impact that the potential would be reduced. I could even see putting a cap on chainsawed stumps per year, but how many chainsawed stumps would it take to “reduce wilderness potential?”
I disagree FWIW that the use of chainsaws has impacts on soils, wildlife and aesthetics. It seems to me that if you have a chainsaw going you get done quicker, get out of the area and leave the wildlife alone for a greater period of time. If aesthetics, couldn’t a chainsaw have a “handsaw emulation attachment”?
Maybe someone can help me understand these distinctions between actions which occur pre Recommended, and Recommended to Designated?