Folks have been kind enough to send the text of the Region 1 Wilderness Policy document we have recently been discussing. Here it is Region 1 RWA Policy. I don’t have any particular expertise in the World of Wilderness (other than experienti
(1) When does the FS find a need to standardize? This is one of the greatest mysteries of my FS career. It has seemed to me that culturally the local level tends to hang on to its autonomy as much as possible. But the argument that Chief Tom Tidwell (then Regional Forester, and/or his then-staff) makes in the letter is that:
“Some areas are managed by more than one unit and the units have different management approaches, particularly for motorized recreation. This results in public confusion and can result in encroachments of illegal activities on to the adjacent forest.” Of course, the argument could potentially be made for the WO to issue a national policy, as Regions may also have neighboring (although perhaps not adjoining) Recommended Wilderness areas. And national groups could easily raise the question “if it’s OK to centralize the approach at the Regional level, why isn’t it OK to centralize at the National level- wouldn’t that would be even less confusing?” I guess I can understand if each Forest makes up its own approach, because that shows up in an EIS and can be questioned, objected to, etc. But that leads to exactly the kinds of problems that the Region 1 letter was intended to solve.
2) The other impression I get is that these decisions seem to be highly technical. In a way, the question of whether it’s suitable or not is ultimately a judgment call. It is not any less a judgment call because there is an elaborate analytical process, but the very elaborateness and complexity can confuse the public (at least it confused me).
After the 2005 letter, along came the 2012 Rule. Perhaps others know this, but weren’t the Directives put out for public comment? And wouldn’t the procedures for Recommended Wilderness be part of the Directives? Here’s a piece of the letter:
The three tests of capability, availability, and need will be used to determine suitability as set forth in Forest Service Handbook (FSH) 1909.12, Chapter 2, 72. . In addition to the inherent wilderness quality an IRA might possess, the area must provide opportunities and experiences that are dependent upon and enhanced by a wilderness environment. The area and boundaries must allow the area to be managed as wilderness.
Capability is defined in FSH 1909.12, Chapter 72 as the degree to which the area contains the basic characteristics that make it suitable for wilderness designation without regard to its availability for or need as wilderness. Availability determination is conditioned on the value of and need for the wilderness resource compared to the value of and need of the area for other resources. Need is the determination that the area should be designated as wilderness through an analysis of the degree that the area contributes to the local and national distribution of wilderness.
I also wondered where it was in statute or regulation that wilderness needs to be “locally and nationally distributed.” There are few or no Grassland Wildernesses that I know of, so perhaps they should be on the top of the list?
From a letter signed by then Regional Forester Tidwell to Sandra Mitchell in 2007.
I hope you will see that the process is very rigorous and intended to eliminate from consideration those areas that are really best suited for uses that are not compatible with wilderness designation. The final decision on which areas to recommend is done through a thorough and open public involvement process.
IMHO if uses are currently there, then to determine that land is “best suited” for being without those uses, is a difficult philosophical question. Because if you are a Wilderness aficionado, then everything could be argued to be best suited for Wilderness, if all you have to do is remove mountain bikes, OHVs, snowmobiles, fire suppression, roads, fuel treatments, and so on. I think the Region 1 twist seems to be that there are some uses like mountain bikes that never should have been allowed in certain areas, and they occupy a less legitimate position than other longer uses.
This whole discussion has given me much sympathy for both the FS and the public who deal with these analyses.