Chain-Saws in Wilderness: Special Case And/Or Slippery Slope?

This is not from the San Juan but illustrates a similar request from the Methow Valley RD in R6 in 2017.

Here’s a link an article on the Methow Valley Ranger District request.

Matthew posted this press release written by San Juan Citizen’s Alliance and Great Old Broads for Wilderness

Here’s the Forest Service side as reported in the Durango Herald. Some excerpts:

The ultimate decision, however, was left up to Brian Ferebee, the Forest Service’s Rocky Mountain regional forester. On May 7, Ferebee approved the request, but noted he was “concerned about the impacts to wilderness character” that chain saw work would have in the two wilderness areas.

As a result, Ferebee placed certain restrictions on the project, such as limiting work to no more than six weeks between June 1 and Aug. 17 and requiring a Forest Service staffer to supervise work.

“The magnitude of obstructed trails across these two wilderness areas, and the potential resource damage that will occur if we do not open these trails to wilderness visitors, warrants the rare and limited exception to allow chain saw use,” Ferebee wrote.


In a previous interview, Jason Robertson, the Forest Service’s lead on the project, said chain saws have been used in wilderness areas in the past, but usually in circumstances after a major storm knocked down vast amounts of trees.


At the heart of the conservation groups’ complaint is the risk that allowing motorized use for trail work could chip away at the Wilderness Act and could be applied to other areas of the U.S. where bark beetles have ravaged forests.

The Forest Service’s Roberts said allowing chain saws into the Weminuche and South San Juan wilderness areas would not set a precedent for other Forest Service districts.

But Robertson’s statement appears to be contradicted by his supervisor’s own words in his letter approving the project. Ferebee said he wants a detailed report of how many trees were cut, total miles of trails cleared and summary of the project.

“Your reports will help determine if any future chain saw allowances are justified and needed to administer wilderness in the Rocky Mountain Region,” Ferebee wrote.

Note: Brian Ferebee is my former boss, so perhaps I am biased. But why would this one be setting a precedent any more than any other approvals of chain saws in Wilderness? There is a difference between collecting data for analysis and future decision making and “setting a precedent” in my mind. I don’t understand exactly what the reporter is thinking.

The FS had done a Minimum Requirements Analysis. Here’s a link to that process, and the FAQ’s, which are very helpful, are here.

In hunting for more information, I ran across a GAO report on this topic from 1970 (50 years ago!). Sometimes the internet is a wondrous thing. Here’s the link.

In GAO’s view, the construction and presence of trails, bridges, and other facilities in wilderness and similar areas, as well as the presence of litter left in the areas by the users, are basically inconslstent with the ideal wilderness concept. GAO believes that, once decisions have been made to construct such facilities and to dispose of accumulated litter, the factors of economy and convenience as well as others should be considered in determining whether the use of motorized equlpment is reasonable and desirable in the circumstances.

12 thoughts on “Chain-Saws in Wilderness: Special Case And/Or Slippery Slope?”

  1. Once, Arizona Wildlife Dept. had a string of pack animals, used mostly for travel in Wilderness to repair and maintain water catchments for desert big game. Maybe they still do. The curious story I heard was that a BLM official objected to the use of a battery powered “motorized” screwdriver for such work in a Wilderness area.

  2. Ok, so I haven’t read the entire post but this sentence from the GAO really caught my eye and stuck in my craw: “GAO believes that, once decisions have been made to construct such facilities and to dispose of accumulated litter, the factors of economy and convenience as well as others should be considered in determining whether the use of motorized equlpment is reasonable and desirable in the circumstances.” BTW – “Leave No Trace” ethics and practices were in their infancy when GAO wrote that report; I doubt there’s much in the way of litter pick up in wilderness areas now. That’s certainly my observation in the areas I visit in Region 6.
    There are of course, differing views re: wilderness management but let’s be honest: GAO is a bean counting agency! They’re not at all about considering the legacy on the landscape that various management decisions produce. I’ve been engaged in wilderness management since 1974 starting on the White Mtn. NF in R9. I later managed wilderness on a ranger district in the Gifford Pinchot NF (R6) and also spent 3 years as the wilderness mgmt. specialist in the supervisor’s office on the GPNF.
    In my professional and personal opinion, which has been evolving since 1974, it is NOT appropriate to base wilderness mgmt. decisions on “factors of economy and convenience.” Those perspectives are at odds with the philosophy of wilderness because managing wilderness areas is about managing for a legacy of a landscape that shows little or no human influence. Yes, Native American burning did influence the veg communities but that was prior to wilderness designation. Polly Dyer, a friend of mine and former member of Great Old Broads for Wilderness, found the word untrammeled and proposed that it be part of the language of the Wilderness Act.
    Basing current or future management decisions on “factors of economy and convenience” is likely to lead to Wilderness landscapes that show more influence of human activity and thus would lose, in my mind, some of the values the authors of the Act sought to preserve.

    Let’s be honest folks, our society has eroded to the point where collectively we no longer live up to our responsibility to adequately fund the maintenance of our public infrastructure whether it be trails in remote areas or our highways in urban areas. We are LOSING the significant public investment that we and prior generations made through a spirit of helping to fund and maintain things that provide for the public good.
    That’s a damn shame! But it is NOT a reason to erode Wilderness values in the name of economy.

    The FS, with the support of volunteer trail maintainers, such as myself, can put together the muscle to use crosscut saws rather than chainsaws. I think that decisions to use mechanized equipment put us on a slippery slope; I say No to the idea.

  3. Hi Sharon,

    Regarding your question: “But why would this one be setting a precedent any more than any other approvals of chain saws in Wilderness?”

    I checked with the groups who filed the lawsuit, which anyone could’ve done, I suppose. According to the them, the decision by your former boss is unprecedented and could set a precedent because it’s apparently the first time the U.S. Forest Service has approved motorized chainsaw use for the entire trail system within two entire Wilderness areas. This was done with zero public input.

    According to the groups, in the past, the USFS simply approved chainsaw use for “Trail 123” in “Wilderness LMNOP.”

    • Matthew, I’m sure you don’t mean to imply that I need to check with people who write press releases that you post? When I post something that means I will check with the people involved, as you did, and I think things work well generally when we do it that way.

      This is one of those things where we can see “ideas about things” potentially giving a different impression than “things.” If as you said, the problem is that the approval is for the “entire trail system” given the condition of those Wilderness Areas, and the fact that today is May 31 and I see snow outside my window in the mountains, that between June 1 and August 17, they will be able to clear all the trails in the Wildernesses. I’m sure they have priorities, but they will also be influenced by the fact that maybe they can’t get in for a while due to the winter we’ve had.

      So the environmental or wilderness character impacts to me are twofold…(1) how many days can folks hear chainsaw noise? (2) How widespread is chainsaw noise? These are noise by space and time parameters, not very complicated to analyze.

      The groups seem to imply that if a specific trail is not designated, then (1) and (2) will be greater and sufficiently greater to become a problem. I’m not sure that I agree with that because we don’t know how many miles/days those people doing it can actually get to.

      It seems to me that they are against the idea of not specifically designating trails (although from some of the initial rhetoric, it sounded as if they were against any chainsaws in Wilderness).

      My personal impression of the Weminuche is that people shortcut and do bad things to soils and creeks when there is too much deadfall. I’m also pretty sure that when I was there there was almost a constant stream of jet aircraft during the night. You could reroute them around the Wildernesses.. but that would be bad for carbon. So given that I have seen destruction from people avoiding deadfall, and aircraft noise is apparently OK, then I don’t see the problem with a discrete, supervised use of chainsaws.

      • Hi Sharon,

        When you, or anyone else, makes allegations, or wonders something aloud, without easily checking with the source to get a basic answer, I feel like we do a disservice to readers and participants of this blog. I see this often happening on this blog, and over the past 7 years or so, it seems to often just come from a certain direction.

        • Hmm… I think if there is an allegation someone raises, say, about Secretary Bernhardt, and you post it, I wouldn’t expect you to check with DOI for their point of view. My thinking is that the directions of different people on this blog come close to cancelling out in the long run.

  4. From the GOBfW: “The groups are asking the court to overturn the Forest Service’s approval and direct the agency to comply with the Wilderness Act by inviting public participation and weighing lawful alternatives to allowing motorized equipment in the wildernesses.”

    It sounds to me like the Forest Service should be concerned about complying with NEPA. If there is no applicable CE that doesn’t require public participation (when the extraordinary circumstances of undertaking a “generally prohibited use” in a wilderness area are taken into account), then there needs to be public participation in some form of NEPA process. It would be precedential to not do that.

    • So clearing trails requires NEPA..there is an applicable CE, and reasonable people could disagree about the existence of extraordinary circumstances. It’s not the mere presence
      as per
      “The mere presence of one or more of these resource conditions does not preclude use of a categorical exclusion (CE). It is the existence of a cause-effect relationship between a proposed action and the potential effect on these resource conditions and if such a relationship exists, the degree of the potential effect of a proposed action on these resource conditions that determine whether extraordinary circumstances exist. (36 CFR 220.6(b))

      I believe that for a CE, scoping is the only public involvement required. I’m not clear on why that would be done even using categories for which decision memos are not required. There does seem to be a judgment call involved though, as I have never seen scoping for others in the same grouping “categories for which decision memos are not required” e.g. mowing lawns at district office. Perhaps more expert NEPA folks can weigh in here.

      This seems to be the category- but maybe not:
      (4) Repair and maintenance of roads, trails, and landline boundaries. Examples include but are not limited to:
      (i) Authorizing a user to grade, resurface, and clean the culverts of an established NFS road;
      (ii) Grading a road and clearing the roadside of brush without the use of herbicides;
      (iii) Resurfacing a road to its original condition;
      (iv) Pruning vegetation and cleaning culverts along a trail and grooming the surface of the trail; and
      (v) Surveying, painting, and posting landline boundaries.
      Cite this category as 36 CFR 220.6(d)(4)

      • Even for a CE without a decision memo, if my memory serves me correctly, the FS needs to notify the interested and the affected parties…back when I used to do that sort of thing, a lot of the responses that we got to CE with no memo projects was “why are you asking me about this – just go do it!”, but occasionally there are other concerns that come up, like the project that would replace a large culvert and close the main road between about 20 homes and town, forcing them to use a longer detour for several months. In that case, notifying those folks helped us work out a better project and helped us put a plan in place for those residents for emergencies, parking, and other concerns.

          • In this case it would have allowed the opponents to bring up the question of extraordinary circumstances and the need for alternatives (and this would allow the FS to assess the risk of litigation if they used the CE).

  5. I heard that the trail-loss situation in a southwestern Wilderness was so bad that the area manager sent a crew out with chainsaws to clear the deadfalls, and did so without begging permission from the hierarchy. The crew was then to make hand cuts in the ends of the logs so people would think no chainsaws were used.

    Thus does absurdity pile on absurdity. The Wilderness Act allows the Forest Service to use chainsaws. It doesn’t need any NEPA analysis (a recipe for years of delay) or public notice.

    And this post from above I love, because it is so emblematic of the nuttiness: ” I heard … that a BLM official objected to the use of a battery powered ‘motorized’ screwdriver … in a Wilderness area.”

    Perhaps the next step will be that agency staff will have to ride horses to the trailheads, lest using motor vehicles to get there “trammel” Wilderness.


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