Bats and bighorns and bears (oh my?)

Two of these were originally posted as comments related to other posts and the third I would have, but Sharon intimated that they might not get noticed there, so here they are at the top end of a post.

BATS

We were discussing how the wolverine is most affected by climate change, and yet ESA requires mitigation of other less harmful activities that we have more control over. The effect of an introduced disease on bats also came up there.  A federal judge has just overturned a decision by the U.S. Fish and Wildlife Service to protect northern long-eared bats as threatened rather than endangered under the Endangered Species Act.  Here’s the Center for Biodiversity’s read-out of the judge’s opinion (there’s a link to the opinion, but I haven’t read it):

The Service argued that since the species was primarily threatened by disease, there was no need to protect its habitat.  But the court rightly noted that, in combination with disease, habitat destruction and other threats can cumulatively affect the bats, and thus are cause for concern.

It’s a point of contention these days whether climate change should be a factor in listing decisions when there is little likelihood of reducing its effects, but the law says it’s important to address and potentially mitigate other actions that may harm the species.

BIGHORNS

The Bridger-Teton National Forest is considering a restocking request for returning domestic sheep to two vacated allotments in the Wyoming Range.  It hinges on changing the forest plan to deemphasize protections for the Darby Mountain bighorn sheep herd. This would purportedly be consistent with the State of Wyoming’s bighorn plans.  The Forest is proposing to do a “focused amendment” to their forest plan,  but …

Bighorn advocates and conservationists who have watchdogged the restocking conversations wanted the Forest Service to instead deal with the issue in its forest plan (revision). The years-long revision process was supposedly coming up, though O’Connor said it’s now indefinitely on hold. Wyoming Wild Sheep Foundation Director Steve Kilpatrick said the Darby Mountain Herd deserves the longer, closer look.

I’m not sure the Forest is going to be able to do a “focused amendment” for this issue, since bighorn sheep should be a species of conservation concern under the 2012 Planning Rule, which warrants greater attention. Maybe this is a case where the inability to revise a forest plan is going to cause some problems. Then there is the question of why these allotments were vacant. The permittees were “bought out” through the efforts of the National Wildlife Federation (to protect bighorns?). Would they need to be paid back?

GRIZZLY BEARS

The discussion of reintroducing wolves to Colorado brought up the experience with grizzly bears in the Selway-Bitterroot Wilderness in Montana and Idaho.  A reintroduction proposal was rejected in 2001, but at least two bears have been documented there in recent years.  Here is the recent news about that.  The Fish and Wildlife Service has written to the Forest Service that bears that have made it there are fully protected by the Endangered Species Act (not an experimental population). All four of these forests are revising or will soon revise their forest plans and will have to provide conditions to support grizzly bear recovery.  The Nez Perce-Clearwater is farthest along but has been avoiding doing that.

Trump Administration Continues Work with States on Endangered Species Protections on Platte River

It seems only fair, that if we’re to read the press releases of, for example, CBD about how bad things are, we should also highlight when there are environmental success stories.  I wouldn’t have found this one except a paragraph in a local newspaper.  Short story: Feds and state are getting along with water providers and other stakeholders to protect endangered species, even to the tune of providing lotsa bucks.

Secretary of the Interior, along with Governors of Colorado, Nebraska and Wyoming, commit an additional $156 million for recovering threatened and endangered species in the Platte River Basin

 

 U.S. Secretary of the Interior David Bernhardt signed an amendment to the Platte River Recovery Implementation Program Cooperative Agreement, along with the governors of Colorado, Nebraska and Wyoming, committing resources to extend the program through Dec. 31, 2032. The Platte River Recovery Implementation Program utilizes federal- and state-provided financial resources, water and scientific monitoring and research to support and protect four threatened and endangered species that inhabit areas of the Central and Lower Platte rivers in Nebraska while allowing for continued water and hydropower project operations in the Platte River basin.

“This program is truly an important partnership that has been successful because of the broad collaboration between federal and state representatives, water and power users and conservation groups,” said Secretary Bernhardt. “All of these stakeholders working together to help recover imperiled species is critical as new water and power projects are continued and developed in the Platte River Basin.”

The program provides compliance for four species under the Endangered Species Act (ESA) for new and existing water-related projects in the Platte River Basin. Examples of existing water related projects include the Bureau of Reclamation’s Colorado Big-Thompson Project on the South Platte River in Colorado and the North Platte Project in Wyoming and Nebraska.

“Programs like the Platte River Recovery Implementation Program are critical to ensuring that Reclamation is able to deliver water and power in an environmentally and economically sound manner,” said Bureau of Reclamation Commissioner Brenda Burman “This program is a true success story of how stakeholders and government from across state lines can work together for the common good.”

And if you see things through partisan lens here’s our favorite Boulderite governor:

“The signing of the Platte River Recovery Implementation Program Cooperative Agreement Amendment marks the celebration of more than a decade of success,” said Colorado Governor Jared Polis. “The commitment by the states and the U.S. Department of the Interior to continue the program’s innovative approach to species recovery and Endangered Species Act compliance is a win-win for the future of Colorado’s citizens and the environment. We look forward to the next 13 years working with our partners to lead in this national model of collaboration.”

Helena project clears the 9th Circuit, except for some “WUI”

Fine specimen of a real antique Morse code telegraph machine.Copyright: Photowitch | Dreamstime.com

The Ninth Circuit Court of Appeals has upheld the Telegraph Vegetation Project on the Helena-Lewis and Clark National Forest, except for one question about the location of the Wildland Urban Interface (WUI).  The case was previously described on this blog here.  That description included this allegation by plaintiffs:

Agency used non-federal definition of the Wildland Urban Interface 


“While the lynx amendment allows logging in the Wildland Urban Interface, it also defines the Wildlife Urban Interface to be within one mile of communities,” Garrity explained. “But the Forest Service used a new definition provided by local counties and then remapped the Wildland Urban Interface to include areas over five miles away from communities.”

The court remanded the decision for 50 acres of the 5000-acre plus area to be treated, and left the record of decision in place while the Forest Service completes its reevaluation:

“The Forest Service has acknowledged that it erred in calculating the wildland-urban interface for the project area. The Forest Service estimates that, once it has corrected its error, 50 acres of forest that it had planned to treat may no longer be eligible for treatment. If that estimate proves correct, the Forest Service represents that it will not treat those 50 acres. We grant the government’s request for a voluntary remand to allow the Forest Service to undertake the necessary reevaluation.”

I have been interested in how WUI is identified, by whom, and using what process under what authority – especially the role of non-federal parties.  WUI is generally  identified based on the Healthy Forest Restoration Act of 2003 (HFRA).  Areas identified using that process qualify for streamlined projects in accordance with HFRA, and may be eligible for particular funding.  However (in accordance with HFRA), WUI projects are still subject to requirements of the governing forest plan.  Management direction for lynx is part of the forest plan, and this article (like plaintiffs) suggests it imposes greater restrictions on part of this project:

“In the second portion of the court’s order, the Forest Service proposed logging and thinning in areas defined as the “wildland-urban interface,” which is where houses or cabins meet the forest. Regulations related to lynx allow the removal of some trees and vegetation in lynx habitat if it falls within the wildland-urban interface and if the agency shows it is part of a wildfire mitigation project. The alliance inspected the area and reported only a handful of houses. The Forest Service conceded in court documents that it erred in calculating the size of the wild-land urban interface based on discrepancies between what qualifies.”

However, this actually indicates that the problem was in the definition of “community” (based the on number of houses), rather than the distance from one.  In fact, the Northern Rockies Lynx Management Direction refers to WUI “as defined by HFRA.”  Those definitions and criteria for “WUI” and “at risk community” are summarized by the Forest Service here.  Although which communities are to be included (they can self-identify) are mostly listed in the Federal Register, that doesn’t address their boundaries.  The district court opinion upheld the Forest Service WUI designation, stating that, “The Powell County Plan does not begin with the HFRA definition; it creates its own, “and “the Court is not persuaded by Council’s attempt to discredit the map provided by the Forest Service in the Telegraph Project EIS” based on that county plan. Yet it sounds like the map may have been wrong in this case.  This all reminds me of my take-home from my Forest Service days that “WUIs are fuzzy.”

Here’s why this might be important to planning.  I agree with the idea that forest plans (like the lynx direction) should identify areas with differences in long-term management that result from a wildland-urban influence.  However, if the WUI definition refers to another source (HFRA and a local plan), instead of being specifically defined in the plan itself through criteria and/or a map, there may be confusion about where and how the plan applies (as seems to be the case here).  (Yes I’m criticizing the lynx strategy for doing that; they didn’t take my advice.)  In addition, if external decisions about WUI locations change, the Forest Service may have to publicly consider whether to adopt that change in its forest plan (that situation wasn’t addressed in this case).  I’m also contrasting “decisions” with new “information” that affects how an existing decision applies (e.g. someone building a new house), which must be considered in a planning context but doesn’t necessarily trigger a plan amendment.  (A court has held that even changes in something like criteria for maps of lynx habitat must be considered in a public planning process when forest plan direction is tied to it.)

(The other issue addressed by the 9th Circuit in its short opinion was the ESA consultation process for grizzly bears.  The court approved a consultation process that tiered to forest plan decisions and consultation, which lead to streamlined project consultation.  The value of forest plan consultation has been questioned, but that value is evident here.)

 

Now what happens when a new species on a national forest is listed under ESA?

Once upon a time, when a new species was listed under ESA, the Forest Service was required to reinitiate consultation on its forest plan regarding the effects of the plan on the species.  Projects were often held up while this was occurring.  As a result of the Cottonwood litigation, involving a new designation of critical habitat for Canada lynx, the law was recently changed so that neither new critical habitat nor listings require new consultation on existing forest plans (as discussed here).

The candy darter (CBD photo) was listed as endangered in late 2018 and it is found on the Monongahela National Forest.  The Center for Biological Diversity provided this news release regarding a proposed timber sale in a watershed where the species is found and where critical habitat for it is being considered:

The U.S. Forest Service this week announced it will withdraw a 2,400-acre logging project in West Virginia’s Monongahela National Forest following objections raised by conservation groups about harm to an endangered fish.

The project would likely have caused significant erosion and sent sediment into rivers and streams, threatening the rare fish and other animals.

“Friends of Blackwater and all of our supporters are very pleased that the Monongahela National Forest supervisor has withdrawn the Big Rock Timber Project proposal,” said Judy Rodd, director of Friends of Blackwater. “Hopefully this is a step toward fully protecting the candy darter, a tiny jewel of a fish found in the timbering proposal area, near the world-famous Cranberry Glades.”

The Forest Service announcement said the project would have been the first of its kind to require formal consultation under the Endangered Species Act for the brightly colored candy darter, which was listed as endangered in November 2018. The Fish and Wildlife Service would have had to calculate how many, if any, candy darters could be killed or harmed by the proposed project. The Fish and Wildlife Service also plans to include portions of the logging project area in its final designation of the fish’s critical habitat. Those issues contributed to the decision to pull the project.

Presumably the Monongahela has come to a full stop on projects that may affect the darter, while they figure out a strategy for consulting with the Fish and Wildlife Service.  This is pretty close to the same result that would have occurred without the “Cottonwood fix.”  This is a situation where consultation on a forest plan has proven beneficial.  It should result in a species conservation strategy that “fully protects” the species’ habitat on the forest that the FWS supports and that can be included in the forest plan.  The FWS may then rely on the forest plan decisions and their biological opinion for analysis of its overall effects, which would simplify and streamline the consultation process for projects.

Post-Cottonwood, they could now choose instead to proceed on an individual project-by-project basis, but why?

(PS – This looks like an example where the administrative objection process prevented the Forest Service from losing a lawsuit.)

Grand Teton Park Killing “Invasive” Goats to Protect Bighorn Sheep

Note this photo is of the sheep, not goats.
Since we have gotten on the topic of bighorn sheep protection...here is a link to an AP story about shooting mountain goats in Grand Teton National Park for bighorn protection.

There are two interesting things about this.. first, that species are “invasive” if they expand their ranges since when (pre-European settlement? Do we actually know what their ranges were then? When do we think like this? What about these cutthroat trout.. are they “invasive”- perhaps not because they didn’t get their on their own power?

The second interesting thing is that non-motorized recreation is apparently also not good for bighorns in this case:

The bighorn sheep herd, by contrast, is considered fragile. They have been pushed out of some of their best habitat by backcountry skiing activity, and their existence is threatened by potential disease transmission by the mountain goats.

Does anyone know if the Park is reducing or eliminating backcountry skiing to protect bighorns?

This Denver news story says that

The Grand Teton National Park Foundation called its mountain goats “perhaps the biggest ecological threat to the area in modern history” to the park in 2014.

but the link didn’t work so I couldn’t check.

Here are some local details from the Idaho State Journal:

Because shotguns will be blasting from helicopters to kill mountain goats in Grand Teton National Park during the coming week, a temporary area closure for the public is being implemented in the central part of the park.

The closure is slated for Sunday through Jan. 12 and is bounded on the south by the South, Middle, Grand Teton, Mount Owen and Teewinot Mountain peaks; on the west by the park boundary; on the east by the western shores of Jackson, Leigh, String and Jenny lakes; and on the north by Rolling Thunder Mountain and Eagle Rest peaks.

“No public access will be allowed in the area during this time,” the park said in a news release. “Signs will be posted at main access locations.”

Wolf Reintroduction Story in Colorado Springs Gazette by Liz Forster

This image of what appears to be a radio-collared wolf was sent to Colorado Parks and Wildlife from a member of the public near Colorado State Forest State Park in July 2019. (Photo: CPW)

The Wolf Reintroduction to Colorado initiative just got enough signatures for the ballot, which reminded me that I never had a chance to post this excellent (IMHO) article by Liz Forster, formerly of the Colorado Springs Gazette and currently a law student at University of Montana. While there tend to be controversies about wolves, this controversy seems to be about whether the State of Colorado lets them come in “naturally” or develops a program to reintroduce them.

Here is my earlier post:

I thought Liz Forster did a great job on this article on reintroducing wolves to Colorado in terms of helping us understand both, or really, many sides. What is most interesting to me is the idea that species need to be reintroduced and how this is portrayed as a scientific idea, rather than a value or preference.

The wolves’ re-establishment in Colorado’s wilderness — ideally, say backers, 100 to 200 within 10 years — would trigger a ripple of benefits among wildlife, plants and other organisms and restore ecosystemic balance, the Wolf Action Fund argues.

“It’s important that we reunite the path of wolf movement from [the] north to south [borders] because with movement you have integration, which is good for ecological health,” said Rick Ridder, the campaign’s spokesman. “It all ties into: let’s keep Colorado wild, let’s keep our wilderness wild and let’s try to keep what we love about Colorado and our mountains for our children and grandchildren.”

The concept of “ecosystemic balance” is questionable, as we’ve discussed before, not least in Botkin’s book Discordant Harmonies. I’m not sure exactly what “integration” or “ecological health” means in that context. I can see that linking the populations from Canada to Mexico could provide for more gene exchange, except that isn’t the Mexican Gray Wolf considered to be subspecies, so it it “good” for them to mate with other gray wolves, or “bad”?. But if it’s good because of gene exchange leading to more diversity, couldn’t we do that now (captive breeding?). But would the subspecies still be “endangered” then and have the same legal hooks for protection? And of course, having more predators may be great unless you happen to be a member of a species that gets predated upon (or have companion animals/livestock that get predated upon), or you happen to be a species that has benefited from more prey. Remember niche theory? There are two ideas that may be important here: 1) the idea that there is some kind of interest of wholeness above that of individual species, or 2) the past is best. Both ideas are interesting to contemplate, but neither actually is a scientific idea. In fact, looking at the past tells us that plants, animals, and a variety of other organisms are constantly changing, moving, and so on- ending up in a variety of unpredictable assemblages over time. And humans have changed both the environment and the movement of species over time.

And logically, if the wolf has been absent for 70 years, are we really “keeping what we love” or trying to duplicate the past we don’t actually remember? Time’s arrow only goes one way, so is that possible? Should we equally get rid of dams and other water infrastructure Colorado rivers to go back to the past? Or kick people out of recreating or other activities? As with all other “let’s go back” interventions, clearly this is a decision where there would be species, and people, winners and losers. There’s not a “science” answer.

Here’s some more interesting stuff from her article:

A study published by the University of Wyoming in April showed that the ubiquity with which the promise of the Yellowstone example was applied to other places might not have as much merit as proponents say. The trophic cascades associated with the reintroduction of an apex predator sometimes happened in the studies they reviewed, sometimes it didn’t.

“We need more studies,” said Jesse Alston, the paper’s lead researcher, in Science Daily. “More tests of this ‘assumption of reciprocity,’ as we call it — particularly via rigorous experimental studies — would be really helpful. This is hard data to get, but we really do need it before we can credibly claim that large carnivores restore ecosystems. They might not.”

A 2018 study by Mark Boyce of the University of Alberta also emphasized the mixed results of wolf reintroduction in areas with significant human presence versus a protected space like Yellowstone.

I would tend to agree with Hemming of RMEF

A ballot initiative, Henning added, also circumvents the wildlife management protocols put in place that require a commission to review the scientific viability of the plan, a public review process and other checks and balances.

“My fear is that it would be rushed,” he said. “The slow, natural immigration of those animals can be softer so that the elk and people can adjust, and we can prepare a management plan for them.”

But Weber says we need to be in more of a hurry.

Natural migration could take years, most likely decades, though, Weber said, and the ecosystem can’t wait that long.

“Coloradans need to go to places where the killing of wolves has led to the destruction of the ecosystem, where the vegetation is destroyed,” Weber said. “Then we can get Coloradans to stand proud and say, ‘We won’t do the same thing.’ ”

I guess I haven’t seen any “destroyed ecosystems” or “destroyed vegetation” caused by lack of wolves, myself, and so I don’t quite understand the urgency.

Winter motorized recreation planning – behind the curve again?

credit

The trend continues – technology makes it easier for more people to get farther into the less trammeled  parts of public lands.  Good planning would project future changes in technology over the life of a plan and – plan for it.  I haven’t researched this question directly, but my impression is that winter travel planning (required by Forest Service regulations) mostly responds to the current state of technology.  I’ve even seen statements like, “we don’t need to worry about closing these areas,” or at least “we don’t need to worry about people complaining if we close these areas,” because people can’t get to them.  What happens when that is no longer true?  NEPA requires consideration of new information relevant to environmental impacts, which may lead to changing a decision.

“Snowbikes” – I imagine there are some national forests that ought to be thinking about going back to the drawing board on their winter travel management plans (and maybe forest plans).  Especially where there are snow-dependent species like lynx and wolverine that are listed under ESA (where new information must be consulted on) or at risk of being listed (and regulatory mechanisms are a consideration).

“After Polaris bought Timbersled in 2015, that’s when things took off,”

“The snowbike market is in its infancy right now, but it’s exploding,”

“It’s a riot,”  “You can make your own line wherever you want to go.”

 

“They’re so agile,”  “You’re able to get into places you never would get into with a snowmobile.”

“It’s just like riding a dirt bike in the woods,”

“For those who have never ridden a snow bike, the best analogy I can think of is this; it is like riding a Jet Ski on sand dunes. There is a freedom unlike anything else I have ever done.”

 

Samo-Samo for CASPO

No Threatened Status for the California Spotted Owl. Current protections remain. The article is a good read, with some of the “usual suspects”.

http://www.calaverasenterprise.com/news/article_a866d476-14d2-11ea-b7e0-7b830918c726.html

Recovery planning for the Gunnison sage-grouse

The U. S. Fish and Wildlife Service has released a draft recovery plan for the Gunnison sage-grouse in Colorado and Utah.  The Center for Biodiversity doesn’t like it, but more to the point, they like less how the BLM is managing Gunnison sage-grouse.  More to the point because recovery plans are not mandatory, while federal land management plans can be – and plan components must be mandatory to be considered “regulatory” enough to carry much weight in ESA listing and delisting decisions.  As the FWS said, “Establishing durable regulatory mechanisms that are binding and enforceable, such as revised land use planning amendments, will be important for recovery.”

CBD:

The recovery plan comes on the heels of BLM decisions not to designate any Areas of Critical Environmental Concern for Gunnison sage-grouse in the Tres Rios and Uncompahgre Resource management plans, and to adopt inadequate safeguards for the birds’ habitat in recent land-use plans. For example, although the draft recovery plan calls on federal land-management agencies to improve their resource management plans and protect suitable habitat within four miles of breeding sites, the BLM’s August 2019 proposed resource plan for its Uncompahgre Field Office protects only habitats within 0.6 miles of breeding sites. The BLM admits this would “fall short of minimum protection standards to maintain sage-grouse viability.”

“Bringing the Gunnison sage-grouse back from the brink requires decisive and concerted action, but instead we have two federal agencies working against each other,” said Michael Saul, a senior attorney at the Center for Biological Diversity. “The Fish and Wildlife Service is urging federal land managers to improve protections for public-land habitat, but the BLM is moving in the opposite direction. This is a recipe for extinction for this beautiful bird. We’ll do everything possible to keep that from happening.”

The timing is also such that BLM plans were released prior to the draft recovery plan.  That means that the BLM should start taking another look at how their plans address this species and take into account the new information and recommended measures.  The same is true for the 10% of sage-grouse habitat that occurs on national forest lands. BLM is not subject to NFMA, so its obligation to maintain species viability to avoid listing under ESA is not as clear as for the Forest Service.  Forest Service plans must “contribute to recovery” of listed species, so failure to address elements of this recovery plan when it is final should raise serious questions.

In addition to specific conservation measures like the four-mile buffers for breeding leks, the draft recovery plan provides some specific desired conditions that could be included in land management plans:

2. Regulatory mechanisms or other conservation plans or programs, such as land-use management plans, reduce and ameliorate threats associated with habitat loss and degradation in all populations, such that:

A. Habitat in Dove Creek is improved and maintained at a quantity calculated to support a HMC of 30, although this criterion is not measured by achieving the target HMC.

B. Habitat in CSCSM is maintained at a quantity calculated to support a HMC of 7, although this criterion is not measured by achieving the target HMC.

C. Habitat is improved and maintained in Gunnison Basin, San Miguel, Piñon Mesa, Crawford, and Monticello at a quantity calculated to support the target HMCs as listed in Table 1.

At a minimum, the land management agencies will need to explain how these plans contribute to meeting their requirements under ESA to manage their programs to promote recovery of listed species, which should include how they are implementing the final recovery plan.

Forest planning for “sustainable” recreation

A former Forest Service backcountry specialist talks about ecological integrity and increasing human recreation activities, and tries to answer the question of “what is sustainable recreation?”  The 2012 Planning Rule requires plan components “to provide for: (i) Sustainable recreation; including recreation settings, opportunities, and access; and scenic character.”

What is “Sustainable Recreation”? The Forest Service defines it as “the set of recreation settings and opportunities in the National Forest System that is ecologically, economically, and socially sustainable for present and future generations.”

Here’s how it’s done:

The Recreation Opportunity Spectrum can be used in forest planning to define a desired condition for management within each zone. Indicators and standards are meant to define the tipping point beyond which management action must be taken.
 If the standard for a backcountry area (called “semi-primitive non-motorized” in ROS jargon) is that no more than six other parties are encountered on a typical day, when the encounter rate exceeds that number some action is supposed to take place to return to the desired condition.
It’s a neat framework, but doesn’t always play out as intended on the ground. ROS doesn’t differentiate between a semi-primitive area in the back yard of a town like Jackson or Bozeman and one that’s two hours away.
That seems like a major shortcoming, especially if all areas with a SPNM designation must have the same desired level of semi-primitive non-motorized use.  However, the Planning Handbook encourages “new approaches,” including creating “desired recreation opportunity spectrum subclasses” §(23.23a).
The usual sequence of remedial actions begins with non-intrusive measures like visitor education. If the problem isn’t solved, additional actions are considered.
The Bridger-Teton forest plan is typical in its prescribed sequence of actions, this excerpt taken from its direction on wilderness. The following recreational strategies should be used, listed in descending order of preference:
First Action – Efforts are directed towards information and education programs and correction of visible resource damage.
Second Action – If the first action is unsuccessful, restrict activities by regulation (for example, set a minimum distance between a lakeshore and where people can camp).
Third Action – If the first and second actions fail, restrict numbers of visitors.
Fourth Action – If first, second, and third actions are not successful, a zone can be closed to all recreation use until the area is rehabilitated and restored to natural conditions.
In my experience, outside of designated wilderness and other special areas where specific laws apply, the Forest Service keeps circling around the first action, which isn’t a bad strategy given the continuing need for it in communities where resident turnover is high.  It’s an ongoing need regardless of the often unmet requirement to step up restrictions. But restrictions trigger blowback, as when the Shasta-Trinity National Forest tried to set encounter limits for the wilderness that includes Mt. Shasta.
People basically said they don’t care if it’s crowded—they just want to reach the summit, and a judge agreed with them. On the other hand, those who float the Selway River are happy to wait until they get a launch day shared by no one else. Since everyone is going the same direction at about the same speed, everyone can experience a bit of peace and quiet. So the application of sustainable recreation standards depends on who is using the forest and what they will accept.
And those are the questions that forest planning should be designed to answer.  (Note:  the Bridger-Teton plan has not been revised, so may not be the current state-of-the-art.  Also, I couldn’t find the court case referred to.)  And this must be done against the backdrop of a requirement for ecological integrity.
User-built trails and roads are often the opposite of sustainable. They develop incrementally and aren’t designed with soil type, grades and curve radii in mind, or the needs of resident wildlife. The trail system after adoption by the Forest Service usually gets reworked so it doesn’t turn into deep ruts or wash into the creek, but where is the analysis that determines that the trail location is right in the first place?  The trail itself becomes more sustainable, but where do the grouse and elk and owls go?
The adoption of forest plan of components for desired recreational use has effects that must be evaluated during the NEPA process, but rarely does the Forest Service devote much attention to this.
The author describes a common fallacious argument that the Forest Service likes to make about sustainability to avoid controversy:
While the planning rule makes clear that ecological integrity underlies compatible uses in a national forest, the ecological, economical, and social sustainability have since been referred to as a three-legged stool, with all three legs of equal importance.
But if you parse the actual language of the Planning Rule, it is apparent that the ecological leg needs to support more weight (driven by the substantive diversity requirement of NFMA) (my emphasis).
“Plans will guide management of NFS lands so that they ARE ecologically sustainable and CONTRIBUTE TO social and economic sustainability; CONSIST OF ecosystems and watersheds with ecological integrity and diverse plant and animal communities; and HAVE THE CAPACITY TO PROVIDE people and communities with ecosystem services and multiple uses that provide a range of social, economic, and ecological benefits for the present and into the future.