Letters Needed Now for High Sierra WildernessThe deadline is fast approaching to submit comments on the U.S. Forest Service's draft plan for managing the John Muir, Ansel Adams, Monarch, and Dinkey Lakes wilderness areas. When finalized, the combined plan for all four areas will guide the management of nearly one million acres of wilderness in the heart of John Muir's "Range of Light" for decades to come. All wilderness users and advocates are encouraged to voice their opinions at this time. Once adopted, the wilderness management plan will prescribe the numbers of hikers, horseback riders, and commercial outfits that may use these areas. The plan is also required by law to include all restrictions on grazing, trail-building, campfires, and other activities that are necessary to protect these areas from over-use. However, the draft fails to address many issues raised by conservationists, and special-interest groups have mounted an intensive misinformation campaign and have flooded the agency with letters opposing the few positive aspects of the draft plan. For example, the draft plan designates remote, pristine areas as off-limits to new trail construction. In response, the "Blue Ribbon Coalition" (BRC), a consortium of off-highway vehicle, jet-ski, snowmobile, and similar groups, is whipping the public and local politicians into a frenzy by falsely claiming that under the draft plan "several hundred miles of trails will be obliterated in this pristine zone." The simple truth is that only a very few miles of trails are scheduled for closure under the current draft plan (i.e., where parallel trails already exist and duplicate trails are not needed), and the draft plan actually allows for new trail construction in many areas. Another graphic example of the lies being spread by the BRC and other special interests is their claim that the Mt. Whitney trail would be closed to stock animals by this plan (BlueRibbon Magazine, 8/98), when in fact the Mt. Whitney trail has been closed to stock animals for more than 20 years. (Stock animals have been prohibited on the Whitney trail since the 1970s because of the popularity of the trail and due to the fact that the steep and narrow terrain leaves nowhere for hikers to get safely off the trail in order for stock parties to pass.) The BRC and some commercial mule-packing outfits based in the Sierra are also spreading misinformation about the effects of the draft plan's proposed group size limits. The draft plan calls for maximum group sizes of 15 persons and 25 stock animals on trails, and 8 persons and 8 stock animals off of designated trail corridors. Although the draft plan clearly allows recreational stock use to continue in all areas where it is allowed today, stock users have disseminated misleading claims that the plan "proposes to create management zones where 85% of the total acreage would not be managed for pack and saddle stock use." Such misleading information was used to convince 3 local Members of Congress (John Doolittle, George Radanovich, and Jerry Lewis) to sign an emotional letter to the Regional Forester opposing the lower group size limits for off-trail travel. Scientists have for many years recommended smaller group size limits for off-trail travel, due to the impacts of large groups both on the environment and the experience of other visitors. Wildland researchers have concluded that off-trail travel by stock animals is particularly damaging and should be avoided altogether. But without strong support from conservationists, the Forest Service may be forced to back off even from its overly modest proposal to reduce group size limits for off-trail travel to 8 persons and 8 stock animals. In response to decreasing trails budgets, and due to the fact that many trails in the Sierra that traverse steep or sensitive terrain were never properly constructed to withstand stock animal use, the draft plan proposes that several primitive trails will not be upgraded or maintained for stock travel. Specifically, the draft plan proposes that several steep east-side passes (such as Shepherd, Sawmill, and Taboose) will not be improved to facilitate travel with stock animals. However, stock users would still be allowed to use the existing rough routes if they so desire. During the initial public comment period, many hikers requested that the agency create a modest network of "foot-travel-only" trails so that they could enjoy an experience free of the dust, manure, and flies that often result along trails used by stock animals. But the draft plan proposes no new "stock-free" trails. Nevertheless, many private and commercial stock users want Shepherd, Taboose, and Sawmill passes and other primitive trails to be upgraded and forever maintained to higher stock standards, and they are vehemently opposing the Forest Service's modest proposal to leave a few trails in their existing primitive condition. Whether the agency's proposal to forego improvements on a few primitive trails makes it into the final plan will depend largely on the public comments. Respondents should give their opinions about Shepherd, Taboose, Sawmill, and Baxter passes by name. Another concern to conservationists is that individuals have long been limited by a quota system that restricts daily entry at many trailheads, but commercial outfits (such as horse- and mule-packing businesses and commercial mountain guides) are not subject to the quota system, and the commercial outfits are in fact allowed to write their own wilderness permits. Gary Guenther of Wilderness Watch, a nonprofit wilderness advocacy group, has pored through piles of government documents and discovered that, within the last twenty years, access by private backpackers to some areas of the Eastern Sierra has been cut by almost 40 percent, while commercial outfits have been granted incremental increases. "The records show clearly that access by private users to Eastern Sierra wilderness has been steadily reduced while the number of commercial stock animals in use is at an all-time high."said Guenther. Many who recreate in the High Sierra are questioning the fairness of such an arrangement, especially since the Forest Service continues to reduce hiker quotas with one hand, and with the other hand grant increases to commercial pack stock outfits—often without asking for public input or preparing environmental assessments. Perhaps the biggest disappointment with the draft plan is that it contains no meaningful limits on commercial use of these areas. While the draft plan would prohibit any additional commercial outfits from using these areas, it would allow the existing commercial outfits to expand, with no concrete limits on their growth. The Forest Service had promised conservationists that limits on existing commercial uses would be included in this plan, but the agency appears to have reneged on that commitment, and has included in the draft only vague language that says a "needs assessment" for commercial uses will be conducted at some future unspecified date. A "needs assessment" is required for these areas (and should have been conducted years ago) because the Wilderness Act of 1964 generally prohibits commercial uses of wilderness areas unless the managing agency makes a finding that a specific commercial use is "necessary" to achieve one or more goals of the Act. For example, commercial outfitter and guide services are often deemed necessary to facilitate safe wilderness travel by persons with disabilities, or beginners who do not have sufficient experience to travel alone. Conservationists recognize these legitimate commercial uses, and are asking simply that a needs assessment be conducted before the draft plan is approved, and that clear limits on all existing commercial uses be specified in the final plan. Grazing by recreational stock animals (i.e., horses, mules, burros, etc.) is also a key issue in these four wilderness areas. The impacts of stock grazing and trampling on sensitive alpine meadows, wetlands, and lakeshores was one of the key issues raised by the public at the outset of the planning process in 1992. However, although the Forest Service took more than five years to prepare this draft plan, the agency conducted no systematic evaluation of the condition of backcountry areas. "It appears that the agency people wrote this plan at their desks without ever going outside. It is hard to believe that the Forest Service needed more than five years to prepare a draft plan that contains almost no specific information about on-the-ground resource conditions."said Peter Browning of the High Sierra Hikers Association. Most conservationists agree that the agency should assess resource conditions and prohibit grazing in sensitive, high-elevation areas where soils remain perpetually wet. Such "wetland" areas are supposed to be protected under federal and state regulations, but are often forgotten in remote wilderness settings. The numerous deep hoofprints frequently caused by stock grazing in alpine wetland areas can result in accelerated erosion and loss of wetland soils that took thousands of years to form. Another practice that has worked well in other national forests and parks, but which is absent from the draft plan, is "opening dates" for grazing. The concept is simple: Alpine meadows in the Sierra are saturated and susceptible to trampling damage early in the season following snowmelt. As the meadows become drier, they can better withstand trampling and grazing impacts. Opening dates are set by the agencies so that grazing may not commence until the meadows are sufficiently dry to protect against deep hoofprints and other trampling damage, such as streambank "chiseling." Although conservationists asked the Forest Service to include specific opening dates in the plan, the agency says that the need for opening dates will instead be evaluated at some future unspecified date, in the "annual operating plans" prepared for each commercial pack outfit. This approach is unacceptable because there is no guarantee that the existing impacts will ever be addressed, since the preparation and approval of operating plans for commercial outfits are negotiated "behind closed doors" without public involvement or environmental documentation, and because opening dates should be set for all stock users, both commercial and private. Another very controversial element of the draft plan is its scheme for regulating campfires. It has long been known that high-elevation subalpine forests—such as whitebark pine, foxtail pine, limber pine, etc.—do not produce sufficient "ground fuels" (i.e., twigs, branches, etc.) to sustain firewood collection while leaving enough organic material on the ground surface for ecosystem protection. Woody material on the forest floor is needed for a host of reasons, including soil formation, water holding capacity, soil temperature moderation, protection of the soil surface from erosion, and many other ecosystem functions that are critical to plants and animals at high elevations. In recognition of this, many national forests and parks prohibit campfires at high elevations, and conservationists have long supported such regulations because elevational fire restrictions provide protection for subalpine ecosystems in a way that is easy for wilderness travelers to understand. The only opposition to elevational fire limits in the John Muir, Ansel Adams, Monarch, and Dinkey Lakes wildernesses appears to come from a vocal minority of private and commercial users who want to continue to have fires in sensitive subalpine areas even though the adverse impacts are well known. The Forest Service proposal bows to those interests by allowing unlimited campfires in almost all high-elevation areas, until such time that monitoring shows that the ground has been stripped of protective organic cover and standing trees have been cut by campers seeking wood for their campfires. Only then would the agency regulate fires, and only the most heavily impacted areas would be closed. One key problem with this approach is that the agency has little or no funds for monitoring campfire impacts. Even worse, such an approach allows significant and easily avoidable damage to occur before the agency takes corrective action. Curiously, the draft plan even says that managers will "adjust quotas" (i.e., reduce visitor access) before the agency considers elevational campfire closures. This means that the Forest Service will tell you to stay out of certain areas before they will regulate the behavior that is causing the problem. The most common-sense approach, which has been used successfully in many other areas, is to establish elevations above which campfires are not allowed, and criteria for adopting site-specific fire closures below those elevations as needed. Such an approach would prevent predictable impacts in a way that is very easy for the public to understand, and simple for the agencies to enforce. The use of airspace over wilderness by military jets is another issue of concern to many who visit these areas. The ongoing expansion of military training flights over the Sierra is making it increasingly difficult to have a peaceful "wilderness experience." The military often argues that it cannot moderate its flights over wilderness areas unless the applicable wilderness plan identifies a quantitative threshold for noise. It is therefore crucial that the Forest Service hear from the public that the natural quiet is an important reason why so many of us visit wilderness, and that the draft plan needs to be supplemented to include quantitative standards to fully protect the natural quiet from the intrusion of military and other aircraft. If noise standards are not incorporated into the draft plan, military training routes over these areas will be allowed to increase with virtually no limits. Unless the Forest Service hears a loud and clear message from wilderness advocates, vocal commercial outfits and selfish short-sighted users will prevail. Unless conservationists put pen to paper at this time, the High Sierra wilderness will be further degraded, and the discrimination against private parties in favor of commercial interests will continue. Now is the time to make your opinions known! What you can do: Send a letter to the Forest Service by November 2, 1998 (postmark deadline). State that you are commenting on the "Draft Environmental Impact Statement: Management Direction for the Ansel Adams, John Muir, Dinkey Lakes, and Monarch Wildernesses." Use the article above to inform your opinions, and consider raising the following points:
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