INTRODUCTION
HUMAN POPULATION AND TRAFFIC
WATERSHED/CARRYING CAPACITY
OTHER SPECIFIC THREATS TO WATER QUALITY
ROADLESS AREAS
PEER REVIEW OF SCIENTIFIC AND TECHNICAL DOCUMENTS
WILDERNESS
1.MT. AIRE WILDERNESS ADDITION
2.MT. OLYMPUS WILDERNESS ADDITION
3.TWIN PEAKS WILDERNESS ADDITION
4.LONE PEAK WILDERNESS ADDITION
NON-WILDERNESS LAND DESIGNATION
RESIDENTIAL/COMMERCIAL DEVELOPMENT
RECREATION
1.SKI RESORT RECREATION
2.DISPERSED AND BACKCOUNTRY RECREATION
3.MOTORIZED RECREATION
ECOSYSTEM MANAGEMENT AND BIODIVERSITY
FRAGMENTATION OF WILDLIFE HABITATS
NATIVE PLANT AND ANIMAL SPECIES
BATS
BOREAL TOAD
STATUS AND NEEDS OF RARE AND SENSITIVE SPECIES
PLANTS
THE PLAN IS UNLIKELY TO PROVIDE FOR THE LONG-TERM VIABILITY OF NATIVE CUTTHROAT TROUT
PRELIMINARY REVIEW OF THE LAND AND RESOURCE MANAGEMENT PLAN
FOREST PLAN AMENDMENTS
CATAGORICAL EXCLUSIONS
CONCLUSION

INTRODUCTION

In addition, SOC commends the Forest Service for involving the public throughout the process of producing a thorough, well researched DEIS. SOC agrees with the Forest Service that public opinion is an important element to consider in formulating a Forest Plan, and SOC thanks the Forest Service for their extensive efforts to involve the public during the process.

However, when an area of the Forest is being fundamentally degraded because of human overuse, the Forest Service must not bend to public sentiment or commercial pressures that request increased human use or request the potential for increased human use. In such a situation, it becomes the duty of the Forest Service to tell the public that activities that tend to hasten the degradation of National Forest land will not be allowed.

No area of our National Forest is as threatened by human overuse as the tri-canyon area of the Wasatch Range east of Salt Lake City (Millcreek Canyon, Big Cottonwood Canyon, and Little Cottonwood Canyon). No other area is so immediately at risk. The Forest Service has within its jurisdiction the power to write a Forest Plan that will save the tri-canyon area and ensure its future as a beautiful and vital part of our National Forest for many generations. But the Forest Service must act now or the tri-canyon situation will deteriorate to the point of being unmanageable when the next Forest Plan is undertaken ten to fifteen years from now.

HUMAN POPULATION AND TRAFFIC

The Salt Lake City Department of Public Utilities (SLCDPU) offers the following statistics with an implicit warning that is unmistakable:

1. There are 1.6 million people living along the Wasatch Front today (SLCDPU). By the year 2021, the population on the Wasatch Front is expected to increase by about 50%, to about 2.4 million, and by the year 2050, it will most likely have doubled or tripled (sources: GOPB DEA, SLCDPU). Pressure to use the WCNF, whether it is recreational, industrial or real estate development purposes, can be expected to increase at least proportionately.

2. The Utah Department of Transportation (UDOT) studies indicate an enormous amount of vehicle traffic in these three canyons that have no highway outlet at the upper end. (The single exception is Guardsman Pass Road in Big Cottonwood Canyon, which is partially unpaved and closed in the winter.) In 1989, the average daily traffic in Little Cottonwood Canyon alone was 12,085 vehicles, according to the UDOT Average Daily Traffic Study. By 1996, that figure had risen to 16,540. (SLC Watershed Management Plan '99, Ap. G, p. 148)

3. A Forest Service study ranking the amount of recreation use in the National Forests showed the following: In 1992, the Wasatch-Cache/ Uinta National Forest did not rank among the top ten most heavily-used National Forests in the country. By 1995, just three years later, the Wasatch-Cache/Uinta ranked number one in Recreation Visitor Days, topping all other National Forests in recreation use. The focal point of this serious situation is the area of greatest population concentration, the tri-canyon area.

The problem of human overuse in the tri-canyons is serious and worsening season by season. SOC feels that the Forest Service can and should reverse the tri-canyon deterioration. It is in their power to do so. But if the Forest Service chooses to ignore the need to give special attention to the tri-canyon area, if they fail to write meaningful policy to protect this area against human overuse in the Forest Plan now being formulated, the tri-canyons will be inevitably and irreversibly lost as a meaningful National Forest.

WATERSHED/CARRYING CAPACITY

Three of the Salt Lake City watershed drainages lie within the tri-canyon area. Of utmost importance is that two of those drainages provide the largest and the second largest water yields in the entire Salt Lake City watershed area. Over one-third of Salt Lake Valley's water comes from the watersheds of Big and Little Cottonwood Canyons.

Water quality at the present time exceeds federal standards, but SOC and SLCDPU fears that increased human overuse of the area will cause rapid degradation of the watersheds. The tri-canyon area is limited in size, but the number of people wanting to use that area is increasing rapidly. SLCDPU warns that the carrying capacity of the tri-canyons is now often strained to its upper limit on weekends and holidays. When that limit is exceeded on a day-to-day basis, year in and year out, as will inevitably happen because of valley population growth, the quality of the valley's water will be seriously threatened. Meaningful action to guard against that disaster must be written into the Forest Plan Revisions being formulated now.

All streams on the Forest are Category 1 (Utah Administrative Code R317-2-12.1.1) streams which the Forest Service is not allowed to degrade (Anti Degradation Policy Utah Administrative Code R317-2-3.2), be it through logging OHV use or other pollution sources. This policy says that, "No water quality degradation is allowable which would interfere with or become injurious to existing in stream water uses." (R317-2-3.1) "waters of high quality ?shall be maintained at existing high quality." This Plan does not provide adequate protections to ensure that this happens.

It may be that watershed protection in the tri-canyons is even more important than previously thought. Over one-third of the city's surface water comes from the tri-canyon watersheds. Surface water is that water which flows from the mountain reservoirs and streams. The remaining water used by the valley comes from wells and springs, from water within the underground aquifers of the valley, which is called ground water.

It is obvious that the source of surface water for the valley is the streams and reservoirs of the mountains. The source of the valley's groundwater, however, has not been as well understood. Historically, it was thought that the replenishment for the valley's aquifers generally came from the benches, not from sources higher up involving the entire mountain block of the range front. It was thought that the mountain watersheds probably affected groundwater recharge, but that they did so over a long period of time, perhaps over a period of 100 years. Studies done by the U.S. Geological Survey (USGS), particularly one undertaken in 1995, indicate that that historic belief is not supported by the facts. The USGS studies indicate that replenishment for the valley's aquifers does indeed come from the entire mountain block.

A study is being completed at the present time, which precisely verifies the USGS findings. Andrew Manning is a graduate student at the University of Utah doing his doctoral dissertation on the groundwater hydrology of the Salt Lake Valley and the Wasatch Range. The study is funded by a grant from SLCDPU. Manning is working closely with the USGS. His study, using noble gas tracers, has verified with certainty that the mountain block including the lower canyons and the range front does indeed affect groundwater recharge. And it affects that recharge on a much shorter time scale than over a period of 100 years.

Groundwater, as it comes from wells, is generally untreated water. Consequently it becomes doubly important to protect the mountain watersheds. Additionally, these new findings indicate that the Salt Lake City Watershed affects a much larger area than the 400,000 residents within the Salt Lake City Water District. The aquifers involved in the groundwater replenished by these mountains involve wells and springs owned not only by Salt Lake City, but also by Holladay, White City, South Salt Lake, Sandy, Murray, Midvale, and the Jordan Valley Water Conservancy.

One of the major thrusts of the 1999 Salt Lake City Public Utilities Management Plan was a proposal to assemble a Blue Ribbon Panel of national experts to help determine what additional data was needed to measure pollution indicators in the watershed. The study has been completed, and now the long-term protection procedures are beginning to be implemented.

OTHER SPECIFIC THREATS TO WATER QUALITY

If, day after day, the carrying capacity of the tri-canyons is exceeded, as certainly it will be in the face of the human population explosion in the valley over the next 20 years, the quality of drinking water for hundreds of thousands of people will be jeopardized. This must be the driving concern of the Forest Service regarding the management of the tri-canyon area as they formulate the new Forest Plan.

Salt Lake Valley borders a desert. Water is precious. When we have allowed the tri-canyon watershed to deteriorate beyond acceptable water standards, there will be no place to turn for replenishment of the valley's water. SOC agrees with the SLCDPU that the best way to protect watershed is to designate that land as wilderness.

Avalanche control work often uses explosives that leave a residue in the snow. Everyone has seen the "soot" ring around the explosive craters. Every year it is estimated that 22,400 pounds of explosives are dropped on the Wasatch Mountains by UDOT, ski resorts, and recreational ski helicopters to trigger avalanches. The explosives residue is composed of toxic and mutagenic nitrogenous compounds that ultimately find their way into the water with a resultant deterioration of water quality. Studies are being published from ski areas in the Wasatch which look at nitroaromatic compound levels in areas that are bombed for avalanches. The studies have been conducted by David Naftz and Ryan Rowland of the USGS (2329 W. Orton Circle, SLC, UT 84119) and provide compelling evidence that avalanche control work could be degrading water quality. These studies should be obtained and standards put in place through the Forest Plan, which will protect water quality from nitro aromatic compounds.

ROADLESS AREAS

SOC is concerned that the Preferred Alternative, while protecting roadless areas in theory, lessens that protection by placing many roadless areas in management prescriptions other than 1.5 (Recommended Wilderness), 2.6 (Undeveloped Areas), or 4.1 (Backcountry, Non-motorized). SOC urges the Forest Service to allocate all roadless areas to management prescriptions, which clearly emphasize their undeveloped and roadless characteristics.

In the case of the tri-canyons, the Preferred Alternative gives a 4.3 (Backcountry Motorized) designation to Mineral Fork in Big Cottonwood Canyon. This is clearly a mistake. Mineral Fork is an important part of the Salt Lake City watershed. Mineral Fork is a part of the Inventoried Roadless Area. Yet the Forest Service is proposing to allow motorcycles and ATV's continued use of that canyon. Motorized recreation has no place in roadless areas. Motorized recreation has no place on watershed lands. Mineral Fork is both. Summer motorized recreation must be prohibited in this canyon.

The Preferred Alternative states that maintaining inventoried roadless areas as undeveloped will ensure biodiversity and species viability. (DEIS p. 2-38) Motorized use of the backcountry is the fastest way to "develop" for human use a previously healthy wildland setting. Motorized recreation requires little physical effort, so it is capable of bringing many people very quickly onto a landscape. The noise and pollution of motorized recreation disturbs wildlife. Wildlife hides and, in time, wildlife leaves. The natural vegetation of the land is destroyed. When man brings his machines into an area, he dominates that land. It belongs to him and becomes lost to wildlife.

The DEIS says that changes to summer Travel Management maps will not be considered within the Proposed Forest Plan. (DEIS p. 2-44) Certainly in the case of Mineral Fork, the designation must be changed to protect the watershed, and it must be changed to be in compliance with the roadless rule. If the Forest Service can change winter Travel Management maps within the framework of the Forest Plan, then it can certainly change summer maps.

Mineral Fork is a beautiful area that borders on existing wilderness. It is home to deer, elk, moose, fox, coyote, cougar, and bobcat and many fragile alpine species of plants. Mineral Fork contains the most frequently used nest of the Big Cottonwood golden eagles whose sustainability is threatened by such backcountry motorized recreation as the ski helicopter, the ATV, and the motorcycle. Mineral Fork must be given the recognition that the roadless designation implies.

PEER REVIEW OF SCIENTIFIC AND TECHNICAL DOCUMENTS

For example, in 1998, the WCNF contracted the Governor's Office of Planning and Budget to produce forecasts of skier visitation to Utah resorts. The resultant GOPB analysis was fatally flawed on numerous independent grounds, as documented in comments submitted by SOC and SOC members to the WCNF during the Solitude Master Development Plan DEIS public comment period. Those comments are incorporated here by reference. If the GOPB analysis had been submitted to peer review in 1998, it would have been rejected or repaired, and several subsequent decisions that used it would have been based on information instead of imagination. Any further use of the GOPB skier visitation forecasts in EISs will be challenged in court. The fact that these ten-year forecasts are five years out of date is sufficient cause: "Reliance on stale scientific evidence is sufficient to require re-examination of an EIS." City of Carmel-By-The-Sea v. U.S. Department of Transportation, 95 F.2d 892, 900 (9th Cir. 1996).

WILDERNESS

"A Wilderness, in contrast with those areas where man and his works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain."

In describing its goals for wilderness management, the Forest Service writes:

"The long-term goal is to maintain wilderness, where ecosystems are primarily influenced by the forces of nature, provide a diversity of opportunities for public use, enjoyment and understanding of wilderness, and preserve a high quality wilderness resource for present and future generations . . . Since the Wilderness Act became law, millions of people have visited designated Wilderness for solitude, recreation, spiritual enhancement, and natural appreciation . . . Wilderness is important as a sanctuary for undisturbed ecosystems, for maintenance of species diversity, protection of threatened and endangered species, as well as non-endangered plants and animals, protection of watersheds and clean water, protection of airsheds and clean air." (DEIS, p. 3-234)

Alternative #6, the Forest Service Preferred Alternative, fortunately turns away from the outdated 1985 Forest Management emphasis on commodity outputs, on harvesting the resources of the National Forest for human consumption. The Preferred Alternative attempts to embrace, at least in its rhetoric, the very ideals that created the Wilderness Act. The Preferred Alternative emphasizes biodiversity, conservation of large roadless areas, terrestrial and aquatic restoration, limitation of human use where restoration and protection of properly functioning ecosystems are needed, and dedication to other important wildland values such as watershed functioning, ecological reserves, biodiversity corridors, and opportunities for solitude. (DEIS, p. S-7/8)

Therefore, it is a major disappointment to discover that this Alternative, which recognizes 600,000 roadless acres within the Wasatch-Cache National Forest, recommends that only 70,000 acres of that area be designated as wilderness additions. That figure represents only 12% of the roadless areas. The disappointment deepens when we learn that within the tri-canyon area, where wilderness is needed most, the Preferred Alternative gives no new wilderness designations at all.

The tri-canyon area is the most immediately threatened area of the National Forest. The ultimate way to protect watershed, to ensure healthy aquatic and terrestrial habitat, to restore and protect the natural beauty of the land is to designate that land as wilderness.

Why is the Forest Service so reluctant to propose that priceless roadless, watershed, wild land be recommended as wilderness? SOC has asked that question of many Forest Service employees. The most frequent answer is that wilderness designation makes it difficult for the Forest Service to manage the land adequately. One often-cited example is that because motorized equipment cannot be used within a wilderness area (such as power saws to clear downed trees over a trail), trail maintenance becomes difficult. Another example is that fire management cannot easily be done in wilderness areas.

Evaluation of potential Wilderness for Roadless Areas is based on three primary criteria, which are outlined in the Forest Service Handbook 1909.12,7. The criteria are lumped under the titles "Capability," "Avail-ability," and "Need." In the tri-canyon area of the Wasatch-Cache National Forest five prospective wilderness additions are analyzed: Lone Peak, Twin Peaks, Mount Olympus, White Pine, and Mount Aire.

On examining Appendix C, an interesting pattern in the analysis emerges. Leaving aside the Lone Peak additions numbered # 0419027, the other proposed additions are judged to satisfy the requirements of Availability, Capability, and Need in all but two aspects. These two stumbling blocks are essentially the same in each of the Twin Peaks, Mt. Olympus, White Pine, and Mt. Aire pro-posed additions. They are:

1.Under the Capability criterion, we find mention of the sights and sounds of nearby urban areas or highways as factors that presumably might disqualify the area for Wilderness status.

2.In each of these cases, under the Availability criterion, permitted helicopter skiing is mentioned. In some of the proposed additions there is also mention of proposed ski resort expansion into the areas under consideration

Except for these factors, the proposed additions are judged to fulfill all the criteria for wilderness status. As a result, the fact that in the Preferred Alternative 6 there is no recommended wilderness for the tri-canyons area comes as a startling non sequitur. Why, indeed, is there no recommended wilderness on the roadless areas of the tri-canyon area?

The "sights and sounds" argument against wilderness classification in the tri-canyon area has been around at least since the early 1970's when it was used in the case of the original Lone Peak Wilderness discussion. That the argument is irrelevant is clear from the fact that Congress chose to create the Lone Peak, Twin Peaks, and Mt. Olympus Wilderness areas, thereby dismissing it. Besides, the proposed additions are farther from metropolitan sights and sounds than existing Wilderness.

Whether or not to issue permits for helicopter skiing is the responsibility of the Forest Service. In Appendix C, the only impediment to fulfillment of wilderness criteria in the four proposed additions under discussion appears to be the helicopter skiing permits. The Forest Service has the power to emphasize watershed and habitat preservation and the values of solitude and serenity included in the desirable goals of both the 1964 Wilderness Act and the Forest Service Handbook.

In the Forest Service Handbook 1909.12,7 in subsection 3 under ô7.21 one finds the following:

Outdoor Recreation Opportunities. Determine an area's capability of providing primitive and unconfined types of recreation such as camping, hunting, fishing, mountain climbing, ski touring, canoeing, boating, river rafting, backpacking, hiking, riding, photography, and other outdoor activities.

The absence of helicopter skiing from this list is notable and appropriate. Save Our Canyons has long opposed helicopter skiing in the heavily used tri-canyon area and favored extending wilderness areas. We favor the extension of the wilderness areas because of the resultant secure protection of watershed and habitat.

The presumption that Congressional action on wilderness is (at the moment) unlikely is irrelevant to the recommendations of the Forest Plan or the position taken by Save Our Canyons. The Forest Plan is to be in force for some fifteen years, not just for the duration of the current administration or term of office of Forest Administrators. Save Our Canyons' interests will continue long beyond the fifteen-year horizon and so will the Forest Service's responsibilities to protect the public resources under their supervision.

SOC has developed a Wilderness Proposal for the tri-canyons. It includes most of the inventoried roadless areas within the three canyons, encompassing the Salt Lake City watershed wilderness and stretches north and east of that area to include an extension of the land in the tri-canyons that continues to retain its natural and beautiful forest character.

Brief descriptions of the four areas of the SOC Wilderness Plan are as follows, from north to south. Use this description in conjunction with the SOC Wilderness Proposal Map submitted in 1/00.

1. Mt. Aire Wilderness Addition: This area includes the inventoried roadless land that lies between Millcreek Canyon on the south and Parleys Canyon and the Lambs Canyon Road on the north. Grandeur Peak and Mt. Aire are within this area. Certain trails, such as the Pipeline Trail and the Big Water Trail are not included in the proposed wilderness so that they may continue to be used as popular mountain biking trails. SOC proposes that the southern boundary of this wilderness addition be the Pipeline Trail, not the Millcreek road, for that reason.

The Mt. Aire drainage is not currently tri-canyon watershed. But the SLCDPU emphasizes that population growth may soon force the city to include this area in the Salt Lake City Watershed Plan. Future Forest Service planning should take this into account.

The area between Elbow Fork and Lambs Canyon in Millcreek is currently part of the Parleys Canyon watershed, which, after Big and Little Cottonwood watersheds, supplies Salt Lake City's third largest water yield. SLCDPU stresses the need to protect the integrity of all the city's watersheds, not just those of Big and Little Cottonwood Canyons. Consequently, the Mt. Aire Wilderness Addition becomes important in its buffer position between the tri-canyon watersheds and the Parleys Canyon watershed.

The Mt. Aire Wilderness Addition is one of the favorite hiking, camping and picnicking areas within the tri-canyons. Designating this land as a 1.3 Wilderness Area (#3 Opportunity Wilderness Class) would stress its importance as part of the threatened tri-canyon area. Opportunity Class 3 "is characterized by predominantly unmodified natural environment but impacts might persist from year to year. During peak season and in popular areas concentrated use is more common and opportunities for solitude and unconfined recreation more limited." (Appendices, p. D1-4)

In the southeast corner of the Mt. Aire Addition, there is a piece of private land, which provides an important corridor for wildlife between the Mt. Aire and the Mt. Olympus Wilderness Additions that is already owned by SLC and managed similar to wilderness

2. Mt. Olympus Wilderness Addition:

The main part of this proposed wilderness is one continuous piece of land but can most easily be described by dividing it into two portions: The first portion includes all the land north and east of Mt. Raymond and Gobbler's Knob that for political reasons was omitted from the Mt. Olympus Wilderness Area when it was established as wilderness in 1984. This land, which includes the beautiful areas of Bakers Spring, Alexander Basin, Wilson, and Soldier Fork, appears as an open wound in the existing wilderness, a gash that cries for healing. This land was not designated as wilderness originally because of the desire of a powerful few to use the land for helicopter skiing. SOC urges the Forest Service, once again, to consider the threat of human overuse in the tri-canyons in regard to any motorized recreation. It is exactly impacts of this kind that SOC is urging the Forest Service to actively disallow in the Forest Plan Revisions.

The second portion of the Mt. Olympus Wilderness Addition lies to the east and south of Big Water Trail. In deference to the mountain bikers who use Millcreek Canyon extensively, SOC proposes that certain trails such as the Big Water Trail not be included in the proposed wilderness. Bikers would also have access to the Great Western Trail, which forms the northern and eastern boundaries of this portion of the Mt. Olympus Wilderness Addition. The southern boundary is Big Cottonwood Highway or the private land that borders the highway. Landmarks included in this portion of the Mt. Olympus Wilderness Addition are the Reynolds Gulch area adjacent to and east of the existing wilderness, Dog Lake and the Mill D Trail to Dog Lake, the Desolation Lake area including the section of Desolation Trail between Dog Lake and Desolation Lake, the areas of Little Water Peak and Powder Park that lie south and west of the Great Western Trail, Beartrap Fork, Mule Hollow, and the public lands of the Willow Lake and Mill F areas.

This land is inventoried roadless land. It is (with the exception of Little Water Peak and Powder Park) a vital part of the Salt Lake City watershed. This land has retained its wild and natural character. It is home to a wide variety of wildland vegetation and animals. The threatened Wasatch Shooting Star (Dodecatheon dentatum var. wasatchensis) grows in the naturally occurring riparian areas of this land. A pair of Big Cottonwood golden eagles uses this north side of Big Cottonwood Canyon extensively as foraging territory. This land deserves wilderness designation.

There are two corrections in the boundaries of the existing wilderness that need to be made to properly complete the Mt. Olympus Wilderness Area. One is in the Porter Fork area and various places along the Big Cottonwood Highway. When the existing wilderness was created, unnecessarily wide buffers were placed around human developments. Boundaries should be tightened in these areas to include all portions of the roadless areas with current wilderness setbacks used around major roads.

The second consideration is the inclusion of Neff's Canyon in the Mt. Olympus Wilderness Area. Water tanks and other major impacts will remain outside the wilderness area. This designation will ensure long-term protection for this piece of National Forest that is especially vulnerable to human overuse because of its location just beyond the houses on Salt Lake City's east bench.

3. Twin Peaks Wilderness Addition: This area includes Mineral Fork on the west, the upper section of Cardiff Fork, Reed and Benson Ridge, Days Fork, and ends with Silver Fork on the east. It does not include the lower section of Cardiff Fork.

The area within this Wilderness Addition is Inventoried Roadless Area and deserves wilderness designation. It is an area that is extremely precious to backcountry hikers and skiers because it contains some of the most beautiful wildland in the Wasatch Mountains. It is habitat for a multiplicity of birds and animals. A hike into the backcountry of these side canyons of Big Cottonwood Canyon may produce sightings of deer, moose, fox, and coyote. Evidence of resident cougar and bobcat are present. A SOC observer identified an immature goshawk this summer (2001) in Days Fork near an area that several years ago had a resident pair of goshawks.

The Twin Peaks Wilderness Addition recommended by SOC is the nesting territory for the pair of golden eagles that inhabit Big Cottonwood Canyon. The six main nests of that pair of goldens lie within the Twin Peaks Wilderness Addition. It is suspected that ski helicopter activity there is causing the gradual decline of golden eagle nesting success. On April 1, 1995, and again on April 11, the helicopter was observed repeatedly flying too close to the nest cliff for the nesting eagle to remain on the nest. In each case, the nesting eagle abandoned the nest. The observer recorded that after the second incident the eagle failed to return to the nest. Consequently, there was no successful nesting in 1995. Nor was there successful nesting in 1996, 1997, 1998, or 1999. In 2000, the Big Cottonwood golden eagles nested successfully and raised a healthy fledgling. It is important to note that the spring of 2000 was very warm. The snowmelt was rapid with few heavy snowfalls in late March and early April, a condition that precluded ski helicopter activity in the lower canyon containing the successful nest. For reasons such as this, for continued viability of species, SOC's Proposed Twin Peaks Wilderness Addition should be added to the existing Twin Peaks Wilderness.

As in the Mt. Olympus Wilderness proposal, boundaries should be extended to include the entire roadless area and to utilize current setback measurements from roads. In addition, SOC urges the Forest Service to include the National Forest lands of the Deaf Smith Canyon area west of the existing Twin Peaks Wilderness. This wildland is home to forest wildlife. A pair of golden eagles maintains one of its nests in Deaf Smith Canyon. The North Fork of this wild area contains one of the largest limber pine trees in the Wasatch.

There is one reason that overshadows all others for giving wilderness designation to SOC's Twin Peaks Addition. In fact, it is a reason of such importance that the Forest Service can hardly do otherwise. This reason extends as well to SOC's Lone Peak Addition, Twin Peaks and to a large section of SOC's Mt. Olympus Addition. These proposed additions are the vital watershed areas of the tri-canyons. Previously in our response, we discussed the absolute necessity of providing meaningful protection for the Salt Lake Valley watersheds within the framework of the Wasatch-Cache National Forest Plan Revisions. If the Forest Service ignores the strong probability of water quality degradation due to human overuse of the tri-canyon area, the consequences will be disastrous for a huge and growing metropolis.

4. Lone Peak Wilderness Addition: This area includes White Pine and Scotties Bowl. It is a natural extension of the existing Lone Peak Wilderness since it is an area of unusual beauty and a prime wildlife habitat and is directly adjacent to the existing Lone Peak Wilderness. The Lone Peak Wilderness Addition is the entire strip of land that lies between existing wilderness and a ski resort. The Preferred Alternative supports no expansion of ski resort boundaries. Consequently the logical management prescription for this piece of land is 1.5, Recommended Wilderness. SOC has decided to pull its boundary back to the Temple Quarry trail so that it can remain open to biking.

The Uinta National Forest joins the Wasatch-Cache National Forest to the south. Both Forests are writing their Forest Plan Revisions at this time. The Preferred Alternative of the Uinta National Forest Plan proposes to designate as wilderness the piece of land directly southeast of, and adjacent to, SOC's Lone Peak Wilderness Addition. The cooperation of the Wasatch-Cache with the Uinta Forest in designating these two pieces of land as 1.5 will round out the entire Lone Peak Wilderness in a logical and appropriate way.

User education concerning wilderness will be an important component of the tri-canyon wilderness designations. Canyon users are often careless out of ignorance. Natural wildland vegetation and animals most often suffer because people do not realize that this land, although it belongs to everyone, is not their home. It is home to wildlife. It can easily be destroyed if humans do not come quietly, with respect, and in small numbers. When, in spite of wilderness designation, people come on the land with their machines, vegetation is trampled and destroyed by the heaviness and the pollution of the machines. Noise pollution and the frantic movements of a machine cause wild animals to escape into hiding. Their lives are disrupted and in time they leave the area.

The natural world of the tri-canyons is generally kind to human beings; it welcomes us if we are careful not to disturb the world in which we trespass. The spiritual value, the health of the human mind, involved in connecting with that natural world is becoming more and more important as open space shrinks and urban areas grow. A wilderness that includes most of the tri-canyons presents the Forest Service with a unique opportunity to educate a public that is increasingly urban. The public school system is the logical place to focus that education. When children are taught how to go into the mountains, they quickly learn a guardianship of the land and feel the importance of their connection with it. Having a large and unique wilderness in their backyard will provide a natural laboratory for learning. It will instill generations of Wasatch Front residents with the ability and desire to care for the world's remaining natural lands.

SOC applauds the vision encompassed in the philosophy of the Preferred Alternative. However, this philosophy needs to be backed be action. SOC strongly urges the Forest Service to accept the SOC Wilderness Proposal.

NON-WILDERNESS LAND DESIGNATION

The following Management Prescriptions should be given to the remaining land within the tri-canyon area:

4.5 - Developed Recreation Areas: 1. The area within the existing SUP boundaries of the four ski resorts (Solitude, Brighton, Snowbird, Alta). 2. Developed picnic grounds, trailhead parking lots, and campgrounds along the major roadways if these facilities are now in existence and if they are not inventoried roadless areas. SOC agrees with the Forest Service that it may be "appropriate to harden these highly used sites to reduce biophysical impacts and keep people where this mitigation is provided". (DEIS p. 2-46) Hardening these sites in specific ways may help protect the watershed.

With the exception of a few roadless areas occurring beside major roads - narrow strips of land that need inclusion in the proposed wilderness - the Preferred Alternative and SOC are in agreement on the 4.5 land designation.

4.1 - Backcountry Non-motorized Recreation: 1. The Pipeline Trail, Big Water Trail, the Great Western Trail and the Temple Quarry Trail are not included in SOC's proposed Mt. Aire Wilderness Addition in order to accommodate mountain bikers who have historically used these trails extensively.

2. The lower portion of Cardiff Fork in Big Cottonwood Canyon is already designated as Backcountry Non-motorized in the Preferred Alternative.

The 4.2 designation - Dispersed Non-motorized Recreation - cannot be used because the future intent of the 4.2 designation is not clear and lacks specificity. For example, the description of the 4.2 designation includes this phrase: "travel within the area is generally non-motorized". (Appendices, p. D1-9). It is conceivable, therefore, that at some future time, motorized recreation could be introduced.

2.6 - Undeveloped Areas: 1. The public land between the Brighton and Alta Ski Resorts, and all Roadless Areas outside of 1.5 designations.

RESIDENTIAL/COMMERCIAL DEVELOPMENT

SOC commends efforts of the SLCDPU to purchase private lands within the tri-canyons and turn these lands into undeveloped watershed areas. SOC hopes that the SLCDPU will continue these efforts with successful results. Curbing any further commercial or residential development in the tri-canyons will help alleviate the problem of human overuse. SOC joins the SLCDPU in opposing any further residential/ commercial development in the tri-canyons, which would inevitably cause new, additional uses of the Forest, exacerbating the problem of human overuse. SOC urges the Forest Service to write the following directives into the new Forest Plan:

1.The Forest Service will continue to consider for approval modifications within existing developments such as ski resorts, but it will not approve any new use or change to facilities whose purpose is to attract more people to the canyons.

2. The Forest Service recognizes the shortage of water available for tri-canyon development and supports the SLCDPU's strict control of all water within the area. The Forest Service will not allow any public lands in the tri-canyons to be used for the importation of water from a source outside the Salt Lake City Water District. No trespass of public lands by ditches, pipelines, or any other water-carrying method will be allowed for the purpose of importing water from an outside source to enhance private land for development.

3.The Forest Service will approve no new land exchanges within the tri-canyons that would create developable private property from what is now National Forest land. This protection will ensure that no land exchange such as the one involving Mineral Basin will again take place.

It will also ensure that private development in the foothills of the tri-canyons will at last be contained since no exchanges of public for private property will be allowed. Strict foothill watershed protection is vital in light of the recent groundwater studies showing the importance of the lower canyons on groundwater recharge. Winter range for wildlife is threatened due to housing developments moving inexorably upward in the foothills. To ensure the protection of the remaining winter range and the protection of valuable watershed, no new land exchanges will be allowed in any area of the tri-canyons.

RECREATION

1. Ski Resort Recreation: The Preferred Alternative allows no expansion of ski resorts beyond their existing boundaries. SOC applauds the Forest Service for proposing to include this necessary regulation in the new Forest Plan.

Unfortunately, "Expansion beyond existing boundaries" is being allowed to take new paths. SOC urges that these activities not be allowed. For example, the Forest Plan should explicitly prohibit:

a.Concerts whose noise pollution goes beyond resort boundaries, buildings on ridgelines that affect the visual quality of the Forest beyond resort boundaries, nighttime lighting that intrudes upon lands beyond resort boundaries.

b.Resort-sponsored activities that lead visitors beyond ski boundaries, such as paragliding or new hiking/biking trails, or any outfitter guide services.

c. Avalanche control outside of ski resort boundaries and traffic corridors.

Nowhere in the proposed Forest Plan document is there reference to any local government planning and zoning regulations, the Wasatch Canyons Master Plan or the Foothills and Canyons Overlay Zone. It is vital that the Forest Plan include wording similar to that suggested below within the Recreation Desired Future Conditions for the tri-canyon management area (4-99) and within the Forestwide Subgoals-Recreation, page 4-16:

"Forest management guidance is also provided by county and city planning and zoning regulations. Although not legally bound to adhere to these planning and zoning codes, the WCNF will always conduct its management of the forest in a manner that is compatible with the word and intent of such city and county zoning regulations."

The language on page 4-28, Guidelines for Recreation Development, needs to be tightened substantially to read:

"(G40) Develop facilities based only upon evidence that all the following criteria is met:

a.Will meet a previously demonstrated proven public demand. b.Will serve to reduce concentration at existing sites. c.Will reduce resource impacts from recreation use and existing developments. d.Will reduce currently existing negative watershed impacts e.Will be consistent with forest-wide goals. f.Will be non-urbanized, natural resource-based. g.Will be compatible with a natural appearing forest and rangeland setting. h.Will require no additional specialized facilities. i.Will not serve to draw additional users to the forest."

The wording on page 4-16 currently reads as: "Encourage private enterprise to develop recreational facilities on and off the Forest that provide for a range of recreation opportunities (e.g. camping, and picnicking areas, trailheads and interpretative sites." This recommendations should be dropped.

Guideline 52 on page 4-30 should be elevated to that of a standard and the wording be revised as follows:

"Resource management activities will not be permitted to reduce Scenic Integrity below the objectives stated for the Management Prescription Categories."

The definition of what constitutes "New Recreation Development" (page 4-39) is not specific enough. This definition needs to be amended to the following or similar wording:

"New Recreation Development refers exclusively to major structural public use facilities such as campgrounds and trailheads. Recreation facilities commonly situated in urban environments, such as, but not limited to, tennis courts, swimming pools, slides, amphitheaters, and ice-skating rinks are not considered recreation development within this description. Trails and single restrooms are also not considered recreation development within this description."

On page 4-48, Developed Recreation Areas, the second to last paragraph needs to be tightened in order to avoid the construction of facilities designed to meet an unproven future demand or that is designed to increase patronage at the expense of another ski resort in the currently existing static, no-growth ski industry.

On page 4-99, "Recreation Desired Future Conditions," the wording shown under "Recreation activities and developments within ski resorts" needs to be substantially changed to read:

"The ski resorts in Big and Little Cottonwood Canyons will continue to provide skiing and snowboarding facilities in the winter and other outdoor recreational activities during other seasons that meet the test of being non-urbanized, natural resource-based, compatible with a natural appearing forest and rangeland setting, do not require additional specialized facilities, do not serve to attract additional people to Big and Little Cottonwood Canyons, and meet the test of filling a proven public demand not satisfied elsewhere."

The balance of the language found on this page needs to be tightened substantially. The current wording provides carte blanche to ski resort operators to do almost anything they desire. The following wording is warranted:

"Land and facilities within ski area permit boundaries will be managed with strict emphasis on skiing and snowboarding, while providing summer recreational opportunities that satisfy the requirements listed above?. New resort development will be confined (strike 'generally') to the permit boundaries in effect at the time of revision?within the limitations and capabilities of the natural environment and current (year 2000) transportation infrastructure." Further wording changes: "Development will be designed with a high level of attention to scenic integrity. Facilities and infrastructure will be designed and constructed to harmonize with the natural setting, with strict adherence to the Salt Lake County Foothills & Canyons Overlay Zone, underlying Salt Lake County ordinances and Salt Lake County Canyons Master Plan."

On page 4-100, "Recreation Special Uses," the current wording reads as: "No new major events will be authorized (events involving more than 100 people), except those occurring within ski resort permit boundaries, authorized under the resorts' Special Use Permits and identified in the resorts' operating plans." This would include Eco Challenge type events. This wording needs to be tightened to not only include the number of participants but also include the type of event that will and will not be permitted. For example, mountain bike races that have a negative impact on the natural environment. The Forest Plan should explicitly prohibit any event that allows substantial light or sound pollution to escape from the immediately affected area. This wording should be changed to read as follows:

"No new major events will be authorized (events involving more than 100 participants and spectators combined) except those occurring within the ski resort permit boundaries, authorized under the resorts' Special Use Permits, identified in the resorts' operating plans and meet the test of not resulting in substantial noise, light or other pollution escaping the special use permit boundaries, nor events that lead participants beyond special use permit boundaries. Environmental impact statements, including TES studies for plants and animals that may be affected in the areas surrounding these events, are required."

Issue #4 on page 3-4 states that ski area boundary expansions are not allowed nor are new ski areas. Where is this management direction stated as a standard? The Forest Plan needs a specific standard, on a Forest-wide basis that reads as follows:

"Ski and snowboard area boundary expansions are not allowed nor are new ski or snowboard areas." This management direction must be a standard, not a goal or a desired future condition.

The wording on page 4-96, Roads/Trails/Access Desired Future Conditions, for the tri-canyon area needs to be changed to that of a standard and be amended to read as:

"Parking capacities of canyon parking lots (ski area, developed and dispersed recreation sites will not exceed (instead of `being maintained at') currently existing 2000 levels unless modification is needed for watershed protection or to facilitate mass transit."

2. Dispersed and Backcountry Recreation: Dispersed and backcountry recreation is a challenging problem facing the Forest Service as they attempt to formulate meaningful policy for the threatened tri-canyon area. Hikers, bikers, ski tourers, snow-shoers, mountaineer skiers, backcountry snowboarders, fishermen, picnickers, campers, snowmobilers, ATV enthusiasts, sightseers, solitude seekers - all add to the ever-increasing problem of dispersed and backcountry recreation in an area that can support little more. What are the solutions?

Some measures can be taken to help alleviate the problem. A few of these are:

a.Harden the sites along the major roads that are picnic areas, trailhead parking lots, and campgrounds in a way that would best protect the watershed and prevent adverse human impacts on the natural setting.

b.Monitor snowmobile use of public lands carefully and issue citations to violators. Snowmobile recreation is not allowed on public land in the tri-canyons, but snowmobiles are present in such areas because property owners are allowed to use snowmobiles to access their property from the road. Illegal snowmobile recreation is an increasing problem in the Cardiff Fork area because of the large amount of private land there. Effective monitoring of snowmobile use on the public land surrounding these private holdings may help to solve the problem.

c.Adopt the SOC's Wilderness Proposal. Designate the Inventoried Roadless Areas of the tri-canyons as wilderness. Historically, wilderness designation has allowed the Forest Service to set certain limits on the size and activities of groups going into the area. This precedent would be followed in controlling backcountry use of the tri-canyon wilderness. User education at access points and trailheads would be extensive. wilderness monitoring plans would be formulated and implemented.

By designating Mineral Fork as wilderness, the problem of adverse impacts to the environment and to the watershed by summer motorized recreation would be solved in the tri- canyons, since Mineral Fork is the only tri-canyon area that allows summer motorized recreation. A few ATV's are capable of destroying a natural ecosystem quickly as witnessed last summer by a SOC observer in Mineral Fork on August 12, 2000. Three ATV users were competing to see who could climb a steep slope of public land off the trail shortly above the stream crossing. The winner of each round got a can of beer. The activity destroyed the vegetation on the hillside.

Adopting SOC's Wilderness Proposal would protect the tri- canyon airshed. The ski helicopter is one of the most intrusive forms of motorized recreation, impacting wild backcountry ecosystems more than is commonly acknowledged. Natural healthy wild ecosystems consist not only of viable populations of land and water animals, but also of birds. Traditionally, the tri- canyons were home to goshawk, peregrine falcons, and golden eagles. These species appear to be leaving the area. Undoubtedly, the relentless invasion of airspace in the backcountry forks of the tri-canyons by the ski helicopter is a primary reason for the apparent disappearance of these species. No studies have been done on ski helicopters and their effect on these birds, but observations indicate that the adverse impact is significant. Earlier in this response we mentioned that an observer witnessed nesting interference of the Big Cottonwood golden eagles by ski helicopter activity in 1995. Careful observation of ski helicopter/eagle interaction in subsequent years leads this observer to believe that the helicopter is instrumental in the frequent nesting failure of this pair of birds in spite of half-mile buffer zones placed around the nests. The golden eagle is protected by the Bald and Golden Eagle Act of 1940, and therefore must be provided adequate protection against human harassment. Birds of prey are an important indicator of the health of a wildland ecosystem. Protection of these lands from all forms of motorized recreation will be accomplished through adoption of the SOC's Wilderness Proposal. Since the ski helicopter company operates under a special use permit, SOC urges allowing the operation to continue until the current permit expires in 2004 but not thereafter.

d.The use of non-motorized contrivances needs to be addressed in the Forest Plan. Many of these new hybrid devices were exhibited at recent Outdoor Retailer Shows in Salt Lake City. They look like skate boards, surfboards, snowboards or skates but with wheels attached. These devices are capable of going down mountain trails as well as off trail. They could easily rut mountains, degrade watersheds and disturb wildlife. Any wheeled, non-motorized devices except bicycles (where permitted) and wheelchairs should be prohibited.

e.Rock climbing creates Forest management challenges. The Forest Plan needs standards and guidelines to provide adequate management direction. For example, the Plan needs to give management guidance to the current and proposed parking areas that remove wildlife habitat and bring more people to the area. Climbing should be disallowed that will either intentionally or unintentionally remove a significant amount of vegetation. Climbers sometimes trim scrubby areas and mossy walls or are sometimes destroyed by the presence of climbers. The Salt Lake Slips area of Big Cottonwood Canyon was once entirely moss covered before climbers scrubbed it bare with wire brushes. The Forest Plan should specifically prohibit this kind of activity.

f. Begin studies now within the new Forest Plan on ways to solve the problem of human overuse in the tri-canyons. The SLCDPU is willing to be involved in studies that will help to solve the problem of saving the watershed in the face of uncontrollable population growth. Authorizing studies on ways to control highway traffic and backcountry use are absolutely essential within the new Forest Plan. If studies are begun now, solutions could be implemented within ten years.

g. The Forest plan does not sufficiently analyze the rise of extreme sports on the Forest such as base or bungee jumping, nor does it analyze hang gliding or para-gliding. These activities have negative impacts on plants, animals and environment and should be prohibited. At a minimum these activities should be anticipated and guidelines put in place to mitigate and monitor the impacts. Scenic commercial aircraft overflights should be prohibited.

The Forest Service points out that studies of this kind are expensive. How much is protection of our priceless watershed worth? How important is it to keep this still-viable, deeply loved part of the National Forest from certain destruction due to human overuse? The SLCDPU is willing to cooperate closely with the Forest Service. The tri-canyon problem is of such importance that federal funding to begin serious studies should be requested.

3. Motorized Recreation

The Preferred Alternative states that maintaining inventoried roadless areas as undeveloped will ensure biodiversity and species viability (DEIS p. 2-38). Motorized use of the backcountry is the fastest way to "develop" a previously healthy wildland setting for human use. Motorized recreation requires little physical effort, but allows individuals to cover far more terrain than they would otherwise. Simultaneously, over that larger area, ORV users inflict more damage, pollution and noise to the ground, air and water, and over a larger area around the individual, than any non-motorized recreationist could. The noise and pollution of motorized recreation disturbs wildlife. Wildlife hides and, in time, wildlife leaves. The natural vegetation of the land is destroyed. When man brings his machines into an area, he dominates that land. It belongs to him and becomes lost to wildlife.

That land is also lost to people seeking a quiet walk in a natural setting. On a fine-weather weekend, summer or winter, a stroll up any of the popular trails in the Wasatch will show that casual walkers or snowshoers who never venture more than a half-mile from trailheads outnumber all other users by several-fold. Some are not physically prepared for a hard hike, due to age, infirmity, lack of acclimatization or exercise; others are not experienced enough to go further, especially in winter; some are taking their young children or babies with them; others are simply not interested in climbing 3,000 feet up a rugged trail. It may be safely assumed, however, that all of them seek to enjoy a quiet walk in the clean air of their National Forest, away from the noise, pollution and business of the surrounding cities. Even a rude hiker, trail-runner or mountain biker can significantly reduce the quality of that experience. An ORV user can shatter it. Other recreationists in the vicinity of an ORV user are forced to tolerate more noise and worse pollution than is allowed on the city streets that they came to the Forest to get away from.

Naturally, non-motorized recreationists try very hard to avoid areas where motorized recreation is allowed. Their first encounter with an ORV user in a given area will usually be their last visit to that area. In effect, areas that are used by motorized recreationists are treated as "Closed to hikers." The injustice of permitting a small, disproportionately destructive user group to displace all others where it is permitted at all is self-evident. However, this displacement effect has other damaging consequences for the Forest and the public.

The casual non-motorized recreationists described above need gradual, open trails, preferably ones that reach an open stopping point less than a mile from the trailhead. Because of the ruggedness of the Wasatch range, there are few such areas and trails, and the areas that fit that description are often roaded. They are also, by definition, within a mile of a highway. Therefore, they are often allocated to motorized recreation. For example, the Guardsman's Pass road and surrounding area in winter are one of the few areas in the upper Wasatch near Salt Lake City where a novice cross country skier might find terrain that is gradual, open, and accessible enough for them. However, since the entire area is used by snowmobiles, only more skilled skiers venture there, since they can avoid snowmobiles by skiing the steeper forested slopes above. The same problem affects the upper end of Farmington Creek, which is designated 4.4 (dispersed motorized) in the Preferred Alternative. These examples illustrate the general tendency of the Preferred Alternative to allocate easily accessible areas to motorized recreation. As a result of this tendency, the Preferred Alternative surrounds scenic roads throughout the WCNF with areas allocated to motorized recreation. In effect, the highway environment that the casual hiker sought to escape has been extended into the natural areas, and now he must hike through this buffer zone as well to reach his goal. Even if these hurdles do not discourage him immediately, he may be disinclined to visit the Forest again. Should the WCNF effectively deter enjoyment of the Forest edges by the elderly, the inexperienced, by tourists unfamiliar with the area and not acclimatized to its altitude, or by families with young children? If the few areas that these people can reach and use are allocated to motorized recreation, they will be shut out of their Forest.

The displacing effect of motorized recreation has a different result for more experienced non-motorized recreationists, who are even more averse to motorized recreation. For example, the portion of the upper tri-canyon area that has not been developed into ski resorts contains some of the best backcountry skiing within a few hours' driving distance of Salt Lake City. It is also readily accessible by non-motorized recreationists. However, it is heavily used by the helicopter skiing concession. As a result, many backcountry skiers look for a more natural backcountry experience in other parts of the Wasatch, so they penetrate deeper and more frequently into the Wilderness areas than they otherwise would. This example illustrates how motorized recreation, by its strong displacement effect on non-motorized users, causes increased impacts even on Wilderness areas. Naturally, the same mechanism acts in summer. Hikers learn to drive to the very end of every road-like trail before beginning their hike, and therefore reach deeper into previously unused areas. Hikers who do not will breathe the dust of ORV users passing them on the trail.

The WCNF may not be able or willing to directly control the distribution of non-motorized recreationists on the Forest. However, reducing the amount of motorized recreation in accessible areas would greatly increase the number of users those areas can handle. This would reduce the number of recreationists that more remote and pristine areas would suffer. Encouraging motorized use - as the proposed Forest Plan does - will reduce the capacity of accessible areas to accommodate human-powered users, and cause many of them to expand their usage into previously unused areas. The proposed Forest Plan will therefore result in more widespread impacts on natural resources than the SOC Alternative. Thus, decisions made by the WCNF will strongly affect the distribution of non-motorized recreationists, whether this is acknowledged or not.

It must be pointed out that the expected distributions of various user groups can be modeled in the same way that distributions of endangered species and their reactions to encroachment have been modeled for decades. There is no justification for the claim that the problem is too complicated or indefinable to study. It is also worth noting that, unlike humans, displaced wildlife does not simply move to another area: if suitable habitat exists nearby, it will already be occupied, and the displaced animal will have to compete with resident animals. Regardless of which animal wins the competition, one will die. If an animal is displaced, it means that its habitat has been rendered unsuitable, and the population size will therefore decrease, making it more vulnerable to permanent extinction.

The effect of motorized recreation must also be considered at the ecosystem-wide level over time periods exceeding the life of a Forest Plan. The WCNF has enjoyed the luxury of being surrounded by undeveloped private land, which buttressed many of the wildlife populations in the WCNF (see "fragmentation of wildlife habitats," below). This luxury is rapidly disappearing, and within a few decades, the WCNF may be an island in a suburban sea. If the WCNF itself remains fragmented by developed areas and regions devoted to motorized recreation, it stands to lose all its sensitive wildlife populations. The Forest Service cannot alter the course of development outside its boundaries, but that course is predictable, and the Forest Service is required to consider its effects. Recommending more wilderness areas would consolidate and strengthen the WCNF against this impending loss.

ECOSYSTEM MANAGEMENT AND BIODIVERSITY

FRAGMENTATION OF WILDLIFE HABITATS

The PRLRMP and DEIS fail to adequately disclose to the public the difference between a naturally fragmented spruce/fir forest, as a function of natural fires, that contains a mosaic of habitat types, fire resistant wet areas, and aspen regeneration and the kind of unnatural fragmentation that is observed today on the WCNF as a function of excessive large-scale logging, ski area development and road building. What are the implications of this unnatural fragmentation on native wildlife populations? SOC suggests the use and analysis of Landsat photos in this process.

Habitat fragmentation--the dissection of large, contiguous habitats into smaller, more isolated units--has been identified as one of the greatest threats to biological diversity, as it exerts its effects both through loss of habitat and isolation of remaining patches. Considerable scientific research has documented the negative effects of habitat fragmentation on many wildlife species in native spruce/fir ecosystems, such as those that exist on the WCNF. In addition to the quantitative loss of habitat associated with timber harvest, fragmentation also leads to declines in the quality of remaining habitat due to "edge effects." Edge effects that have been documented in coniferous forests include changes in forest microclimates, reduced reproductive success of forest songbirds, and the proliferation of shade-intolerant, "weedy" plant species. The PRLRMP and DEIS do not adequately address these serious concerns.

Given the potential effects from fragmentation associated with described Forest Plan alternatives, how will the impacts of fragmentation on biological diversity be monitored and evaluated in the future? A thorough landscape analysis on the effects of forest fragmentation, including determinations of the amount of "forest interior" habitat, mean and median patch size, patch area/perimeter ratios, and connectivity between forest stands, should be conducted in order to evaluate the effects of fragmentation on biodiversity. Only alternatives that do not contribute to the current degree of fragmentation that has already occurred due to past timber harvest and road building should be considered. To what degree has past clearcutting in the spruce/fir zone contributed to the fragmentation and degradation of natural habitats on the WCNF?

The Plan also fails to fully address concerns about the impact of this extensive fragmentation on the many species sensitive to fragmentation, edge effects, and related conditions.

NATIVE PLANT AND ANIMAL SPECIES

SOC recommends that the definition of viability be written as follows:

A population essentially certain to persist well distributed throughout its current range and, in the case of populations whose viability is in doubt, it includes any extension of the current range necessary to secure the viability of existing populations.

"Essentially certain" means something on the order of a 99% chance of persistence for at least 1,000 years (Schaffer 1981, 131-134). SOC does not necessarily advocate population viability modeling for all known species on the Forest, and therefore has not suggested that these numeric standards be included in this definition. However, they should be spelled out in the Final Plan for conducting viability analysis where it is indicated by the apparent status of a population.

The Final Plan must reflect a commitment by the Forest Service to maintain the viability (see definition above) of all populations of native plant and animal species. The program described in the Plan would allow a number of species to fall through the cracks and become extirpated from the Forest before management adjustments could be made.

The following standard should be included in the final Plan:

"Until inventories of all plants and animals listed on the state sensitive lists can be conducted and action taken to protect these resources, do not allow any activity that will potentially impact these resources."

Another improvement in the Plan should commence with a change in the definition of sensitive species. It should clarify that designation of species demanding special management attention is not optional. In addition, it should incorporate the notion of representativeness included in the present regulatory specifications for "management indicator species." (See 36 C.F.R. õ 219.19(a)(1)) The growing scientific criticism of diversity indicators has to do with reliance on indicator species as an exclusive strategy. Moreover, very little if anything will be gained by restricting responsibility for designation of sensitive species to either the Forest Plan or the Regional Forester. Both should contribute, given that the sensitivity of a species may or may not extend beyond the boundaries of individual forests. SOC urges the following definition of sensitive species be utilized:

"All species of plants and animals that require special consideration to assure their population viability, and other species sensitive to management impacts, whose designation will facilitate maintenance of diversity during Forest Plan implementation."

As mentioned above, only a limited amount of confidence can be reposed in a sensitive species approach, however well implemented, to provide for the viability of all native populations. To the extent that it is to make a significant contribution to overall diversity, the basis for species designation is critical. SOC suggests that, with assistance from a scientific advisory panel, the Forest Service should develop an improved basic criteria and a procedure for sensitive species selection and include them in its final Plan.

SOC also stresses that it is not sufficient to consider population viability as a constraint only on projects that actively alter habitat. Numerous other influences, for many of which the Forest Service bears or shares responsibility, threaten the population component of diversity on our National Forests. Among these are past habitat alteration or destruction, the presence of invasive exotic species, and the persistence of herbicides, pesticides, and other toxic chemicals. These issues have been poorly addressed. Dealing realistically with population viability requires assessing these continuing impacts and compensating for or accommodating them appropriately. This demands the sort of broad perspective unlikely to be achieved outside of the revised forest planning process (except for some species listed under the Endangered Species Act); it will require affirmative intervention and it is almost certainly not to be achieved simply through standards and guidelines for other management actions.

The proposed Wasatch-Cache National Forest Plan on page 2-6 states that in order to maintain healthy ecosystems we must first answer the basic questions: "What is out there?" "Where is it?" and "Where did it come from?" Clearly the last WCNF Plan did not answer these basic questions. The proposed Plan also fails to put forth a process to answer these questions. What is needed is a comprehensive survey of each ecosystem within the Forest including surveys of all plant and animal life and subsequent mapping of all species within the Forest. This could be carried out with an interdisciplinary team surveying one or two watersheds each year over the course of the new Plan. There has never been a comprehensive survey of such important canyons as Little Cottonwood or City Creek. No complete survey of flora or fauna has ever been conducted of these canyons. There may well be imperiled species within the Wasatch-Cache Forest that we do not even know about. You cannot hope to manage important natural resources if you do not know what, where or how they came about.

Guideline G12 on page 4-24 of the Plan calls for the use of native plant species in revegetation efforts, preferably from genetically local sources. However, the glossary in the Plan defines "native species" as "All species of plants and animals naturally occurring, either presently or historically, in any ecosystem of the United States." This would include as many as 30,000 species of plants, the vast majority of which have never been found in Utah, Wyoming or especially in the Wasatch-Cache National Forest. The proposed Plan guideline should call for the use of seed for revegetation from naturally occurring plant species known from within the WCNF wherever possible. Preference should also be given for genetically local sources.

The WCNF Proposed Plan on pages 5-11 through 5-17 calls for monitoring and evaluation of the Plan. While this section delineates how and when the Plan is to be monitored, there are no specific goals or standards of each criterion for success or failure during the Plan. For example, under TES plant species management the measurement indicator is the percent of individuals in a population affected by activities. No specific percentage is given for a threshold of concern or Plan failure and consequently, evaluation of the monitoring process will be subjective. Specific goals for success or failure for each measurement indicator should be set forth in the Plan and presented in this section.

The Proposed Plan, on page 4-15, suggests that plant collection for sustainable cultural uses would be allowed. This would open a Pandora's box of private plant collectors encroaching public land for their own benefit; this should be prohibited and not encouraged at all. Plant collection is not needed to promote seed production. Seed collection, which is provided for elsewhere in the Plan, will suffice. The Forest-wide sub goal of plant collection should be removed from the Plan.

The Forestwide sub goal of Noxious Weed Control is also discussed on page 4-14 of the Plan. Regrettably, noxious weeds are not defined in the glossary or elsewhere in the Plan that we could find. The definition of noxious weeds needs to be clearly defined and species listed to prevent unnecessary removal of desirable species.

Because the Forest faces budget constraints and increasing usage, the Forest should have as one of its forestwide goals the education of the public about the Forest's natural resources. Such programs as Celebrating Wildflowers should be increased. The Forest Service should also seek volunteers and other non-profit organizations to assist in preserving and maintaining the Forest resources.

Forestwide Objective number 20, calls for the Forest to work with others to complete the Bonneville Shoreline trail and the Great Western Trail in the next ten years. These trails should meet Forest Service trail standards and biological clearance should be carried out to ensure that no TES species are affected by the new trail.

Forestwide Objective 23 calls for baseline surveys to be conducted to determine use and satisfaction of Forest users. This is a good objective, however, follow up surveys are only called for every five years. This should be conducted at least every two years to be useful and meaningful to management decision-making over the course of the fifteen-year plan.

BATS

BOREAL TOAD

In 1995, field researcher Paul Bartelt expressed the opinion that the causes of amphibian decline in the West were related to habitat alteration at historic sites. His research was conducted to determine potential impacts of forestry practices on boreal toads. He found that evaporative water loss by the toads was increased by 10 fold in clear cut areas. His findings indicate that the toads select locations that allow most efficient thermal and hydro regulation; thus making overhead cover very important. Paul had the misfortune to observe the movement of a large herd of sheep through his toadlet nursery area. He found the expected trampling mortality as well as the large number of metamorphs that were dead from desiccation due to the removal of overhead cover by trampling and grazing.

This critical issue must be thoroughly addressed in the Final Revised Plan. If substantive changes are not made soon in the management of potential toad habitat in riparian/wetland areas, this species could soon disappear completely from the WCNF. What changes does the WCNF intend to make in its grazing program in order to restore and recover the Western Boreal Toad on the forest?

According to the Snowbird FEIS p. 3-80, the boreal toad has been recently confirmed on three occasions at Snowbird. It is also known historically from 5 locations in the Heber Ranger District of the Uinta National Forest according to: "Historical Distribution, Current Status and Range Extension of Bufo Boreas in Utah"by D.A.Ross, T.C.Esque, R.A.Fridell and P. Hovingh, Herpetologlogical Review, 1995. This species is listed on the Utah Division of Wildlife Resources Sensitive Species List as a species of special concern with declining population and is also on the new Region Four Forest Service Draft Sensitive Species List (1999). Furthermore, new genetic work by Dr. Anna Goebel, University of Colorado, closely links the boreal toads of northern Utah to those of Colorado. Mark S. Jones of the Colorado Division of Wildlife, Aquatic Research, states that: "Mitochondrial data suggest that toads Bufo Boreas migrated into Colorado from northern Utah, because haplotypes very closely related to those in Colorado and southeast Wyoming have been found in northern Utah."

STATUS AND NEEDS OF RARE AND SENSITIVE SPECIES

Special management attention should be given to the habitat needs and threats of:

1.All species listed as species of special concern, sensitive, ESA candidate (including species on the former C-2 list), threatened, endangered, G1-G4 on the WCNF or any other surrounding or nearby land management unit.

2.Species listed as management Indicator Species by the WCNF or any other surrounding or nearby land management unit (not already listed as a TES species). This includes but is not limited to the species noted in the DEIS.

3.Any other species that is rare or imperiled on the WCNF or any other surrounding or nearby land management unit, regardless of whether its status has been formally recognized in any manner. This includes the list of species in the DEIS appendices.

PLANTS

THE PLAN IS UNLIKELY TO PROVIDE FOR THE LONG-TERM VIABILITY OF NATIVE CUTTHROAT TROUT

PRELIMINARY REVIEW OF THE LAND AND RESOURCE MANAGEMENT PLAN

While rare and unique communities surely deserve protection, nothing in the Preliminary Review of the Land and Resource Management Plan (PRLRMP) ensures that a significant number of communities will be identified and preserved, that they will comprise something more than an "ecosystem zoo" whose constituents cannot be expected to survive over the long term, or that their selection will contribute meaningfully to the overall diversity of the WCNF. Conservation of the full natural range of ecosystems is appropriate not only in its own right, but also for its contribution to landscape, species, and genetic diversity.

FOREST PLAN AMENDMENTS

CATEGORICAL EXCLUSIONS

CONCLUSION

Although many of the comments found in this document are expressed in the context of the tri-canyon area, the points expressed and recommendations made apply to the entire Forest. The tri-canyon area is but a microcosm of the Forest management challenges facing the entire Wasatch-Cache National Forest.

Non-binding and non-specific are the watchwords for this proposed Forest Plan. Whereas the Forest Service feels the existing Forest Plan is too rigid and does not allow adequate Forest management flexibility, the proposed Plan resides at the opposite end of the spectrum. This Plan desperately needs to find a balance between these two extremes. It is not there yet. It can safely be predicted that the ambiguous nature of this proposed Plan will unnecessarily subject current and future Wasatch-Cache National Forest managers to an array of pressures from commercial and special interest groups as they argue that the Forest Plan does not prohibit their particular consumptive use plans. And these promoters and groups will be correct. There is very little language in this Plan that clearly prohibits inappropriate uses of the Forest. The proposed Forest Plan simply fails the enforceability and intent test.

The Plan fails to provide a full articulation of a Desired Future Condition (DFC) for the WCNF. Instead, it provides a "Desired Condition" statement for each geographic management area. These statements are too vague to provide much useful management direction or an expression of management goals to which the Forest can be held accountable. Developing a detailed DFC for the all of the ecosystems, habitats, and resources on the WCNF is a necessary component of developing an adequate and reasonable long-term management plan. The Desired Future Condition must be specific enough that from it can follow an entire range of specific management provisions to which the Forest will be accountable. The notable lack of sufficiently strict, clear, and thorough standards in the Plan is a closely related deficiency. It is impossible to develop and commit to such standards without a clear articulation of the long-term management goals. A failure to correct this glaring and crucial deficiency in the revised Forest Plan, coupled with, for example, unprecedented recreational use in the next decade will permanently damage this critical National Forest.

The proposed Plan's lack of recommended wilderness is distressing and unwarranted. The Forest Service is sacrificing permanent protection of the Forest to its perceived short-term management needs. The Forest Service argues that wilderness designation is not necessary to adequately protect the forest. SOC and many others argue that wilderness status is the only means by which wild areas will permanently remain wild and untrammeled.

The WCNF Forest Plan revision team and upper Forest Service management have the responsibility, not only to the public, to create a document that will support future WCNF managers as they find themselves dealing with increasingly vexing human impacts as the human population in Utah inexorably grows. As the Plan now stands, it fails this responsibility. . Until the Forest Service has determined the "Limits of Acceptable Change" or the "Carrying Capacity," wise judgment requires the Forest Service to put a temporary halt to any new development, issuance of new permits, waivers, or ski resort operating plans. The Forest Service should not allow any new actions until it has determined the likely effect the proposed actions will have on the ecosystems watershed and wildness of the Forest. Responsible Forest management requires the managers to protect the Forest from all actions which may exceed the "Limits of Acceptable Change" or the "Carrying Capacity."

Save Our Canyons thanks the Forest Service for giving careful consideration to what is proposed here. Simply put, the Forest Plan that will be written this year will determine the fate of the Forest. If nothing is done, if vigorous measures are not taken to address the tri-canyon and other management area problems, human overuse will cause irreversible deterioration of the watershed and the wild forest ecosystems long before the next Forest Plan is undertaken. The problems are not being exaggerated. Unfounded alarms are not being sounded. If what is said comes to the Forest Service as a dire warning, so it is intended to be.