1 November 2001

Wasatch-Cache National Forest
Attn: Plan Revision Team
8236 Federal Building
125 South State Street
Salt Lake City, UT 84138

Dear Planning Team members:

These comments are submitted in response to the WCNF Proposed Forest Plan and associated DEIS released in spring, 2001. I am writing on behalf of the Ogden Group of the Sierra Club, which currently has about 400 members in Weber, Box Elder, Morgan, and northern Davis Counties. My specific comments will be restricted mainly to the territory of our Group, namely, the Ogden Ranger District and the north-Davis portion of the Salt Lake Ranger District. However, our Group supports the positions of the rest of the Sierra Club and other conservation organizations regarding other parts of the WCNF. In particular, we support the positions on the DEIS and Proposed Plan advocated by the Bear River Watershed Council, the High Uintas Preservation Council, Save Our Canyons, and the Wild Utah Project. Of the six alternatives presented in the DEIS, we are most in support of Alternative 1.

Within the Ogden area, we are generally pleased with the way the Preferred Alternative (6) seems designed to protect the relatively undeveloped character of most of the Forest Service lands. We are especially pleased with the designation of most of the Upper South Fork roadless area as proposed wilderness in Alternative 6. We also commend the Forest Service for recognizing the importance of watershed protection in the proposed managment of most of the rest of the area.

We have several concerns, however, with certain details of the Preferred Alternative, as well as some more general concerns with the DEIS and the planning process. These concerns are described in the sections below.

General Comments on the Planning Process and NEPA

MPC Definitions

We are concerned that the definitions of the various Management Prescription Categories (MPC's) have changed significantly during the two-year public planning process, and that the MPC's in the DEIS are more complex than ever before. The definitions of the MPC's are now different in each alternative, and for some alternatives (including the Preferred Alternative), the definition of a given MPC depends on whether it is applied to an inventoried roadless area. Furthermore, the question of whether motorized recreation is allowed has been entirely divorced from the MPC classification, except in wilderness and proposed wilderness.

These complexities make it extremely difficult for the public to offer meaningful comments on the alternatives and the Proposed Plan. The comparison of alternatives in Table 2-1 of the DEIS is especially misleading because of the varying MPC definitions. Also, our earlier suggestion that certain areas be classified as MPC 2.6 or 4.2 now requires further clarification, because the definitions of these MPC's are no longer the same as when we made this suggestion. Even now, when we recommend a given MPC for an area, we must be careful to specify which alternative's definition of that MPC we are thinking of. Except when otherwise specified herein, we will assume that the MPC's are to be defined as in the Preferred Alternative.

The bifurcation of MPC definitions for roadless/non-roadless areas seems illogical. For instance, consider MPC 3.1 (in the Preferred Alternative). As we understand it, this MPC is intended to emphasize watershed protection, with a secondary emphasis on habitat preservation. Yet outside of inventoried roadless areas, this MPC would permit road building and major new recreation developments such as campgrounds. Such developments are inconsistent with the stated theme of this MPC and should be prohibited whether or not an area meets the 5000-acre criterion for official roadless status. As a second example, we don't understand how new recreation developments can be permitted under MPC's 4.1 and 4.3 inside inventoried roadless areas, but prohibited under these MPC's outside inventoried roadless areas (see page 4-49 of the Proposed Plan). If anything, the restrictions should be greater within roadless areas. Similarly, MPC 2.7 is more restrictive (by prohibiting grazing) outside inventoried roadless areas than inside them.

The most awkward problem with the MPC's, though, is that despite their complexity, they fail to span the full range of possible managment practices. There is no MPC, for instance, that would permit bicycle access but prohibit motorized access to an area. Within inventoried roadless areas, there is no MPC in the Preferred Alternative that emphasizes recreation but prohibits major recreation developments. The only MPC's that prohibit grazing are inapplicable to most areas for unrelated reasons. In general, the new set of MPC's makes it extremely difficult to give any meaningful protection to areas that are roadless but less than 5000 acres. Some of these deficiencies, we believe, may be violations of the NEPA requirement that a full range of alternatives be considered in the DEIS.

Roadless Areas

We understand the difficulty faced by the Forest Service in drafting a new management plan while the status of the national-level roadless rule is in flux. But despite this difficulty, the Proposed Plan needs to be clear and unambiguous. The roadless status of several areas (especially Public Grove and the three Francis units) is ambiguous in the Proposed Plan, and it is unclear how you are proposing to manage these units should the national roadless rule not be implemented. On one hand, the terms "proposed plan" and "preferred alternative" seem to imply that the management prescriptions in this alternative will be favored by decision makers even in the absence of a national roadless rule. On the other hand, specific language within the Proposed Plan (e.g., page 4-88) seems to imply that certain units would be managed in other ways were it not for the national roadless rule. Some might even interpret the Proposed Plan to imply that, should the roadless rule be suspended, the definitions of all MPC's, even within roadless areas, would revert to the versions that apply outside of roadless areas. These ambiguities create additional obstacles that hinder meaningful public comment on the Proposed Plan.

ROS Maps

The summer Recreation Opportunity Spectrum (ROS) maps included in the DEIS present a host of further ambiguities that make the Proposed Plan (and the other alternatives) contradictory and impossible to interpret. In many cases the ROS Class definition (from Table 11 in the Proposed Plan) is inconsistent with the proposed MPC of an area. A particularly glaring example is the red ("urban") designation of the Davis County foothills, implying that routes are "highly developed for motorized use often with mass transit supplements available; trails are constructed for ease of movement, many are paved or graveled" (page 4-57). The "urban" designation is equally inappropriate for the west shore of Pineview reservoir and the North Arm Wildlife Trail area. Along Ogden Canyon, a wide swath containing no roads or trails at all is colored green for "rural." Many peripheral portions of roadless areas are designated "roaded natural," while several trailless areas are designated "semi-primitive motorized." Generally, the summer ROS maps imply a much higher level of development and motorized access than either the current condition or the rest of the Proposed Plan.

One problem with the summer ROS maps seems to be a confusion over whether they are prescriptive or merely descriptive. An undeveloped mountainside that lies near a paved highway (say, in Ogden Canyon) might accurately be described as offering a rural (rather than primitive) recreational experience, but this need not imply that the mountainside itself is accessible by vehicle or even by foot trail. Similarly, while a single motorized trail may have an effect on the recreational experience throughout a mile-wide corridor, it is inappropriate to therefore paint the entire corridor as if motorized access were permitted throughout.

Clearly, it is appropriate during the planning process to determine what recreational experiences will be available in each area under each alternative. The proposed plan itself, however, should be a prescriptive document that unambiguously stipulates what is allowed where. The summer ROS maps fail to accomplish this, because they imply that much more motorized access will be allowed than is actually intended.

Travel Planning

The summer ROS maps also flatly contradict the stated intention of the DEIS (page 1-14) not to make "site-specific determinations of specific locations" for uses such as motorized recreation. The scale of the ROS maps allows them to be read to an accuracy of less than 100 yards, so these maps effectively specify the exact routes along which motorized travel will be allowed. Except in some proposed wilderness areas, the maps for all six alternatives show continued motorized access wherever it is currently allowed. Differences between the six ROS maps actually imply increased motorized access in most of the alternatives. For example, the map for Alternative 6 shows the entire Public Grove roadless area as either "roaded natural" or "semi-primitive motorized," implying far more motorized access than the current situation which is better represented by the Alternative 1 map. The Alternative 5 map goes further still, showing (for instance) increased motorized access to the Sugar Pine roadless area, Jumpoff Canyon, and North Ogden's Coldwater Canyon. In at least one location, even the Alternative 1 map shows currently nonmotorized trails as motorized: the spur trails that branch south from the Lewis Peak trail to peaks 7862 and 7887, which are unambiguously omitted from the allowed routes depicted on the 1991 Ogden Ranger District Travel Map.

The Forest Service needs to decide whether the current planning process will address summer motorized travel routes or not. If not, then the final adopted plan should not include any maps showing exactly where motorized use is allowed.

However, we believe that NEPA, NFMA, and 36 CFR 219 require the Forest Plan to include at least some general travel planning, at the same level of detail as is used to determine the MPC's. Furthermore, the DEIS must analyze a full range of alternatives at this level. The present DEIS fails to meet this requirement, because it does not analyze any alternatives that would restrict motorized access more than currently (except in proposed wilderness). A full range of alternatives would include an alternative that prohibits any motorized recreation in roadless areas, even if these roadless areas are not recommended as wilderness (either because they do not have sufficient wilderness characteristics or because it is desired to allow bicycle access).

The inconsistency is especially apparent if we focus on the area that our Sierra Club Group represents: the Ogden Ranger District and the north-Davis portion of the Salt Lake Ranger District. Within this area, none of the six alternatives in the DEIS would close a single foot of trail to motor vehicles. Indeed, all six alternatives would open at least one new trail to motorcycles. Most of the six alternatives would allow additional new motorized access, while Alternative 5 would increase motorized access very significantly, as indicated both by the summer ROS map and by the designation of large areas in MPC 4.3, 4.4, or 4.5. Considering only alternatives that would expand motorized access, not those that would diminish motorized access, is a clear violation of NEPA.

(We understand that the DEIS does allude to the possibility of limiting the number of simultaneous motorized users in some areas, perhaps by implementation of a permit system. This vague suggestion, though better than nothing, is not sufficient to satisfy the NEPA requirement that a full range of alternatives be analyzed.)

Although we are generally impressed by the efforts that the Planning Team has made to encourage public participation in the planning process, the present issue is obviously one for which the process has broken down. I (representing the Ogden Sierra Club) initially raised the issue of motorized recreation in the Ogden area when the planning process was just getting started, in a letter to Bernie Weingardt dated 29 May 1999. In late 1999, at an alternative development workshop held at Ogden High School, I participated in a group facilitated by Tony Botello, focusing on nonmotorized recreation. During our discussion, I emphasized to Tony that at least one alternative in the DEIS should close the entire Wasatch Front to motorized recreation; he made a written note of this comment and assured me that such an alternative would be developed. However, when the preliminary alternatives were published in summer 2000, the document was contradictory (and hence ambiguous) over whether motorized recreation would continue to be allowed in certain areas classified as MPC 2.6 (in Alternatives 1 and 2). I pointed out this contradiction to Tom Scott both in person and in a letter dated 17 August 2000. That letter was quite explicit in stating that the DEIS must consider and analyze an alternative that prohibits off-road motorized recreation everywhere along the Wasatch Front. It is extremely disappointing to see that after all these efforts, our comments have been disregarded by the Planning Team. It is even more disappointing that the Planning Team has disregarded NEPA.

As a remedy, we suggest that a column for motorized recreation be restored to each of the tables that define allowed and prohibited activities by MPC. Summer off-road motorized recreation should be prohibited in MPC's 2.1 through 2.7, 3.1, 3.2, 4.1, and 4.2. (Winter off-road motorized recreation could be permitted in some areas managed under 3.1 and 3.2.) Summer motorized recreation should also be prohibited in all roadless areas. Finally, the summer ROS maps should be omitted from the Plan.

Lack of Comprehensive Analysis

Although the DEIS contains some general discussion of the types of environmental damage that are currently occurring in the WCNF, it offers very few details and no quantification. This is especially true of damage caused by grazing, off-road vehicle use, and other recreational uses.

There is no data in the DEIS on the present amount of dispersed motorized (or nonmotorized) recreation taking place, or on the effects of this recreation on the environment. To cite a specific example, while the DEIS mentions the recent "sharp increase" in ATV use in Willard Basin as well as the trails that have been illegally created by this use, it does not assess the seriousness of this problem, much less attempt to measure the overall effect of motorized recreation in the Willard roadless area in terms of erosion, siltation, human waste, vegetation, or wildlife. Similar problems occurring in many other areas are not even mentioned in the DEIS. Furthermore, the DEIS contains no site-specific analysis of the expected levels of environmental damage due to increased motorized use in each of the six alternatives.

Similar comments apply to other forms of recreation (campgrounds, dispersed camping, ski areas) and to grazing: The environmental effects are occasionally mentioned in passing, but are not assessed in a systematic or quantitative or site-specific way. Most significantly, there is no site-specific analysis of how the likely environmental effects would vary from one alternative to another. Because of this shortcoming, this DEIS cannot be used as a basis to permit any new grazing or any new motorized or developed recreational use where such use is not permitted and occurring already. Any such new uses would instead require a site-specific NEPA analysis and a demonstration, based on that analysis, that the proposed use would not damage the environment.

Recommendations on Specific Areas

Francis Roadless Areas

We do not understand why the Francis roadless area is not recommended as proposed wilderness in any of the alternatives. The north portion alone is larger than the nearby Burch Creek roadless area, which is recommended as proposed wilderness in Alternative 1. But the area available for wilderness is larger still, because the private inholdings that separate the north and middle Francis units may someday be acquired by the Forest Service, and in any case are unlikely ever to be developed. The character of the Francis area is very similar to that of Burch Creek in terms of wildness, solitude, and physical challenge. One could argue that the Francis roadless area is actually more scenic, because it includes the Adams Canyon waterfall as well as Thurston Peak which is over 9700 feet elevation. There is also the long-term possibility of Forest Service acquisition of the adjoining Gailey Ranch property, which would significantly add to both the acreage and the ecological importance of this roadless area.

We would, however, exclude from the proposed Francis wilderness the lowest foothill areas below about 5200 feet elevation, so that the Bonneville Shoreline Trail (both existing segments and likely future segments) would remain open to bicycles.

With this minor exclusion, we recommend that the adopted Forest Plan designate the Francis area as proposed wilderness, MPC 1.5. We further recommend that if MPC 1.5 is rejected in the adopted Plan, that the wilderness character of this area be preserved, preferably by use of MPC 2.6 or 4.2, and by prohibiting all conflicting uses including both summer and winter motorized access.

The most serious conflicting use in the current preferred alternative would be heli-skiing. We believe that heli-skiing in this area is inappropriate, for a variety of reasons. The proximity to a large suburban area would make helicopter noise a major nuissance. Other heli-skiing areas are already available on nearby private land such as around James Peak. And as argued in the Lewis Peak section below, Utah's ski industry has grown very little in recent years, so there is no need for expanded heli-skiing opportunities.

The effect of livestock grazing on watersheds in the Francis roadless area needs to be assessed.

Mt. Ogden

We applaud the designation of the Burch Creek roadless area (or rather, what's left of it since the recent Snowbasin expansion into Strawberry Bowl) as proposed wilderness in Alternative 1. We recommend that this option for Burch Creek be incorporated into the preferred alternative and final adopted Plan. However, the lowest foothill regions should be excluded from the proposed wilderness to allow bicycle use of the Bonneville Shoreline Trail (both current segments and likely future segments extending southward to Weber Canyon). With this minor exclusion, there are no significant conflicting uses in this area.

We further recommend that the nearby area extending from Taylor Canyon to Coldwater Canyon, east as far as the Sardine Canyon powerline, be added to the Burch Creek proposed wilderness. A more appropriate name might then be the Mt. Ogden roadless area and proposed wilderness. Currently there is only a corner connection between the Forest Service Taylor Canyon property and the inventoried Burch Creek roadless area. However, this corner connection occurs on very rugged terrain that is unlikely ever to be developed. The private lands on the sections that meet at this corner are owned by Snowbasin to the northeast and by the Malan/Rasmussen family to the southwest. It seems quite possible that the Forest Service might someday acquire at least a portion of one or the other of these sections. Ideally, the Forest Service should acquire the entire Malan/Rasmussen property; this would allow the incorporation of such popular hiking destinations as Malan's Peak and Waterfall Canyon into the Mt. Ogden Wilderness. (Again, the proposed wilderness should exclude a strip along the foothills up to the level of the Bonneville Shoreline Trail.)

Should this area not be recommended as proposed wilderness in the final Plan, its wilderness values should still be protected by use of MPC 2.6 or 4.2 and exclusion of all conflicting uses. (MPC 3.1 might also be appropriate, but only if its definition is modified to prohibit road building, recreation developments, and motorized recreation, even outside of inventoried roadless areas.) The description of the "desired future condition" of the Burch Creek roadless area, on page 4-87 of the Proposed Plan, should be modified to say that "any proposal for special uses in the area must comply with the prohibition on road construction and have no impact on roadless characteristics." The same language should apply to the Taylor Canyon -- Cold Water Canyon area.

The Plan should state that "lift-served recreation at Snowbasin Ski Area will be discouraged from spreading outside the current ski area boundary."

We find it odd that in the currently offered alternatives, Taylor Canyon would actually receive more protection (with road building prohibited) in Alternative 5 than in Alternative 6.

The importance of the Mt. Ogden area for nonmotorized recreation, as well as for watershed protection, cannot be over-emphasized. The entire east side of the mountain as well as the ridgeline has now been developed and commercialized, without even going through a NEPA process. It is time to draw a line and prohibit any developments from encroaching on the west side of the mountain. We note that the Preferred Alternative would inappropriately permit road building and major recreational developments in Taylor Canyon, Hidden Valley, Warm Water Canyon, and Cold Water Canyon. Public hearings held only a few years ago on the proposal to put a tram up Taylor Canyon indicate that these kinds of developments are very strongly opposed by local residents. The nonmotorized trail system on Ogden's east bench and extending up the mountain is a point of pride for the city, and a significant incentive in attracting new businesses, employees, and students to the area. A designated wilderness area above the Bonneville Shoreline Trail would protect most of this priceless resource indefinitely, and would be an added selling point for the city.

Incidentally, none of the maps in the DEIS reflect the recent acquisition of the property along the Bonneville Shoreline Trail just north of Taylor Canyon and west of Hidden Valley. This property should be included in the roadless area, and what is east of the Bonneville Shoreline Trail should be included in the proposed wilderness.

Wheeler Creek

The area extending from the Sardine Canyon powerline eastward to Wheeler Creek and the FS boundary, between Ogden Canyon on the north and the old Snow Basin road on the south, is too small to qualify as an inventoried roadless area yet should still be treated as one due to its importance for watershed protection and nonmotorized recreation. The same is true of the area south of the old Snow Basin road that includes the East Fork and Middle Fork of Wheeler Creek. This is an area where MPC 3.1 (watershed protection) would seem very appropriate, except that according to the definition on page 4-46 of the Proposed Plan, road building and recreation development would still be allowed since this is not an inventoried roadless area.

Under the MPC definitions in the current Proposed Plan, then, the most appropriate MPC for these areas would be 2.6, with the added stipulation that motorized recreation be prohibited. MPC 3.1 or 4.2 might seem more appropriate, but only if the definitions of these MPC's are modified to prohibit road building, recreation development, and motorized recreation (both summer and winter).

We are especially disturbed that the Alternative 6 map shows a sliver of pink, apparently indicating MPC 4.5, along the old Snow Basin road from the ski area down to approximately where the Middle Fork of Wheeler Creek crosses the road. This sliver also seems to encompass the Wheeler Creek wetlands and much of the creek bed itself. (The winter ROS map similarly shows a corridor along the old highway that would apparently be open to snowmobiles.) This designation is in conflict with the Forest Service's long-standing commitment to preserving the water quality in Wheeler Creek. It is also completely unnecessary, given the proximity of privately owned lands just across the highway, which can be used for any needed recreation developments. We strongly urge that this designation be changed to conform with that of the surrounding area, as recommended in the previous paragraph.

Lewis Peak Roadless Area

This roadless area is not recommended as proposed wilderness in any alternative, apparently because of the conflicting use by bicycles and motorcycles along the Skyline and Lewis Peak trails. We concur that bicycle use of these trails should be allowed to continue, but we recommend that motorized recreation be prohibited throughout the entire roadless area. At present, nonmotorized users have a fair chance of enjoying a quiet trip into this area, but motorized use is sure to increase in the future, eventually driving out nonmotorized users as has happened elsewhere. Increased motorized use would also adversely affect water quality and wildlife habitat. Even at current use levels, the Forest Service is unable to enforce the current travel plan, which prohibits motorized use of the spur trails to peaks 7862 and 7887. The Forest Service has also been unable to prevent the creation and continued use of multiple braided trails along much of the ridgeline route. (This is a good example of an environmental problem that is not even mentioned in the DEIS, much less explored in terms of consequences.) Finally, because opportunities for quiet and solitude along the ridgeline of Mt. Ogden have now been eliminated, it is important that the Forest Service provide such opportunities in other ridgeline environments.

If the Forest Service elects to allow continued motorized access to the Lewis Peak area, it should be on an alternate-day basis or in some other way that ensures that motorized use will not be the dominant summer use. The paragraph pertaining to Lewis Peak on page 4-87 of the Proposed Plan should then be modified to read: "Lewis Peak Roadless Area will be managed so that nonmotorized recreation remains the dominant type of recreation. Motorized recreation will be limited to those routes designated as motorized in the 1991 Travel Map, and restricted in time (for instance, to alternate days) in order to preserve nonmotorized recreation opportunities. Motorized use off of designated routes will be monitored, and if within five years management practices are still unable to prevent such use, then all motorized travel will be phased out. Any proposal for special uses in the area must comply with the prohibition on road construction and have no impact on roadless characteristics."

We also suggest the creation of a proposed wilderness area (MPC 1.5) that incorporates the western portion of the Lewis Peak roadless area, west of the Skyline Trail, with a cherry-stem for the Lewis Peak trail (but not for the spur trails to peaks 7862 and 7887). The Bonneville Shoreline Trail along the foothills should also be excluded. The total acreage is well over 5000 even with these exclusions, and there are no other conflicting uses.

We applaud the closure of the Lewis Peak roadless area to snowmobiles in the Proposed Plan, and strongly urge that this closure be incorporated into the final adopted Plan. Snowmobile use here is currently almost nonexistent, so this area is being used more and more by snowshoers seeking peace and solitude. Given the ever-increasing capabilities of snow machines, it is important to prevent their future incursion into this area.

We also applaud the prohibition in the Proposed Plan of any expansion of Nordic Valley Ski Area into this roadless area. However, because such an expansion would be permitted in Alternative 5, we should explain here why it would be inappropriate. According to the statistics on page 3-181 of the DEIS, downhill skiing in Utah has increased only 19.5% over the last 14 years, an average rate of only 1.3% per year. (The following page quotes a figure of 1.8% per year, but does not support this figure with any raw data.) At the five ski areas in the Wasatch-Cache National Forest, the total increase has been only 2.9%, implying an annual rate of 0.2%. Yet over the same time period, the total lift capacity of the five WCNF ski areas has increased 59.3%. Obviously this increase has been far in excess of the actual skier demand; it is especially alarming that the huge recent expansion in lift capacity has not led to any significant increase in the number of skiers.

The forecast on page 3-182 of the DEIS that skier visits will grow over the next seven years at an annual rate of 3.4% comes across as pure speculation, or perhaps pure wishful thinking on the part of ski area owners. Rising lift ticket prices have driven away much of the local population, and although the destination skier market has made up for this loss during the economic boom of the 1990's, this trend seems sure to end due to the current economic recession and decrease in air travel. The long-term future is, of course, uncertain, but the Forest Plan that we adopt for the next 15 years should be based on established trends and foreseeable developments, not pure speculation about the distant future.

The DEIS gives no statistics for dispersed recreational use of the Forest, but anecdotal evidence suggests that dispersed recreation (both summer and winter) is growing much faster than the ski industry. Since the amount of National Forest land is finite, fairness would suggest that the area devoted to ski areas be decreased, to accomodate the increasing fraction of dispersed recreation. The damage to watersheds and wildlife that accompany ski area development are additional reasons to prohibit any further ski area expansion.

Willard Peak Roadless Area

For the same reasons as in the Lewis Peak area, we recommend that all off-road motorized activity in the Willard roadless area be prohibited. This area offers unique scenery and the best summer wildflower viewing in the Ogden Ranger District, so motorcycles should not be allowed to drive away nonmotorized users, as will inevitably happen if current management prescriptions are left in place. The area also provides important habitat for raptors, and it is unknown what effect motorized users might be having on the quality of this habitat.

As in the Lewis Peak area, if the Forest Service disagrees and decides to allow continued motorized access, this access should at least be prohibited on alternate days. The paragraph beginning at the bottom of page 4-87 of the Proposed Plan should then be modified to read: "Willard Peak Roadless Area will be managed so that nonmotorized recreation remains the dominant type of recreation. Motorized recreation will be limited to those routes designated as motorized in the 1991 Travel Map, and restricted in time (for instance, to alternate days) in order to preserve nonmotorized recreation opportunities."

We do not object to the four-wheel-drive road to Willard Basin remaining open. However, something needs to be done to protect the basin from the ATV abuse that is currently occurring. Vehicles need to be kept away from the shoreline of the pond, and unauthorized tracks and trails need to be revegetated. The current state of the basin is not only an aesthetic disaster, but is also surely creating water quality problems. The following language should therefore be added to the Plan: "Motorized use off of designated routes will be monitored, and if within five years management practices are still unable to prevent such use, then all motorized travel will be phased out."

Like so many other areas, it is hard to say whether the appropriate MPC for the Willard roadless area is 2.6, 3.1, or 4.2. What's important is that road construction, recreation developments, and off-road motorized use be prohibited, in order to protect watersheds, habitat, and nonmotorized recreation opportunities. The language in the Proposed Plan regarding special uses should therefore be strengthened to read: "Any proposal for special uses in the area must comply with the prohibition on road construction and have no impact on roadless characteristics."

Public Grove

Summer motorized recreation in the Public Grove area should be restricted to routes shown as motorized in the current Travel Plan. No new road construction or other developments should be permitted, in order to preserve watershed quality. Page 4-89 of the Proposed Plan suggests that new motorized routes may be created; as explained above, this would require a separate NEPA analysis that thoroughly documents impacts on soils, water quality, wildlife habitat, etc. The first two sentences in the second paragraph on page 4-89 should therefore be deleted from the Plan.

Snowmobile use of the Public Grove area has increased dramatically in recent years, making this yet another area where snowmobiles have driven out cross-country skiers and snowshoers. The Forest Plan should stipulate unambiguously that skiers and snowshoers have a right to recreate in this area unharassed by snowmobiles. Such a requirement could be implemented either by prohibiting snowmobiles from part of the area, or by allowing snowmobiles only on alternate days.

Middle Fork Wildlife Management Area

MPC 3.2 (emphasis on wildlife habitat) seems appropriate for this area, but the definition of this MPC needs to be modified to prohibit new road construction, recreational developments, and motorized recreation. If the definition of MPC 3.2 is not changed, then this area should be assigned MPC 2.6.

Upper South Fork Roadless Area

We endorse the recommendation of most of this area as proposed wilderness in the Proposed Plan. However, the proposed wilderness area should encompass the entire roadless area, including the northern portion that is designated 3.2 in the Proposed Plan. A wilderness boundary that coincides with the roadless area boundary will be much easier to sign and enforce, and will also create an accessible area for nonmotorized winter recreation without unduly inconveniencing snowmobilers who will still have access to nearly all of the Monte Cristo plateau.

Wilderness status for this area will ensure its continued role as a link in the wildlife corridor connecting the Uinta Mountains to western Wyoming and eastern Idaho. A secondary argument for wilderness status is the need for wilderness recreation opportunities in the Ogden Ranger District, which currently has no wilderness.

The winter ROS map for Alternative 6 shows (presumably incorrectly) that snowmobile use would be permitted in a portion of this proposed wilderness near Causey Reservoir. This error should be corrected.

Monte Cristo Plateau

Here again, MPC's 3.1 and 3.2 should be redefined to prohibit road building, recreational development, and summer motorized recreation, even outside of inventoried roadless areas. These prohibitions are needed in order to preserve this plateau as a link in the regional wildlife corridor. Although we are not recommending the Sugar Pine roadless area for wilderness status at the present time, it should be managed to preserve its wilderness characteristics.

We recommend that snowmobiles be prohibited along and near roads 073 and 201 which extend southward from the highway, in the vicinity of the north end of the Upper South Fork roadless area. This prohibition will make enforcement of the proposed wilderness boundary much easier, and will also help create an accessible area for nonmotorized users, south of the highway. There is ample room for snowmobiles along the highway itself and to the north.

We note that the DEIS does not assess the environmental damage caused by snowmobiling on air quality, watersheds, or wildlife habitat. Such an analysis needs to be performed, with possible actions including further restrictions on where and when snowmobiling is allowed, and/or emissions and noise limits on snowmobiles. A paragraph to this effect should be added to the Proposed Plan.

Mollens Hollow Roadless Area

Because of the ecological importance of this area and its role as part of a regional wildlife corridor, we recommend this roadless area for proposed wilderness status, MPC 1.5.

Further Comments

Lands Acquired in the Snow Basin Land Exchange

The public lands disposed of in the Snow Basin Land Exchange offered the best cross-country ski touring in the Ogden area, while much of the land acquired in the land exchange is too steep for cross-country skiing. We recommend, though, that all lands acquired in the exchange, including those in the Logan Ranger District, be placed off-limits to snowmobiles, in order to offset the loss of nonmotorized recreation opportunities at Snow Basin.

Grazing

Commercial grazing is currently of very little economic consequence in the Ogden Ranger District and the northern Salt Lake Ranger District, but it does have serious adverse effects on riparian areas, water quality, and certain wildlife habitats. These adverse effects may be interfering with the function of portions of the regional wildlife corridor that passes through the eastern portion of the Ogden Ranger District. Unfortunately, the DEIS does not assess the extent of this problem.

As noted above, the DEIS cannot be used as a basis to permit any additional livestock grazing, because it does not include the comprehensive alternatives analysis of this issue that NEPA requires. We recommend that no new commercial grazing be permitted in the WCNF, that the effects of grazing be studied in more detail, and that grazing be phased out where adverse effects are occurring.

Because nearly every MPC in every alternative would permit grazing, we also believe that the treatment of grazing in this DEIS fails to span the full range of alternatives required by NEPA.

Reclaiming Damaged Sites

The discussions of reclaiming damaged recreation sites (such as unauthorized trails and dispersed campsites) in the DEIS seem to imply that no active reclamation would be permitted under the "hands-off approach" of Alternative 1. We cannot locate a definitive statement in the DEIS of exactly what is and isn't allowed in Alternative 1, or in any other alternative, but if we take these statements at face-value, then clearly, Alternative 1 needs to be modified. Where concentrated use by humans (or by livestock) has damaged soils or vegetation, it is entirely appropriate for humans to play an active role in returning the site to a more natural condition. Of course, in wilderness and proposed wilderness, any human intervention must be accomplished without motorized travel.

If this shortcoming of Alternative 1 has played a role in the decision by the Forest Service to reject Alternative 1 as the preferred alternative, then this decision needs to be revisited. The MPC assignments and wilderness recommendations in Alternative 1 should not be rejected simply because this alternative happens to have an unrelated, undesired restriction on reclaiming isolated damaged sites.

Conclusion

We are grateful for this opportunity to comment on the DEIS and Proposed Forest Plan. As always, the Sierra Club is prepared to work with Forest Service officials for the benefit of our National Forests and the people who use them.

Sincerely,

Daniel V. Schroeder
Chair, Ogden Group Sierra Club
1444 Binford Street
Ogden, UT 84401

Enclosure: Map of wilderness recommendations near Ogden

cc: Tom Scott, Ruth Monahan, Rick Vallejos