• Undesignating Wilderness — By George Nickas
  
  
• Wilderness Recreation - Balancing Freedom and Protection — By By David Cole, Aldo Leopold Wilderness Research Institute, Rocky Mountain Research Station, U.S. Forest Service
  
  
• A Question of Ethics and Enforcement — By Meredith Taylor
  
  
• Land Board OKs Bulldozing Roads in Arizona Wilderness Area — By Joe Feller
  

Undesignating Wilderness

— By George Nickas

The Forest Service has adopted a new strategy for dealing with the resource impacts in Wilderness caused by recreation overuse, but the plan isn’t what you’d expect. Rather than reducing human impacts and crowding, the Forest Service has simply decided that some places in Wilderness will not be managed as Wilderness any more. Instead, they’ll be managed as high-use recreation areas. Bill Worf, the Forest Service’s first Wilderness program leader has decried the new strategy as “nothing short of the defacto undesignation of Wilderness.”

Researchers have long documented that impacts from recreation use are increasing throughout the Wilderness System. They’ve noted that management strategies based on user education and “leave no trace” messages alone have not been enough to stem the damage. While many managers reluctantly acknowledge that problems exist, for a variety of reasons they’ve been unwilling to risk public criticism or political threats for imposing controls on recreation use. Ignoring the problem has been bad enough, but now the Forest Service has given the status quo its blessing.

The Forest Service plan is laid out in a document simply titled, “Wilderness Recreation Strategy.” The strategy has three parts: 1) protect opportunities for high quality wildland recreation experiences outside Wilderness (this piece of the strategy is being implemented through such efforts as the President’s roadless area initiative); 2) make it a priority to protect low use Wilderness to ensure nondegradation (this has not and probably will not be implemented); and 3) downgrade some existing Wildernesses or parts of Wildernesses to be managed as high-use recreation areas. It’s this third part, the notion that the Wilderness resource can be divvied up so that one component part (i.e. recreation) can be emphasized and the others discarded that threatens to unravel the Wilderness System.

The strategy professes a desire to limit the areal extent of the new high-use class of wilderness, but that’s wishful thinking. Cramming more people into these places will cause more impacts, more crowding, and the high-use areas will keep spreading. The new strategy stands on faith alone — the belief that tomorrow’s managers will have the courage to intervene where today’s managers won’t, and the hope that users who are resisting limits today will support limits tomorrow. Both assumptions run against the grain of reality. All the new strategy really accomplishes is to avoid, or at best postpone, the tough decisions about recreation use that need to be made today. As time goes by there will be fewer options, tougher choices and more degraded Wilderness.

Zoning Wilderness into various degrees of pristineness has long been a part of Wilderness management planning, but the new strategy is fundamentally different. The zoning concept, as it has been historically applied, is guided by the policy of “non-degradation.” In short, the non-degradation policy dictates that the wilderness character of each area will be maintained or improved. It recognizes the inherent diversity in the system – that not all areas will provide the same degree of solitude or exhibit the same lack of evidence from past human use. It requires that when a conflict arises between protecting Wilderness or allowing resource use, that Wilderness values must dominate. Non-degradation recognizes that while no area is ever likely to reach the ideal of “absolute Wilderness,” that the ideal must remain the goal. It also recognizes that some existing conditions are unacceptable and must be improved. This has been the guiding, albeit illusive, policy of national forest Wilderness management since the Wilderness Act passed. It has been memorialized in the Forest Service Manual (see Figure 1).

With the new strategy, the policy of non-degradation is replaced by the policy of accommodating visitor use as the overarching goal for wilderness management. All of the many values of Wilderness–from solitude for humans to security for wildlife–will be forced aside to facilitate ever-increasing recreation use. Conditions that have heretofore been deemed unacceptable will now be appropriate (see Figure 2). Maintaining or improving existing Wilderness conditions will no longer be necessary, thus managers will have vast latitude to decide how much degradation to allow. Controlling impacts in high-use areas won’t be possible without resorting to the kind of management tactics usually associated with developed recreation areas. It won’t be long before more and more trails will be graveled and boardwalked to halt erosion. Toilets will be installed to protect water quality or because many of the new users will find digging cat holes too unappealing. Camping will be restricted to designated campsites with permanent fire grills to limit the profusion of bare ground and fire rings. Firewood will be packed in by rangers or concessionaires in order to protect what little remains of dead or downed wood. Hitchracks and corrals will be provided to contain stock. Rangers will be on regular patrol, and may even offer educational campfire discussions including tales of how it was a few decades back when Wilderness was wild. The purpose of the Wilderness Act, to secure for present and future generations an enduring resource of Wilderness, will have been vanquished as a guiding force for Wilderness management.

All of us who visit Wilderness can cite plenty of evidence where the current management strategies aren’t working. In its best light, the Forest Service’s new strategy represents the very real concern that many parts of the Wilderness System are steady decline and that management must change. (See the article by wilderness researcher David Cole on page 3 for a discussion of options faced by managers.) The FS strategy suggests that the only way to save some parts of the Wilderness System is to sacrifice others. Promoters of the new strategy hope to gain some protection for more pristine areas by granting managers the option to write off others. It’s a choice that’s unacceptable to Wilderness Watch, but one that Wilderness advocates and managers are being forced to confront. And in that light, the new strategy may be doing Wilderness a favor.

Editor’s Note: Upcoming issues of the Watcher will discuss in greater detail some of the key challenges surrounding recreation use. If you would like a copy of the new Forest Service “Wilderness Recreation Strategy,” please contact our office.

— By David Cole, Aldo Leopold Wilderness Research Institute, Rocky Mountain Research Station, U.S. Forest Service

Among the primary benefits of the National Wilderness Preservation System are the recreational opportunities it provides to pursue enjoyable activities, contemplate nature and solitude, grow spiritually and so on. Unfortunately, such use is also among the primary threats to wilderness character. Starting in the 1970s, managers of a number of wildernesses responded to rapidly increasing recreation use by implementing management programs restricting both numbers of visitors and visitor behavior. Through much of the 1980s and 1990s, management emphasis shifted to visitor education. There were reports that wilderness use was no longer growing and hopes that impacts could be controlled by persuading visitors to Leave No Trace. By the late 1990s, however, consideration of further restriction—even in the number of day visitors—is increasing again.

Several recent research studies suggest the need to strengthen and perhaps alter recreation management strategies for the wilderness system. First, there is strong evidence that recreation use of wilderness is increasing. A second disturbing trend is the slow degradation of wilderness lands—particularly those that remain close to the ideal of outstanding opportunities for solitude and being virtually unaffected by recreation use.

Visitor education has not been capable of controlling the proliferation of impact. Ironically, one of the causes of the degradation of low use wilderness is the well-intentioned attempt to reduce recreation impacts in high-use locations in wilderness. The result has often been increased use of locations without use limits, often more lightly-used wilderness. Lightly-used locations are highly vulnerable to being adversely impacted by even small increases in recreation use, because at low use levels, slight increases in frequency of use can cause dramatic increases in impact and slight increases in encounter frequency can cause dramatic reductions in solitude.

What strategies should managers employ to deal with increasing wilderness recreation use and expanding impact? How should they balance the desire to provide free access to the tremendous benefits provided by wilderness recreation with the desire to protect wilderness in a near-pristine and uncrowded state? One option is to attempt to maintain all wilderness lands in a near-pristine condition and to keep use densities at the very low levels necessary to provide the social setting that most wilderness visitors prefer. This option is clearly responsive to the idealized image of wilderness conditions described in the Wilderness Act. However, it would probably mean instituting permit systems and limiting use across the entire wilderness system. This would be particularly unpopular when applied to day use of wilderness.

The second strategic option is to allow unlimited wilderness use everywhere. Management could attempt to mitigate the impacts of increasing use through visitor education, intensive site management and on-site behavioral restriction. This is currently the most common management regime in the wilderness system. The probable costs of this option are the loss of near-pristine conditions and low-user-density experiences across much of the wilderness system and increased crowding in popular locations.

The final two options represent alternative means of compromising between the goal of preserving near-ideal wilderness conditions and the goal of unlimited access. Problems in popular wilderness locations could be reduced by diverting use from high-use locations to low use wilderness. This is the approach currently in place in most wildernesses that have implemented use limits. Research suggests that these benefits (reduced impacts and increased solitude in popular places) may not be that substantial, however, and costs include substantial degradation of conditions in low use wilderness, the places that still are close to the wilderness ideal.

The fourth strategic option—a compromise now being seriously considered by Forest Service wilderness managers—would maintain a broader spectrum of conditions in wilderness. High levels of visitation would be permitted to continue in some locations. At the same time, most wilderness lands would be protected—more aggressively than they currently are—in their current low use condition. The benefits of this approach would be maintenance of most of the wilderness system close to the low use ideal envisioned in the Wilderness Act, while being somewhat responsive to (1) increasing demand for wildland experiences and (2) the preferences of onsite visitors. The costs of this approach are (1) acceptance of substantial social interaction in some high-density wilderness locations and (2) the probable need to restrict access to much of the wilderness system—even the low use lands that experience increased use.

In most wildernesses, recreation use is high and/or increasing, so one of these options must be selected. None of the choices are ideal. As a society, however, it is time to carefully consider the values a wilderness system can provide and develop a recreation management strategy that optimizes those values.

— By Joe Feller

Editors note: In the Spring 1999 Wilderness Watcher, we told you of our efforts to stop a proposed motor vehicle access and a road to a private inholding in the Mt. Tipton Wilderness in Arizona. BLM has yet to make a decision on that proposal. The story below details another egregious breach of Wilderness protection in the largest BLM Wilderness in Arizona.

In two decisions issued on November 24 and November 30, 1999, the Interior Board of Land Appeals (IBLA) affirmed decisions by the Bureau of Land Management (BLM) to authorize a hobby rancher to use a bulldozer to reconstruct long-abandoned jeep roads in and around Peeples Canyon in the Arrastra Mountain Wilderness in western Arizona.

One of the abandoned roads that will be reconstructed leads to a private inholding at the bottom of Peeples Canyon. The others lead to abandoned livestock water developments on three sides of Peeples Canyon. The decisions also authorize the rancher to use a backhoe within the Wilderness to reconstruct all of these water developments, some of which were abandoned so long ago that no traces of them are currently visible.

Peeples Canyon is the centerpiece of the Arrastra Mountain Wilderness and arguably the single most famous feature in any Arizona BLM Wilderness. Arizona Highways magazine has described Peeples Canyon as “one of the wonders of public land in Arizona.” BLM environmental impact statements have described Peeples Canyon as a “rare and lush riparian habitat in the midst of a rugged desert,” as having “exceptional wilderness values,” and as an example of “the rarest and most productive wildlife habitat” in western Arizona. A BLM booklet describes Peeples Canyon as “uniquely pristine.” The state of Arizona has classified the stream in Peeples Canyon as a “Unique Water,” a designation reserved for water bodies that are of “exceptional recreational or ecological significance because of [their] unique attributes.”

The BLM decisions affirmed by the IBLA will have a devastating impact on the wilderness qualities of Peeples Canyon and the Arrastra Mountain Wilderness. According to the BLM’s own environmental assessment, reconstruction of the abandoned road in Peeples Canyon will require “major” and “extensive” earthmoving work on a steep slope within the canyon. According to the same environmental assessment, this work and the subsequent motor vehicle use will create a motor vehicle route within Peeples Canyon that “would look maintained and appear to casual observers as a road receiving regular and continuous use,” will create “long-term” and “permanent” visual impacts in Peeples Canyon that will violate the BLM’s management standards for Wilderness, and may cause the raptors for which Peeples Canyon is famous, including peregrine falcons, to be “forced off their nests during nesting season by the presence and disturbance of humans and vehicles” and to “abandon the area as a nesting site for tracts less exposed to human activity.”

In affirming the two BLM decisions, the IBLA rejected appeals by a coalition of conservation organizations comprising the National Wildlife Federation, The Wilderness Society, the Maricopa Audubon Society, the Yuma Audubon Society, and the Palo Verde and Rincon Groups of the Sierra Club. These appellants had argued that the bulldozing of roads within a congressionally-designated Wilderness would be contrary to the Wilderness Act’s prohibition of roads and contrary to the Act’s command that the BLM “preserve the wilderness character” of the area. They also argued that the BLM had violated the National Environmental Policy Act (NEPA) by failing to consider several alternatives that would have avoided bulldozing roads within the Wilderness. The IBLA summarily rejected all of these arguments.

Secretary of the Interior Bruce Babbitt has the authority to review decisions of the IBLA. The appellants are considering petitioning Secretary Babbitt to overturn these decisions.

For more information contact Joe Feller, College of Law, Arizona State University; Tempe, AZ 85287-7906. (480) 965-3964 (office)(602) 431-6834 (home) joseph.feller@asu.edu.