By Brett Haverstick

I arrived at the Corn Creek trailhead about 4 p.m. in the afternoon. The sun was still hot, and the river canyon felt like an oven, particularly for May. After a few hours of hiking along the trail, I reached Horse Creek, a small tributary of the Salmon River. The creek was loud and brimming bank-to-bank with spring runoff. I decided to cross the creek using the foot-bridge—it was the wrong time of the year to wade into the water and attempt a stream crossing!

by Harriet Greene

Wind River Range, Bridger Wilderness, Pinedale, Wyoming: 

by Kevin Proescholdt

The recent decision by Forest Service District Ranger Crystal Powell to deny the permit to run the La Luz Trail Run race through the Sandia Mountain Wilderness may be understandably unpopular with some runners and race organizers (“La Luz race hits end of trail as Forest Service denies permit,” Albuquerque Journal, May 15). But this decision is the proper one to protect the wilderness character of this iconic area.

Wilderness is the most protective land designation in the United States. My organization, Wilderness Watch, works to safeguard Wildernesses around the country. We often challenge Forest Service decisions and occasionally take the agency to court when it violates the 1964 Wilderness Act. But in the case of the La Luz race permit, the Forest Service has made the right decision in accordance with the Wilderness Act and agency policies, and there are good reasons for runners and others to support this decision.

Wildernesses contain a huge array of values, many of them intangible like protecting opportunities for solitude, and some of them more tangible like protecting wildlife and increasingly scarce habitat. These values go far deeper than physical impacts to trails or whether litter is left behind. Wildernesses are emblematic of our human recognition of their inherent wildness, and symbolic of our society’s need for restraint and humility in dealing with them. By designating an area as wilderness, we recognize that area’s right to function on its own, without the active management and manipulation used on other federal lands and without the types of intensive intrusions prominent there.

Commercial activities and competitive races degrade a wilderness’s wild character. They detract from an area’s wildness and make an area more like the lands overrun by civilization, rather than “in contrast with those areas where man and his works dominate the landscape,” as the Wilderness Act states. That’s why the framers of the Wilderness Act and Congress included a prohibition on commercial activities in designated wildernesses, with only a very narrow exception for some outfitting and guiding activities. The Forest Service’s wilderness regulations also contain prohibitions on commercial activities and competitive events.

I sympathize with organizers of the trail run, particularly when the race has occurred since before Congress designated the Sandia Mountain Wilderness. But all across the country are examples of activities once allowed in areas that have needed to end after an area was designated as wilderness, all to better protect the wild character of these special lands for future generations and for wildlife, which are continually squeezed into smaller and smaller pockets of secure habitat. In Minnesota’s Boundary Waters Canoe Area Wilderness (BWCAW), for example, the 1978 BWCAW Act ended many activities, including a competitive international canoe race, to better protect the area.

Other options likely exist for the race. A few years back, the organizers of a winter sled dog race wanted to route its race through a portion of the BWCAW. The Forest Service appropriately rejected that proposed route, and the race organizers eventually selected a different route. That outcome­—finding another venue or route outside of designated wilderness—may also well work for La Luz Trail Run, a far better outcome than weakening protections for the Sandia Mountain Wilderness.

Editor's note: Kevin's piece ran in the Albuquerque Journal on 5/31: https://www.abqjournal.com/2395565/ending-la-lu-zrun-safeguards-wilderness-2.html
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by Suez Jacobson

A long wait – almost 50 years – to learn

How deeply and completely

The wild magic of the Boundary Waters

Could burrow.

A self-identified mountain girl

Lost to still, flat black water

Contained by granite outcroppings

Layered in midnight green pines

Topped with iridescent spring birches.

by Dana Johnson

Along the high-elevation, wind-swept ridges of the West, a long-lived, gnarly-branched pine is in trouble.  A species of stone pine known for its high stress tolerance and adaptability, whitebark pine is slow-growing and can live between 500 – 1,000 years.  Lacking wings for wind-dispersal, its calorie-dense seeds are spread primarily by Clark’s Nutcracker, a member of the crow family with a specialized bill for extracting large seeds from pinecones and a pouch under its tongue for stashing and carrying seeds long distance.  Those seeds are a prized food source for a range of species, including the imperiled grizzly bear. 

As tough as the species is, whitebark pine is facing mounting pressures from climate change, decades of fire suppression, blister rust, mountain pine beetles, and competing conifers migrating to higher elevations in response to warming temperatures.  Already found at high elevations, many worry that whitebark pine will have nowhere to run. 

This cocktail of stressors has landed whitebark pine on the short-list for federal listing under the Endangered Species Act.  Unfortunately, the proposed listing rule allows logging and other “forest management” activities in whitebark pine habitat, and is, per usual, loudly silent on actions that might address the underlying causes of global warming.  Instead, it focuses heavily on intervention and manipulation strategies—like selectively breeding and planting blister rust resistant trees, pruning and thinning stands, fighting back other migrating conifers with logging, applying insecticides and pheromones, and even wrapping pinecones in wire mesh to keep red squirrels and Clark’s nutcrackers from getting at the seeds.

This is a familiar story.  Humans are exceedingly bad at exercising restraint and simply not doing things.  Rather than drastically reducing consumption, travel, recreation, and development—things that take real personal and political sacrifice but create space for other species to exist—we put an enormous amount of effort into developing technologies that enable us to continue with business as usual or at least provide a veil of plausible deniability regarding our impact on the world.  Slap enough windmills on the hilltops, and we’ll never have to slow down.  Gather enough data on wildlife, and we can invade their space with abandon.  Or, worst case, fire up the helicopters, pluck the critters from their homes, slap tracking collars on their necks, and drop them elsewhere.  There is a deep tendency to treat everything as if it is merely an engineering challenge that is solvable with enough data and ingenuity (and money). 

This is not to say we shouldn’t pursue things less harmful than our current things—we’ve dug quite an overwhelming hole with climate change, and we need to be creative in how we deal with it.  But too often our efforts are tunnel-visioned on maintaining the status quo, and the tougher conversations about how we exist on this planet are altogether muted. 

Take for instance grizzly bears.  A widely cited research paper states that “[h]umans are the primary agent of death” for grizzlies.  We know this.  When humans and bears mix, bears end up dead.  So, areas with less human access and activity (e.g. recreation, logging, fast-moving cars and trains, etc.) are areas with fewer dead bears.  And in areas with greater human activity, we sorely need greater tolerance (and compassion) for bears.  As with so many other species reacting to rapidly changing conditions, we need to provide grizzlies with the space to move and adapt, and we need to keep open minds about what that might look like.  Yet, in the whitebark pine listing rule, the Fish and Wildlife Service downplays the importance of whitebark pine as a food for grizzlies calling them “opportunistic feeders.”  But whitebark pine is often found in remote, high elevation sites away from humans.  When whitebark pine seeds are scarce, bears search out other food, which often brings them into lower elevations and in closer contact with humans.  We don’t much care for the idea of sharing our favorite creek-side trail with a berry-munching grizzly or dealing with potholes in our golf courses from a bear digging up earthworms, so when an “opportunistic” bear ends up in our space, we trap the bear and move him back to his allotted “recovery zone.”  And if the bear crosses our line in the sand again—looking for food, or a mate, or a new home—we kill him, and we go to great pains gathering more data and rationalizing all the reasons why this is the way of things, why we don’t need to change our own behavior or ask, “What gives us the right?”

These tendencies toward control and entitlement make our collective agreement on Wilderness pretty remarkable.  Wilderness is a conscious reflection of human restraint—a place where we decided there is value in Nature’s own wild order, in the autonomy and freedom of the wild, and in allowing the land to play whatever hand it is dealt without our intentional interference.  It is a recognition that we don’t and can’t know everything and that we might learn something if we step back and observe what happens when we don’t impose our will.  Because of this, unsurprisingly, Wilderness is some of the best habitat left for species trying to eke out an existence alongside humans.  

The idea of Wilderness as a self-willed landscape has been a difficult one for land management agencies.  They have an ingrained history of modifying public lands to achieve “desired conditions,” an idea laden with value bias even in the best of times.  Throw climate change and all of its uncertainties into the mix, and the increasing urge to actively maintain static conditions becomes all the more problematic. 

Even though the agencies often resist it on the ground, their policy guidance reflects the value in Wilderness.  Agency guidance states, “Wilderness areas are living ecosystems in a constant state of evolution[,]” and “[i]t is not the intent of wilderness stewardship to arrest this evolution in an attempt to preserve character existing” at some prior time.  And, “A key descriptor of wilderness in the Wilderness Act, untrammeled refers to the freedom of a landscape from the human intent to permanently intervene, alter, control, or manipulate natural conditions or processes.”  And, “Maintaining wilderness character requires an attitude of humility and restraint. We preserve wilderness character by … imposing limits on ourselves.”  In Wilderness, we “[p]rovide an environment where the forces of natural selection and survival rather than human actions determine which and what numbers of wildlife species will exist.” 

Agency policy is taking a notable turn.  One agency stated its “policy prior to climate change was to take a ‘hands-off’ approach where overt human influences were not the primary reasons for population fluctuations.”  It now believes its role is shifting to  adaptive management to maintain “natural conditions,” and this conversation is growing across the agencies.  This—at its core—is a conversation about whether we will allow Wilderness to persist into the future. 

This shift is reflected in the proposed whitebark pine rule.  It lists Wilderness under “Challenges to Restoration,” setting the stage for conflict between an imperiled species and an imperiled landscape.  But this is likely a false conflict.  Roughly 29 percent of whitebark pine habitat is in Wilderness.  Given the variables and unintended consequences inherent in manipulations, that 29 percent should be set aside as an important baseline for comparison to our tinkerings elsewhere.  The listing rule acknowledges “a high degree of uncertainty inherent in any predictions of species responses to a variety of climate change scenarios. This is particularly true for whitebark pine given it is very long lived, has a widespread distribution, has complex interactions with other competitor tree species, relies on Clark’s nutcracker for both distribution and regeneration, and has significant threats present from disease, predation, and fire.”

It also acknowledges “[t]here is no known way to control, reduce, or eliminate either mountain pine beetle or white pine blister rust…particularly at the landscape scale needed to effectively conserve this species.”  In fact, “the vast scale at which planting rust-resistant trees would need to occur, long timeframes in which restoration efficacy could be assessed, and limited funding and resources, will make it challenging to restore whitebark pine throughout its range. One estimate indicates that if planting continues at its current pace, it would take over 5000 years to cover just 5 percent of the range of whitebark pine[.]”

This does not appear to be a scenario where we have to grapple with fine lines.  There is no discrete, human-caused disruption in Wilderness that can be corrected with a discrete, short-lived intervention.  This is not an errant patch of spotted knapweed along a stock trail that can be pulled.  But it is illustrative of the moral and ethical questions coming our way.  Climate change will continue to cause vast changes in the world as we know it, and we will see more attempts to mitigate the effects through ongoing, counterbalancing manipulations.  The question will be whether we lose Wilderness in the process. 

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Dana Johnson is the staff attorney for Wilderness Watch, a national wilderness conservation organization headquartered in Missoula, MT, www.wildernessswatch.org.

Photo: Keith Hammer

by Howie Wolke

In late October, Marilyn and I headed south for a 226 mile 21-day float trip down the Grand Canyon of the Colorado River. There were four of us, in two rafts. For most of the 20,000 or so folks who annually float the Colorado, the scenery and numerous challenging rapids are big attractions. But for Marilyn and me, the big draw was the vast desert wilderness that the river punctuates. Although I hadn’t rowed challenging whitewater in nearly two decades, we all made it through the rapids upright, though I had a few close calls.

Wilderness. The Big Outside (Foreman and Wolke, Revised Edition 1992) inventoried the Grand Canyon wildland complex at 2,700,000 acres of roadless country in one unbroken block, the fourth largest such area in the lower 48 states. The 2.7 million acre wildland includes over a million roadless acres within Grand Canyon National Park, but also a number of contiguous national forest and BLM roadless areas and designated wildernesses. 

by George Nickas

A while back I received an email from the founders of a recently established organization that was created out of a concern for the “wilderness visitor.” They wrote to challenge Wilderness Watch’s long-time insistence that the fundamental mandate in the Wilderness Act requires managers to—first and foremost—protect each area’s wilderness character. They claim WW’s position misinterprets the law, has incorrectly shaped the views of much of the conservation community and, to the degree we influence the federal agencies, caused them to protect Wilderness from the people.

The gist of their argument is that Wilderness was established to provide recreation opportunities, and that the emphasis many put on protection is diminishing the recreational opportunities that Wilderness affords. To bolster their view they point to language in the law, repeated three or four times, that says wilderness areas “shall be administered for the use and enjoyment” of the American people. The law’s protection requirements, according to their point of view, are operative to the degree they don’t unduly interfere with the overarching purpose of providing recreational opportunities.

I’ve heard variations of this argument before. A long-time wilderness advocate once tried to convince me that recreation was the chief purpose of the Wilderness Act, and as proof offered that the Act uses the words “use and enjoyment” or “recreation” a combined seven times, while “protect” or its derivatives are used only five. I replied that since the Wilderness Act uses the word “mining” 11 times, maybe it was mining, not recreation or protection that the Act sought to achieve! It ended that discussion, but obviously hasn’t ended the debate.

The purpose of the Wilderness Act was never lost on the Act’s architect and supporters. Testifying to Congress in 1962, the law’s chief author and lobbyist Howard Zahniser, explained, “The purpose of the Wilderness Act is to preserve the wilderness character of the areas to be included in the wilderness system, not to establish any particular use.” This directive was codified in the statute with the clear mandate that “[e]ach agency administering any area designated as wilderness shall be responsible for preserving the wilderness character of the area and shall so administer such area for such other purposes for which it may have been established as also to preserve its wilderness character.”

The benefits of “use and enjoyment” of Wilderness were also high on Zahniser’s list, but the concept wasn’t merely synonymous with recreation. He understood the phrase in a much more expansive and meaningful way. Responding to a critic who claimed it was rather selfish to set aside large areas for the limited few who would use them, Zahniser insisted that those who sought out wilderness deserved the opportunity to experience it, but he also explained that the use and enjoyment extended to

“many people who never even hope to explore it…they find relief and inspiration in the wilderness vicariously, and a consciousness of its existence is essential to them. This may be hard to explain, but the people I know who want the wilderness saved for these reasons greatly outnumber those I know who want the wilderness saved for their own excursions.”*

None of this suggests recreation isn’t an important public purpose of Wilderness. To many of us our time spent in Wilderness is essential to our being. But Wilderness is valuable for many reasons, including for its own sake; it doesn’t derive its value from us. Wilderness can exist and thrive without recreation, and indeed some areas do, but for us to have an authentic wilderness experience there has to be a real Wilderness to enjoy.

*Quoted from “The Wilderness Writings of Howard Zahniser,” by Mark Harvey. A must read for wilderness advocates who want to understand more about the person, the ideas and the language underpinning the Wilderness Act.
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George Nickas is the executive director of Wilderness Watch.

By Paul Willis

There is an art of conducting oneself in the lower regions by the memory of what one saw higher up.  —René Daumal, Mount Analogue

Sitting here, high on the shoulder of a peak in the Ansel Adams Wilderness, I am looking down at a grassy swale where I startled a herd of eleven mule deer. From this height they are now too small to be seen, but they kept their ground as I detoured around them on scree and talus, not wanting to disturb their pasture. And looking down in the other direction, a blood-red canyon drops away to the round expanse of an alkali lake, from this vantage point its two or three islands an obvious continuation of a series of craters to the south. And, looking up, the summit of the mountain I'm on rises gently, inviting me to visit before thunderheads build and explode, just as they did yesterday on my way down another summit. Such a relief to be lost in sky, no other purpose beyond placing the next boot, the next hoof.     

By Ned Vasquez

For many years, dating back even to my childhood, I have dreamed of spending time in the Alaskan wilderness. In August, 2019 this dream became a reality when my middle daughter and I spent 9 days rafting the Kongakut River in the Arctic National Wildlife Refuge.

Our trip was organized through a guiding company based in Fairbanks. Our group consisted of 6 clients and 2 guides and we were fortunate to have a highly compatible group. The guiding company did an excellent job of orienting us to the nature of the Arctic National Wildlife Refuge and ensured that we were as minimally impactful as possible.

By Frank Keim

Old days drift slowly into new days

and the white eye of the Arctic sun rolls

bright across the night,

as we trek

south

up the Hulahula River,

named more than a century ago

by Hawaiian whalers stranded

on an ocean cold and frozen

before its time.

by Howie Wolke

INTRODUCTION

In 2016, legendary ecologist Edward O. Wilson published Half Earth: Our Planet’s Fight for Life. In this remarkable book, Wilson documents the ongoing anthropogenic planet-wide biological meltdown, the greatest extinction event since a meteor crashed into the Gulf of Mexico, about 60 million years ago. As a remedy, Wilson argues for protecting half of the Earth’s terrestrial acreage as inviolate nature reserves.

Flash back to the early 1980s. The original wilderness-focused Earth First! suggested that a fair balance for wilderness and civilization might be 50% for each. It was called “crazy”, “radical”, “unrealistic” and other terms of endearment not fit for print. And in my 1991 book Wilderness on the Rocks, I suggested that 30% of the U.S. be designated wilderness as a short term goal. That was also ridiculed as “unrealistic”.

Today, the “Nature Needs Half” coalition is promoting Wilson’s vision, and the “Thirty by Thirty” movement is gaining traction in the mainstream political discourse. Its goal is to protect 30% of the Earth’s landscape in nature reserves by the year 2030. The 30/30 goal is now considered by many to be attainable. And it is gratifying to see land protection efforts of this magnitude inch their way into the public discourse. The 30/30 goal does not mean that 30% of the land would be designated wilderness in the United States. Wilderness is our highest level of protection and it will be an important part of the equation. But other protective strategies, which also protect natural habitats for wildlife, biodiversity and other ecosystem values, will also be essential, especially for lands that lack wilderness characteristics. The purpose of this essay is to advance the discussion on how to effectively protect nearly a third of the U.S. landscape, including but not limited to designated wilderness.

DISCUSSION

30/30 would be a great start toward Wilson’s more thorough vision of Half Earth. But in my view, it is just that: a great start. Increasing numbers of scientists have concluded that 30/30 is the minimum starting point for conserving native biodiversity. The International Union for the Conservation of Nature (IUCN) has endorsed 30/30, along with a growing list of American and international conservation groups.

President Joe Biden has endorsed 30/30, as has California Governor Gavin Newsom. There is also plenty of public support for protecting wildlands. According to a poll by the Center for American Progress, about 86% of Americans support the 30/30 concept, including 76% of polled Republicans. Clearly, when it comes to land protection, there is a huge disconnect between Republican politicians and the rank and file.

The extinction crisis is driven by habitat destruction and fragmentation, pollution, poaching, the proliferation of exotic weed species plus climate change. The meltdown is fueled by a growing human population that continues to expand unabated like a spreading cancer into remaining natural habitats around the globe, displacing native life and ecosystems. Some ecologists estimate that half of the estimated 10 million species that we share the planet with could be extinct or plummeting toward the eternal abyss by late this century. Thus, the need to protect land and water becomes more acute. Conservation biologists assert that we need to protect big interconnected landscapes as nature reserves.

Of course, protecting wild nature isn’t just about countering the biological meltdown. Wilderness is the primary repository of 3.5 billion years of organic evolution on this blue green spinning ball of life that we call Earth. Wilderness is the fundamental environment that shaped all known life, including humans, though many deny this primal connection. That’s why new wilderness designations and good wilderness stewardship should top the 30/30 agenda, while recognizing that other kinds of land protections will also be essential.

I also believe that wild nature has intrinsic value, something that’s worthwhile for its own sake, independent of the multitude of benefits it provides humans. That’s my primary motive as a conservationist. Many of us simply love all that is wild—and we know deep in our primate bones that Aldo Leopold said it best: “A thing is right when it tends to preserve the integrity, stability and beauty of the biotic community. It is wrong when it tends otherwise.”

“Untrammeled”, “primeval”, “natural”, and “where the imprint of man’s (sic) work is substantially unnoticeable” are phrases used in the 1964 Wilderness Act to define designated wilderness (I believe the authors of the Wilderness Act used the term “natural” to describe a landscape dominated by native plants and animals. Thus I do not consider croplands, livestock pastures and monocultures of exotic weeds to be “natural”). Today's National Wilderness Preservation System encompasses about 111 million acres, or about 4% of the U.S. landscape. Yet about half of that acreage is in Arctic and Subarctic Alaska, whereas only about 2.7% of the lower 48 states is designated Wilderness.

Because of this geographic disparity, for the 30/30 campaign, let’s view these two geographies through distinct lenses, so that at least 30% of the lower 48 is protected. And, let’s set the 2030 goal for Alaska at 50%. In that vast realm that’s still mostly wild, achieving Wilson’s goal would be easy, at least from a landscape viewpoint. For starters in Alaska, the Naval Petroleum Reserve (keep that oil in the ground, where it won’t harm the atmosphere!), the entire Alaska Range east of Denali, and most of the Chugach and Tongass national forests should all be protected as designated wilderness.

Where do we find 30%—or 50%—of our landscape to protect? Start with the existing National Wilderness Preservation System (2.7% of the lower 48 states). Then, add protections for all roadless areas, wilderness study areas, and backcountry areas administered by our four federal land management agencies. Based upon research I did back in the 1980s, I estimate that roughly 12-15% of the land area of the lower 48 states is in a wilderness or near-wilderness condition. This includes over a hundred million additional acres—according to agency inventories—of wilderness or semi-wilderness quality lands in the lower 48 states, in national forest and BLM-administered roadless areas and Wilderness Study Areas alone! We can also designate many new national parks, monuments and wildlife refuges.

States can also add to the protected acreage by adding parks and wildlife preserves. A few states already maintain significant protected wildland acreages: New York’s Adirondack Forest Preserve, for example. In the private domain, large holdings with conservation easements and protected holdings of land trusts and conservancies might also qualify as “protected” lands under 30/30. We can also use additional tax incentives for conservation easements plus the Land and Water Conservation fund to acquire additional conservation lands.

In addition, we can restore the wilds! There is vast potential for wildland restoration (“re-wilding”) across tens of millions of acres of the public domain. We can even restore wilderness. The Wilderness Act’s authors never intended for the definition of wilderness to preclude lands that were less than pristine. Note that according to the Wilderness Act, the imprint of humanity’s work must simply be “substantially unnoticeable”. In fact, Congress can and has designated wilderness for lands that had been previously roaded, clearcut and otherwise developed. Once designated, under the Wilderness Act, agencies must manage such lands as wilderness, letting nature re-wild the landscape. In fact, most wilderness areas in the eastern U.S. have been re-wilding themselves, for the most part just by being left alone.

Yet agency bureaucrats routinely violate the Wilderness Act by allowing illegal developments in designated wilderness. And Congress too often enacts wilderness bills with special provisions (for example allowing for off-road vehicular use in wilderness for ranchers) which weaken wilderness protections. Nonetheless, in this imperfect world, designated wilderness remains our highest level of land protection in the U.S., and should be a big component of the 30/30 movement. Thus, as we move toward 30/30, keeping designated wilderness areas truly wild (the primary mission of Wilderness Watch) will assume even more importance!

I mentioned entrenched bureaucrats. Here’s an example: According to Custer-Gallatin National Forest Supervisor Mary Erickson, “I view all public lands as being protected.” It is hard to believe, I know, but yes, I heard her say that. Thus, in her worldview, giant eroding weed-infested clearcuts, roads gouged across 45-degree slopes (including a 400,000+ mile road network on national forest lands alone!), open- pit mines, oil fields, ORV sacrifice areas, heavily fenced livestock pastures with devastated riparian zones, exotic weed monocultures, dams, pipelines, power corridors, ski areas, summer homes and more constitute the fabric of “protected” public lands. We must guard against bureaucrats who would water down the meaning of “protected” land. Otherwise, 30/30 will be used to simply rubber stamp existing agency mismanagement.

SPECIFICS

Which brings us to the central question of both the Nature Needs Half and the 30/30 movements: “What constitutes ‘protected’ land?” We need definitive standards in addition to those in the Wilderness Act, which will assure that all of the 30% is really protected. 

For example, the U.S. Geological Survey defines 4 levels of land protection called “Gap Status”. Status level 1 represents the strictest level of protection and Status 4 the least. Without detailing each of these levels, I would argue that even Gap Status 1 is weak, and that Status levels 2 through 4 represent little more than business as usual for public lands under typical agency multiple (ab)use management. For the record, Gap Status 1 is defined as

     An area having permanent protection from conversion of natural land cover and a mandated management plan in operation to maintain a natural state within which disturbance events ( of a natural type, frequency, intensity and legacy) are allowed to proceed without interference or are mimicked through management.

Here's another, slightly better definition of protected land utilized by the International Union for the Conservation of Nature (IUCN) and the United Nations Environment Programme (UNEP):

     A protected area is a clearly defined geographical space, recognized, dedicated and managed, through legal or other effective means, to achieve long term conservation of nature with associated ecosystem services and cultural values.

I propose that we combine the best aspects of the above two definitions, and then further strengthen the definition with a few caveats. My proposed definition of protected land:

     A clearly defined geographical area having permanent protection through legal or legislated or other effective means, to achieve long term conservation of nature with associated ecosystem services and cultural values. Natural conditions are maintained and the conversion of natural native land cover is precluded. Natural disturbance events and processes such as wildfire, flood and predation, are allowed and encouraged.

I believe this to be a workable definition, with the following caveats:

• Mechanized Travel must be restricted to designated roads within reserves.
• New road construction is prohibited.
• Resource extraction such as mining, oil drilling and commercial logging are prohibited.
• Lands that have been impacted in the past, including logged over lands and lands with limited or primitive road networks, can be included if a management plan is in place to restore and maintain wild and natural conditions (re-wilding).
• In some regions of the world, existing subsistence hunting/gathering/fishing rights—preferably via traditional primitive means—might continue, depending upon the circumstance. However, this question probably merits more of a discussion than is practical in this brief overview.
  
  

Here are some examples of lands that could constitute our protected 30%:

• The National Wilderness Preservation System
• National forest and BLM Roadless areas and Wilderness Study Areas
• Protected state wildlands such as those in New York’s Adirondack Forest Preserve
• National Parks
• National Monuments
• National Wildlife Refuges
• Forest Service and BLM-administered multiple use lands in which a plan is in place to restore wild and natural conditions (re-wilding).
• Private conservation lands in which natural conditions are maintained via conservation easement or other legal protection(s)
• About 24 million acres of lands included in the Northern Rockies Ecosystem Protection Act, which designates new wilderness areas, biological corridors, and wildland recovery areas in the U.S. Northern Rockies.
• Protected public and private lands in Montana’s growing American Prairie Reserve
• Existing and potential biological corridors
  
  

Here are a few examples of lands that should NOT be included in the “protection” category:

• Lands that are intensively grazed and managed primarily for livestock production
• Croplands or manicured urban parks not characterized by native vegetation, even if they are maintained as “open space” by conservation easements
• Typical Forest Service- and BLM-administered “multiple use lands” that are managed for timber production, livestock, minerals, and mechanized transportation. As noted above, such lands can be moved into “protected” status if a re-wilding plan replaces “multiple abuse”.

And finally, the first step to 30/30 should be a National Wildlands Inventory conducted by an independent panel of scientists to identify both public and privately-owned wildlands that could qualify for some level of protected status under a 30/30 plan. Part of the inventory—and ultimately part of the 30/30 plan—should specifically identify the country’s major eco-regions, to assure that each ecoregion  has at least one protected area that is large enough (and/or functionally interconnected with other nearby wild areas) to support most of the native keystone species—large carnivores, for example —for that ecosystem.

SUMMARY

Wildland conservation has an opportunity to move forward with a bold plan to protect wilderness and other wild habitats on nearly one third of our landscape. Conservation groups can support the 30/30 movement as a minimum starting point, looking ahead to E.O. Wilson’s Half Earth vision as the long term goal.

Achieving 30/30 will not be easy. It faces a hostile gauntlet of the usual bad actors: entrenched bureaucrats, myopic and corrupt elected officials plus the industry lobbies that work to thwart most conservation initiatives. Not to mention the rapidly expanding army of mechanized recreationists, including mountain bike organizations. Yet the history of conservation proves that commitment and determination can overcome enormous political obstacles. Today’s global ecological crisis demands that we dramatically increase land and water protections. This includes pushing for maximum protected acreage for wilderness quality lands and other areas that remain relatively natural and wild.

Like cockroaches, humans can adapt to and even thrive in nearly every artificial environment imaginable. Like Mumbai, for example. Or Houston. Or the expansive monocultural wastelands of Kansas. But is cockroach habitat and vast impoverished human-scapes the world that we wish to pass on? The least we can do for future generations of both human and non-human life is to approach wildland conservation as though the survival of life as we know it on Earth depends upon it—which in fact, it does. Enacting a strong 30/30 plan would be a great start.

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Howie Wolke is a long-time wilderness proponent. He has been a board member for Wilderness Watch on and off for over two decades, including two terms as President. He is a retired wilderness backpacking and canoeing guide/outfitter who now enjoys wilderness adventure without having to be responsible for others. He and his wife, Marilyn Olsen, and their dog Rio live in the foothills of the Gallatin Range, just north of Yellowstone National Park in southern Montana.

Author’s note: Thanks go to Marilyn Olsen and Wilderness Watch board member René Voss for their suggested edits, many of which have been incorporated into the final version. However, any errors and anything the reader might deem to be offensive are entirely my responsibility.

By Cathy Brandt

Due to life-long arthritis and now a bit of the "A" word (age), I can't hike very deep into wilderness areas. However, when I do I'm looking to experience solitude—to get away from masses of people and their litter, cell phones, dogs barking, and aircraft noise. It's very sad that some people have never been away from these distractions and never know what they're missing.

We all deserve wild solitude and I feel human beings actually need it. In the wild all of our senses experience fresh cues, and our lungs take in more clean air and oxygen. For some of us, it can also be a very emotional experience. A few tears may be shed at the sight of a wondrous peak, or a gurgling moss-lined creek. Wild places are my church, and many would agree with me on that!

By Scott Crain

The Juniper Dunes Wilderness area is a 7000-acre part of the National Wilderness Preservation System, located in southeastern Washington State. It lies just a few miles north of what used to be a quiet part of the state, now exploding with population and development. The Hanford Nuclear Reservation lies a few miles to the southwest, one of the most polluted nuclear waste sites in the country. Just outside the barbed wire fence that surrounds Juniper Dunes lies an off-road vehicle area promoted by the Bureau of Land Management for ORVs and other motorized activities. 

I was born and raised a few miles south in Pasco. When I was a kid, the Dunes, as we called them, were a place to go target shooting, driving four wheelers, and doing all sorts of other things that our parents didn't want to know about. I've moved on, but those activities continue unabated right up to the wilderness boundary.

By Kevin Proescholdt

In August, my family and I enjoyed our second canoe trip of the summer in the Boundary Waters Canoe Area Wilderness (BWCAW) of northeastern Minnesota.  The 1.1 million-acre BWCAW is a lakeland wilderness with over 1,000 lakes connected by rivers, streams and portage trails. It is part of Superior National Forest and is one of the most visited (if not the most visited) Wilderness in the National Wilderness Preservation System.

We enjoyed five days of paddling, portaging, camping, swimming, fishing, and laughing.  But we did have to contend with strong winds almost the entire trip, including becoming windbound overnight at a point of land where the strong west winds howled unimpeded along many miles of open lake.

By Jessica Howell-Edwards

Cumberland Island Wilderness is part of the Cumberland Island National Seashore in southern Georgia, administered by the National Park Service (NPS). It was previously sanctioned as a UN Biosphere Reserve, and is located just miles from Kings Bay Naval Base and also nuclear warhead storage.

I firmly believe that all Wilderness experiences have the potential to be transformative in our lives, but Cumberland Island Wilderness offers a complex variation of ecosystems that only a southeastern barrier island can: towering sand dunes, freshwater lakes, maritime forest, salt marshes, and deserted beaches.

By René Voss

So now I know why people came up with the idea of aerial spraying DDT to kill pesky bugs ... like the thousands of mosquitoes that attacked me over the summer solstice in the Emigrant Wilderness.  Relentless beasts!

As I was walking out of the Wilderness I struck an interesting conversation with a fellow hiker who was local and had been visiting the Emigrant Wilderness for over 50 years.  He said he had seen many changes since he first started hiking there as a kid.  His name was Larry.  I know this because he was wearing a "Larry" belt buckle ... local for sure.

By Brett Haverstick

I just returned from a recent backpacking trip into one of our nation’s first Wilderness areas, the Selway-Bitterroot Wilderness of north central Idaho and western Montana. It was a typical June trip in the Northern Rockies with thunder, lightning, rain, hail, clouds, and sun. The forests were greening up, the rivers and creeks flowing at a strong clip, and the birds were both active in flight and song. My personal trip diary reflected that I observed bald eagles, osprey, red-tailed hawks, ravens, pileated woodpeckers, hummingbirds, western tanagers, Canada geese, common mergansers, and more.

by Dana Johnson

You might recall that in January 2016, the U.S. Forest Service authorized Idaho Department of Fish and Game (IDFG) to make 120 helicopter landings in the River of No Return Wilderness to place radio telemetry collars on 60 elk, despite the Wilderness Act’s clear prohibition on motorized intrusions and its directive to preserve an untrammeled Wilderness. To our knowledge, this was the most extensive helicopter intrusion in Wilderness that has ever been authorized. IDFG said the project was necessary to study an elk-population decline that has occurred since the return of gray wolves to the Wilderness and to inform IDFG’s future decisions concerning hunting, trapping, and “predator control” actions in the Wilderness.

Represented by Earthjustice, Wilderness Watch, Friends of the Clearwater, and Western Watersheds Project filed suit in Federal District Court—hours after receiving a copy of the signed special use permit authorizing project implementation. Within the next three days—over the weekend—while the suit was pending and before we could get before the judge, IDFG inundated the River of No Return Wilderness with repeated helicopter flights and landings. And, even though it was abundantly clear IDFG was not authorized to harass and collar wolves, IDFG nonetheless captured and collared four wolves. IDFG released those 60 elk and four wolves with collars transmitting precise location points to IDFG – an agency with an unapologetic history of wolf extermination efforts and a current plan to “aggressively manage elk and predator populations,” including exterminating 60 percent of wolves within the Middle Fork Zone of the River of No Return Wilderness.

The judge assigned to the case was no stranger to this issue. Back in 2010, after the reintroduction of wolves in Idaho, the same judge sat on our case where IDFG requested permission from the Forest Service to use helicopters to dart and collar at least one wolf in every pack in the same area. The judge reluctantly allowed the activity because the case represented the “most rare of circumstances” where “[i]t was man who wiped out the wolf from this area[, and] now man is attempting to restore the wilderness character of the area by returning the wolf.” But, the judge noted “the next helicopter proposal in the [Wilderness] will face a daunting review,” and “[t]he Forest Service must proceed very cautiously here because the law is not on their side if they intend to proceed with further helicopter projects in the [Wilderness].” The judge also put the Forest Service on notice that it “would be expected to render a final decision [on any future helicopter projects in the Wilderness] enough in advance of the project so that any lawsuit seeking to enjoin the project could be fully litigated.” 

Not surprisingly, the judge was concerned that “[t]he agency ignore[d] that directive in the present case,” and then the agencies argued that the Court didn’t have jurisdiction to review the case because IDFG had already completed the action. The Court rejected that argument, found the Forest Service in violation of the Wilderness Act and the National Environmental Policy Act, and enjoined IDFG and the Forest Service from utilizing the fruits of their illegal activity. Specifically, the judge’s order 1) forbade the Forest Service from considering the data from the illegally placed collars and from approving any future wildlife-related helicopter projects without delaying implementation for at least 90 days to allow time for litigation, 2) forbade IDFG from using any of the illegally obtained collaring data to justify future collaring proposals in Wilderness, and 3) ordered IDFG to destroy data received from the collars.

Both the Forest Service and IDFG appealed that ruling to the Ninth Circuit Court of Appeals. But, the appeal was narrow. The agencies did not contest their violations of the Wilderness Act and NEPA. Instead, they argued, once again, that the Court did not have jurisdiction to hear the case in the first place because the action was already done and that, even if it did have jurisdiction, it went too far in its injunction against IDFG and the Forest Service. 

In March 2020, after four years of litigation, we received an opinion from the Ninth Circuit largely upholding the lower Court’s order but narrowing the injunction. The Circuit reduced the 90-day implementation delay to 30 days, and it held IDFG does not need to destroy the data it obtained, but the Forest Service cannot consider that data as a basis for any future projects in the Wilderness. Importantly, the Circuit flatly rejected the argument that the case could evade judicial review by virtue of the agencies rushing to complete the project before the judge could rule, noting:

[The Forest Service] was aware that Wilderness Watch had lodged objections to the proposed operation and planned to challenge the permit in court at the first opportunity. On Wednesday, January 6, 2016, Wilderness Watch received notice of final agency action and requested a copy of the permit. On Thursday, January 7, Wilderness Watch received a copy of the permit, effective immediately, and filed its complaint. Wilderness Watch requested that the agency halt implementation of the operation to allow for a legal challenge. [The Forest Service] did not respond to this request until close of business on Friday, January 8. The agency denied the request. Wilderness Watch prepared a motion for emergency injunctive relief on Saturday, expecting to file it first thing on Monday, only to receive notification on Sunday that the operation had been completed earlier that morning. This sequence of events transpired in spite of the district court’s admonishment to [the Forest Service], in a 2010 proceeding regarding a similar helicopter operation, that the agency would be expected to issue future permits with enough time to allow for potential legal challenges. The record shows that in the weeks leading up to the issuance of the subject permit, Wilderness Watch reminded [the Forest Service] of the 2010 order. The record also makes clear that IDFG plans future helicopter operations, and that [the Forest Service] approval was motivated, at least in part, by the IDFG’s threat to proceed irrespective of [the Forest Service’s] approval and the [the Forest Service’s] desire to avoid litigation with the [IDFG] Director.

While this ruling will make it more difficult for the agencies to avoid judicial review of similar projects in the future, we know we have not seen the last of IDFG’s relentless focus on killing wolves, and we know they’ve got their eyes set on the River of No Return Wilderness. And, as the Ninth Circuit observed, the Forest Service has taken pains to avoid a show-down with IDFG—we have no indication this will change either. In fact, shortly after we received news of the Ninth Circuit opinion, IDFG announced that it killed 17 wolves in the Lolo area in Idaho—a remote, roadless area in the Nez Perce-Clearwater National Forest north of the Selway-Bitterroot Wilderness. Wolves in the Lolo area have been brutally targeted by IDFG for years in an effort to inflate elk numbers to meet IDFG’s objectives. We know from Freedom of Information Act documents and other reports that IDFG regularly utilizes GPS collaring data to track and kill wolves, oftentimes through aerial gunning. Even more appalling, the documents and reports also show that IDFG and cooperating agencies utilize “Judas wolves”—a collared wolf that is tracked to its pack via GPS data. The pack is killed, but the collared “Judas wolf” is spared and then tracked until it establishes with another pack. Then that pack is gunned down, once again sparing the collared wolf who is doomed to repeat this horrible cycle over and over again. 

IDFG’s narrative about the Lolo area sounds remarkably similar to the story it is telling about the Frank Church-River of No Return Wilderness. It has a plan to kill 60 percent of the wolves in the heart of the Wilderness to return elk numbers to levels observed in the 1990s – before the return of wolves to the Wilderness and before the restoration of natural predator / prey dynamics. We assume IDFG will pull no punches in pursuing that goal. We’ve already seen, and challenged, IDFG’s use of a professional trapper to kill two resident wolf packs—the Golden Creek and Monumental Creek packs—deep in the Wilderness. The Forest Service authorized IDFG’s use of a Forest Service cabin to serve as the trapper’s base camp, and it waived special use permit requirements, which allowed IDFG to proceed without public notice or federal oversight. As noted above, we challenged two IDFG helicopter-assisted collaring projects in the Wilderness, both geared toward advancing IDFG’s Elk Management Plan and its “aggressive” predator control measures. These projects were carried out under authorization from the Forest Service, including the rushed implementation of the second project in blatant disregard of a federal court order. And, in the last year, IDFG has significantly relaxed hunting limits on wolves and pushed to open airstrips within and adjacent to the Wilderness to increase hunter access. 

All of this is going on with Forest Service acquiescence and to the detriment of Wilderness, the values it safeguards, and the wild places and animals that find increasingly rare refuge within its borders. The Forest Service—the agency entrusted to protect this Wilderness pursuant to the tenets of the Wilderness Act—has demonstrated that it finds IDFG the squeakiest wheel. We will keep the pressure on in the courts, but we need to be louder than IDFG. We need to raise our collective voice in defense of this incredible place, in defense of the animals who call it home, and in defense of the idea of Wilderness. Intensive manipulation of wildlife populations is fundamentally antithetical to preserving “an area where the earth and its community of life are untrammeled by man” and “primeval character and influence” are retained. The use of helicopters to pursue, capture, and place telemetry tracking collars on wild animals deep within the Wilderness—to transmit their every movement to a computer, manned by a “game” agency that places high value on control and manipulation—is fundamentally antithetical to everything Wilderness is about. It’s well beyond time for the Forest Service to take a stand for Wilderness.

And, even though its track-record is not encouraging, IDFG can also take this as an opportunity to pivot. IDFG will face growing public opposition to its wolf eradication and Wilderness manipulation efforts, and the latest court case has made it much more difficult for IDFG’s activities to slide under the radar of judicial review. It is time for IDFG to adopt an approach to wildlife management that respects natural processes and Wilderness. It is incumbent upon the Forest Service to ensure this happens.

You can help defend wolves and Wilderness in Idaho by writing to the responsible U.S. Forest Service officials and demand they stop sanctioning Idaho’s aggressive predator killing programs.

You can also make a special donation to Wilderness Watch to help us continue the fight to defend wolves and Wilderness in Idaho.

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Dana Johnson is the staff attorney for Wilderness Watch, a national wilderness conservation organization headquartered in Missoula, MT, www.wildernessswatch.org.

What’s All the Buzz in the Boundary Waters?

by Dana Johnson

The Boundary Waters Canoe Area Wilderness (BWCAW) is located within the Superior National Forest in Minnesota and stretches over 115 miles along the Minnesota-Ontario border. The Wilderness, along with Canada’s adjoining Quetico Provincial Park, protects a complex ecosystem of nearly 3,000 glacial lakes connected by a vast, meandering network of streams and portages. This watery landscape is home to a diverse mix of wildlife, and it holds one of the largest remnants of uncut forest east of the Rockies. Humans have relied upon its natural abundance for centuries, including the Ojibwe who navigated its waterways in birch bark canoes. More recently, the area offers an increasingly rare connection to a world that existed before an expanding population, with all of its fast-paced and heavily consumptive interests, took hold.

Efforts to protect this area from the fallouts of Westward Expansion, industrialization, and motorization span back over a century culminating in the designation of the BWCAW. Sigurd Olson, one of the eloquent leaders in the push to protect the Boundary Waters, recognized a tie between the silence of the canoe and something we were losing through the story of progress—the knowledge of what it is to be of and with the land and waters. 

"The movement of a canoe is like a reed in the wind. Silence is part of it, and the sounds of lapping water, bird songs, and wind in the trees. It is part of the medium through which it floats, the sky, the water, the shores.... There is magic in the feel of a paddle and the movement of a canoe, a magic compounded of distance, adventure, solitude, and peace. The way of a canoe is the way of the wilderness, and of a freedom almost forgotten. It is an antidote to insecurity, the open door to waterways of ages past and a way of life with profound and abiding satisfactions." -Sigurd Olson, The Singing Wilderness, 1956

Sigurd would be troubled to learn that roughly one-fifth of the Wilderness’s waterways are still subjected to the persistent back and forth buzzing of motorboats including, on some routes, commercial towboats carting paying clients and their canoes to campsites and remote drop-off locations within the Wilderness, turning many entry-points and travel routes into busy motorways. The popular entry point of Moose Lake, where commercial towboat use is particularly excessive, is known for its motorized bottlenecks and the whine of engines. During one trip to survey the Moose Lake entry-point, Wilderness Watch staff were told by an outfitter that Wilderness visitors who would not otherwise consider a motorized tow regularly take a tow because paddling through motorized use areas is so unpleasant. The motorized mess in the Boundary Waters is a good example of why when Wilderness areas are designated it is so important to make sure it’s via a clean wilderness bill, without special provisions. 

The Wilderness Act was passed as a counterweight to “an increasing population, accompanied by expanding settlement and growing mechanization,” and to safeguard a few wild areas “in contrast with those areas where man and his own works dominate the landscape.”[1] It expressly prohibits motorized and mechanized uses within Wilderness recognizing that these things represented the opposite of the restraint and humility needed to guard against our compulsion to stand as masters and controllers of the world around us.

It was in this context that the Boundary Waters Canoe Area Wilderness was designated as one of the original Wildernesses in the 1964 Wilderness Act. Unfortunately, due to the familiar story of political pressure, the Wilderness Act included a confusing special provision allowing motorized use already existing in the BWCAW, as long as such use would not undermine the “primitive character of the area.”[2] Motorized use always undermines the primitive character of a wilderness area—that’s why the Wilderness Act prohibits it! This provision was short-lived. In response to “the confusion and litigation generated by the proviso, as well as in reaction to threatened deterioration of the wilderness from excessive use,”[3] Congress repealed the special provision and enacted the BWCAW Act of 1978.[4]

Unfortunately, once again due to political pressure, Congress was not able to eliminate motorboat use outright. Instead, this time around, Congress prohibited all motorboat use within the Wilderness except on a few specifically named lakes, instituted phase-outs of motorized use on other lakes, and imposed motor size restrictions.[5] On lakes where motorboat use was allowed, Congress set a statutory cap at “the average actual annual motorboat use of the calendar years 1976, 1977, and 1978 for each lake,”[6] and the Forest Service calculated and allocated that cap through a series of entry point quotas for each lake. What followed was decades of confused and inconsistent statutory application, an indecipherable hodgepodge of management policies and practices, multiple rounds of litigation, and an increase in particular types of motorized use to the detriment of the Wilderness. Commercial towboat use is a prime example. 

Congress did not expressly contemplate the continued use of commercial towboats when it passed the BWCAW Act in ’78, and the Forest Service has never been clear on how it monitors commercial towboat use in relation to the overall statutory cap on motorboat use. That notwithstanding, towboat use continued, and the Forest Service adopted measures to regulate it in the 1993 BWCAW Management Plan. The Plan required towboat operators to obtain special use permits, and it limited towboat use to “1992 levels for numbers of boats, trips, current operators, and specific lakes.” However, Wilderness Watch learned from a series of Freedom of Information Act requests that the Forest Service has not consistently monitored actual commercial towboat use since the inception of the BWCAW Act or since the 1993 Plan, it does not appear to know what the level of towboat trips from 1992 was, it has allowed some commercial towboat operators to run towboat services without a special use permit, and it appears that actual commercial towboat use has been steadily increasing.

Making matters worse, the Wilderness Act prohibits commercial enterprise in Wilderness with the exception of certain “necessary” commercial services.[7] The exception requires a specific finding of necessity—something typically done through a “commercial needs assessment” with requisite public involvement and formal National Environmental Policy Act review. The Forest Service had not done this either, and it wasn’t about to. So, we sued. That lawsuit resulted in a settlement where the Forest Service agreed to prepare a commercial needs assessment to get a handle on the current amount of actual towboat use in the Wilderness, make a determination on whether towboat services are necessary at all—particularly given their impact on wilderness character, and if the Forest Service deems them necessary, to what extent. The Forest Service agreed to complete this process by November 2019.

The Forest Service produced a document that attempts to assess the amount of current towboat use, but it doesn’t assess that use in the context of the overall regulatory scheme (the limitations imposed by the Act and the Plan) and explain how current use is within those limits, it does not analyze necessity in the context of impacts to wilderness character and opportunities for motorized recreation outside of Wilderness, and a host of other issues. You can read our concerns about the Forest Service’s Draft Needs Assessment here: https://wildernesswatch.org/images/wild-issues/2019/10-09-2019-WW-Comments-BWCAW-CNA.pdf.  Likely in response to the concerns we raised in the Draft Needs Assessment, the Final Needs Assessment included a reference to an “extent necessary worksheet” that might address some of our concerns (and comply with the settlement agreement). However, in a nod to Orwell, when we submitted a Freedom of Information Act request for this worksheet, the Forest Service refused to give it to us saying the information was privileged and exempt from disclosure. 

The Forest Service has indicated it will likely, at an undisclosed point in the future, engage in National Environmental Policy Act review of commercial towboat use in the BWCAW. We’ll keep everyone posted about that process and encourage public involvement when the time comes. In the meantime, the towboats keep buzzing under the cloak of regulatory ambiguity and agency confusion, and we’re assessing our options for additional legal challenges. The moral of the story: Clean, simple wilderness bills without special provisions best protect Wilderness, and we must keep demanding them from Congress. In an era where much of the environmental movement has become apologetic in its approach to land protection, it isn’t surprising that wilderness bills littered with compromise are considered the norm. And we know we can’t expect the agencies to do the right thing without constant vigilance and pressure.

The very idea of Wilderness is on the line, and we must keep the courage to hold that line.

[1] 16 U.S.C. § 1131(a), (c).

[2] 16 U.S.C § 1133(d)(5) (1976), repealed by Pub. L. No. 95-495, 92 Stat. 1649, 1650 (1978).

[3] Minnesota v. Block, 660 F.2d 1240, 1246 (8th Cir. 1981).

[4] Pub. L. No. 95-495, 92 Stat. 1649 (1978). 

[5] Pub. L. No. 95-495, T92 Stat. 1649 (1978), 92 Stat. at 1650, 4.

[6] Pub. L. No. 95-495, T92 Stat. 1649 (1978), 92 Stat. at 1651, 4(f).

[7] 16 U.S.C. § 1133(d)(5).

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Dana Johnson is the staff attorney for Wilderness Watch, a national wilderness conservation organization headquartered in Missoula, MT, www.wildernessswatch.org.

by Kevin Proescholdt

At the end of October, Wilderness Watch filed a formal objection to the new Final Land Management Plan for the Chugach National Forest in response to the Forest Service’s seemingly intentional disregard for protecting the 2 million-acre Nellie Juan-College Fiord Wilderness Study Area (WSA) that is part of the Chugach. In January, Wilderness Watch participated in an objection resolution meeting with the Forest Service, though the agency has not yet ruled on any of the objections we raised.

The Congressionally-designated Nellie Juan-College Fiord WSA in Alaska’s western Prince William Sound is an ecological and scenic treasure of roughly 2 million acres of ancient rainforest, stunning mountains, sprawling glaciers, and meandering fiords laced with hundreds of remote islands. The Nellie Juan-College Fiord WSA is also the nation’s largest Wilderness Study Area.

Not a single acre of Wilderness has been designated on the 5.4 million-acre Chugach National Forest, further elevating the importance of protecting the Nellie Juan-College Fiord WSA. Unfortunately, the agency’s Final Land Management Plan for the Chugach fails abysmally to protect the wilderness character of the Nellie Juan-College Fiord WSA.

Wilderness Watch filed the formal objection with Alaska Wilderness League, Eyak Preservation Council, WildEarth Guardians, and the Wilderness Society, highlighting the following concerns:

• The Final Plan downgrades protection for the WSA.  The past two Chugach management plans have directed the Forest Service to protect “presently existing wilderness character” of the WSA, but the new plan downgrades that management to the undefined and meaningless standard of “presently existing character,” which would allow never-ending degradation over time. 
   
• The Final Plan eliminates use of the Minimum Requirements Analysis (MRA), a tool for protecting wilderness. The 1964 Wilderness Act generally prohibits the use of motor vehicles, motorized equipment, structures and installations, allowing their use only if it is “necessary to meet minimum requirements for the administration of the area” to preserve its wilderness character. Congress included this clause in the Wilderness Act to minimize the use of nonconforming activities that agencies often want to do when stewarding Wilderness.  Though terribly weak and are often abused by the agencies, the MRA process is still better than nothing. The Forest Service completely eliminated the use of MRA in the Final Chugach Plan, suggesting the agency has little or no intention to analyze the impacts of its management activities on the WSA’s wilderness character.
   
• The Final Plan eliminates WSA protection for 100,000 acres of wilderness-quality lands.  The federal government acquired lands from other ownerships within the boundaries of the Nellie Juan-College Fiord WSA as part of the settlement following the Exxon Valdez Oil Spill (EVOS) in 1989. Past Chugach National Forest plans haven’t differentiated between WSA lands and EVOS-acquired lands within the WSA, but the new Final Plan does, and creates a new management area classification for the EVOS lands that could well lead to degradation and development over time. The Forest Service should instead equally protect the EVOS-acquired lands by managing them as WSA lands, and the agency should also recommend the EVOS-acquired lands within the WSA for wilderness designation.
   
• The Final Plan needs a larger Wilderness recommendation.  As part of any Forest Plan, the Forest Service recommends to Congress areas that the agency believes should be formally designated as Wilderness. The agency recommended only 1.4 million acres of the 2 million-acre WSA for Wilderness designation. But this is Alaska, after all, home to some of the wildest, largest, and most magnificent wilderness lands in the nation, including the Nellie Juan-College Fiord WSA.  The agency should instead recommend all of the qualifying lands in and adjacent to the WSA for Wilderness designation.
   
• The Final Plan fails to protect Chugach National Forest roadless areas. The Final Plan fails to incorporate Roadless Rule protection for all Inventoried Roadless Areas on the Chugach. The Inventoried Roadless Areas are National Forest lands on the Chugach outside of the WSA that retain wild and roadless characteristics. Particularly with the Forest Service proposing in a separate action (the Alaska Specific Roadless Rule) that the protection for any Alaska roadless area could be eliminated after a 45-day comment period, the need to protect the Inventoried Roadless Areas on the Chugach is greater than ever. The Final Plan should incorporate Roadless Rule protections for these roadless areas on the Chugach so they retain some protection even if the Alaska Specific Roadless Rule is adopted.
  
  

The formal administrative objection process continues, as Wilderness Watch and our allies urge the Forest Service to protect the wilderness lands on the Chugach and in the Nellie Juan-College Fiord WSA. We will continue to fight to protect the wild character of the magnificent Nellie Juan-College Fiord Wilderness Study Area so that future generations may also know the awe-inspiring beauty and magnificent wilderness qualities of these nationally important lands.

Read our Objection
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