GIANT SEQUOIA NATIONAL MONUMENT PLAN DRAFT ENVIRONMENTAL IMPACT STATEMENT
The BlueRibbon Coalition comes up with user-friendly alternative to Wilderness Designation.The BRC has developed a less restrictive alternative that is more conducive to public needs and wishes and perhaps more appropriate for what the majority of Americans expect from a Wilderness designation; not the severe and highly restrictive reality of the classification. The Wilderness label is often used quite carelessly – as the letter from Don Amador to Jim Whitfield explains. To help shed some light on the BRC’s proposal and purpose, we’ve included Amador’s letter in its entirety.March 17, 2003
Jim Whitfield, Team Leader
Giant Sequoia National MonumentRe: Giant Sequoia National Monument Plan DEISDear Mr. Whitfield: Please accept these comments to the Giant Sequoia National Monument Plan Draft Environmental Impact Statement (DEIS) on behalf of the BlueRibbon Coalition (BRC), a national trail access organization that promotes responsible use of public lands for multiple-use recreation. These comments shall not preclude other BRC officials or members from submitting their own comments on the DEIS.The BRC commends and supports the agency’s selection of Alternative 6 and its direction to manage the entire Monument with the widest range of management strategies. However, there are a number of areas where the DEIS should be improved and these areas should be addressed and included in the process.ISSUE ONE: In the “Wilderness” category of the section “Management Direction Common to All Alternatives,” you state that the Plan will “Provide for wilderness use, protection of the wilderness resource, and reduction of conflict between the uses of wilderness and the wilderness values of solitude and naturalness… .” This appears to be a misuse of the terms wilderness/Wilderness. We believe “Wilderness” should only be used to refer to lands specifically designated by Congress under the Wilderness Act of 1964. Many “Wilderness advocates” attempt to inject the term “wilderness” into this dialogue in an apparent attempt to create a “buffer” around designated Wilderness and to preclude land managers from allowing certain activities in these “wilderness” lands that some might consider inconsistent with “Wilderness.” The term “wilderness” is a value laden and subjective term that will actually cause conflict between user groups instead of reducing conflict.REMEDY: Delete use of the term “wilderness” from the DEIS and use the term “Wilderness” to refer to lands specifically designated by Congress under the Wilderness Act. Substitute the term “Backcountry” for “wilderness” since that term more accurately describes land in the Monument where “Evidence of man’s activities may be present and obvious to a knowledgeable observer. However, this evidence is not dominant and the landscape is generally perceived as possessing natural or primitive (i.e. Backcountry) characteristics.”ISSUE TWO: The BRC appreciates agency efforts to preserve off-highway vehicle (OHV) use on designated roads. However, we object to the directive that OHV use will been banned on designated trails. Rather than embrace trail closure directives that were adopted without a site specific public process, the BRC believes that OHV use should be allowed on designated trails with historic motorized access. A decision to close an “area” (designated trails) to OHV use represents a final decision which could be challenged by aggrieved parties in accordance with the Supreme Court decision in Ohio Forestry Assn. v. Sierra Club. We feel this is an unjustified risk in a programmatic document like the Plan.REMEDY: Rather than close designated routes to OHVs in the DEIS, the plan should incorporate the route designation process described in the Sierra Framework where the agency will inventory and designate OHV roads, trails, and areas. And, during that process the existing routes will remain open until a site specific analysis is performed. However, we do recognize and support efforts by the Forest to identify and address use causing “adverse” impacts to the resource. Allow continued and historic OHV use on designated roads AND trails within the Monument.ISSUE THREE: There are still outstanding RS2477 assertions on various travelways within the Monument. This legal process, and/or potential remedy, was not adequately addressed in the DEIS. Even if the agency will attempt to regulate travel along such routes this analysis still must occur in a site-specific process similar to that discussed for Issue Two above.REMEDY: Describe agency action to address, and to provide relief for, outstanding RS2477 assertions.I appreciate the opportunity to comment on the DEIS and look forward to working with the agency for the better management of our public lands.Sincerely, Don Amador
Western Representative
BlueRibbon Coalition, Inc.
The BlueRibbon Coalition comes up with user-friendly alternative to Wilderness Designation.The BRC has developed a less restrictive alternative that is more conducive to public needs and wishes and perhaps more appropriate for what the majority of Americans expect from a Wilderness designation; not the severe and highly restrictive reality of the classification. The Wilderness label is often used quite carelessly – as the letter from Don Amador to Jim Whitfield explains. To help shed some light on the BRC’s proposal and purpose, we’ve included Amador’s letter in its entirety.March 17, 2003
Jim Whitfield, Team Leader
Giant Sequoia National MonumentRe: Giant Sequoia National Monument Plan DEISDear Mr. Whitfield: Please accept these comments to the Giant Sequoia National Monument Plan Draft Environmental Impact Statement (DEIS) on behalf of the BlueRibbon Coalition (BRC), a national trail access organization that promotes responsible use of public lands for multiple-use recreation. These comments shall not preclude other BRC officials or members from submitting their own comments on the DEIS.The BRC commends and supports the agency’s selection of Alternative 6 and its direction to manage the entire Monument with the widest range of management strategies. However, there are a number of areas where the DEIS should be improved and these areas should be addressed and included in the process.ISSUE ONE: In the “Wilderness” category of the section “Management Direction Common to All Alternatives,” you state that the Plan will “Provide for wilderness use, protection of the wilderness resource, and reduction of conflict between the uses of wilderness and the wilderness values of solitude and naturalness… .” This appears to be a misuse of the terms wilderness/Wilderness. We believe “Wilderness” should only be used to refer to lands specifically designated by Congress under the Wilderness Act of 1964. Many “Wilderness advocates” attempt to inject the term “wilderness” into this dialogue in an apparent attempt to create a “buffer” around designated Wilderness and to preclude land managers from allowing certain activities in these “wilderness” lands that some might consider inconsistent with “Wilderness.” The term “wilderness” is a value laden and subjective term that will actually cause conflict between user groups instead of reducing conflict.REMEDY: Delete use of the term “wilderness” from the DEIS and use the term “Wilderness” to refer to lands specifically designated by Congress under the Wilderness Act. Substitute the term “Backcountry” for “wilderness” since that term more accurately describes land in the Monument where “Evidence of man’s activities may be present and obvious to a knowledgeable observer. However, this evidence is not dominant and the landscape is generally perceived as possessing natural or primitive (i.e. Backcountry) characteristics.”ISSUE TWO: The BRC appreciates agency efforts to preserve off-highway vehicle (OHV) use on designated roads. However, we object to the directive that OHV use will been banned on designated trails. Rather than embrace trail closure directives that were adopted without a site specific public process, the BRC believes that OHV use should be allowed on designated trails with historic motorized access. A decision to close an “area” (designated trails) to OHV use represents a final decision which could be challenged by aggrieved parties in accordance with the Supreme Court decision in Ohio Forestry Assn. v. Sierra Club. We feel this is an unjustified risk in a programmatic document like the Plan.REMEDY: Rather than close designated routes to OHVs in the DEIS, the plan should incorporate the route designation process described in the Sierra Framework where the agency will inventory and designate OHV roads, trails, and areas. And, during that process the existing routes will remain open until a site specific analysis is performed. However, we do recognize and support efforts by the Forest to identify and address use causing “adverse” impacts to the resource. Allow continued and historic OHV use on designated roads AND trails within the Monument.ISSUE THREE: There are still outstanding RS2477 assertions on various travelways within the Monument. This legal process, and/or potential remedy, was not adequately addressed in the DEIS. Even if the agency will attempt to regulate travel along such routes this analysis still must occur in a site-specific process similar to that discussed for Issue Two above.REMEDY: Describe agency action to address, and to provide relief for, outstanding RS2477 assertions.I appreciate the opportunity to comment on the DEIS and look forward to working with the agency for the better management of our public lands.Sincerely, Don Amador
Western Representative
BlueRibbon Coalition, Inc.
