Dear Reviewing Officer:

From: To: Subject: Date: Attachments: Peter Hart FS-r02admin-review Objection Re: Maroon Bells Snowmass Wilderness Overnight Visitor Use Management Plan Monday, August 14, 2017 8:38:01 PM Final Objection to the Maroon Bells - Snowmass Wilderness Overnight Visitor Use Management Plan.pdf Exhibit A - WW Scoping Comments on the MBSW Overnight Visitor Use Management Plan.pdf Dear Reviewing Officer: Wilderness Workshop (WW), a 501(c)(3) dedicated to the preservation and conservation of the wilderness and natural resources of the White River National Forest and adjacent public lands, respectfully submits the attached objection to the Draft Decision for the Maroon Bells Snowmass Wilderness Overnight Visitor Use Management Plan. Please confirm receipt of this email, the attached objection, and Exhibit A. Thank you, Peter Hart Staff Attorney/Conservation Analyst Wilderness Workshop PO Box 1442 Carbondale, CO 81623 www.wildernessworkshop.org 970.963.3977 (office) 303.475.4915 (cell)

PO BOX 1442, CARBONDALE, CO 81623 www.wildernessworkshop.org 970.963.3977 Via Electronic Submission: r02admin_review@fs.fed.us August 14, 2017 Reviewing Officer c/o USDA Forest Service, Region 2, Rocky Mountain Region Attn. Objection Reviewing Officer-Planning Department 1617 Cole Boulevard, Building 17 Lakewood, CO 80401 Re: Maroon Bells Snowmass Wilderness Overnight Visitor Use Management Plan Dear Reviewing Officer: Wilderness Workshop (WW), a 501(c)(3) dedicated to the preservation and conservation of the wilderness and natural resources of the White River National Forest and adjacent public lands, respectfully submits this objection to the Draft Decision for the Maroon Bells Snowmass Wilderness Overnight Visitor Use Management Plan.1 WW submits this objection pursuant to 36 C.F.R. 218 et seq. WW has a long-standing interest in management and protection of resources within the Maroon Bells Snowmass Wilderness Area (MBSW), and a long track record of participating in agency decisions related to management of the area. WW has participated in this Visitor Use Management Plan throughout the process, and seeks to continue participating through the objection process to ensure the project proposal is finalized in a thoughtful way that ensures protection of important ecological values in the project area. I. GENERAL BACKGROUND WW participated in the planning process by submitting written comments on the Proposed Maroon Bells Snowmass Wilderness Overnight Visitor Use Management Plan as well as the 1 The Draft Decision was noticed by officials from the White River National Forest in the Glenwood Springs Post Independent on June 29, 2017. See http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/1042 54_FSPLT3_4032381.pdf, at 2 (last accessed 8/14/17). 1

accompanying Draft Overnight Visitor Use Management Plan (hereinafter, Plan ). 2 WW s prior comments qualify the organization as an entity that may file an objection to this project. 36 C.F.R. 218.2, 218.5(a). This objection is timely filed via email within 45 days of publication of the legal notice in the Glenwood Springs Post Independent. 36 C.F.R. 218.9. WW provides the following information pursuant to 36 C.F.R. 218.8: Interested Person s Name and Address (36 C.F.R. 218.8(d)(1)): Sloan Shoemaker Executive Director Wilderness Workshop P.O. Box 1442 Carbondale, CO 81623 Phone: (970) 963-3977 Email: sloan@wildernessworkshop.org Name of Proposed Project, responsible official, and location (36 C.F.R. 218.8(d)(4)): Name: Maroon Bells Snowmass Wilderness Overnight Visitor Use Management Plan Responsible Official: Forest Supervisor Scott Fitzwilliams Location: White River National Forest, Aspen Sopris Ranger District; Grand Mesa, Uncompahgre and Gunnison National Forest, Gunnison Ranger District. II. GENERAL INTEREST AND NATURE OF OBJECTION WW supports the Overnight Visitor Use Management Plan and commends the Forest Service for recognizing enduring and significant problems related to the overuse of certain areas in the MBSW, including Crater Lake, the Four Pass Loop and the Conundrum Hot Springs. WW supports the Plan s direction and management actions, especially: (1) the Plan s adaptive nature and phased application across the entire MBSW; (2) the target permit system limiting the number of visitors in order to deal with overnight user s biophysical impacts and increase in resource damage; (3) establishing a zoning system across the MBSW; and (4) establishing a system of designated campsites in areas of intensive use while documenting damage to natural resources. WW submits this objection to participate in the process and assist the Forest Service in continued effort to address the degradation of natural resources in the MBSW while simultaneously preserving visitors ability to experience unconfined and primitive recreational opportunities in the area. WW seeks to assist the Forest Service in resolving any and all objections related to the Plan in a collaborative manner that is consistent with the review process pursuant to 36 C.F.R. 218.11. If there are objection resolution meetings, WW requests an opportunity to participate in those meetings. 2 Wilderness Workshop s December 5, 2016 comment letter is attached hereto as Exhibit A and referred to throughout this objection as WW Scoping Comments. 2

III. WILDERNESS WORKSHOP S ISSUES IN DETAIL WW made three specific suggestions pertaining to the Draft Environmental Assessment and the Draft Plan. WW asked the Forest Service to clarify language describing when a permit system will be implemented. See WW Scoping Comments, at 4. Within the Draft Plan, in tables 7, 8, 9 the Forest Service has taken into consideration WW s suggestion and clarified language from If a Zone GAOT capacity threshold is exceeded in any 3 years of a 5 year period, implement a GAOT capacity allocation (permit) system to If the GOAT capacity threshold for any zone is exceeded in any 3 years of a 5 year period, implement a GAOT capacity allocation (permit) system. We support this clarification and want to ensure the changes are carried forward in any plan implemented after objections are resolved. Further, WW appreciates the Forest Service s accounting for the difference in visitation rates between seasons and proposing a limited entry permit system rather than requiring permits for zones that have not exceeded the GAOT threshold. Nonetheless, WW hopes the Forest Service will consider decreasing zone GAOT allocation numbers prior to the implementation of this project. See WW Scoping Comments, at 2-3. WW did ask the Forest Service to consider seasonal use of the permit system. See WW Scoping Comments, at 2. The agency chose not to address this concern for several reasons. See MBSW VUM Plan, Environmental Assessment, Appendices 1, at 5. WW understands the agency s rationale, but would like to continue participating in any relevant conversations that occur during the objection period. Lastly, WW agrees with the Forest Service that the majority of the management actions discussed in Tables 7, 8, and 9 are designed to address issues that specifically arise from highintensity use. WW does not oppose any of the management actions and understands that specific conditions or impacts may necessitate the use of all or a subset of these actions. However, WW believes that the problem is best addressed and most effectively handled by targeting the root of the problem high-intensity use, which is directly caused by too many people. Therefore, by limiting the zone GAOT allocation and decreasing the numbers, the management actions could be limited to a smaller set. Minimizing the intensity and amount of regulations any given MBSW visitor is required to comply with will also help maintain visitors wilderness experience, which is supposed to be about solitude, freedom, exploration and adventure. We hope to work with the Forest Service through the objection process to minimize and streamline the number of regulations visitors to the MBSW must navigate. IV. CONCLUSION WW applauds the Forest Service for addressing the problem of high-use in the MBSW, particularly in the summer season. WW supports the Plan s adaptive nature and inclusion of a Permit System as a tool to effectively address the biophysical impact from intense overnight use while aiming to preserve the natural conditions of the MBSW and continue to provide, as close 3

as possible, unconfined and primitive recreational opportunities. WW looks forward to participating in the Forest Service s objection process for the Maroon Bells Snowmass Wilderness Overnight Visitor Use Management Plan. WW also looks forward to assisting the Forest Service educate users about the Plan and implement the Plan effectively. Respectfully submitted, Sloan Shoemaker Executive Director 4

* Wilderness Workshop * Scott Fitzwilliams Erin Carey USDA Forest Service Sopris Ranger District White River National Forest 620 Main Street, Carbondale, CO, 81623 via e-mail: ebcarey@fs.fed.us December 5 th, 2016 Dear Mr. Fitzwilliams and Ms. Carey, The following are the Wilderness Workshop (WW) scoping comments on the proposed Maroon Bells - Snowmass Wilderness Overnight Visitor Use Management Plan as described in the Scoping Letter (SL) dated November 2nd, 2016 and the accompanying Draft Overnight Visitor Us Management Plan (Plan). Wilderness Workshop (WW) is a 501(c)(3) dedicated to preservation and conservation of the wilderness and natural resources of the White River National Forest and adjacent public lands. WW engages in research, education, legal advocacy and grassroots organizing to protect the ecological integrity of local landscapes and public lands. WW focuses on the monitoring and conservation of air and water quality, wildlife species and habitat, natural communities and lands of wilderness quality. WW is the oldest environmental nonprofit in the Roaring Fork Valley, dating back to 1967 with a membership base of over 800. Many of our members live, work, recreate and otherwise use and enjoy lands managed by the WRNF including the Maroon Bells-Snowmass Wilderness (MBSW). Our founders were instrumental in the expansion of the MBSW and our organization has been deeply involved in the ongoing management, monitoring and protection of the MBSW for our organization s entire history. I. INTRODUCTION Wilderness Workshop is fully supportive of the proposed Overnight Visitor Us Management Plan. We applaud the Forest Service for recognizing the significant and ongoing problems associated with the popularity and overuse of certain areas of the MBSW and think the proposed Plan is commensurate to the problem at hand. We are glad to see this proactive step being taken and are committed to supporting the Forest Service s decision and any future implementation. Below we include several minor thoughts and suggestions concerning the Plan and are eager to work with the Forest Service to help with any refinements during the NEPA process. II. SUPPORT FOR THE PLAN Wilderness Workshop strongly supports the direction and management actions proposed in the Forest Service s Overnight Visitor Use Management Plan for the Maroon Bells- Snowmass Wilderness Area. The Maroon Bells-Snowmass Wilderness is one of the 1

country s premier wilderness areas yet is threatened by significant over use in several popular locations. Over the past decade or more, the number of overnight visitors has significantly increased leading to a degradation of both the ecological values and the human experience. The proposed Plan is an important and needed step to resolving these issues. Wilderness Workshop would be happy to partner with the F.S. to help educate the public about the importance and benefits of the Plan. We support the adaptive nature of the Plan and its application across the entire wilderness area, as this will allow for additional steps to address existing and future problems associated with visitor use across the entire wilderness area. We support the use of a targeted permit system to deal with the increasing resource damage. We applaud the solution of creating a zone system across the wilderness area, which will determine where a permit system is needed. Allowing visitors to generally camp anywhere within a zone for which they have a permit will help to maintain wilderness values of solitude, adventure and exploration. We also understand and support the need for instituting a system of designated campsites in areas of intensive use and documented damage to natural resources. III.CONSIDER SEASONAL USE OF THE PERMIT SYSTEM AND OTHER MANAGAMENT TOOLS While the MBSW is heavily used in the summer months, it sees very little overnight visitor use during the winter when trails are snow covered. The scoping documents do not differentiate between summer and winter use of the MBSW or specific high use locations. Wilderness Workshop recommends that the Environmental Assessment analyze which months see the highest visitation to determine if a permit system is required and/or would make a difference in visitation of the MBSW during the winter. We also acknowledge that a summer only permit season may have the affect of increasing use in otherwise less visited times of year as visitors look to avoid a permit, the Forest Service may also want to consider this impacts. We recommend that a permit system not be employed during the winter due to low amounts of visitor use and the likelihood that use will be spread out rather than concentrated due to the inability of visitors to locate established campsites or even certain trails. Instituting a permit system is important but changes the experience of the visitor. If it is not necessary to implement a year round permit system, we recommend implementing only a seasonal permit system. IV. PRIORITIZE PERMIT SYSTEM AND GAOT REDUCTIONS IN MANAGEMENT ACTION PHASE 3 In tables 7,8 and 9 the Draft Overnight Visitor Us Management Plan (Plan) identifies a series of management actions if certain thresholds are reached for five indicators of impact to the MBSW. These management actions are divided into three phases. For all indicators except GAOT/Zone, phase three management actions include all or a subset of the following: Implement site specific or area closures. Implement length of stay limits. 2

Implement dog prohibitions. Implement campfire prohibitions. Implement seasonal closures. Implement group size limits. Restrict stock use and/or numbers. Require human waste pack out. Restrict camping to designated campsites. Restrict travel to one-way. Restrict trailhead parking. Decrease zone GAOT allocation. Because a number of these management actions are likely to affect visitors experience in the MBSW, Wilderness Workshop recommends prioritizing decreasing zone GOAT allocation numbers prior to implementation of some of these management actions. Specifically, the following actions should only be implemented after zone GAOT allocations have been decreased and been proven to be insufficient to achieve management goals: Restrict camping to designated campsites. Restrict travel to one-way. Implement campfire prohibitions. Implement seasonal closures. Implement group size limits, Implement site specific or area closures. Implement length of stay limits. Because most of these management actions are designed to address issues that arise from a high intensity of use, decreasing the zone GAOT allocation will likely be the most effective tool to address the issues. Thought of another way, the seven management actions listed above are symptoms of an underlying problem (too many people), whereas decreasing the zone GAOT allocation addresses the root cause itself. To be clear we are not opposed to any of these management actions and understand certain impacts or conditions may require the use of any or all of these actions. Our intent is to minimize the amount and intensity of regulations a visitor to the MBSW will encounter. It is our opinion that visitors would rather have a permit system in more zones (or fewer permits available), but that once a permit was obtained, regulations would be as minimal as possible. This will help ensure that wilderness experiences such as solitude, adventure, freedom and exploration continue to be a part of visitor s time in the MBSW. In other words it s better to have fewer visitors who get as traditional a wilderness experience as possible than more visitors spending time in a more regulated environment (perhaps similar to what they would encounter in a National Park). 3

V. CLARIFY THE LANGUAGE FOR WHEN A PERMIT SYSTEM WILL BE IMPLEMENTED. Management Action Phase 2 for the indicator GAOT/Zone states, If a Zone GAOT capacity threshold is exceeded in any 3 years of a 5 year period, implement a GAOT capacity allocation (permit) system. Initial GAOT capacity allocations are displayed in Table XX1. This statement is not entirely clear as to what will trigger a permit system. Wilderness Workshop recommends changing the statement to: If the GOAT capacity threshold for any zone is exceeded in any 3 years of a 5 year period, implement a GAOT capacity allocation (permit) system. Initial GAOT capacity allocations are displayed in Table XX. VI. CONCLUSION Wilderness Workshop commends the Forest Service for addressing the problem of highuse in the MBSW. We support the adaptive nature of the Plan that includes a permit system as one way to address the impacts to highly popular locations in the Wilderness. Furthermore, we appreciate the use of a zone system that not only limits the permit system to targeted areas where it is needed but also helps to maintain a traditional wilderness experience for the visitor. We recommend several small adjustments to the Plan to further maintain as unstructured an experience as possible for the visitor, namely by prioritizing the use of a permit system of decreasing the number of available permits. We also support the full range of management actions proposed in the Plan. We look forward to helping the Forest Service in the design, education and implementation of the Plan. Sincerely, Will Roush Conservation Director Wilderness Workshop PO Box 1442 Carbondale, CO 81623 www.wildernessworkshop.org 970.963.3977 (office) 206.979.4016 (cell) 1 The correct table number should be added to this for the final Plan. 4