Rock Creek Stakeholders Concerns & Responses

NOTE: The following are WWA’s responses to the specific Rock Creek stakeholders’ questions and concerns that were brought up during our Rock Creek Stakeholders Meeting on December 12, 2007. Each individual received a personalized letter addressing the specific concerns he or she raised. For this public record, we won’t identify who presented each question or concern, but we have represented every single one of them here. Because we want you to see the responses as we authored them to each individual, some of them may contain similar information or research. The only changes that have been made are for clarification and to respect the stakeholders’ privacy. Also, we have linked the appropriate research and references throughout these responses to make all the supporting documentation convenient and accessible; when clicking on some of these links you will be leaving the Wyoming Wilderness Association website.

Please contact our office at (307)672-2751 or email dave@wildwyo.org with any questions or comments.

Ensuring the maintenance of both the Cloud Peak and Willow Park Reservoirs is not only an immediate interest to the Ditch Company, but is a matter of public health and safety. As such, keeping this access and preserving maintenance options are paramount in the establishment of the Rock Creek area as wilderness. Although the proposed wilderness boundary may have been drawn on the map to include many areas that will require motorized access and mechanized management activities, Wyoming Wilderness Association’s (WWA) goal in this process of meeting with members of the Ditch Company individually, as well as orchestrating the stakeholders meeting, was to identify specific areas where mechanized management activities are needed so that we can draw an appropriate boundary that will accommodate everyone’s needs.

We thank you for your input and sharing these specific areas with us, and we will work with the Forest Service (FS) and Congress to adjust the boundary to help ensure that we can provide adequate access to areas along the north side of the proposed wilderness. We do not want to prevent any management activities or exclude any historical users of the Rock Creek area when it becomes wilderness, so our intention is to work to exclude these specific areas from the recommended wilderness by adjusting the boundary to give these areas a standard 200-foot buffer. Excluding these areas from the wilderness will form an ideal area that both allows the necessary management activities and protects the wilderness qualities of peace and quiet, solitude, and primitive use. WWA suggests a future meeting to ensure that boundary adjustments are satisfactory in allowing for necessary management activities.

The original FS proposed wilderness boundary included many areas and structures - including the horse pasture, Hepp Cow camp, and caretakers’ cabins - that will require motorized access and mechanized management activities. WWA’s goal in this process of meeting with stakeholders is to identify these areas so that an appropriate boundary can be drawn in an attempt to accommodate everyone’s needs and allow for continued activities in those areas.

We thank you for sharing these specific areas with us, and we will work with the FS and Congress to adjust the boundary to help ensure that we can provide adequate access to areas along the north side of the proposed wilderness. We do not want to prevent any management activities or exclude any historical users of the Rock Creek area when it becomes wilderness, so our intention is to work to exclude these specific areas from the recommended wilderness by adjusting the boundary around them and giving them the standard 200-foot buffer.

In order to maintain the possibility of mechanized use for dealing with downfall or other obstructions, as you mentioned, the buffer would also be utilized where the northern part of the proposed boundary approaches Ditch Creek. This will provide ample space for any management or maintenance that needs to occur on the ditch, as well as allowing mechanized and motorized uses to continue unhindered in the other identified areas as well. By working to adjust the boundary to exclude these areas from the wilderness, we will form an ideal area that both allows the necessary management activities and protects the wilderness qualities of peace and quiet, solitude, and primitive use.

Again, we thank you for this information on a specific area that needs to be excluded from the wilderness. As far as we can tell, the area where the test holes are will be adequately buffered and left out of the proposed wilderness. We may need to follow up with you on exactly where these holes are to ensure we have the right area. Wyoming Wilderness Association will advocate for access to be maintained so that equipment will be able to get in there and do what needs to be done for the upkeep of the reservoir.

WWA understands the importance of trail maintenance to the area guest ranches, given the history and traditional uses of the Rock Creek area for guest outings and horse packing. The National Wilderness Act of 1964 was passed to ensure that areas in the National Wilderness Preservation System are managed in ways that protect the natural, wild qualities of the area, as well as the experiences of solitude and primitive, unconfined recreation. The National Wilderness Act of 1964 defines wilderness as:

“A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this chapter an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value (emphasis added).”

The quality of solitude and the opportunities for primitive and unconfined recreation are often the very aspects of our western landscapes that provide the allure and attraction for out-of-state visitors.

Typically, trail maintenance in wilderness is done with non-motorized and non-mechanized means to minimize the evidence of human work and to prevent noise pollution associated with chainsaws and other mechanized equipment, therefore minimizing the evidence of human presence and preserving the opportunity for a true wilderness experience.

However, we understand it is essential to be able to maintain trails to ensure access to the area. When dealing with downed trees, this usually translates into the use of axes, bucking saws (single person), and cross-cut saws (two people). But, according to Craig Cope, Wilderness Director for the BNF, when clearing trees with these hand tools presents a hazard to personal safety, which would be the case if there was really thick blowdown or clusters of downed trees in a specific area, a management decision could be made to utilize dynamite to clear the trails. The FS has used this method in the Cloud Peak Wilderness (CPW) before with great success, and plans to continue using it in the future.

If the use of mechanized equipment for trail maintenance was to continue, it would require a special written provision in the actual wilderness legislation. WWA thinks that it is important to consider how special provisions such as this could possibly compromise the values protected by the Wilderness Act. WWA realizes the importance of trail maintenance to your guest ranch operations and wants to work together to find a solution which ensures trails are maintained to suitable standards for horse packing and guest outings, while maintaining a primitive wilderness experience in Rock Creek.

One possible option for achieving this is to organize volunteer trail crews of private citizens and outdoor recreation groups. he FS gladly accepts volunteers to assist in trail maintenance, and WWA plans on coordinating efforts to get local citizens involved in maintaining trails in the Rock Creek area. With directed effort and community involvement, we can ensure that The area will remain accessible for everyone who wants or needs access, including guest ranching operations, grazing permittees and private recreationists.

As Powder River District Ranger Mark Booth explained at the meeting, there might have been some confusion arising from initial maps not being as detailed as they could have been, but the proposed boundary was drawn with the specific intention of leaving all existing motorized routes outside the wilderness. Enclosed is a copy of the revised map of the proposed southern boundary (East and West, highlighted in orange) in which the roads are clearly left out of the Wilderness by a 200-foot buffer. Again, to reiterate what Mr. Booth mentioned at the meeting, one of the major advantages of the recommendation of Rock Creek for wilderness is that no motorized roads or trails will have to be closed or decommissioned, since there have never been any in the area.

We appreciate your proposal for moving the boundary line to the top of the ridge where the FS District boundary lies, but this may cut more land out of the proposed wilderness area than is truly needed to accommodate the established mechanized and motorized uses occurring in the area. While it is a geographic boundary that would be easily established and recognized, we feel it is not worth the removal of approximately 3,500 acres of potential wilderness, over 10 percent of the proposed area (your estimate was 6,000 acres, or almost 18 percent of the area). Once again, our intent is to establish an agreeable boundary that will adequately buffer specific areas while maintaining as much of the proposed wilderness area as possible.

At this point, we are still working with the FS to determine the specific details about the management of conifer encroachment. We are reviewing documentation of how this fits into the requirements for grazing permit administration, and we are waiting for additional information from the Forest Service. We will get back with you as soon as we find out the specific implications of this issue.

Generally speaking, any activity that you are legally required to undertake in order to fulfill the stipulations of your Term Grazing Permit, will be allowed regardless of a wilderness designation for Rock Creek. We are trying to determine whether or not conifer encroachment falls into this category, and we are having difficulty in determining where it is documented and how it is legally incorporated into the permit.

You can be assured that any activity legally required by your grazing permit will continue, as explicit allowances for grazing and grazing management activities are put forth in the Forest Service Manual (FSM) Section 2323.22-Congressional Grazing Guidelines, the document which guides grazing management in all wilderness areas. These guidelines were included as a handout at the meeting, and we have included another highlighted copy for your reference. They ensure the continuation of grazing and grazing-related management activities, as summed up in the end of the document:

“…If livestock grazing activities and facilities were established in an area at the time Congress determined that the area was suitable for wilderness and placed the specific area in the wilderness system, they should be allowed to continue.”

It should also be noted that one of the goals of organizing the stakeholders meeting was to compile a complete picture of the existing activities that are occurring in the Rock Creek area and along its boundaries. We appreciate you marking down your managed areas on our map, and with this in mind we are working to establish a proposed boundary that will exclude all of the areas requiring motorized and mechanized uses, such as the cow camp, Ditch creek, cabins, and pastures.

Our goal is to leave these areas out of the wilderness by adjusting the boundary around them and giving them the standard 200-foot buffer. While grazing activities would be allowed to continue within the wilderness, excluding these management-intensive areas will absolutely ensure no conflicts or complications will arise with the continued use or maintenance associated with them, as well as providing a contiguous area of wilderness that preserves the wild qualities of peace and quiet, solitude, and primitive recreation.

We understand that public perception can lead to negative interactions when undertaking activities not normally associated with or allowed within an area such as a wilderness. This stems from a lack of public awareness about permitted and grandfathered uses in these areas, which can only be overcome through public outreach and education. Like the non-resident hunter issue, WWA addresses this with every opportunity we get to educate the public about the implications of this designation. Grandfathered uses for grazing permittees are deliberately and explicitly allowed, and we do our best to convey that to everyone we approach about this issue. There likely will be situations in which you encounter someone who doesn’t understand or approve, but, as you know, as long as you are acting within the terms of your grazing permit and undertaking grandfathered management activities associated with the permit, they are the ones in the wrong, not you.

A wilderness designation for Rock Creek will in no way affect the grazing allotments or the availability and access to existing grazing-related facilities and structures. If Rock Creek is designated as wilderness, grazing, along with the associated management activities, on the Willow Park and Rock Creek allotments would be allowed to continue in accordance with the specific requirements outlined in each permittee’s Term Grazing Permit. This assurance is explicitly written into the 1964 National Wilderness Act; Section 4(d)(4)(2) states:

“The grazing of livestock, where established prior to the effective date of this Act, shall be permitted to continue subject to such reasonable regulations as are deemed necessary by the Secretary of Agriculture.”

Since grazing has historically occurred in the Rock Creek area, it will continue to do so after it is designated wilderness.

There shall be no curtailments of grazing in wilderness areas simply because an area is, or has been, designated as Wilderness, nor should Wilderness designation be used as an excuse by administrators to slowly “phase out” grazing. Any adjustment in the number of livestock permitted to graze in wilderness areas should be made as a result of revision in the normal grazing and land management planning and policy setting process, giving consideration of legal mandates, range conditions and the protection of the range resource from deterioration…. If livestock grazing activities and facilities were established in an area at the time Congress determined that the area was suitable for Wilderness and placed the specific area in the Wilderness system, they should be allowed to continue.

This language gives clear direction and absolute protection of grazing and grazing facilities in Wilderness. Again, because grazing and management facilities were established in Rock Creek before it was analyzed and deemed suitable for wilderness designation, grazing will continue unabated from potential wilderness designation. These guidelines were provided as a handout at the meeting in December, and we have enclosed another copy with the applicable passages highlighted.

However, it should be noted that in accordance with the Bighorn National Forest (BNF) land management and planning procedures, every grazing allotment has to undergo a National Environmental Policy Act (NEPA) evaluation to assess the allotment and ensure it is maintaining the desired range conditions and protecting the resource from deterioration. The two allotments within the Rock Creek Proposed Wilderness- Willow Park and Rock Creek - are in the middle of this process right now. According to Scott Gall, Rangeland Specialist for the BNF Powder River District, the Willow Park allotment NEPA assessment has been completed and is currently being disputed in litigation, with which WWA has absolutely no involvement or influence. The Rock Creek allotment NEPA is currently underway with an estimated completion in September 2008.

The distinction between the wilderness recommendation/designation process and the required NEPA evaluation is very important to make. These are two absolutely separate processes that have no affect on each other; they just happen to be occurring simultaneously in the Rock Creek area. Any changes in cattle allotments that may occur will be a result of the NEPA evaluation, not of the wilderness recommendation or potential designation.

Although Rock Creek is not an official wilderness area, the topographic features and the fact that there are no motorized roads or trails make normal activities associated with grazing management challenging. You mentioned at the stakeholders meeting that you have already had difficulties in accessing Ginger’s cabin for making repairs. Given that the area has always been historically managed as a primitive roadless area and has no motorized roads or trails, we assume no one has been able to use motorized transport, and instead have had to rely mainly on horse packing as the means for material delivery to the cabin. Wilderness designation would not affect your ability to use horse-packing or any other non-mechanized means of delivering your cow camp materials. In short, wilderness designation would not change the access possibilities that currently exist.

That being said, we feel we should address the possibility of helicopter use separately. At the stakeholders meeting you mentioned that significant repairs are needed at Ginger’s cabin and that helicopter delivery of the necessary materials seems to be the best option. If this proves to be the case, you may want to ensure those materials are delivered by helicopter prior to an enacted wilderness designation, as motorized use would be prohibited by wilderness designation. Of course, since it would be for the maintenance of a grazing related facility, the opportunity for a specific exemption exists if it can be proven that it is absolutely necessary and no other non-motorized means will suffice. But your best option would probably be to get those necessary supplies delivered before it even becomes an issue.

At the stakeholders meeting you mentioned that you had read a passage from the Final Environmental Impact Statement (FEIS) for the Bighorn National Forest’s (BNF) Revised Land and Resource Management Plan (LRMP) regarding increased pressure on grazing permittees resulting from a public perception of wilderness. We believe you were referring to the following passage from Chapter 3 (page 3-407) of the LRMP FEIS:

“Indirect effects from wilderness management include 1) an increased expectation of no livestock presence by forest visitors and associated complaints, 2) a need to manage around a recreational “wilderness” experience to minimize conflicts, with a potential increase in people and horse use (and associated conflicts) over levels prior to this designation, 3) a need to manage for wilderness character and plant communities, and 4) a potential loss of opportunity for issuance of off-road travel permits for administration of grazing permits.”

We understand your worries about these possible effects, especially the emphasis you placed on numbers 1 and 2 above: the increased public pressure from recreational use. We can’t say that there won’t be public pressure and negative feedback from recreational wilderness users; this passage in the Forest Plan is based on legitimate trends in acknowledging the public’s expectations of a wilderness experience. However, your grazing allotment is explicitly protected within the National Wilderness Act of 1964, as well as the FSM’s Congressional Grazing Guidelines, which have been developed to absolutely clarify and direct management to provide for permitted grazing activities within wilderness areas. As long as you’re managing your allotment as outlined in your permit, the public will be in the wrong, not you.

As we have conveyed to you previously, you can be assured that any and all management activities associated with the administration of your Term Grazing Permit for the Rock Creek allotment will continue unabated from wilderness recommendation or the designation process. Again, this is explicitly and directly guaranteed in Section 2323.22 of the FSM-Congressional Grazing Guidelines. This document was included in the handouts at the December meeting, and we have enclosed another highlighted copy for your reference. Summed up, the main point of the document, which clearly makes allowances for grazing and grazing management in Wilderness, is:

“There shall be no curtailments of grazing in wilderness areas simply because an area is, or has been designated as wilderness, nor should wilderness designations be used as an excuse by administrators to slowly “phase out” grazing” (emphasis added).

“The maintenance of supporting facilities, existing in the area prior to its classification as wilderness (including fences, line cabins, water wells and lines, stock tanks, etc.), is permissible in wilderness. Where practical alternatives do not exist, maintenance or other activities may be accomplished through the occasional use of motorized equipment” (emphasis added).

Since your grazing program has historically been a part of the Rock Creek area and all your facilities and uses have been established prior to the wilderness evaluation and designation, your cattle grazing and grazing-related management activities will be allowed to continue with Wilderness designation.

Furthermore, it is important to make the distinction between the Rock Creek wilderness recommendation and the National Environmental Policy Act (NEPA) evaluation that, as you know, is currently underway on the Rock Creek allotment. The NEPA evaluation is a federally required process for reevaluating grazing allotments on the BNF. As Chapter 3, page 3-402, of the Revised LRMP FEIS explains:

“Site-specific NEPA analysis is completed during the allotment management planning process. The Bighorn National Forest is on a 15-year schedule to update and revise allotment management plans as mandated by the 1995 Rescissions Act… Project level allotment NEPA decisions are developed using the goals and objectives as well as the standards and guidelines of the approved forest plan. More specific grazing prescriptions can be developed during the allotment management planning process to address site-specific issues.”

Basically, this explains that individual grazing allotments will be evaluated based on the overall desired conditions, standards and guidelines outlined in the Forest Plan. The revision of the plan in 2005 changed these criteria for many aspects of forest management, but they did not change for grazing or grazing activities.

A vital distinction needs to be made in differentiating this NEPA analysis from the potential Wilderness designation. These are two different processes that have nothing to do with each other, they just happen to be occurring simultaneously within the Rock Creek area. Any changes that occur on your grazing allotment and permitted cattle numbers will be a result of NEPA analysis and forest-wide management goals. As the LRMP FEIS explains on page 3-406:

“It is entirely possible that as project-specific NEPA decisions are developed and applied [as with your Rock Creek allotment evaluation], and where these factors [forest plan standards, guidelines, and management area directions] and other issues occur and overlap, a decrease in AUM’s permitted may result.”

While there may be some increased recreational use in Rock Creek if it becomes Wilderness, WWA has done some research that provides evidence that a large increase in use is not likely. Based on the physical features present in the area and the way that it will be incorporated into an existing Wilderness area, we believe that usage increases will be minimal, and should not create detrimental impacts to the resource.

According to Ralph Swain, the FS Rocky Mountain Region Wilderness Director, Wilderness areas that receive the highest use, and the resulting access pressures, are usually centered around high-profile magnet areas, such as alpine peaks and popular fishing lakes. In the Cloud Peak Wilderness (CPW), this phenomenon is illustrated by the vast difference in usage between the Cloud Peak/Bomber Mountain areas, along with the corridors directly accessing these features, and the backcountry areas and access corridors away from these popular peaks. While Rock Creek contains outstanding scenic views and unique recreation opportunities, it does not contain the type of high-profile features that typically attract most Wilderness visitors.

Furthermore, according to Mr. Swain, many Wilderness areas receive a slight increase in usage immediately after designation, resulting from the increased publicity and awareness of the area. This increase, though, is usually temporary and tapers off to traditional levels after the initial spike. In the case of Rock Creek, however, this initial spike in use may be minimal since it will not be designated as a separate, distinct wilderness area. Instead, Rock Creek will become part of the already established CPW, thereby minimizing the unsolicited publicity that could result if it were designated as its own distinct area.

Also, it is important to realize that the county road which provides access to Rock Creek through the Bud Love Habitat Unit is only one of seven public access points to the area. With so many other accesses, any increase in use will hopefully be dispersed, preventing any access corridor from being overwhelmed.

Obviously, one major step in assuring this dispersal of use lies in public education and awareness. WWA has been, and will continue, taking every opportunity that we get to educate the public about minimum impact camping techniques (Leave No Trace) as well as all the viable access points into Rock Creek. Since we value this area so much, we are eager to inform people about all the accesses to the area, the other six being: from Penrose Trail via Willow Park, from the HF Bar up the South Fork of Rock Creek, and the four points on the south side of the area from 4-wheel drive roads 396 and 388, leading to Triangle Park, Keno Creek, and the South Fork of Rock Creek.

We definitely realize that overuse of an area can be detrimental, as you illustrated with your example of certain areas in the CPW, and we acknowledge your desire to keep Rock Creek out of the spotlight. Our view is that while it may receive some initial attention and publicity if designated (it will be Wyoming’s first Wilderness designation in 24 years, after all), it will not be overwhelmed with use to the point that the resource will be degraded and the wild qualities of the area will be compromised.

Also, looking at the long-term vision for Rock Creek, we feel that pursuing this designation right now while the area remains wild and pristine is worth the minor spotlight associated with that. If this area is not permanently protected, somewhere down the road a major spotlight will be illuminating the possibilities for timber, mineral development, ATV use, or road building, which will permanently compromise the uniquely primitive habitat, traditional uses, and recreation opportunities that Rock Creek provides. In other words, drawing a little attention to it now to preserve it as it is in perpetuity far outweighs the attention that may arise in the future from development and motorized access pressures which would permanently alter this primitive landscape.

According to Craig Cope, Wilderness Director for the BNF, the possibility of implementing a quota system for the CPW is presented and outlined in the BNF management standards and guidelines (pg 1-58 of the Revised LRMP). However, it could only be enacted for the entire CPW, not just a specific area within the CPW, meaning that overall recreational use would have to reach a threshold that would justify a wilderness-wide limit. Again, we don’t feel that use will increase to such a level that would cause significant degradation based on the reasoning presented above.

As with the public meetings on this issue, the EIS analysis also happened as a part of the Forest Plan Revision process. Again, this one specific designation action was not isolated in its own process. However, complete analysis of existing wilderness on the BNF, as well as other Roadless Areas eligible for wilderness recommendation, was done and included in the Forest Plan Final EIS and the Appendices to the Final EIS, available on the BNF website at:
http://www.fs.fed.us/r2/bighorn/projects/planrevision/documents/final/index.shtml

The passage in the Revised LRMP FEIS that seems to be the basis for your concern begins on page 3-405 in Chapter 3:

“There has been an increasing tendency in recent years for some ranchers to sell off a portion of their deeded lands in an attempt to keep the remainder as a viable ranch unit, and to keep it in historic family ownership (Mitchell 2002).”

Instead, it merely acknowledges the fact that this trend is occurring on private lands adjacent to Federal lands throughout the western United States. While the FEIS document doesn’t go into any detailed explanation of the reasons behind this trend, they can vary widely depending on the specific area being discussed. Generally speaking, overall trends in the nation of increasing population growth combined with the growing desire to live in scenic, rural areas contribute to financial decisions being made by private ranchers, who may find subdividing and developing portions of their land more profitable than maintaining their ranching operations.

The rest of this section in the FEIS, as well as the cited study, deal with the negative effects of this subdividing tendency and the complications that can arise with managing livestock and wildlife in increasingly fragmented landscapes.

We understand your concerns for the continued sustainability of your ranching operation, and we hope you understand that this national trend is not a product of wilderness designations putting ranchers out of business. In reality, a variety of social, personal, cultural, and economic factors all combine to influence rancher decisions. For more information on this issue, we urge you to look at the Forest Service publication “Cooperating Across Boundaries,” available on the web at: http://www.fs.fed.us/openspace/cooperatingacrossboundaries.pdf

We definitely understand your concerns over illegal use of your private road, and the worries that those problems will only multiply with the increased use of Rock Creek if it becomes a designated wilderness.

So first of all, it is important to note that given the physical features of the Rock Creek area and the way it will be incorporated into an existing wilderness, it is unlikely that this potential wilderness designation will result in an overwhelming increase in recreation use. According to Ralph Swain, the FS Rocky Mountain Region Wilderness Director, Wilderness areas that receive the highest use, and the resulting access pressures, are usually centered around high-profile magnet areas, such as alpine peaks and popular fishing lakes. In the Cloud Peak Wilderness (CPW), this phenomenon is illustrated by the vast difference in usage between the Cloud Peak/Bomber Mountain areas, along with the corridors directly accessing these features, and the backcountry areas and access corridors away from these popular peaks. While Rock Creek contains outstanding scenic views and spectacular recreation opportunities, it does not contain the type of high-profile features that typically attract most wilderness visitors.

Furthermore, according to Mr. Swain, many Wilderness areas receive a slight increase in usage immediately after designation, resulting from the increased publicity and awareness of the area. This increase is usually temporary and tapers off to traditional levels after the initial spike. In the case of Rock Creek, however, this initial spike in use may be minimal since it will not be designated as a separate, distinct wilderness area. Instead, Rock Creek will become part of the already established CPW, thereby minimizing the unsolicited publicity that could result if it were designated as its own distinct area.

As these trends show, the increase in usage and the associated access pressure should be minimal if Rock Creek is designated as wilderness. But, as you and other members of the Ditch Company shared with us, illegal use of the Willow Park Road has been a recurring problem, especially during hunting season with nonresident hunters trying to access the roadless area. As with other illegal motorized uses and abuses on the Bighorn National Forest, this seems to be an education and enforcement issue. We cannot make any promises or commitments on behalf of the FS to increase patrols in the area, but we will continue to take every opportunity that we get to educate the public about the 7 legal access points into Rock Creek. Since we value this area so much, we are eager to educate people on the appropriate, legal ways to access it: from Penrose Trail via Willow Park, from the HF Bar up the South Fork of Rock Creek, Sayles Creek through the Bud Love (March 10-Nov 10), and the four points on the south side of the area from 4-wheel drive roads 396 and 388, leading to Triangle Park, Keno Creek, and the South Fork of Rock Creek.

Obviously, public awareness resulting from clearly labeled maps and appropriate signage is essential in helping to minimize confusion and prevent users from perceiving the Willow Park Road as a viable access point. Of course, there will always be issues with illegal motorized use everywhere on the forest, but since this has been a problem in the past, a wilderness designation for Rock Creek may be an opportunity to disseminate accurate information and possibly even lessen unauthorized use on your road. The number of nonresident hunters trying to access the area from the Willow Park Road would likely decrease with a wilderness designation, since they would be required to be accompanied by professional outfitters or resident guides, who would presumably utilize the legal access points to the wilderness.

This question was addressed at the meeting when it came up, but we want to make sure you know what the access to the area will be. There are currently seven legal, public access points: The motorized Penrose Trail via Willow Park, the South Rock Creek Canyon through the HF Bar, Sayles Creek through the Bud Love (March 10-November 10), and four points on the southern side of the area from FS roads 388 and 396 leading to Triangle Park, Keno Creek and the South Fork of Rock Creek.

There will be no changes in access from what is currently available. No new access will be opened, and no existing access will be closed.

This is an excellent question, and it’s really the basis for WWA’s entire campaign in the Rock Creek area. Really, the only potential problem we see with how Rock Creek is right now, is that this is how it is right now. Because this is such a special area that has never seen any development or roads; because it provides unparalleled wildlife habitat and recreation opportunities; because it encompasses an ecosystem and vegetation types that are not permanently protected as Wilderness anywhere in Wyoming, WWA feels that Rock Creek is worthy of protection beyond the next 10 or 15 years. Sure, it would probably retain similar management prescriptions in the next forest plan, but as FS District Rangers Mark Booth and Craig Yancey explained at the meeting, there is no guarantee; no one can definitively foresee what is in store for Rock Creek beyond the current forest plan - unless it becomes wilderness.

In the FS evaluation and wilderness suitability analysis that was part of the Forest Plan revision process (enclosed for your reference, pg C-57 of Appendix C to the LRMP FEIS), Rock Creek met or exceeded all the criteria for potential wilderness areas (you will see that the only element which did not rank as “high” in the analysis was manageability, which was based on criteria and boundary issues that have either been addressed already by the FS or are being addressed through WWA’s effort to revise the northern boundary). WWA feels this recommendation illustrates the extraordinary wild and pristine characteristics of a unique area, and that it merits some attention and effort to carry it through to official designation. This is a rare opportunity to truly protect a special area in perpetuity; we feel the time is ripe to take action and ensure the Rock Creek area will remain as wild and beautiful as it is today for generations to come.

We understand that a wilderness designation carries certain implications and restrictions regarding mechanized uses and motorized access, which is why we’ve made it a priority to involve all the area stakeholders in this process. We want to get a complete picture of the current uses in the area, as well as the specific areas that need, or will need in the future, these types of access and management so they can be excluded from the designated wilderness.

Our goal in this entire process is precisely to leave it like it is, and ensure it will be left like it is forever. With the current trends on our public lands, however, we feel that the window to keep places like Rock Creek the way they are is rapidly closing. Demand for resources is increasing, technology is improving, and resource extraction companies are beginning to find it more and more profitable to explore and develop previously overlooked or undeveloped landscapes. The only sure-fire, foolproof, absolutely definite way to keep Rock Creek like it is lies in wilderness designation.

The National Forest Management Act (NFMA) established the Forest Planning process in 1976 with the intent that Forest Plans be updated every 10-15 years. With the most recent revision of the Bighorn National Forest (BNF) Plan in 2005, the Rock Creek Roadless Area was the only Roadless Area to be recommended for wilderness designation on the entire forest. WWA feels this recommendation illustrates the extraordinary wild, pristine characteristics of Rock Creek and merits some attention and effort to carry it through to official designation.

The Forest Service (FS) can only make the recommendation for Wilderness management through this planning process, which only happens once every 10-15 years (sometimes it actually approaches 20). Therefore, this recommendation represents a rare opportunity to truly protect a special area in perpetuity. We feel the time is ripe to take action and ensure the Rock Creek area will remain as wild and beautiful as it is today for generations to come.

Right now, management of Rock Creek has been such that it has remained a pristine, undeveloped piece of wildlife habitat and sanctuary for backcountry recreation. Right now, there is little potential for development conflicts from timber, oil, gas, or road-building. As FS District Rangers Mark Booth and Craig Yancey explained at the meeting, this cannot be guaranteed beyond 10 or 15 years, however, which is exactly why we feel right now is also the time to act to absolutely ensure the area will continue to exist as it always has.

No one can foresee what the future holds, but the trends in our public lands are apparent and definite. Demand for resources is increasing, technology is improving, and corporations are finding it more profitable to explore previously untapped areas for valuable resources. We know that resource extraction is a necessary part of modern life and it will occur, but there are certain special places that are undeveloped that provide rare opportunities to remain primitive and untouched. Rock Creek is one of these places, and we are making it a priority right now to look to the future and make sure it keeps its traditional wild values. Wilderness designation is the only sure-fire, fool-proof, permanent way to ensure protection for Rock Creek and the rare values it represents.

Since Wilderness designation requires congressional legislation, we are at the point in the process where organizations and citizens must advocate for Rock Creek to become wilderness. As a local organization working to protect Wyoming’s wild public lands, WWA is taking the lead to build awareness and public support for Rock Creek’s permanent protection. Given the nature of the political process, our efforts are not tied to a specific administration or locked into a certain timeline, but instead are the result of a unique opportunity to protect this special place.

We believe it is essential to ensure local public involvement from the beginning of the public outreach process, especially with area stakeholders. The intent of the December meeting was to ensure that area stakeholders were aware of the recommendation and to help develop a more complete picture of stakeholders’ activities and traditional uses of the area, with the hope of working together to ensure that the area remains as wild and pristine as it always has been without excluding the traditional activities and interests that have historically been a part of it.

The assertion of road encroachment stems from a user-created extension on FS road 396 that has been incorporated into the BNF motorized system. Enclosure 4 is a packet of FS maps that substantiate this claim. Looking at Map 1 in the series, a copy of the 1974 BNF travel map, you see that FS road 396 (highlighted on all the maps) ends in the middle of Section 23. In Map 2, from the 1982 BNF travel map, road 396 still ends in Section 23, as it does in Map 3 from the 1985 BNF Forest Plan. Then, in Map 4, the 1989 BNF travel map, road 396 has been extended approximately one mile northward into Section 14, which is how it remains in Map 5 from the 2005 Final Environmental Impact Statement (FEIS) for the Forest Plan.

This road extension did not occur through an official Forest Planning process or travel management revision, but rather is the result of illegal motorized use extending beyond the legal road. Eventually, it became so well worn that it was just incorporated into the motorized road system for the BNF.

This one mile of illegal road eliminated a large chunk of the Rock Creek Roadless Area from being eligible for Wilderness, and illustrates just how large of an impact can be made by a short stretch of motorized road. Map 6 in the packet is a map produced by WWA which illustrates the estimated acreage that was removed from roadless/potential wilderness status as a result of this illegal road encroachment. The illegal road segment is highlighted in yellow and the lost areas are hatched in orange.

WWA is definitely not trying to mislead the public regarding this issue; we are merely trying to present the facts about illegal motorized encroachment and the significant effects it can have on roadless areas and recommended wilderness.

While there was some dialogue around this question at the meeting, we feel it is worth addressing it again here to make sure the information is presented accurately. The Forest Service (FS) public meetings and comment sessions that have been held regarding this potential designation were a part of the BNF Forest Plan Revision process. No meetings were held by the FS specifically focused on this one area and this one potential designation. All the areas recommended for wilderness were a high-profile element of the Forest Plan revision. This issue was open to comment at any of the meetings, as well as during every public comment period, and was especially prominent after the Draft Environmental Impact Statement (DEIS) was issued which outlined different options for recommended wilderness areas. Below is the summary of the Forest Plan process from the BNF website with the public input and involvement opportunities highlighted:

Date	Action	Comments
November 1999	Notice of Intent	The notice of intent to revise the Bighorn National Forest Plan initiates the Revision process. The NOI was published in the Federal Register on November 10, 1999.
October 2000 -January 2001	Public Meetings	A series of public meetings were held in six locations: Buffalo, Sheridan, Gillette, Lovell, Worland and Greybull. Public input helps define the revision issues.
July & August 2001	Field Trips	Two public field trips to Meadowlark Lake on the south end of the mountains and Burgess Junction on the north end.
January 2003	Public Meetings	Meetings planned to discuss potential alternatives.
2003 - Early 2004	Analysis of Alternatives	The ID team analyzes the effects implementing each Alternative would have on resources in the forest.
July 2004	Draft Plan/DEIS	The analysis of the effects of implementing each Alternative is published in a Draft Environmental Impact Statement (DEIS). The DEIS is accompanied by the release of the Draft Revised Forest Plan (DRFP), which identifies the BNF preferred alternative. A 90 day public comment period follows the release of the DEIS and the DRFP.
July, August, September 2004	Public Meetings	The Bighorn NF hosts public meetings and solicits comments on the DEIS and DRFP.
September 2005	Final EIS/Final Revised Plan	The Record of Decision was signed on September 30, 2005. The Final EIS and the Final Revised Forest Plan are currently being published. The FEIS is similar to DEIS but incorporates additional information based on the review of the DEIS.

We realize that it could have been difficult to fully understand the multiple facets of the Forest Plan revision, and consequently how decisions would affect individual areas, but the FS has their own protocols and systems in place to ensure they inform the public to the best of their ability and keep interested parties involved throughout the process. As you can see, public input and comments are a major part of the revision process.

We definitely understand your frustration with making your voice heard in what can seem like an overwhelming sea of comments. After speaking with FS Rangeland Specialist Scott Gall about this issue, though, we’d like to offer some insight into this process.

According to Scott, even though you wrote one letter that fell into a pool of 18,000 comments, many of which were mass-generated in what you call the “Sierra Club method,” your input was still documented and taken into account. Scott explained that every set of comments is read, evaluated, and fit into a spectrum of decision options.

While there were 18,000 comments received, the fact that those are generic, mass-generated emails or form letters is taken into account, just as the fact that you took the time to write a personal letter is taken into account. It is important to realize that just because the ideal outcome that you had in mind was not translated into the final FS decision, it does not mean that you were not heard or properly taken into consideration.

The FS faces great difficulty in making land management decisions, trying to find the delicate balance between what is most popular, most effective, and most beneficial for the public’s natural resource. We speak from experience when we say we know it can be extremely frustrating at times when you feel like you’re not being heard, but it is important to remember that the public process is in place for a reason, which is to allow every perspective to be heard. With such a wide variety of comments being generated, it is impossible for everyone’s ideals to be reflected in a final decision.

As Powder River District Ranger Mark Booth explained at the stakeholders meeting, any meetings that will happen in the future with this process will not be associated with the FS; their part is done. However, in moving this process forward, the public will be informed and input will be heard during the Congressional process, as mandated in Section 3(d)(1) of the National Wilderness Act of 1964:

“(d) (1) The Secretary of Agriculture and the Secretary of the Interior shall, prior to submitting any recommendations to the President with respect to the suitability of any area for preservation as wilderness --

(A) give such public notice of the proposed action as they deem appropriate, including publication in the Federal Register and in a newspaper having general circulation in the area or areas in the vicinity of the affected land;

(B) hold a public hearing or hearings at a location or locations convenient to the area affected. The hearings shall be announced through such means as the respective Secretaries involved deem appropriate, including notices in the Federal Register and in newspapers of general circulation in the area: Provided, That if the lands involved are located in more than one State, at least one hearing shall be held in each State in which a portion of the land lies;

(C) at least thirty days before the date of a hearing advise the Governor of each State and the governing board of each county, or in Alaska the borough, in which the lands are located, and Federal departments and agencies concerned, and invite such officials and Federal agencies to submit their views on the proposed action at the hearing or by not later than thirty days following the date of the hearing.”

Also, outside of this official Congressional designation process, WWA will continue educating the public and presenting accurate information regarding Rock Creek and its potential wilderness designation through public events, presentations, and meetings. While it is true that we are an organization with a specific goal in mind (permanently protecting the unique Rock Creek area), our method of accomplishing this is to maintain open and honest communication with area stakeholders, elected officials, and the general public. As evidenced by the organization of the stakeholders meeting, we are committed to hearing all points of view regarding this designation, and we are dedicated to continuing the dialogue and presenting all the information that we have to all interested parties.

WWA understands that the implications of the outfitter/resident guide requirement for non-resident hunters are of major concern in this potential wilderness designation process. As an organization advocating for this designation, this issue gets addressed in every opportunity we have to educate the public and elected officials about this designation. However, WWA is not planning on having state-wide meetings for the sole purpose of gathering input and hearing concerns about the non-resident hunter issue, as it is a state law that is beyond our control. Because of this, our main approach has been, and will continue to be, presenting the facts and the actual requirements of the statute, and the possible ways of complying with it while keeping inconvenience to hunters at a minimum (the option for utilizing a resident guide seems to be the easiest way to maintain hunting access without additional cost to non-resident hunters).

We spoke with Dan Thiele with Wyoming Game and Fish (WYG&F) in Buffalo, and according to him, G&F will not notify non-resident hunters who have historically hunted in the area. He explained that it would be difficult to determine who has actually hunted within the Rock Creek area that is proposed for wilderness and who has hunted in areas that are outside of the proposed wilderness boundary. He did say that if the designation didn’t happen before next hunting season, they would attempt to inform the hunters that will be recreating in Rock Creek about the proposed wilderness and the resulting outfitting requirement.

“No nonresident shall hunt big or trophy game animals on any designated wilderness area, as defined by federal or state law, in this state unless accompanied by a licensed professional guide or a resident guide.”

As Jim Seeman from WYG&F stated at the meeting, the original intent of the law was to provide for the safety of out-of-state hunters that may not be familiar or accustomed to the rigorous conditions of the Wyoming high country, where all of the designated wilderness in the state is. Even though the Rock Creek proposed wilderness encompasses lower elevation forest lands that may not be as dangerous or as hard to access as most of the high country wilderness in the state, the law will still apply since it does not differentiate or grant exceptions based on landscape conditions. It should also be noted that the law only applies to big and trophy game animals, meaning that the requirement for outfitters or resident guides doesn’t apply for non-resident hunters hunting game birds or coyotes in wilderness areas.

“The commission may also specify other areas of the state, or specific big or trophy game species, for which a licensed professional or resident guide is required for nonresidents, for purposes of proper game management, protection of hunter welfare and safety, or better enforcement of game and fish laws” (emphasis added).

This law also supports local Wyoming economies by requiring visiting hunters to utilize the services of Wyoming outfitters. This can be problematic and raise concerns, though, when dealing with an area such as Rock Creek in which non-residents have historically been able to hunt without an outfitter or guide and are all of a sudden required to pay extra money for an outfitter.

For this reason, WWA has really been focusing on the resident guide option as a viable avenue for non-resident hunters hunting in the Rock Creek area. It provides a relatively easy, cost-free option for maintaining hunting access if it becomes wilderness. The statute also defines this process and the stipulations associated with it as follows:

“Any resident possessing a valid resident big or trophy game animal license may apply for and receive a resident guide license. The resident guide license shall be issued without charge or bond by the commission, any district supervisor or resident game warden upon receipt of an affidavit from the resident stating the names and addresses of the nonresident hunters to be guided, the game to be hunted, the area to be hunted, and that the resident has not received nor will accept directly or indirectly any compensation for his services as a guide. A resident guide shall not guide more than two (2) nonresident hunters in any calendar year on any national forest, wilderness area, national game refuge, or national park, except as provided in W.S. 23-2-401, nor shall he accept any compensation or gratuity for his services. The name and license number of the nonresident hunter shall be placed on the back of the resident guide license and stamped or signed by the issuer.”

We realize that this may be problematic for some hunters who may not have local connections, but since this is a state law, we have to work with it the best that we can. As an organization, we are utilizing every opportunity we have to educate the public and elected officials about this issue, and the possible options for maintaining hunting access to the area for non-residents. A complete copy of the statute is enclosed for your reference. We have also enclosed a copy of the hunting fact sheet that we compiled which was handed out at the meeting. This has the numbers of hunters that have traditionally used the area and the number that may be affected by the statute, as well as some additional statistics about elk security habitat on the BNF.

Since Rock Creek contains the highest concentration and largest continuous block of elk security habitat on the BNF, we feel it is worth working around this state law to ensure that this unique habitat gains permanent protection and will be providing high-quality recreation opportunities for generations to come. Research done by Trout Unlimited (which we have enclosed) shows that high quality elk security habitat supports larger, healthier elk populations, which intern leads to long-term hunting success and an overall healthier, sustainable hunting economy. Giving that elk security habitat permanent protection is also providing long-term insurance to local businesses, outfitters such as yourself, and outdoor enthusiasts and recreationists.

We definitely understand your concerns for how this wilderness designation may affect your business, especially since you’re happy and content with your current situation. However, since the statute that requires nonresident hunters to be accompanied by a licensed outfitter or resident guide is a state law, it will not be overturned or exempted for the Rock Creek area if it becomes wilderness.

WWA knows that this is a major issue arising with the potential wilderness designation for Rock Creek, which is why we are utilizing every opportunity we have to educate the public, area stakeholders, and elected officials about the specific requirements of the law and the possible options for compliance while minimizing inconvenience to nonresident hunters and area outfitters.

As you can see, the law gives two options for non-residents to meet the requirements in wilderness areas, one being the licensed professional guide (which is where your business has the potential of being affected by being pushed into providing more guided hunts) and the other being the resident guide.

The law has the benefit of supporting local Wyoming economies by requiring visiting hunters to utilize the services of Wyoming outfitters. This can be problematic and raise concerns, though, when dealing with an area such as Rock Creek in which non-residents have historically been able to hunt without an outfitter and will all of a sudden be required to pay extra money for a fully guided hunt in the same area.

For this reason, WWA has been focusing on educating people on the resident guide option. We feel this provides a relatively easy, cost-free way for nonresidents to maintain their hunting opportunities in Rock Creek, while also relieving the pressure from outfitters, like you, to take on more clients needing fully guided hunts.

The statute defines the qualifications for becoming a resident guide and the process that must occur as follows:

We realize that this may be problematic for some hunters who may not have local connections, but creative ways can be developed to connect willing locals with nonresidents in need of resident guides. A complete copy of the statute is enclosed for your reference. We have also enclosed a copy of the hunting fact sheet that we compiled which was handed out at the meeting. This is a good overview of the total number of hunters in the area and the number of non-residents that could be affected by the statute, as well as some statistics on elk security habitat on the Bighorn National Forest (BNF).

Additionally, as briefly mentioned at the meeting by Powder River District Ranger Mark Booth, it is possible to establish additional outfitting permits in the area if the demand for outfitting/guide services is more than you can, or want, to accommodate. According to Craig Cope, Wilderness Director for the BNF, once the need for additional permits is identified, the official process to determine the actual number of needed permits is undertaken. Once the total number of permits needed is determined, prospective outfitter applications are reviewed and the appropriate permits are issued to the most qualified applicants. With this process available, you can be assured that the responsibility to accommodate any increase in hunters needing fully guided hunts will not fall solely on your business.

Since Rock Creek is such a special area in that it contains the highest concentration and largest continuous block of elk security habitat on the BNF, which you can probably attest to, we feel it is worth working within this state law to ensure that Rock Creek’s unique habitat gains permanent protection and will be providing high-quality hunting and recreation opportunities for generations to come.

Research done by Trout Unlimited (which we have enclosed) shows that this type of high-quality elk security habitat supports larger, healthier elk populations, which in turn leads to long-term hunting success and an overall healthier, sustainable hunting economy. Providing Rock Creek, and its elk security habitat, permanent protection as wilderness is also providing long-term insurance to local businesses, outfitters such as yourself, and outdoor enthusiasts and recreationists.

This question was briefly addressed when you asked it at the meeting, but just to provide you with more detail, we have spoken with Craig Cope, Wilderness Director on the BNF, to get more information on the actual process. According to him, the process to establish additional permits will begin moving forward when the preliminary demand for additional outfitting days (this is the unit which the FS uses in measuring outfitting volume) in the area is determined, either through public complaints of outfitter unavailability or by monitoring the number of nonresident hunting licenses issued for the area. An official prospectus process will then begin which will make a final determination on the actual number of additional days that are needed. This need will then be fulfilled through the review of outfitting applications and the issuance of new permits to the most qualified applicants.

While the fire-fighting response for any forest fire depends on multiple factors and circumstances, a Wilderness designation for Rock Creek would not really change the management responses available. Basically, in dealing with naturally ignited fires in areas such as Rock Creek, the FS strives to maintain a hands-off approach and allow the fire to play its natural role. However, if fires are human-caused or pose a threat to high-value areas on the forest (developed facilities, structures, etc…) or private property, suppression action is taken to reduce or eliminate that threat. Technically, any fire-fighting techniques undertaken in a designated wilderness will have to comply with the non-motorized, non-mechanized mandate of the National Wilderness Act. But, those stipulations can be exempted by the Forest Supervisor or Regional Forester in the case of defending high-value areas or private property, which would be the only circumstances in which a fire would be actively suppressed in the area anyway.

With that general picture in mind, it is worth delving into more detail to gain a better understanding of the FS decision-making processes and management options concerning wildfires. Fire-fighting in many areas on the forest is no longer dealt with as it has been in the past with the goal of strict fire suppression; instead, the agency has developed a system of assigning Appropriate Management Responses (AMR) for different areas of the BNF, based on the desired conditions, standards and guidelines, and the values associated with various management classifications.

The Rock Creek area, if designated as wilderness, would encompass areas of both the 1.11 and 1.13 management prescriptions, named as pristine wilderness and semi-primitive wilderness, respectively. The general outline for management of areas within this category is explained as follows in Chapter 2 of the 2005 Revised LRMP:

“… Ecological processes such as fire, insects, and disease are allowed to operate relatively free from the influence of humans. Vegetation composition and structure results from predominantly natural succession and natural disturbance processes, while non-native vegetation is rare” (emphasis added).

The specific “Desired Conditions” concerning fire for both of these prescription areas (1.11 and 1.13) are defined as (again from Chapter 2 of the 2005 BNF Revised LRMP):

“Evidence of the effects of natural fire may be present and persist. Lightning caused fires are allowed to play, as nearly as possible, their natural ecological role in wilderness. The risks and consequences of wildfire within wilderness or escaping from wilderness are reduced to an acceptable level with consideration given to sustaining the wilderness characteristics that are dependent upon the role of wildfire in addition to the fire’s proximity to high value areas on the Forest.”

As you can tell, the theme in managing wilderness areas is to actually manage them as little as possible, allowing natural processes to occur unhindered unless extenuating circumstances (proximity to private property and high-value areas) dictate the need to alter those processes. Based on these overall desired conditions, the FS then narrows the scope of actual allowable fire-fighting methods based on the standards and guidelines for managing fire, from pg 1-48 of Chapter 1 of the BNF Revised LRMP (enclosed for your reference).

As you can see, the first guideline requires an application of “an appropriate management response” (AMR) as outlined in the Forest Fire Management Plan and the accompanying map from Appendix A of the BNF Revised LRMP (also enclosed, with the Rock Creek area highlighted). The Rock Creek area currently falls under the “prescription” designation, as it would if it became designated wilderness. We spoke with Jon Warder, BNF Fire Management Officer, for some clarification. He explained the basic process for the area: naturally-ignited fires will be allowed to burn relatively free from human intervention to play their natural role in the ecosystem, unless they pose a threat to safety, private property, or high-value areas of the forest, in which case aggressive suppression action will be taken. Human-caused fires will always warrant suppression.

Looking at Table 1-12 on the enclosed handout from Chapter 1 of the BNF Revised LRMP (pg 1-48), you can see the allowed responses (highlighted for management areas 1.11 and 1.13). Looking at the footnotes, bulldozers can only be used with Regional Forester approval, and helicopters, motorized equipment, and mechanical transport can only be used with Forest Supervisor approval, as mentioned above.

As with the options for fire-fighting, all trail maintenance will have to be done with non-motorized and non-mechanized means. When dealing with downed trees, this usually translates into axes, bucking saws (single person), and cross-cut saws (two people). However, according to Craig Cope, Wilderness Director for the BNF, when clearing trees with these hand tools could present a hazard to personal safety, which would be the case if there is really thick blowdown or clusters of downed trees in a specific area, a management decision could be made to utilize dynamite to clear the trails. The FS has used this method in the CPW before with great success, and plans to continue using it when necessary.

We also understand your concerns with the issue of FS priority in maintaining the area once it becomes wilderness, especially when you’re experiencing frustrations with the current management. Although we cannot make any promises or guarantees on behalf of the agency, we can say that they do the best they can with the resources that they have. Obviously, they do not have the personnel and resources to promptly clear all trails after every major storm or a particularly harsh winter; and of course, they operate on a longer time frame than sometimes seems logical. However, they do prioritize management needs, and have even hired contract trail crews in the past to meet needs that they knew exceeded their in-house capabilities to effectively maintain. So, while it can be frustrating, we must have confidence in the FS as the managing agency and trust that they will do the best they can.

In addition, there are certain measures that private citizens and interested parties can pursue. The FS gladly accepts volunteers to assist in trail maintenance, and we hope to cooperate with local outdoor groups to organize some volunteer outings to help clear trails and ensure that the area is accessible for grazing permittees, guest ranching operations, and private recreationists.

The appropriate management activities for any given area on the Bighorn National Forest are defined and guided by the objectives and guidelines set forth in the Forest Land and Resource Management Plan.

“Forested vegetation composition and structure are undisturbed by human intervention and predominantly mature to over-mature, unless regenerated by natural processes such as fire, insects, wind or disease. Vegetation is characterized by a variety of structural stages, a variety of tree sizes, and standing and downed dead trees. Recently disturbed areas have openings with many dead, standing trees. Over time, these areas will regenerate and grow from seedlings to mature stands, and the standing dead trees will fall and become woody debris” (emphasis added).

Craig Cope expanded on this basic premise of hands-off habitat management, explaining that prescribed burn