The Forest Service is revising its management plan for the Pisgah and Nantahala National Forests. The revised plan governs the way the million-acre-plus forest will be managed for the next 15 to 20 years, incorporating guidelines for “multiple uses” like outdoor recreation, timber harvest, wilderness, and wildlife habitat conservation.
The final version of this plan will be released in late 2017, but a key preliminary step came in July, 2016: the release of wilderness evaluations. Unfortunately, the results fail to properly document the wilderness characteristics of the areas evaluated. This will inevitably prevent deserving areas from being recommended for wilderness. In western North Carolina, there are over 350,000 acres of lands inventoried with “wilderness characteristics”—meaning that they provide opportunities for solitude and non-motorized recreation, protection of old growth forest and rare and threatened species, and more.
The Forest Service is accepting public comments on the evaluation and draft alternatives. Tell the Forest Service that these areas need to be properly evaluated, with the most deserving being considered for wilderness recommendations so that we may protect our valuable wildlands.
Click here to view a table of area-specific Forest Service evaluations and corresponding responses from The Wilderness Society.
What’s wrong with the wilderness evaluations and draft alternatives?
Deserving areas, and portions of areas, have been improperly evaluated and/or excluded from analysis. This could prevent them from being considered for wilderness or other protections in the future.
- The Forest Service is required to evaluate the degree to which an area has wilderness characteristics, not whether or not an area has wilderness characteristics.
- The evaluations ignore the realistic standards set by the 1975 Eastern Wilderness Act, which rejected the unrealistic “purity standard” that the U.S. Forest Service had taken when considering potential wilderness areas. The current overzealous rejection of areas is a reversion to the “purity standard” of wilderness that was rejected by this Act.
The Draft alternatives are premature and inadequate.
- The Forest Service is supposed to provide opportunities for public input on the draft evaluation report and then revise the report prior to determining which areas to carry forward in one or more alternatives.
- In this case, the Forest Service has released draft alternatives concurrently with the draft evaluation report.
- There should have been workshops, meetings, and an informal review period to engage the public regarding which areas to analyze in draft alternatives.
- Developing draft alternatives before incorporating public feedback on the evaluation report is confusing and a misinterpretation of the planning rule.
- As they stand now, the draft alternatives are inadequate. They do not address the full range of issues on the forest, and they ignore the interests of many stakeholders.
- The USFS should integrate all plan issues and themes, including wilderness, into a range of alternatives that address all relevant issues and balance multiple uses and interests.
- Many of our treasured roadless, unfragmented and wild areas are not included in the alternatives.
The evaluation phase of forest planning is an inappropriate time in which to make “management trade-offs.”
- In these evaluations, areas or portions of areas have been prematurely dropped from analysis because of existing uses within those areas. This, by definition, implies that the Forest Service is trading one form of management for another, ignoring the multiple interests of all of the stakeholders.
- This violates the directives that the Forest Service is supposed to follow.
To avoid a NEPA violation, the Forest Service must reconsider which areas to carry forward for NEPA analysis to ensure a range of reasonable alternatives.
- The National Environmental Policy Act (NEPA) is one of our most important environmental laws. It holds federal agencies accountable for their actions by directing them to take into account, and publicly disclose, the environmental consequences of their proposed actions while providing an avenue for citizens to comment.
- NEPA requires that the Forest Service consider all reasonable alternatives representing public interests.
When and how to comment:
Deadline: Comments will be most useful by the end of September.
Subject line: Summer Building Blocks
Or mail to:
Attn: Plan Revision Team Leader
National Forests in North Carolina
160 Zillicoa Street
Asheville, NC 28801
How to structure your comments:
- Address your comments to the Plan Revision Team Leader
- Thank the Forest Service for the opportunity to comment on their work.
- Tell them who you are and what’s important to you.
- Be specific. Tell them what they missed. The most helpful comments at this stage are specific comments about areas, particularly regarding the area’s apparent naturalness, opportunities for solitude and unconfined recreation, size and manageability, and special values.
- Show the Forest Service that there is political support for more wilderness in western North Carolina. While they are not supposed to consider politics at this stage of the forest planning process, it doesn’t hurt to emphasize that it does exist.
- Emphasize the importance of roadless areas.
- State that all of the areas in the inventory have wilderness characteristics and should be protected accordingly. Each area’s wilderness characteristics should be noted in the evaluations and conclusions should not be made at this step.
- Close by letting the Forest Service know that you understand they have complex rules to follow, and that you again appreciate the opportunity to comment.
Helpful Resources and Links
Scan the list in this helpful chart for your favorite places in the Pisgah or Nantahala, and use this data to help you make the case for better protection of our Mountain Treasures.
Information, Presentations, evaluation forms, and mapping tools for the Wilderness Evaluations from the US Forest Service
More information on the Planning Process from the US Forest Service