We need you to speak up for the Anaconda Pintler and Lee Metcalf Wildernesses and the congressionally designated West Pioneer and Sapphire Wilderness Study Areas in Southwestern Montana by August 9.
The U.S. Forest Service is proposing to renew existing outfitter permits in the entire 3.4 million-acre Beaverhead-Deerlodge National Forest without any environmental analysis, maps indicating where many of the camps are, or disclosure of the impacts from these commercial operations. The agency proposes to use a simple "categorical exclusion" instead of doing an analysis in an environmental assessment or more detailed environmental impact statement. The proposal includes all new permits plus expansions of existing permits issued since 2017, neither of which ever went through any environmental analysis.
Ironically, last year the Forest Service proposed an environmental assessment (EA) that would have been the basis for renewing existing permits and some new outfitting proposals. The Forest Service "scoping" letter explains the agency heard from the public and scrapped the EA, yet now the agency takes a step backward by providing even less opportunity for public input with this proposed categorical exclusion.
The Anaconda Pintler Wilderness, with its high peaks, mountain goats, and recovering grizzly bear population, holds the distinction of being one of the original 54 Wilderness areas designated with the passage of the 1964 Wilderness Act. The Lee Metcalf Wilderness, home to grizzlies and adjacent to Yellowstone National Park, is named after the late Montana senator who helped pass the Wilderness Act and later legislation protecting other Wildernesses.
The Beaverhead-Deerlodge National Forest, Anaconda Pintler Wilderness, and Lee Metcalf Wilderness have a history of outfitting and guiding, and some outfitters have been great supporters of protecting Wilderness. But, outfitting and camps have impacts that are often glossed over or overlooked, including degraded campsites—some with inappropriate structures—and wilderness trails so heavily used by pack animals that they more resemble roads than foot or horse trails.
Now the Forest Service proposes to renew special use outfitter permits that will be in place for at least a decade without disclosing the impacts from these commercial operations.
While a map is provided with the agency's short letter, it omits the boundaries of the Wildernesses and Wilderness Study Areas. Further, the agency's scoping letter lacks important information, such as annual inspections, public complaints or concerns, or monitoring, to ensure the currently permitted uses are appropriate for these Wildernesses. A project of this size, involving 47 commercial permits spread across 3.4 million acres, needs to have an environmental impact statement.
Please speak up for Wilderness by August 9 at this link: https://cara.fs2c.usda.gov/Public//CommentInput?Project=66448 |
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Please urge the Forest Service to protect the Anaconda Pintler and Lee Metcalf Wildernesses and the Sapphire and West Pioneer Wilderness Study Areas as it considers renewing outfitter permits. Use your own words, but consider the following points: - The Forest Service's responsibility is to preserve the wild character of these areas, not to promote any particular use, such as outfitting and guiding.
- A project of this size, involving 47 commercial permits spread across 3.4 million acres, needs to have an environmental impact statement with accompanying public input.
- Some key specific information is lacking, despite the Forest Service requesting specific comments. For example, the small-scale maps do not show Wilderness or Wilderness Study Area boundaries. The list of outfitters omits the actual number of used service days and whether they operate in Wilderness or Wilderness Study Areas. The Forest Service offers no information about outfitter performance (collectively or individually), and the letter offers no information about the condition of the areas used by outfitters, even though the agency admits "there is a need to improve our administration and oversight of the outfitting and guiding program." Accordingly, the Forest Service must make this information available for public review on its website and extend the public comment period by 30 days following publication.
- Outfitters should not have special privileges—like permanent campsites often in the most desirable locations—but should operate as the general public does.
- None of the new permits or expansion of existing permits issued since 2017 should be renewed in this process since those permits never went through an environmental analysis and public involvement process. A categorical exclusion (CE) is cursory, at best, and inadequate in this instance. Further, given the many impacts outfitting has on the Wilderness, the Forest Service must not use a CE to renew any outfitter permits. The Forest Service admits it is must improve its outfitting program, yet it starts out on the wrong foot by proposing to renew permits across the entire national forest with limited analysis and public involvement.
- Proposed "design features" (detailed aspects of outfitter activities related to resource concerns) should have been included in permits and need to be strengthened. For example, outfitting guides and their clients should be required to carry pepper spray in grizzly habitat and the permitted 20 head of pack animals per party in most of the Lee Metcalf Wilderness is too much for that area; instead, the Forest Service should adopt a maximum of 12 pack animals and 12 people, and even less where on-the-ground conditions dictate.
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