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White Mountain National Forest, New Hampshire

Speak up for Wilderness in the White Mountain National Forest!

The Forest Service (FS) is accepting public comments on a proposal to amend its Forest Plan in regards to Wilderness trail management in the White Mountain National Forest (WMNF) in New Hampshire and Maine. The agency is trying to do the right thing by addressing trail issues in Wilderness in the WMNF, but Wilderness Watch and one of our local allies, Standing Trees, believe that rather than amend its Forest Plan, the FS should consider trail relocations in Wilderness on an individual basis. Please speak up before the April 23 deadline and urge the agency to adopt this different approach that would be better for Wilderness.

The WMNF includes six Wildernesses covering nearly 150,000 acres: the Pemigewasset, Great Gulf, Presidential Range-Dry River, Wild River, Sandwich Range, and Caribou-Speckled Mountain Wildernesses. Native wildlife such as moose, black bears, Canada lynx, fishers, beavers, white-tailed deer, coyotes, peregrine falcons, and bobcats call the mountains, hardwood and spruce-fir forests, and river valleys here their home. The White Mountain National Forest and its Wildernesses, popular with hikers and skiers, have seen a lot of use in recent years.

There are trailless zones in Wilderness in the WMNF, and the current Forest Plan requires trails in Wilderness to be located within designated trail corridors. (Trail corridors are 1000’ wide, with trails running through the middle of the corridor.) The FS is proposing to change its Forest Plan to allow trail relocations outside of established trail corridors in Wilderness. The proposed change to the Forest Plan could allow trails to be relocated to currently trailless areas.

The FS has just one concrete proposal as of now to relocate a deteriorating trail—the Webster Cliff Trail—that sits just outside the Presidential Range-Dry River Wilderness. The presence of a cliff in the immediate area calls for possibly relocating the trail into the Wilderness.

We suggest that the Forest Service, instead of amending its Forest Plan, conduct site-specific assessments for trail relocations within Wilderness, including for the Webster Cliff Trail. In fact, the Forest Service states a site-specific NEPA analysis on the Webster Cliff Trail relocation is needed whether this proposed Forest Plan amendment goes through or not. It’s worth noting that trail relocations in Wilderness could possibly happen within established trail corridors, making a Forest Plan amendment unnecessary. Looking at individual trail relocations also allows for better analysis of impacts to Wilderness; if the FS amends its Forest Plan, it may not look at all impacts for future trail relocations.

Since trail relocation outside of established trail corridors in Wilderness is an exception to the White Mountain National Forest’s Wilderness plan, the FS needs to look at impacts on site-specific basis. Trailless areas help protect plants and wildlife, keep Wilderness from being overrun by humans, and offer a truly primitive experience for those who venture into these areas. The Forest Service should not weaken Wilderness protections in trailless areas by amending its Forest Plan to allow trails potentially throughout Wilderness in the White Mountain National Forest.

In addition, we are concerned by the precedent that would be set if the White Mountain National Forest uses a Categorical Exclusion from the National Environmental Policy Act to make their proposed Forest Plan amendment. Categorical Exclusions allow the agency to make management decisions with reduced analysis and public input. A Forest Plan amendment will have lasting and wide-ranging impacts, and should only be undertaken with rigorous analysis and public feedback.

As a final thought, it’s commendable that the FS intends (as verbally indicated to WW) to carry out Wilderness trail work without the use of use mechanized or motorized equipment.

Please submit a comment by April 23. Comments need to be submitted here: https://cara.fs2c.usda.gov/Public//CommentInput?Project=63551

Please use your own words where possible, but consider the following talking points:

  • The Forest Service should drop its proposed Forest Plan amendment for the White Mountain National Forest as it considers how to address Wilderness trail management. Amending the Forest Plan to allow trail relocation throughout Wilderness could weaken protections for currently trailless areas, which help protect plants and wildlife, keep Wilderness from being overrun by humans, and offer a truly primitive experience or those who venture into these areas.
  • The Forest Service should instead conduct site-specific NEPA analysis for all trail relocations it proposes outside of established trail corridors in Wilderness, including for the Webster Cliff Trail. Trail relocation in Wilderness outside of designated trail corridors is an exception to the WMNF’s Wilderness plan, and looking at trail relocation on an individual basis allows for better analysis of impacts to Wilderness.
  • The Forest Service should make every effort to relocate trails in Wilderness within established trail corridors.
  • The Forest Service should not use a Categorical Exclusion to amend its Forest Plan. A Forest Plan amendment will have lasting and wide-ranging impacts, and should only be undertaken with rigorous analysis and public feedback.
  • All trail relocation work in Wilderness should be completed using traditional skills and tools, rather than motorized and mechanized equipment.

Thank you!

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Photo: Looking into the Pemigewasset Wilderness, NH by ScenicNH Photography 

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