United States 

Department of 

Agriculture 

Forest 

Service 

Intermountain 

Region 

Wasatch-Cache 

National Forest 

February 2003 

 

Final Environmental

Impact Statement

Appendix A – Response

to Comments
Final Environmental Impact Statement 

Wasatch-Cache National Forest 1 

APPENDIX A 

Table of Contents 

 First 

Page 

Number 

Appendix A....................................................................................................... A-1 

Public Involvement ........................................................................................... 

Introduction.................................................................................................... 

Public Outreach.............................................................................................. 

Summary of Public Comment........................................................................ 

General Overview of Public Comment .................................................... 

Overview of Comment on Specific Topics .............................................. 

Analysis of Public Comment ......................................................................... 

Agency Response to Comments .................................................................... 

Planning and Decision Process................................................................. 

Public Involvement and Collaboration ..................................................... 

Relationship to Other Planning and Rulemaking Processes..................... 

The Forest Planning Process..................................................................... 

Funding and Fees...................................................................................... 

Alternatives............................................................................................... 

Alternative Development.......................................................... 

Adequacy of Alternatives ......................................................... 

Comparison of Alternatives ...................................................... 

Suggestions for New Alternatives ............................................ 

Alternatives Considered in Detail............................................................. 

Forest Plan Direction................................................................................ 

Management Prescription Categories ....................................... 

Recreation Opportunity Spectrum ............................................ 

Recreation Opportunity Spectrum – Site Specific 

Designations.............................................................................. 

Affected Environment .............................................................................. 

Environmental Values General................................................. 

Ecosystem/Restoration Management........................................ 

Topic 1: Watershed Health Management ................................ 

Soils, Water, and Geologic Resources............................. 

Air Resources................................................................... 

Topic 2: Biodiversity and Viability Management ................... 

Biodiversity and Viability Management General ............ 

Wildlife ............................................................................ 

Management Indicator Species........................................ 

Threatened, Endangered, and Sensitive Species.............. 

Vegetation........................................................................ 

Topic 3: Roads and Access Management ................................ 

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Final Environmental Impact Statement 

Wasatch-Cache National Forest 2 

Infrastructure General ...................................................... 

Trailhead Access and Parking.......................................... 

Road System Management .............................................. 

Trail System Management ............................................... 

Travel Management – Planning....................................... 

Travel Management – Motorized Access to Forest 

Resources ......................................................................... 

Travel Management – Roads and Trails .......................... 

Travel Management – Motorized Seasonal Restrictions . 

Travel Management – Winter Motorized ........................ 

Travel Management – Mechanized.................................. 

Topic 4: Recreation and Scenery Management ...................... 

Recreation and Scenery Management.............................. 

User Conflict/Monitoring and Enforcement .................... 

Motorized Recreation....................................................... 

Motorized Recreation – Off Road Vehicles..................... 

Motorized Recreation – Snowmobiles............................. 

Motorized Recreation – Heli-skiing................................. 

Motorized Recreation – Watercraft ................................. 

Non-Motorized Recreation .............................................. 

Ski Areas.......................................................................... 

Hunting and Fishing......................................................... 

Outfitter-Guides/Special Use Permits.............................. 

Camping........................................................................... 

Dogs ................................................................................. 

Miscellaneous Activities.................................................. 

Scenery............................................................................. 

Topic 5: Roadless Areas/Wilderness Management ................. 

Roadless Areas/Wilderness Management General .......... 

Roadless Area Management ............................................ 

Wilderness Management.................................................. 

Topic 6: Suitable Timberlands................................................. 

Suitable Timberlands General.......................................... 

Adequacy of Analysis...................................................... 

Allow Timber Harvest ..................................................... 

Not Allow/Restrict Timber Harvest................................. 

Insects and Disease .......................................................... 

Topic 7: Rangeland Capability, Suitability, and Forage 

Production................................................................................. 

Rangeland Capability, Suitability, and Forage 

Production General .......................................................... 

Legal Considerations ....................................................... 

Rangeland Management................................................... 

Subsidies .......................................................................... 

Grazing............................................................................. 

Topic 8: Special Designations ................................................. 

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Final Environmental Impact Statement 

Wasatch-Cache National Forest 3 

Special Designations General .......................................... 

Research Natural Areas.................................................... 

Special Interest Areas ...................................................... 

Wild and Scenic Rivers.................................................... 

Topic 9: Oil and Gas Leasing .................................................. 

Oil and Gas Leasing General ........................................... 

Adequacy of Analysis...................................................... 

Allow Leasing.................................................................. 

Do Not Allow/Restrict Leasing ....................................... 

Topic 10: Fire Management..................................................... 

Fire Management General................................................ 

Adequacy of Analysis...................................................... 

Legal Considerations ....................................................... 

Education ......................................................................... 

Fuels Management........................................................... 

Heritage Resources ................................................................... 

Locatable and Salable Minerals................................................ 

Adequacy of Analysis...................................................... 

Mineral Extraction ........................................................... 

Social and Economic Analysis.................................................. 

Social and Economic Analysis General........................... 

Social Values ................................................................... 

Economic Values ............................................................. 

Lands, Real Estate, and Property Boundary Management ....... 

Lands, Real Estate, and Property Boundary Management 

General............................................................................. 

Land Purchases and Exchanges ....................................... 

Access .............................................................................. 

Other ................................................................................ 

 Copies of Letters from other Government Agencies ........................... 

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Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 1 

APPENDIX A – PUBLIC INVOLVEMENT 

Introduction 

As a federal agency, we are required to solicit public comment on our draft plans 

involving significant actions under the National Environmental Policy Act (NEPA). 

Further, we are directed to “assess and consider [the resulting] comments both 

individually and collectively.” In addition, we view such comments as critical in helping 

us to shape a responsible plan for management of the Wasatch-Cache National Forest that 

best meets the Forest Service’s mission, legal mandates, the goals of NEPA and the 

National Forest Management Act (NFMA), and the interests of the American public as a 

whole. 

Forest and Intermountain Region leadership and the forest plan interdisciplinary team 

have examined the range of public opinion on the issues and alternatives identified during 

the forest plan revision process. The Forest Service places high value on the reasoned 

and heartfelt comments that were received. 

This appendix includes five sections. The first section outlines the public outreach 

activities and efforts made to solicit public input during the forest plan revision process. 

The second section is a summary of the 3,700 responses to the Draft Environmental 

Impact Statement (DEIS) and Proposed Forest Plan. The third section describes how we 

analyzed the formal public comment we received on the DEIS and Proposed Forest Plan. 

In the fourth section we list the public concerns and our response to them. The fifth 

section includes copies of all comments received on draft EIS from the Federal, State, 

and local agencies and elected officials. 

Public Outreach 

Because the land and resource management planning process determines how the lands of 

the National Forest System are to be managed, the public is encouraged to participate 

throughout the planning process. Several opportunities were presented to members of the 

public to gather their input and allow involvement essential to drafting these documents. 

Initially, areas where the plan needed changes or updating were identified by the 

Planning staff, after reviewing environmental documents on file, the 1992 Monitoring 

Report, meetings and letters from the public, and conversations with other Forest 

personnel. These needs for change were formally taken to the public in April of 1999 in 

the Preliminary Analysis of the Management Situation (PAMS). It also included an 

assessment of conditions and described the new framework for a forest plan. The 

concept of management prescriptions was introduced as part of the framework. 

Throughout April and May 1999 public information forums in 11 communities were 

held. We heard from several hundred people through letters, e-mail messages, and 

conversations at open houses. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 2 

The Need for Change topics evolved into the Revision topics. Once revision topics were 

identified, in September of 1999 the Proposed Action for Plan Revision and Notice of 

Intent (NOI) for the preparation of an environmental impact statement were released for 

comment. Public meetings were held in four communities to explain the Proposed Action 

for the Forest Plan Revision. Approximately 150 people attended these meetings and 

some 247 comments were received. 

In November and December 1999 we began to develop alternatives to rthe Proposed 

Action. Public workshops (8 sessions in 4 communities) were held to review issues and 

to engage the public in assisting with mapping of alternatives. Over 400 people attended. 

Opinions were diverse and the level of interest in Forest Plan Revision high. There were 

significant comments on snowmobiling, livestock grazing, recreation opportunities, and 

roadless/wilderness areas. The alternatives were developed to reflect these comments. 

At key points we provided feedback to the public about our progress and comments we 

had heard. A Wasatch-Cache Newsletter on Plan Revision Update was mailed to 1,695 

people in December 1999. Early in the new year a summary of public comments on the 

Proposed Action and their disposition were sent to participants. 

A document explaining the five preliminary alternatives was mailed to public for 

comments in August of 2000. Feedback from the public helped the Planning team refine 

the alternatives to be analyzed in depth and the development of the preferred alternative 

to be displayed in the DEIS and Proposed Plan. It was crafted using some aspects of 

other alternatives. 

In May 2001 we mailed the Proposed Forest Plan and Draft Environmental Impact 

Statement out to public and other agencies for review. Recognizing the complexity and 

detail of the planning document and maps we hosted a series of open houses in key 

communities. Forest leadership and the Planning Team were on hand to answer 

questions and gather comments. 

During the summer and fall, planning team members appeared at numerous organization 

meetings to listen and explain the Proposed Forest Plan. In October and November we 

held formal oral comment hearings in key communities. We received over 200 oral 

comments on DEIS and Proposed Forest Plan. By the close of the comment period in 

November 2001, the forest had received over 3,700 formal comments on DEIS and 

Proposed Forest Plan. In June of 2002 a newsletter providing a general overview of these 

comments was mailed to nearly 5,000 recipients. 

The Final EIS examines seven alternatives. Alternative 7 was formulated to deal 

specifically in response to comments on the draft EIS and new analysis completed after 

development of the release of the DEIS and Proposed Plan. Each alternative contains a 

theme that provides emphases for human uses and physical and biological resource 

management. 

Members of the Forest Planning staff have coordinated with other federal agencies, the 

Bureau of Land Management; Fish and Wildlife Service; National Park Service; and 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 3 

Natural Resources Conservation Service; and various state agencies, including the 

Department of Natural Resources; the Utah Division of Wildlife; and the Governor’s 

Office of Planning and Budget. Staff also coordinated with Utah State University, U.S. 

Congressional representatives, county planners and county commissioners. 

Beginning in May of 2000 we coordinated and consulted with Uinta County, Wyoming 

and Summit County, Utah who have been identified as Cooperating Agencies. 

Summary of Public Comment 

The following is a summary of public comment received by the Wasatch-Cache National 

Forest (WCNF) regarding the draft revised Land and Resource Management Plan (Forest 

Plan) for the WCNF and accompanying Draft Environmental Impact Statement (Draft 

EIS). The comment period was May 9 to November 1, 2001. The WCNF received 3,762 

responses, including transcripts of oral comments from formal public meetings, letters, 

emails, and faxes. 

The summary begins with a general overview of public comment on the Draft EIS and 

Forest Plan, and follows with a discussion of respondents’ main areas of concern. This 

summary is not intended to provide an exhaustive account of public concerns. Indeed, 

much of the comment on the WCNF Draft EIS and Forest Plan consists of site-specific 

requests for management prescription category allocations and travel/recreation 

allocations; these site-specific comments cover so much ground (figuratively and 

literally) that they do not lend themselves to a brief summarization. This summary, 

therefore, is intended only to give a general discussion of the pervasive themes running 

through public comment. 

General Overview of Public Comment 

Public comment on the Draft EIS and Forest Plan is far-reaching, often highly detailed, 

and represents a wide range of values and perspectives with respect to public land 

management in general and management of the WCNF in particular. Given this wide 

range of values and perspectives only broad generalizations are possible. 

In general, those who comment fall roughly into two groups: those who tend to 

emphasize preservation and protection of forest natural resources, and so request greater 

restrictions on various human uses; and those who tend to emphasize motorized access to 

and traditional use of forest lands, and so request either fewer or at least no additional 

restrictions. The distinction between these two groups is not absolute. The former group 

also values access and use; while the latter group also expresses concern for forest 

protection. Virtually everyone who comments on the Forest Plan and Draft EIS cares 

about the condition of the WCNF and about the value it has to users of all types. The 

difference is one of emphasis, and this often revolves around each group’s perception of 

the nature and degree of impacts caused by human activities, especially recreational 

activities. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 4 

This difference in emphasis is reflected in the preferences people voice regarding the 

general management philosophy that ought to guide the WCNF. The preservationoriented group favors ecosystem/restoration management: they stress preservation of 

natural processes and landscapes, ecosystem protection, and restoration of degraded 

areas. The use-oriented group favors multiple use management which, under their 

interpretation allows much more active management of forest resources, allows 

traditional levels of commodity extraction and grazing, and allows widespread motorized 

recreation (this management philosophy is referred to in the document as Traditional 

Multiple Use Management). 

These different perspectives drive the comments people offer on virtually every topic. 

The single most frequently mentioned topic in public comment, however, is recreation, in 

particular motorized recreation. Preservation-oriented respondents frequently request that 

motorized recreation, both summer and winter, either be restricted or prohibited—in 

general, under certain conditions, or in specific areas. Use-oriented respondents 

frequently request that motorized recreation, both summer and winter, either be allowed 

or at least not be further restricted—in general, under certain conditions, or in specific 

areas. 

Those who ask that motorized recreation be restricted appeal primarily to environmental 

and social considerations. According to these respondents, motorized recreation causes 

erosion and degrades the environment, damages watersheds, produces noise and air 

pollution, and disrupts wildlife. The noise and exhaust, they say, also disrupts nonmotorized recreationists who go into the canyons to escape from the hustle and bustle of 

urban life, and to gather peace and mental rejuvenation from quiet, pristine landscapes. 

These respondents also say that restrictions will not negatively impact motorized users 

inasmuch as there are already so many areas open to them. 

Those who ask that motorized recreation not be restricted argue that it does not harm the 

environment. While some people violate motorized boundaries and engage in behavior 

that is harmful to resources, they say, that is no reason to restrict all users; rather, the 

WCNF should rely on education and enforcement. Beyond that, these respondents appeal 

primarily to social and economic considerations. Many say that motorized recreation has 

become a much-loved family tradition, one that family members of all ages and physical 

abilities can enjoy. Indeed, these respondents frequently argue that motorized access is 

essential for the elderly and the physically impaired (a point countered by other 

respondents, however). Further, they maintain, motorized recreation contributes 

significantly to local economies. 

These different views frame the significant number of site-specific requests made by the 

public. Respondents submit many requests regarding management prescription category 

allocations, travel and recreation allocations, roadless area designations and management, 

and wilderness recommendations and management. These numerous requests relative to 

specific areas, in conjunction with all other concerns raised by the public, reveal how 

important the WCNF is to people, and how much they care about its management and the 

many benefits they derive from it. Further, as allocation decisions are at the heart of the 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 5 

Forest Plan, these comments and their rationales provide the planning team important 

feedback for use in final decisionmaking. Please consult the full summary of public 

concerns to review the site-specific comments as well as to examine the full range of 

public comment. 

Overview of Comment on Specific Topics 

Following is a summary of public comment on specific topics. These topics include forest 

plan development and planning issues, the alternatives, forest plan direction with respect 

to management prescription categories, and various management activities and affected 

resources. 

Forest Plan Development and Public Involvement 

Adequacy of the Document 

A number of respondents make a point of saying they find the proposed Forest Plan and 

Draft EIS well done, clear, and immensely readable. Other respondents suggest various 

ways in which the WCNF should improve its documents. Suggestions include providing 

a more detailed table of contents or an index; producing a cross-walk document to clarify 

the relationship between the current and proposed Forest Plan; providing sufficient detail 

for site-specific travel analysis; improving the quality of its maps; and making various 

technical corrections. 

General Adequacy of the Draft EIS Effects Analysis 

A number of respondents comment that the Draft EIS cumulative effects analysis is 

inadequate. Others advise the WCNF to factor into its effects analysis the effects of 

management—including the level of development—of adjacent non-federal lands. 

Relation of the Forest Plan to the Roadless Area Conservation Rule 

People offer very different views regarding the possible application of the Roadless Area 

Conservation Rule to the WCNF forest planning process. A number of respondents 

advise the WCNF to protect roadless areas in a manner consistent with the Rule 

regardless of the Rule’s legal status. On a similar note, many say the WCNF should 

establish its own strong protection of roadless areas independent of national rulemaking. 

Others advocate that the WCNF not manage roadless areas in accord with the Rule. 

Indeed, assert some, the final Forest Plan should state that it is not required to comply 

with the Rule, pending resolution of legal challenges, and should state that inventoried 

roadless areas will not be subject to any restrictions beyond the assigned management 

prescription category. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 6 

Forest Plan Development General 

A number of respondents offer varied comments regarding the general development and 

adequacy of the Forest Plan. According to some, the proposed plan allows too much 

management flexibility. Suggestions for reducing flexibility include providing detailed 

descriptions of desired future conditions; more effectively integrating desired future 

conditions for each resource to those for management areas as a whole; more effectively 

linking desired future conditions to anticipated management actions; adding specific and 

measurable standards throughout the final Forest Plan; listing prescription-specific 

standards and guidelines separately from forest-wide direction; and eliminating the word 

“generally” from all management prescription category descriptions. Others, however, 

recommend increasing management flexibility—by reducing specificity in the 

management prescription categories, and by reevaluating management prescription 

categories on a district-by-district basis. 

Public Involvement Efforts 

One respondent commends the WCNF for “involving the public throughout the process 

of producing a thorough, well researched DEIS.” Others suggest ways of improving its 

outreach efforts with the public—by expanding outreach efforts with motorized 

recreationists in order to improve support for travel management decisions; by holding 

informational planning meetings at the ski resorts in order to seek comment from out-ofstaters who come here to ski; and by publishing documents and holding meetings in 

Spanish in order to reach the growing Hispanic population who lives along the Wasatch 

Front and recreates in the Tri-Canyon area. Others comment on the need to maintain a 

friendlier, more neutral atmosphere at public meetings, saying that inflammatory 

language—especially comparing environmentalists to terrorists in light of the events of 

September 11—is uncalled for and intimidating to other participants. 

Use of Public Comment in the Decision Process 

A few individuals suggest the WCNF should advise people about how to write effective 

comment and should make it easier to submit e-mail comments. Beyond that, most 

respondents who address this topic offer suggestions on how the WCNF should weigh 

public comment in the decision making process. Some say greater weight should be given 

to those who pay fees. Several say that more weight should be placed on comments from 

local users. Others, however, contend that federal lands are for all of our use. Some 

complain that many people who submit comment are ill-informed about the issues, and so 

greater weight should be given to detailed, scientifically-backed comments. 

Some members of the public emphasize that the comment consideration process should 

not be turned into a vote. Others, however, advise the WCNF to canvass public opinion 

by, for example taking a public opinion poll or field surveying people who are actually 

using the land in question. 
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Wasatch-Cache National Forest A - 7 

Finally, some people suggest that submission of written comment may not provide the 

best means of interaction between the public and decision makers inasmuch as response 

to individual concerns and oral comments at meetings, if it does come, comes at a much 

later date. One individual suggests convening less formal town meetings prior to 

finalizing the Forest Plan; others say the WCNF should provide specific responses to 

individual comments. 

Involvement of Interest Groups 

The perceived influence of special interest groups sparks very divided comment. Some 

thought in many cases powerful national environmental organizations use ‘junk’ science 

and are interested in only closing public lands to vehicle access and recreation. Typical 

comments on the other side is the charge that private and corporate interests have undue 

influence. 

Collaboration 

Respondents suggest that the WCNF should collaborate with state, county, and local 

governments in addressing a number of administrative/management issues—such as the 

size of recreational motorized tags, coordination of wildlife introductions, coordination 

with zoning regulations, and the use of cooperating agency status. Additionally, some 

advise the WCNF to better coordinate its management with that of adjacent national 

forests. Suggestions include working with both the Caribou and Uinta National Forests 

regarding wilderness recommendations; working with the Uinta National Forest to 

establish consistent requirements for the Snowbird ski area; and working with adjacent 

forests to ensure consistent management prescription categories, allocations, and travel 

management plans. 

Alternatives 

Adequacy of Alternatives 

Many people reference the alternatives in their comments. Most respondents justify their 

preference for or against a given alternative within the context of effects on a particular 

resource area; hence it is in the resource sections of the document that most of these 

comments are found. A number of respondents do specifically assert, however, that the 

range of alternatives are inadequate and suggest ways that it could be broadened. Often 

people suggest including an alternative which emphasizes their preferred management of 

a particular resource—e.g., restricting motorized access, eliminating timber harvest and 

grazing, recommending all roadless areas as wilderness, or protecting biodiversity and 

ecosystem services. Some suggest the WCNF provide a balanced range of non-motorized 

winter recreation designations; a wider range of wilderness recommendations; and a full 

range of alternatives for grazing. 

Additionally, a few respondents offer detailed requests for a new alternative. Some 

suggest a new alternative should offer a more balanced approach to resource protection, 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 8 

commodity output, and recreational opportunity than any of the six alternatives under 

consideration. 

Comparison of Alternatives 

Several respondents advise the WCNF to specifically compare the effectiveness of 

Alternatives 1 and 6 with respect to management prescriptions, motorized recreation, 

winter recreation, scenic quality, and ecosystem protection. Others ask that resource 

outputs be provided for each alternative, and that all be compared with respect to forest 

health—including wildfire, insects, and disease. 

Alternatives Considered in Detail 

Of those respondents who specifically address the advisability of implementing a 

particular alternative, most address their comments to Alternatives 1, 2, 5, and 6. 

Alternative 1 – Those who request that the WCNF select Alternative 1 assert that it best 

protects the environment, reduces motorized recreation, preserves recreational 

opportunities, prohibits other development, emphasizes wilderness protection, and 

protects habitat. Conversely, others ask that it not be selected because it promotes 

wilderness above other uses, restricts recreational opportunity, restricts use, and harms 

wildlife habitat. 

Alternative 2 – Some respondents suggest the WCNF select Alternative 2 because it 

preserves the land, protects the environment, and has the least impact on air quality. 

Others say Alternative 2 should not be chosen because it restricts recreational 

opportunities, restricts use, harms wildlife habitat, and promotes wilderness above other 

uses. 

Alternative 3 – A few respondents suggest the WCNF select Alternative 3 because it is 

well balanced, while one individual maintains that it recommends too much area for 

wilderness designation to be acceptable. 

Alternative 4 – A few respondents suggest the WCNF select Alternative 4 because it 

maintains existing uses and represents a fair compromise. 

Alternative 5 – Numerous respondents ask the WCNF to select Alternative 5 because it 

best supports diverse recreational use, as well as other traditional uses, while still 

providing adequate protection for the land, water, watershed, and wildlife of the forest 

ecosystem. They also stress that more wilderness is not needed. Others suggest that 

Alternative 5 should not be chosen because it allows too much off-road vehicle abuse and 

too much development. 

Alternative 6 – Many people advise the WCNF to select Alternative 6. They felt that 

Alternative 6 represents compromise. Those in favor of Alternative 6 emphasize that it 

protects the environment, protects recreational opportunities, and preserves heli-skiing. 
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Wasatch-Cache National Forest A - 9 

Other respondents oppose Alternative 6. Those who oppose it typically fall into one of 

two groups: one group echoes the sentiment expressed in the first part of the above quote 

in saying they really prefer stronger protection and restrictions; the other group opposes it 

because it imposes too much protection. 

Suggested modifications to Alternative 6 reflect these two different perspectives. 

According to some, Alternative 6 should be modified to more adequately protect the 

environment, to protect wildlife corridors, to protect Canadian lynx habitat, and to 

increase the areas recommended for wilderness. Others say it should be modified to 

preserve motorized recreation opportunities, and to create less restrictions overall. 

Forest Plan Direction 

Management Prescription Categories 

Some respondents offer general comments about management prescription categories—

such as that the WCNF should provide a more equitable distribution of acres by 

management prescription categories, or should allocate acreage in inverse proportion to 

the degree of impact of each activity. A few ask the WCNF to clarify the distinction 

between certain management prescription categories, such as that between 3.1 and 3.2, or 

between 2.6 and 4.1. Additionally, a number of respondents ask the WCNF to assign 

more protective management prescription categories to all roadless acres—by utilizing 

Management Prescription Categories 1.5, 2.4-2.7, or 4.1. 

Beyond these general considerations, many respondents make site-specific requests for 

management prescription category allocations. Because many of these requests are so 

detailed and far-ranging, they cannot be adequately summarized. Rather, a few 

generalizations are offered regarding the general direction of these requests. In general, 

most site-specific requests reflect the same emphasis on more protective management 

prescription categories as that found in the comments directed to roadless acres as a 

whole. Most site-specific requests are for Management Prescription Categories 1.5, 2.4-

2.7, 3.1-3.2, and 4.1. Some request Management Prescription Category 4.5 for certain 

locations to allow for ski area expansion. Other comments make very specific 

management requests for certain areas involving multiple management prescription 

category allocations—some focusing on protection/restoration, and some focusing on 

commodity production. 

Recreation Opportunity Spectrum 

Many comments, which are directed specifically to Recreation Opportunity Spectrum 

allocations, are concerned about allocations for motorized recreation. Many request more 

semi-primitive motorized areas, saying the WCNF “[has] failed to adequately plan for the 

increase in popularity of motorized recreation in past years, let alone for the future.” 

Other respondents, however, maintain that semi-primitive non-motorized designations 

can be impacted by the noise coming from motorized designations on adjacent land. 

Many non-motorized recreationists assert that motorized use has exploded along with the 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 10 

power of these vehicles, and request more non-motorized allocations to preserve their 

recreational experience and the environment. Another suggestion made by the public is 

that the WCNF develop four winter recreation classes: 

wilderness, non-motorized, motorized, and motorized heli-ski. 

Beyond these general comments, some people make site-specific requests for Recreation 

Opportunity Spectrum allocations. Most ask the WCNF to apply or extend semi-primitive 

motorized corridors to trails in certain areas, or conversely to close these areas to 

motorized travel. 

General Environmental Values 

Most general comments regarding environmental values address the advisability of 

ecosystem/restoration management versus traditional multiple use management. 

Ecosystem/Restoration Management 

Many respondents request that the WCNF preserve forest lands in their natural state and 

restore degraded areas. People maintain that the WCNF should not rely on intensive 

management to preserve forest resources, but should instead minimize human 

interference. Some ask the WCNF to develop a comprehensive plan for ecosystem health 

and species viability. Within that context, some ask the WCNF to protect and restore 

ecological integrity, and to aggressively restore the historic range of variability by 

“allowing natural disturbance regimes to operate as freely as possible within the 

undeveloped landscapes.” Many feel that this approach best meets both human and 

environmental needs, especially since the Wasatch Mountains provide drinking water for 

many urban communities. 

Traditional Multiple Use Management 

Numerous people advise the WCNF to continue traditional multiple use management. 

They believe multiple-use management goals are the only goals that will ‘best meet the 

needs’ of the public and provide for equal program delivery to all citizens including 

motorized visitors. This view is echoed by most respondents who identify themselves as 

motorized users. People also say this approach is needed to address forest health issues 

and to maintain important social values. Some individuals describe family traditions 

centered around motorized activities in the WCNF and fear that, in the absence of 

traditional multiple use management, they will not be able to continue those traditions 

into the generations to come. A few respondents also emphasize the need to protect 

heritage resources and western culture which is “characterized by access to the land for 

multiple-uses, friendliness, good neighborliness, and sharing”—and claim that traditional 

multiple use management is essential to that end. 
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Wasatch-Cache National Forest A - 11 

Topic 1: Watershed Health Management 

Respondents often express concern over the effects of various agents on water quality—

such as nitro aromatic compounds, sediment, and sewage spills—as well as the need to 

enhance water production. Most comment on water resources, however, addresses 

watershed health. People ask the WCNF to protect watersheds for a number of reasons, 

but primarily to preserve the water supply for a growing population. 

Suggestions to address watershed health include designating sensitive or damaged 

watersheds and directing future management accordingly, and prohibiting any activities 

that degrade watershed health. People ask the WCNF to provide detailed strategies 

regarding water management in the final Forest Plan, and to more adequately analyze 

watershed condition and the impacts of various activities on watershed health. 

Topic 2: Biodiversity and Viability Management 

Aquatic and Terrestrial Habitat 

Most of the comments on the topic of biodiversity and viability management address 

wildlife management. Some suggest that the WCNF improve its analysis of wildlife 

habitat—by instituting appropriate data collection; analyzing anticipated changes in 

habitat components; and analyzing the effects of tree density and road management on 

terrestrial wildlife. Respondents state that the WCNF should protect critical wildlife 

habitat by providing adequate direction for wildlife habitat management, by giving 

priority to actions that enhance habitat, and by preserving large tracts of land. They 

suggest improving aquatic habitat protection by tying the monitoring of aquatic resources 

to specific management implementation, and by maintaining aquatic habitat through 

different allocations of management prescription categories. 

Likewise, respondents ask the WCNF to preserve wildlife habitat corridors—by restoring 

wildlife habitats within the context of eco-regional planning; by protecting habitat 

corridors between forest areas; by protecting national forest lands sufficiently to offset 

adverse effects caused by management practices on private lands; and by prohibiting 

extractive uses, motorized vehicles, and grazing in wildlife corridors. On the other hand, 

some ask the WCNF not to manage for wildlife corridors. 

 

Aquatic and Terrestrial Species 

Some respondents offer specific comment on a number of species. Some ask the WCNF 

to reconsider management of non-native wildlife, especially mountain goats and nonnative fish; others ask the WCNF to emphasize big game species management and to 

protect big game winter ranges. 

A number of respondents address their comments to predator management, in particular 

to management associated with the lynx. Some ask the WCNF to protect the lynx by 

protecting lynx habitat; by taking into account the variety of factors influencing the status 

of the lynx; and by developing goals, objectives, standards, and guidelines specifically 
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Wasatch-Cache National Forest A - 12 

designed to mitigate impacts on the lynx. Others, however, maintain that studies on lynx 

management are inconclusive and that the lynx can survive along with traditional 

multiple use activities. Therefore, these respondents conclude, the WCNF should 

reevaluate any management prescription category designation, or alternative selection 

made based on the lynx, and should not restrict activities because of possible lynx habitat. 

Another species mentioned often is the native cutthroat trout. People ask the WCNF to 

restore and expand its habitat and to better address the impacts of non-native fish species. 

Management Indicator Species 

Various members of the public urge the WCNF to improve its management of 

management indicator species. Suggestions include prescribing goals, objectives, 

standards, guidelines, and mitigation measures for all management indicator species by 

developing an adequate monitoring program for management indicator species; and 

analyzing the relationships between management indicator species, habitat, and other 

species. Some suggest selecting additional terrestrial animals as management indicator 

species, others suggest including predators, or relying more heavily on bird species. 

Threatened, Endangered, and Sensitive Species 

Respondents request that the WCNF better protect threatened, endangered, and sensitive 

species. Suggestions include providing a full range of standards and procedures for the 

selection of sensitive species; managing all threatened, endangered, and sensitive species 

in the context of the overall, functional ecosystem; improving monitoring of these 

species; and conducting surveys for sensitive species before allowing certain activities. 

Vegetation 

People offer a wide variety of suggestions regarding vegetation management. 

Suggestions include providing a mix of vegetative age classes; maintaining more old 

growth forest; eliminating commercial timber harvest; ensuring adequate amounts of 

snags and downed wood; acting to reverse aspen decline; maintaining sagebrush 

communities; protecting the habitat for five unique species of wildflowers; revegetating 

with seed from native plants; and preserving nonvascular plant species. Some also 

express concern over management of noxious weeds. Some suggest restricting activities 

in areas where noxious weeds occur such as to avoid spreading them; others, however, 

say the WCNF should more fairly evaluate the spread of noxious weeds and not assume it 

is caused by motorized recreationists. 

Topic 3: Road and Access Management 

Road and access management is a topic of great interest and concern to many 

respondents. Many of the comments that appear in this section of the document are 

closely related to comments in Recreation section. 
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Wasatch-Cache National Forest A - 13 

Road System Management 

Numerous respondents comment on management of the road system. A few ask the 

WCNF to address Revised Statute 2477 (RS 2477) roads—by evaluating the direct and 

cumulative impacts of road closures on RS 2477 routes, and by recognizing RS 2477 

road rights-of-way claimed by local governments for all routes in existence prior to 1976. 

Most who comment on the road system, however, address the topics of construction, 

maintenance, closure, removal, and obliteration. In addition to general comments 

summarized below, respondents make many site-specific requests for road management 

actions, management prescription category allocations, and recreation allocations that 

would allow or restrict types of travel. 

Road Construction/Reconstruction – A number of people say the WCNF should allow 

road construction—by allowing construction of temporary roads as needed, or by 

allowing reconstruction of road and trail segments that are causing environmental 

impacts. Some people say that road construction should be allowed in roadless areas. 

Others, however, state that road construction should be prohibited, or should be 

prohibited within certain areas. For example, one person suggests the WCNF prohibit 

roads across amphibian travel routes, while another respondent suggests it be prohibited 

in tundra and talus ecosystems. Some also maintain that it should be prohibited in 

roadless areas. 

Road Maintenance – While opinion is divided over the topic of road construction, there 

is a general consensus that existing roads should be better maintained. Some ask the 

WCNF to address its road maintenance backlog. One person relates having witnessed 

very inefficient maintenance activities, and so admonishes the WCNF to be more 

efficient with road maintenance funds and personnel. Some suggest the WCNF raise road 

maintenance and construction standards in order to lessen environmental impacts. 

Specifically, some suggest removing all culverts and replacing them with bridges across 

permanent streams; increasing bridge maintenance; and minimizing the impacts of road 

maintenance near stream channels. 

Road Closure/Removal/Obliteration – Most who address this topic request either that 

the WCNF close and reclaim roads under certain conditions or that it convert roads into 

trails. With respect to the former, respondents suggest the WCNF close roads in 

environmentally sensitive areas; that it close roads strategically in order to link roadless 

areas; and that it follow through with closure and reclamation of roads after timber 

projects are complete. With respect to the latter, one respondent suggests the WCNF 

consider an alternative that converts the backlog of unmaintained roads to motorized 

trails in order to provide challenging recreation opportunities at lower costs, while 

another requests that it continue converting roads to single-track trails. Most motorized 

recreationists, however, strongly object to road closures, including obliteration. Some feel 

that obliteration causes more damage than the existing roadbed. 
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Wasatch-Cache National Forest A - 14 

Trail System Management 

Just as management of the road system is a frequent topic of comment, so is management 

of the trail system. On a general level, a few individuals ask the WCNF to address trail 

system management in coordination with local user groups and to retain emphasis on trail 

system planning in the Tri-Canyon area. In addition to comments summarized below, 

respondents make site-specific requests for trail management actions. 

Trail Construction/Reconstruction – Several people ask the WCNF to expand the 

motorized trail system. Suggestions include providing sufficient summer motorized use 

zones to allow expanded trail systems; expanding the motorized trail network by taking 

advantage of existing snowmobile parking lots and trail corridors or by reopening some 

old logging roads as off-road vehicle trails; and providing more motorized loop trail 

systems. Some also state that motorized trails should be allowed in roadless areas. 

Others, however, urge the WCNF not to expand the motorized trail network on the 

grounds that there is already sufficient motorized recreational access. Some say the 

WCNF should first maintain and streamline the existing motorized trail system before 

constructing new trails. Other individuals say, moreover, that motorized trails should not 

be constructed in roadless areas. 

While most general comments regarding trail construction revolve around motorized 

trails, a number of site-specific requests regarding trail construction address nonmotorized trails. 

Trail Maintenance – Several people request the WCNF increase trail maintenance. 

Suggestions include investing more resources in trail maintenance in order to mitigate 

damage caused by off-road vehicle and hiking use; clearing trails early in the season to 

prevent damage caused by rerouting; adopting trail maintenance methods to reduce 

stream sedimentation; redesigning problem trails rather than closing them; improving the 

safety of trails used by horses; and increasing winter grooming and snowplowing. 

Trail Closure/Removal/Obliteration – Some respondents express concern over trail 

closures for wildlife; one respondent suggests the WCNF use seasonal rather than 

permanent closures for wildlife whenever possible, and close trails to motorized use only 

if negative wildlife impacts are specifically documented. Additionally, this respondent 

suggests that the WCNF should relocate any routes that would otherwise be closed by 

timber, mining, or grazing activities. At the same time, one individual states that the 

WCNF should prevent user-caused conversion of single-track trails to off-road vehicle 

trails through closures and enforcement. 
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Wasatch-Cache National Forest A - 15 

Travel Management 

Members of the public offer many comments related to travel management. Some request 

that the WCNF better analyze travel needs. Suggestions include inventorying and groundtruthing all roads and trails during the travel management planning process; estimating 

the number of miles and locations of user-created trails; fully considering issues found in 

publication FS-643, Roads Analysis; compiling more statistics about use levels and 

opportunities for different recreational types; and analyzing the comparative effects of 

different uses. 

Other respondents are concerned about the effects on travel management of possible 

conflicts between management prescription category and recreation allocations. Some 

individuals ask the WCNF to define how such conflicts would be resolved; others ask 

that, given possible conflicts, prescriptions that are open to misinterpretation be removed. 

Most comments related to travel management, however, consist of site-specific requests 

for travel prescriptions, either for specific roads or trails or for specific areas. Most of 

these requests pertain to motorized versus non-motorized use, both summer and winter. 

Topic 4: Recreation and Scenery Management 

Management General 

Recreation is the most frequent topic of comment on the WCNF Draft EIS and Forest 

Plan. A number of respondents express general concerns about recreation management, 

such as that the WCNF should manage recreation and other forest uses responsibly; 

should treat all user groups fairly; should disperse recreational users; and should not 

restrict access. Quite a few respondents also ask the WCNF to more adequately analyze 

recreational impacts and to conduct a carrying capacity analysis, especially in the TriCanyon area, which is of particular concern to many Wasatch Front residents. Some 

people say the WCNF should educate the public on proper use of the land and increase 

enforcement, particularly before imposing further restrictions. 

People also offer many general comments on allowing or restricting specific activities. 

Some say recreational motorized activities should be allowed in order to promote family 

values, prevent crime, and to accommodate the growing population, as well as to 

maintain the economic benefits derived from recreation. Others say recreation should be 

restricted to protect the environment, forest health, and riparian areas. In addition to such 

general comments, many respondents offer views specific to certain areas of management 

or types of recreation. These comments are summarized below. 

User Conflicts 

Both summer and winter recreationists express great concern over user conflicts. People 

suggest the WCNF consider examples of how other forests have reduced recreational 

conflicts, and that it implement a variety of remedies. One example is back-county skiers 

that ask the WCNF to segregate users. Many snowmobile enthusiasts, however, disagree. 
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Wasatch-Cache National Forest A - 16 

While many non-motorized recreationists assert that motorized vehicles must be 

restricted to reduce environmental harm, user conflicts lie at the center of many requests 

for restrictions. 

Monitoring and Enforcement 

Most who comment specifically on monitoring and enforcement ask the WCNF to 

monitor motorized recreation and enforce regulations. Both motorized and non-motorized 

users often say the WCNF should enforce regulations, though motorized users 

specifically add that this should be done rather than restrict their motorized activities. A 

number of writers ask the WCNF to monitor motorized recreation and enforce regulations 

in specific areas. 

While many respondents—both in comments directed specifically to monitoring and 

enforcement and in comments offered in other contexts—suggest that specific areas 

should be closed to winter and/or summer motorized use, or that these activities be 

otherwise restricted in order to reduce user conflicts, others argue that such 

closures/restrictions will be meaningless without the resources to truly enforce them. 

Motorized Recreation – Off-Road Vehicles 

As noted previously, comments about motorized recreation overlap extensively with 

general travel management, access, Recreation Opportunity Spectrum, and management 

prescription category comments. Opinion on this subject is quite polarized and many 

respondents submit their personal experiences to justify restrictions or their opposition to 

them. 

Many respondents state that motorized recreation should be allowed, because it is a 

legitimate activity and because it does not harm the environment. These respondents also 

say off-road vehicle recreation should be allowed because the majority of the public 

supports it; because it is growing in popularity; because education of motorized users is 

working; and because motorized access leads to higher public appreciation of nature. 

A number of people say it should be allowed because of its importance to families, 

because it is needed for safety or emergency use, and because it is needed to provide the 

disabled and elderly access to forest lands. 

Many other respondents, however, state that motorized recreation should be prohibited or 

restricted. Often they say restrictions are needed because of the harm off-road vehicles do 

to the environment. People say restrictions are needed, further, because of erosion caused 

by user-created trails; because of the cumulative impacts resulting from the exponential 

increase in numbers of motorized users; because of noise and air pollution; because it 

affects non-motorized users’ quality of experience; and because there are already 

adequate opportunities elsewhere in Utah. 
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Wasatch-Cache National Forest A - 17 

Some respondents also make a point of refuting the argument that continued motorized 

access is needed to accommodate the elderly. 

Motorized Recreation – Snowmobiles 

A number of respondents ask the WCNF to more adequately analyze the impacts of 

snowmobiling—by analyzing the impacts of having massive areas of compacted snow 

due to snowmobile use; reevaluating the advisability of allowing snowmobile use when 

snow cover is less than or equal to 12 inches; by incorporating new data into travel 

management planning about the effects of 2-stroke engines on the environment; and by 

analyzing the effects of snowmobiling on air quality, watersheds, and wildlife habitat. 

Beyond these requests, comments requesting either that snowmobiling be allowed or 

prohibited/restricted reflect the same concerns offered with respect to off-road vehicle 

use. 

Many comments request site-specific winter closures—or oppose them—especially in the 

Cache-Box Elder and Uinta management areas. 

Motorized Recreation – Heli-Skiing 

A number of respondents advise the WCNF to allow heli-skiing to continue—because it 

does not harm the environment; because noise is a minimal impact; because it is needed 

for safety reasons and to provide access for the disabled; and because of its positive 

economic impact. 

Others say it should be prohibited or restricted because it negatively impacts wildlife and 

conflicts with other dispersed winter backcountry users. People express particular 

concern over its impacts on birds, especially raptors, arguing that frequent helicopter 

flights in February, March, and April disrupt their nesting habits and hinder reproductive 

success. 

Mechanized Recreation 

Most who address mechanized recreation say it should be allowed—because it does not 

harm the environment; because it has no effect on water quality; because it contributes to 

the economy; and because there is no evidence that bicyclists pose a risk to other trail 

users’ safety. Some, however, counter that it should be prohibited in certain areas because 

it harms the environment and is dangerous to hikers and animals. One organization asks 

that mechanized use be separated from motorized use for travel management purposes. 

This group acknowledges that there may be a need for limited site-specific restrictions 

but asks to be closely involved in these evaluations. 

Non-Motorized Recreation 

Most who address their remarks specifically to non-motorized recreation say it should be 

emphasized—by giving non-motorized users the highest priority; by designating all 
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Wasatch-Cache National Forest A - 18 

remaining roadless areas for non-motorized use; or by setting aside more areas which 

meet a variety of non-motorized needs. Many say that certain areas should be restricted to 

non-motorized uses only—e.g., the Tri-Canyons area, many roadless areas, and the North 

Slope of the Uintas. A few respondents, however, assert that non-motorized activities 

should also be restricted due to environmental impacts. According to some motorized 

users, hikers and skiers disturb wildlife more than they do. 

Ski Area Expansion 

Several respondents state that ski areas should be allowed to expand. These respondents 

say the WCNF should not place restrictions on the ski industry based on the speculative 

possibility that the lynx, or other species, will be placed on the endangered species list; 

and that the WCNF should maintain a flexible policy rather than impose premature 

restrictions. 

Many other respondents, however, argue that ski areas should not be allowed to expand 

any further. These people say that public land should not be used to subsidize real estate 

development; that the ski industry has not experienced growth sufficient to justify 

expansion; that it would take away non-motorized areas; that it is not something which 

benefits the whole population; and that it harms the environment. People object not only 

to expansion in terms of acreage, but also in terms of infrastructure development. They 

say, for example, that the WCNF should prohibit resort building on prominent ridges; 

should prohibit development of trams or lifts in roadless areas; and should not allow ski 

resorts to turn into all season recreation areas or destination resorts. 

Topic 5: Roadless Areas/Wilderness Management 

Roadless Area Management 

Many people ask the WCNF to protect roadless areas, primarily to preserve 

environmental values. Some assert that regardless of the outcome of national rulemaking, 

local forests can and should take the initiative to protect these areas during forest 

planning because they are a limited resource. People ask more specifically to maintain 

roadless area characteristics of all inventoried roadless areas—by keeping existing 

roadless areas roadless, and by prohibiting all development and motorized recreation. 

Some ask that the WCNF protect roadless areas that are adjacent to wilderness areas, 

others that it designate watershed areas as roadless. Respondents also request roadless 

designation for a number of specific areas. 

Others, however, object to designating areas as “roadless” and that many roadless areas 

contain roads. Others maintain that there are already enough roadless and wilderness 

areas, and no more are needed; instead, some suggest, the WCNF should develop a 

backcountry recreation area designation for roadless areas. 
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Wasatch-Cache National Forest A - 19 

Wilderness Management 

Wilderness management and designation is a topic of great interest to respondents. Some 

ask that the WCNF clarify how wilderness areas will be managed; others express 

frustration over the time it sometimes takes to develop a management plan for wilderness 

areas and so ask the WCNF to prepare wilderness management plans in a timely manner. 

Some suggest that before recommending any more areas for wilderness designation, the 

WCNF should enforce existing wilderness regulations, provide education, or better 

explain the balance of resources and the needs of the people. Some suggest the WCNF 

reexamine the criteria for wilderness evaluation and the underlying legislation, and 

consider the capability availability, and need of individual roadless areas in determining 

wilderness potential. 

Wilderness Recommendations 

Many respondents say that the WCNF should recommend additional wilderness areas for 

environmental reasons—to link wilderness areas together; to protect ecological health, 

watersheds, biodiversity, wildlife, threatened, endangered, and sensitive species; and to 

protect areas from the effects of mining and off-road vehicle recreation. People also 

request additional wilderness recommendations to allow research and education, to 

benefit future generations, to preserve the American spirit, and to benefit the economy. 

A number of other respondents ask the WCNF not to recommend any more areas for 

wilderness designation. According to these respondents, wilderness designation is not 

need inasmuch as these areas can be adequately protected with careful stewardship, and a 

wilderness designation precludes management tools needed for forest health. People also 

oppose further recommendations on the grounds that areas should remain open for future 

generations; that motorized access is needed for the elderly; and that wilderness 

designations would restrict recreational access and hurt the economy. Some also urge the 

WCNF not to create de facto wilderness areas by adding more restrictions to proposed 

roadless areas, or by managing recommended wilderness areas for wilderness values. 

Additionally, respondents submit many site-specific requests that certain areas either be, 

or not be, recommended for wilderness designation, often with detailed personal 

comments or reasoning for their requests. 

Topic 6: Suitable Timberlands 

Management General 

On a general level, respondents ask the WCNF to clarify timber management 

prescriptions in the Forest Plan by, for example, including species-specific density 

requirements and management direction. Several people also ask the WCNF to modify 

the standards and guidelines related to timber management in a number of ways, 

generally with the intent to preserve environmental values. 
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Wasatch-Cache National Forest A - 20 

Adequacy of Analysis 

Members of the public offer a number of comments on the adequacy of analysis relative 

to timber management. Some ask the WCNF, for example, to provide a more thorough 

analysis in compliance with the Forest Service Manual; one respondent suggests using 

FORPLAN to calculate allowable sale quantity and long-term sustained yield. Others ask 

the WCNF to analyze the cumulative effects of logging on threatened wildlife, and the 

effects of timber sales on atmospheric carbon levels. Some ask for more recent 

monitoring data and the allowable sale quantity for each alternative. It is also requested 

that the WCNF discuss timber harvest methods in the Final EIS, and that it continue to 

research best management practices for timber harvest methods. 

Timber Harvest 

Some respondents ask the WCNF to allow timber harvest. One of the most common 

reasons given is forest health. People also ask that public fuel wood collection be 

allowed—to reduce fire hazards, warm households, and finance maintenance backlogs; to 

prevent waste of natural resources; and to help clean up the forest. 

Others say the WCNF should restrict timber harvest, primarily to preserve environmental 

values. Some urge the WCNF not to use the concept of forest health as a justification for 

its timber commodity program. People also say timber harvest should be restricted 

because of its low economic value in comparison with amenity values, and because of the 

recreational, scenic, and biological values of the forests. A few individuals say it should 

be prohibited until the WCNF completes a proper accounting of timber harvest costs. 

Quite a few respondents, therefore, express support for Alternative 1, although often they 

concede that its ultimate selection is not likely. 

In addition to these requests that timber harvest in general be restricted, a number of 

respondents ask specifically that it be prohibited in roadless areas—to allow natural forest 

processes to dominate, to preserve ecosystems from fragmentation, to protect wildlife, 

and to preserve roadless values. 

Topic 7: Rangeland Capability, Suitability, and Forage Production 

Management General 

Most comment regarding rangeland capability, suitability, and forage production 

addresses specific topics; these comments are summarized below. On a general level, 

some respondents ask the WCNF to develop improved livestock grazing strategies in the 

final Forest Plan. 

Adequacy of Analysis 

A number of respondents offer comment on the adequacy of analysis relative to 

rangeland management. Several ask the WCNF to adequately analyze the impacts of 
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Wasatch-Cache National Forest A - 21 

livestock grazing—by analyzing environmental and economic impacts, site-specific 

impacts, and impacts on other forest uses; by documenting the rate of aspen decline; and 

by analyzing the effects of grazing against the economic benefits. People also ask the 

WCNF to clarify the relationship between animal unit months and terrestrial conditions; 

to clarify its discussion of permitted grazing levels; to justify its rationale for only closing 

three allotments in the Preferred Alternative; and to verify rangeland condition and trend. 

Rangeland Management 

Respondents offer a wide variety of comment on specific aspects of rangeland 

management, including comment on goals, objectives, standards, guidelines, 

management prescription categories, suitability and capability, conditions and trends, 

properly functioning condition, restoration, monitoring and enforcement, and 

infrastructure. Most of the suggestions offered are aimed at reducing any negative 

impacts of grazing. This general concern over impacts is reflected in comments addressed 

to monitoring and enforcement. People ask the WCNF to monitor and enforce range 

quality standards and allotment management plans—to protect ecological values, to 

ensure overgrazing does not occur, to justify grazing at or near current levels, to meet 

legal requirements, and to protect wildlife and forest health. A few individuals, however, 

assert that, with proper management, the condition of grazing allotments can be 

maintained. 

Allotments and Permits 

Most general comments regarding allotments and permits address the question of whether 

allotments should be maintained, phased out, or closed. Some respondents say the WCNF 

should reduce the number of grazing allotments available in order to protect resources—

by closing vacant grazing allotments, by honoring existing leases but allowing leases to 

expire, and by allowing voluntary allotment retirements and voluntary waiving of grazing 

permits. One respondent, however, maintains that there should be no reductions in 

grazing allotments. 

Grazing 

Several respondents urge the WCNF to continue to allow grazing. They believe grazing is 

an important deterrent to wildfires. They also state that it has been demonstrated in many 

western states that game animals often prefer and thrive on land holdings that are 

managed by and for livestock grazing. They assert the value of proper livestock grazing 

on Utah’s forestlands is much greater than the revenue produced from the grazing fee. 

People argue that with appropriate management to protect forest resources, grazing is an 

acceptable use of public land, even of roadless areas, and that it is an important 

contributor to many rural counties. 

Many other respondents, however, urge the WCNF to restrict, reduce, phase out, or 

prohibit grazing. People recommend it be restricted until condition and trend are verified; 

they say restrictions are necessary to protect water and aquatic resources and to preserve 
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Wasatch-Cache National Forest A - 22 

recreational experiences. People likewise say it should be reduced in order to reach 

biodiversity goals; to prevent topsoil erosion, ground terracing, and vegetation 

destruction; and to restore streams for fishing. People say it should be phased out or 

prohibited to return to properly functioning condition, to allow vegetation to be restored, 

to preserve ecological values, to reduce fire hazard, to prevent the spread of noxious 

weeds, and to preserve scenic quality. Respondents go on to list a number of specific 

places where they would like to see grazing prohibited. 

Topic 8: Special Designations 

Members of the public comment in general that the WCNF should identify more lands for 

special designations. In particular, some ask the WCNF to designate additional Research 

Natural Areas; one respondent asks it to identify potential areas that could contribute to 

diversity in the Research Natural Area system. Some ask the WCNF to manage lands as 

Special Areas in order to prevent impacts that will be harder to reverse, and to consider 

forming additional Special Areas. Additionally, one respondent asks the WCNF to 

provide interim protection for eligible Wild and Scenic Rivers by ensuring proposed 

activities are compatible with protection and designation. Several ask that additional Wild 

and Scenic Rivers be designated, although a few ask that no more designations be made. 

Respondents also refer to specific areas which they request be given, or not given, a 

particular special designation. 

Topic 9: Oil and Gas Leasing 

Some people ask the WCNF to indicate where oil and gas exploration and development 

are to be allowed; to develop detailed standards for managing minerals, oil, and gas 

exploration/extraction in order to protect environmental values; to inspect oil and gas 

development sites; and to ensure that oil and gas exploration sites are restored. People 

also ask the WCNF to more adequately analyze oil and gas potential. 

A few respondents state that oil and gas leasing should be encouraged. Others say it 

should be prohibited in roadless areas in order to protect unique and vital habitat, and to 

preserve roadless characteristics and values. 

Topic 10: Fire Management 

Members of the public offer a number of general comments regarding fire management. 

A common suggestion is that the WCNF should evaluate the feasibility of fire 

management in non-motorized, roadless, and wilderness areas—with respect to 

protecting habitat, managing small roadless areas, meeting desired landscape goals, and 

protecting watersheds. Many other comments include specific suggestions regarding fire 

management strategies. 

Some respondents assert that the WCNF should more fully utilize timber harvest and 

grazing in conjunction with prescribed burns—to avoid wasting resources, to maintain a 

healthy forest, to avert fire risk, to bring the forest back into historic range of variability, 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 23 

and to maintain the viability of local economies. Others, however, say the WCNF should 

reevaluate timber harvesting and mechanical treatments as means to meet forest goals—

because of their inability to restore fire-adapted ecosystems, because of the role of 

standing dead timber in forest wild fires, because mature trees are needed for wildlife 

habitat, because young trees have high fuel load values, because timber harvesting cannot 

replace the role of fire in the forest, and because harvested areas show a strong 

association with increased rate of spread and flame length. 

This same difference of opinion is reflected in comments on prescribed burns. Some say 

the WCNF should not rely on prescribed burns for fire management because they do not 

prevent high-severity fires and because they are not adequate to meet forest goals. Others 

say they should be used in order to maintain bio-integrity. 

Locatable and Salable Minerals 

A few respondents comment on locatable and salable minerals. One requests that the 

WCNF add objectives for mineral and energy exploration and development, and that it 

discuss the management direction for geologic, paleontologic, and mineral resources in 

the Forest Plan. Another respondent asserts that recreational mining should be allowed to 

continue because it is not harmful; others say the WCNF should restore areas with mining 

damage in order to protect watershed health and to restore scenic values. 

Social and Economic Analysis 

Adequacy of Social and Economic Analysis General 

Some respondents ask the WCNF to prepare an adequate socioeconomic analysis—by 

including costs associated with different management activities; by analyzing the receipts 

and expenditures of the fee demo program; by analyzing the social and economic impacts 

on all forest users, not just local communities; and by including the results of specific 

recent studies on recreational economics. 

Social Values 

The two most common concerns related to social values are population growth and 

development. Some people urge the WCNF to factor projected population growth into 

management plans—by identifying the combined impacts of all users instead of viewing 

them separately, and by acknowledging that population growth will result in restrictions 

on traditional experiences. With respect to development, most people say the WCNF 

should prohibit further development of various kinds on the forest. Some say 

development should be prohibited for environmental reasons—to protect wildlife habitat 

and winter range, and to protect watersheds. Some say it should be prohibited for social 

reasons—to provide escape from the urban environment, to preserve natural 

environments for the future, and to avoid bringing more users into the forests. 
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Wasatch-Cache National Forest A - 24 

Adequacy of Economic Analysis 

A number of respondents express concern over the adequacy of the economic analysis 

and offer suggestions for improving it. Some of the suggestions include separating 

different industries and communities, using more recent data, disclosing the real socioeconomic impacts of the various alternatives, using the travel cost method and contingent 

valuation method to analyze social and economic valuations, and including information 

about externalized costs passed on to communities, businesses, and individuals when 

national forests are developed or intensively managed for various activities. Some ask the 

WCNF to strengthen its cost/benefits analysis by, for example, providing a full 

accounting of benefits and costs, including environmental benefits (clean air, clean water, 

etc.) of undisturbed forest lands; and some ask the WCNF to provide a full accounting of 

costs associated with various activities, such as timber harvest and grazing. 

A number of respondents comment on the net public benefits analysis. A few ask the 

WCNF to revise or eliminate that analysis because the 50-year time frame is meaningless 

and because it is based on faulty assumptions. Others say the that WCNF should establish 

accurate benchmarks for the net public benefits analysis; that it should establish an 

analytical process to demonstrate that the final Forest Plan will maximize net public 

benefits; and that it should quantify ecosystem service values and externalized costs of 

commodity production in the net public benefits analysis. 

Economic Impacts 

Several respondents ask the WCNF to acknowledge the important economic contribution 

of various activities, such as recreation and tourism, motorized use, and grazing. 

Lands, Real Estate, and Property Boundary Management 

Several people write to say the WCNF should acquire additional private lands—to protect 

multiple resources, to protect moose habitat, and to preserve watersheds. One individual 

asks the WCNF to eliminate all private inholdings in roadless areas. Another person 

advises the WCNF to consider additional land exchanges, but only with adequate public 

involvement; others, however, urge the WCNF not to exchange lands within the TriCanyon area which would compromise watershed health and wildlife or which would 

create developable private property. 

Additionally, a number of respondents request that the WCNF acquire more access 

rights-of-way across private lands; while one respondent asks the WCNF to process 

easement applications in a timely fashion for inholders. Recreational access, both 

motorized and non-motorized, is of particular concern as adjacent private lands become 

increasingly developed. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 25 

Analysis of Public Comment 

All letters, emails, faxes, comment forms, and transcripts of public hearing testimony 

received as public comment on the proposed forest plan and DEIS were compiled, 

organized, read, and analyzed by the U.S. Forest Service Content Analysis Team (CAT). 

This team, a unit of the U.S. Forest Service Washington Office Ecosystem Management 

Coordination branch, specializes in public comment processing and consideration. This 

team uses a process they have developed called “content analysis” which allows 

systematic review of public comment on a proposed plan or project through the creation 

and use of comprehensive electronic comment database. This method is particularly 

effective in analyzing voluminous comment both individually and collectively, as 

required by NEPA. 

The CAT analytical process is comprised of three main components: a categorical 

coding structure and standardized process for its application, a comment database and 

mailing list, and a set of summary reports. In the content analysis process, each letter, 

postcard, transcript text, or other document (collectively referred to as “response letters” 

in this appendix) is assigned a unique tracking number. Each author or signatory to a 

response is called a “respondent”. All respondents’ names and addresses are entered 

into a project-specific database program to produce a complete mailing list. Each 

respondent is also assigned a unique identifier number for tracking purposes. All 

respondents are linked to their individual responses and comments in the database using 

these identifying numbers. Project-specific demographic information is also recorded in 

the database, such as any self-identified organizational affiliation or whether the response 

letter submitted is part of an organized response campaign. 

Staff analysts then read all public response letters in their entirety and proceed to identify 

discrete comments within them that relate to a particular concern, resource consideration, 

or proposed management action. Every effort is made to keep each comment within 

sufficient context that it is a stand-alone statement. Analysts look for not only each 

action or change requested by the public, but also the reason(s) behind each request in 

order to capture the full argument of each comment. Therefore, paragraphs within a 

response letter may be divided into several comments because multiple arguments are 

presented, or alternatively, several paragraphs that form one coherent statement may be 

coded into one comment. While simple statements of opinion without a rationale are 

captured in the process and entered in the project database, it is the strength of each 

rationale as a complete argument that provides the interdisciplinary team a substantive 

comment to consider. 

Once stand-alone comments are identified, analysts assign each comment to a numerical 

code that identifies the overall subject area. They use a systematic numerical 

categorization or “coding” structure that has been specifically tailored to project 

documents. Each project-specific coding structure is a tool to help sort comments into 

logical groups by topics. In this case, the coding structure was organized to follow the 

topic order of the DEIS and components of the proposed forest plan documents, and was 

designed to be inclusive rather than restrictive in order to sufficiently capture all 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 26 

comments. Depending on project complexity and needs, analysts may also assign 

secondary codes to track those comments that refer to such subtopics as specific plan or 

EIS elements, land areas, or individual roads or trails, to permit finer-scale sorting of 

comments. The coding structure and other supporting documentation is available in the 

administrative record at the Supervisor’s Office in Salt Lake City, UT. 

After being coded, each response letter’s set of coded comments is entered verbatim into 

the project database. This database serves as the complete project record and allows 

analysts and planning team members to run specialized reports, identify public concerns, 

and determine the relationships among them. 

The content analysis process also identifies all response letters that are submitted as part 

of an organized response (or “form letter”) campaign and therefore contain identical text. 

These are grouped by campaign, and all mailing information for each respondent is 

entered into the project database, as well as an identifier code for the campaign. Analysts 

also code a “master” campaign letter and enter all comments verbatim into the project 

database so that they are considered alongside all non-campaign comments. If a 

respondent adds original comments to the organized response letter he or she submits, 

these comments are identified, coded and entered into the database. 

The third phase of content analysis includes composing statements of public concern and 

then preparing a narrative summary. Analysts review the entire comment database, 

sorted by topic area, and then write public concerns to summarize comments that present 

similar arguments or positions. Each formal statement of concern is accompanied by one 

or more sample comments which provide respondents’ specific perspectives and 

rationales regarding that concern. For each sample comment a letter number is provided, 

enabling the reader to track and review the original response, if necessary. 

Each public concern is worded to capture the action that one or more members of the 

public feel the Wasatch-Cache National Forest should undertake and provides the 

decision-maker with a clear sense of actions the public is requesting. Because each 

concern statement is a summary, it can represent one or many comments, depending on 

the actual comments submitted. Concern statements range from extremely broad 

generalities to extremely specific points because they reflect the content of verbatim 

public comments. Once the comments have been exhaustively reviewed and the range of 

concerns identified, CAT then submits a Summary of Public Concerns report to the 

interdisciplinary team, who is responsible for the next stage of comment consideration, 

response to comment. At this stage, the interdisciplinary team determines whether 

comments are substantive and in scope, and then composes responses to comment. For 

more information on the content analysis process, the reader may contact the forest 

Service Content Analysis Team in Salt Lake City, UT. 

Public concern statements are not intended to replace actual comment letters or sample 

quotes. Rather, they can help guide the reviewer to comments on the specific topic in 

which he or she may be interested. All original response letters in their entirety are on 

file at the Supervisor’s office in Salt Lake City, UT. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 27 

Although the list of public concerns attempts to capture the full range of public issues and 

concerns, it should be used with caution. Respondents are self-selected; therefore their 

comments do not necessarily represent the sentiments of the public as a whole. However, 

these reports do attempt to provide fair representation of the wide range of views 

submitted. In considering these views, there is no attempt to treat input as if it were a 

vote. Instead, the content analysis process ensures that every comment is considered at 

some point in the decision process. 

The final CAT reports are summary documents. As such, they are not intended to replace 

the need for interdisciplinary team members and decision-makers to directly review all 

responses and comments. Database reports by topic area allow systematic review of all 

public responses by subject area. Given the rapidly expanding volume of responses 

during comment periods due in part to increasing public interest and the widespread use 

of email, this process can greatly enhance methodical review of comments and meet our 

goal to continually improve decision-making and responsiveness to the public. 

Considering Different Types of Comments under the National 

Environmental Policy Act 

Agencies have a responsibility under the National Environmental Policy act (NEPA) to 

first “assess and consider comments both individually and collectively” and then to 

“respond... stating its response in the final statement.” The content analysis process used 

by the U.S. Forest Service Content Analysis Team (CAT), described in the previous 

section, considers comments received “individually and collectively” and equally, not 

weighting them by the number received or by organizational affiliation or other status of 

the respondent. Public concern statements and supporting quotes from public input form 

the basic summary of public comment and were the primary focus of our interdisciplinary 

team in considering comments. 

The NEPA requires that after we consider comments, we formally respond to substantive 

comments. However, the nature and extent of each response depends on the type of 

concern identified. 

We classified comments, or the concerns identified from them, as either those that fall 

within the scope of decision-making for the plan revision or those that fall outside of the 

scope for any number of reasons described below. Generally, the types of comments 

received, and concerns identified, that were considered out of scope include those that: 

• Do not address the purpose, need, or goals of the Wasatch-Cache National Forest 

2003 Forest Plan Revision (e.g. propose an action in areas beyond the WasatchCache National Forest jurisdiction or that are not directly related to the action 

proposed in the plan, or relate to day-to-day operational issues such as law 

enforcement procedures or road maintenance). 

• Address concerns that are already decided by federal law or national policy. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 28 

• Suggest an action not appropriate for the current level of planning (site-specific 

decisions to construct new roads, campgrounds or facilities, to offer special use 

permits or the sale of timber resources). 

• Propose untenable restrictions on management of the forest or conflict with 

approved plans not being revised in the forest plan revision process. 

• Did not consider reasonable and foreseeable negative consequences. 

We further classified comments within the scope of the plan as either substantive or nonsubstantive. Based on the Council of Environmental Quality’s regulations, a substantive 

comment is one that: 

• Questions, with a reasonable basis, the accuracy of the information in the 

environmental impact statement. 

• Questions, with a reasonable basis, the adequacy of environmental analysis as 

presented. 

• Presents reasonable alternatives other than those presented in the DEIS that meet 

the purpose and need of the proposed action and address significant issues. 

• Cause changes or revisions in the proposal. 

Non-substantive comments, or concerns identified from them, include those that simply 

state a position in favor of or against an alternative, merely agree or disagree with Forest 

Service policy, or otherwise express an unsupported personal preference or opinion. 

We are required to respond only to substantive comments or the concerns identified from 

them. We have chosen to respond to all public concerns identified during analysis of 

public comment, within and out of scope, substantive and non-substantive alike. 

Responses to out of scope concerns are generally restricted to explaining that the concern 

is out of scope and does not merit further attention. A more elaborate answer may have 

been provided for clarity. Responses to substantive concerns are typically more 

extensive, complete, and most importantly, offer an explanation of why or why not and 

where the concern may have resulted in changes to the plan or analysis. If several 

concerns are very similar, they have been grouped for response purposes. Public 

concerns that identified editorial or other errors in the presentation of information in the 

DEIS were used to revise text and make corrections for the FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 29 

Agency Response to Comments 

As described in the previous section, each public concern statement was derived from one 

or many individual public comments. However, these supporting sample comments have 

been deleted here due to space constraints. Our interdisciplinary team reviewed the 

actual letters, public concern statements and the supporting comments in the preparation 

of our responses. Interested parties may consult the full CAT reports and the reading file 

of original response letters on file at the Supervisor’s Office in Salt Lake City, UT. 

Public concern statements and our responses are organized by section to mirror the order 

of the final environmental impact statement (FEIS) by topic area. 

Planning and Decision Processes 

Adequacy of the Document 

Document Organization and Layout 

1. The Wasatch-Cache National Forest should be congratulated for the clarity of 

its planning document.

Response: Thank you. 

2. The Wasatch-Cache National Forest should continue to improve planning 

document by providing a more detailed table of contents or an index. 

Response: Every effort was made to write in plain English and to use charts and 

maps to more effectively present information. We have worked to improve the 

clarity in the draft environmental impact statement. We have now added a listing of 

all tables and figures and created a more detailed table of contents. 

3. The Wasatch-Cache National Forest should produce a cross-walk document to 

clarify the relation between the current and the proposed Forest Plan, with 

potential impacts listed for each change. 

Response: Alternative 4 represents the 1985 (current) Forest Plan as amended. To 

the extent possible, differences between Alternative 4 can be compared with 

Alternative 7, which has been developed in the Revised Plan. Many of the 

standards and guidelines contained in the 1985 Plan are site-specific direction that 

is inappropriate for programmatic type documents. The revised forest plan is based 

on a framework strategy so a one-to-one correlation from one to the other is not 

possible.

4. The Wasatch-Cache National Forest should improve the quality of planning 

document maps.

4.1 Provide sufficient detail for site-specific travel analysis by the public. 

4.2 By increasing readability 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 30 

4.3 By using more color 

Response: We believe the detail of our maps is appropriate for the broad scale type 

of planning such as the revised forest plan. Site-specific travel planning for roads 

and trails is a future analysis, not a part of the forest planning analysis. Because of 

this we don’t see the need for more detailed maps addressing this need. Recreation 

Opportunity Spectrum maps portray the six broad classes of opportunities, not the 

management of every trail and road.

Printing color maps with the draft EIS was very expensive. We continually 

evaluate the balance between spending federal dollars wisely versus communicating 

proposed forest direction. Color maps showing management prescriptions by 

alternative can be viewed in the complete documents package, on a CD or our 

website. Color maps are included as part of the Revised Forest Plan. 

5. The Wasatch-Cache National Forest should number and reference all plates in 

the final Forest Plan. 

Response: We have titled and referenced the oil and gas maps that you refer to as 

plates. 

6. The Wasatch-Cache National Forest should correct errors in the plates 

included in the draft Forest Plan. 

Response: Errors have been corrected. Corrected maps are available in the FEIS 

and Plan complete sets, on CD-ROM and posted on the internet.

7. The Forest Plan should include Figure 2-1 as referenced in the text. 

Response: The Figure has been properly labeled and referenced in the text.

8. The final Forest Plan should include Revision Topic 11 as referenced in the 

text. 

Response: There are 10 revision Topics. This paragraph has been edited to clarify 

the number of topics.

9. The Wasatch-Cache National Forest should edit the poorly written “Response 

to Issue 5” section in the draft Forest Plan. 

Response: We have edited this section. 

10. The Wasatch-Cache National Forest should improve the organizational 

structure of Chapter 5. 

Response: We have improved the layout and structure of the Chapter 5 in the 

Revised Forest Plan. The monitoring section is part of the forest management 

direction of Chapter 4. The process management direction section has been 

reformatted and moved to an Appendix X called Implementation Guidance. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 31 

General Adequacy 

11. The Wasatch-Cache National Forest should expand and quantify effects 

analysis discussions throughout the Final EIS by replacing the extensive 

reliance on professional opinion.

Response: Planning for a unit of the National Forest System involves two levels of 

decisions. The first is the development of a Forest Plan that provides direction for 

all resource management programs, practices, and protection measures. The second 

level of planning involves analysis and implementation of management practices 

designed to achieve goals and objectives of the Forest Plan. This level involves sitespecific analysis to meet NEPA requirements. By the very nature of programmatic 

planning it is impossible and inappropriate to quantify site-specific effects. Since 

the Forest Plan is a broad framework, which does not directly commit to 

development, there are inherent limitations in predicting what development, and 

consequently what effects, will actually occur. When we have relied on science to 

support our analysis, it has been cited. In some cases, however science is simply 

not available and we must rely on the professional judgment of resource specialists. 

12. The Wasatch-Cache National Forest should better balance the effects analysis 

of management activities by changing biased statements that exaggerate the 

benefits of active management. 

Response: We have improved watershed and wildlife sections to more fairly 

evaluate the effects of active management. 

13. The Wasatch-Cache National Forest should properly account for and mitigate 

cumulative effects. 

Response: In reviewing the adequacy of the cumulative effects analysis in the EIS, 

it’s important to acknowledge that the cumulative effects for a forest plan are quite 

different than those of a site-specific action. We have expanded the discussion of 

other agency actions and private land effects in Chapter 3 of the FEIS to the degree 

that is appropriate in a programmatic document. In addition because the Plan does 

not make an irretrievable commitment of resources, we are not relying on 

mitigation measures to reach a Finding of No Significant Impact. 

14. The final Forest Plan should not rely on best management practices (BMPs) to 

mitigate cumulative environmental effects because this is insufficient to ensure 

compliance with the Clean Water Act

Response: We feel that BMPs, standards and guidelines, and soil and water 

conservation measures are effective means to reduce adverse effects from sitespecific project implementation. The revised Forest Plan does not propose sitespecific projects of which mitigation measures could be proposed, but provides for 

broad-scale planning. At this scale of planning, the revised Forest Plan identifies 

BMPs, standards and guidelines, and soil and water conservation measures as ways 

the WCNF can use to reduce adverse effects of site-specific projects. Projects that 

implement the revised Plan may use mitigation measures to reduce adverse effects 

and it is at this point that effectiveness of mitigation measures should be evaluated. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 32 

The Forest Plan assumes that BMPs will be used during project implementation to 

reduce impacts from a site-specific project. 

For their respective states, Utah and Wyoming have authority to determine 

compliance with the CWA. The State of Utah provides the authority to use BMPs 

to control nonpoint sources of pollution as stated in section 3.2 High Quality Waters 

– Category 1 in section R317-2-3. Antidegradation Policy, in R317-2, Utah 

Administrative Code (FEIS reference: Utah, State of. 2000a). 

15. The Final EIS should include an analysis of risks from private lands that affect 

the health of the forest and adopt a more conservative strategy in the Forest 

Plan 

Response: We agree that the adjacency of private lands to the Forest and their 

development contribute to effects on national forest system lands in varying 

degrees. We have expanded the discussion of other agency actions and private land 

effects in Chapter 3 of the FEIS to the degree that is appropriate in a programmatic 

document. As we developed the forest plan it was always with an awareness of the 

context of the forest and private lands. 

Public Involvement and Collaboration 

Public Information 

Accessibility of Information for the Public 

16. The Wasatch-Cache National Forest should recognize that complex changes to 

management prescription categories between scoping and draft have made 

meaningful public comment difficult. 

Response: We agree the definitions of management prescription categories have 

evolved since they were first introduced in the preliminary AMS. Much of this 

change was the result of incorporating public comment and adapting to national 

initiatives. We recognize their application and interpretation in each alternative does 

require thoughtful analysis. However, because of this we specifically included very 

detailed tables of allowed activities with each alternative description in Chapter 2. 

Use of Information in the Decision Process 

17. The Wasatch-Cache National Forest should base its decision on sound science. 

Response: Sound science should always be the basis for decisions. However, 

often, science is simply not available for many of the decisions we make. In some 

cases there are differing scientific opinions and no one definitive answer exists. 

18. The final Forest Plan should state that all accompanying technical documents 

will undergo external peer review. 

Response: The level of scientific scrutiny requested is not a requirement of the 

1982 implementing regulations for the National Forest Management Act. Many of 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 33 

the technical documents that were relied upon in our analyses are those published in 

scientific journals. The planning team has used the best available information to 

conduct their analyses 

Public Involvement Efforts 

19. The Final EIS should evaluate the effects of multiple planning processes on 

public involvement. 

Response: We recognized the demands placed on the public because of the many 

national and local planning efforts that were ongoing during our 4-year revision 

process. Because of this we included extended periods for public response when 

possible, such as a 5-month review period for the DEIS. 

20. The Wasatch-Cache National Forest should continue its extensive public 

outreach efforts.

Response: We view public outreach as very important and plan to continue our 

efforts. 

21. The Wasatch-Cache National Forest should expand its outreach efforts with 

motorized recreationists to improve support for travel management decisions.

Response: We are always striving to improve public outreach so those affected by 

management decisions participate in their formulations and understand and are fully 

aware of them when they are implemented. Organizations representing special 

interests provide an excellent opportunity to increase our outreach. We do have to 

balance our outreach efforts with available personnel, time, and expense. 

22. The Wasatch-Cache National Forest should eliminate its bias toward 

commercial interests in its consultations with stakeholders.

Response: We do not feel that we are biased in our conversations with commercial 

interests. We often ask questions of our constituents to characterize the current 

condition from their point of view. We always acknowledge the source of our 

information. 

23. The Wasatch-Cache National Forest should improve outreach efforts to out-ofstate residents by holding informational planning meetings at the ski resorts.

Response: Skiers, often out of state residents, represent a unique situation for 

public outreach. Many receive information in the mail and respond in writing. In 

the past informational meetings held at the ski resorts have been poorly attended 

since most visitors are more interested in leisure activities. Ski area permittees often 

distribute material to their guests. Our mailing list reveals out of state addresses, 

many whom are skiers. 

24. The Wasatch-Cache National Forest should improve outreach efforts to 

Hispanic residents during Forest Plan implementation and future planning by 

publishing documents and holding meetings in Spanish. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 34 

Response: We agree this is an increasing segment of our society that requires a 

specialized approach. 

25. The Wasatch-Cache National Forest should not allow intimidation at public 

meetings by disallowing inflammatory threats of closure violations and 

accusations of terrorism by environmentalists.

Response: We too regret that some members of the public felt their safety was 

being threatened. While we did have law enforcement present at those meetings it 

did not stop the confrontational attitude of some members of the public. We felt if 

we had taken a more aggressive stance, we may have incited violence. 

26. The Wasatch-Cache National Forest should not schedule meetings during 

hunting season. 

Response: There are so many segments of society that compose those interested in 

forest management, it is next to impossible to plan public meetings that don’t 

conflict with someone’s schedule. Public meetings were logically scheduled in 

relationship to the steps in the planning process. 

Use of Public Comment in the Decision Process 

27. The Wasatch-Cache National Forest should provide clear guidelines on how to 

write effective comments. 

Response: We recognize with such a comprehensive set of documents, such as the 

revised forest plan, it is extremely difficult to know where to focus one’s review. 

You make a good suggestion to consider when releasing future planning documents 

for public review.

28. The Wasatch-Cache National Forest should make submitting email comments 

easier by providing a direct link from the website. 

Response: We published our e-mail address and received a large share of 

comments via the internet. Adding a link is an avenue we will explore. 

29. The Wasatch-Cache National Forest should weigh public comments 

differentially. 

29.1 By giving particular attention to comments submitted by college students 

29.2 By giving greater weight to users who pay fees 

29.3 By giving greater weight to comments from local residents 

Response: The Wasatch-Cache National Forest is a national resource and decisions 

regarding the management of this forest are made in conjunction with national as 

well as local concerns. There are many viewpoints within Utah and within the 

nation that the Forest must consider. All of these comments are valid and were 

reviewed and considered in the final documents. 

30. The Wasatch-Cache National Forest should give equal weight to comments 

from out-of-state residents. 

Response: See response 29. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 35 

31. The Wasatch-Cache National Forest should establish a clear standard for 

consideration of public comment by prioritize detailed, scientifically-backed 

comments. 

Response: Every comment received was read and considered when developing the 

revised forest plan and FEIS. 

32. The Wasatch-Cache National Forest should use misinformed public comments 

to frame its educational strategy for users. 

Response: All of the public comments received have been very instructive in 

where and how we need to focus our information and education strategy. Working 

with community groups and organizations is one way of spreading resource 

management messages. These activities are very important and will continue to be a 

tool used to spread information in the future. We included an objective in the 

Revised Forest Plan emphasizing the areas of our education efforts as we 

implement the Plan. 

33. The Wasatch-Cache National Forest should not make the comment 

consideration process a vote.

Response: We agree. Public comments are not considered votes when making a 

decision. Every substantive comment and suggestion has value whether expressed 

by one respondent or many. Public comments help us better understand the 

sentiment behind particular viewpoints and values, reveal new information 

previously not considered, and provide clear understanding of the implications of 

our decisions for various interests. 

34. The Wasatch-Cache National Forest should consider broader public opinion. 

34.1 Rather than just that of people who officially comment in writing 

34.2 Rather than just that of people who are vocal in public meetings. 

Response: Please see the response to 33. Decisions made in the revised forest plan 

are not determined by public opinion. We have followed the NEPA and NFMA 

regulations that provide direction on solicitation of public input. It relies on those 

who make written and oral comments. 

35. The Wasatch-Cache National Forest should establish better means of creating 

dialogue with the public rather than delayed summary responses to written 

and oral comments. 

Response: At this final stage of the revision planning process, we agree that 

responding in writing to comments is not very satisfying to either those who wrote 

the comments or for us as forest planners and managers. A written response to 

substantive comments is required by the implementing regulations of NEPA. 

During the previous phases of the planning process we felt that constructive 

dialogue was conducted between many parties. Individual conversations at open 

houses, discussions with organizations at their invitation and constituent phone calls 

were very informative. Open houses are planned shortly after the release of the 

decision. In addition, we look forward to having more dialogue at the local level for 

small-scale projects as the revised plan is implemented.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 36 

36. The Wasatch-Cache National Forest should convene town meetings prior to 

finalizing the Forest Plan.

Response: We agree that some type of meeting with engaged citizens is worthwhile 

and scheduled open houses shortly after releasing the decision. 

37. The Wasatch-Cache National Forest should canvass public opinion. 

37.1 By taking a public opinion poll. 

37.2 By surveying forest users. 

Response: Please see the response to 33. Decisions in the revised forest plan are not 

the result of a public opinion survey or a vote counting process in which the 

outcome is determined by the majority viewpoint. 

38. The Wasatch-Cache National Forest should provide specific responses to 

individual comments on the preliminary alternatives. 

Response: We have found that there is a common misperception among some 

members of the public that because the decision does not reflect their opinion then 

we have not considered their opinion. When making a decision we have to look at 

the broad array of comment, which is often conflicting, and then make a reasoned 

choice. Rarely do we make a decision that satisfies everybody. With a 

comprehensive effort such as forest planning, a response to every comment heard at 

every phase is an unwise use of planning resources. At the preliminary alternative 

phase, we believed planning team efforts were more wisely spent analyzing and 

incorporating comments instead of developing specific responses to individual 

comments. 

39. The Wasatch-Cache National Forest should not allow public sentiment to 

overrule environmental protection when damage is occurring from overuse. 

Response: We agree.

Involvement of Interest Groups in the Planning Process 

40. The Wasatch-Cache National Forest should consult with mountain bicycling 

organizations early in the summer travel management planning process.

Response: All user groups should be involved in scoping efforts during future sitespecific travel planning. Successful implementation of decisions often depends on 

involvement throughout the process. 

41. The Wasatch-Cache National Forest should consult with user groups before 

closing trails to them (ie. mountain bikers). 

Response: Being involved in future site-specific travel planning will allow user 

groups to voice their comments and be informed of decisions. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 37 

42. The Wasatch-Cache National Forest should include motorized recreation 

planners on the interdisciplinary team and advisory boards. 

Response: We intend to include all interested parties including user groups and 

their representatives in future travel planning following the guidelines of the 

Federal Advisory Committee Act. 

Influence of Interest Groups in Decision-making 

43. The Wasatch-Cache National Forest should not cater to special interest 

groups. 

43.1 Environmental groups 

43.2 “Eco-terrorists” 

43.3 Influential private and corporate interests 

43.4 Motorized recreational groups

Response: Throughout the planning process there has been a broad array of public 

viewpoints expressed. Each point of view believes the opposing interests are 

receiving preferential treatment. This is simply not true. The planning team has 

met with any individual or group to discuss their concerns when a request was 

made. All of comments were reviewed and considered in the final documents. 

44. The Wasatch-Cache National Forest should determine what constitutes a 

special interest according to the group’s impacts on forest lands, giving the 

greatest consideration to those causing the least destruction. 

Response: We use the term “special interest” to help us understand the needs and 

demands of many varied forest users. Because of the many varied interests there is 

no normal use of the forest. The range of alternatives responds differently to each 

issue thereby gives greater consideration to one type of user versus another. 

Regardless of a person or groups’ interest all forest uses should be properly 

managed. 

45. The Wasatch-Cache National Forest should consider that special interest 

groups provided biased information to their members. 

45.1 Motorized groups 

45.2 Environmental groups 

Response: All comments were reviewed and considered in the content analysis 

process whether they appear to be based on misinformation or not. Comments that 

were apparently based factual errors or misinformation are responded to by 

correcting the error or by offering the agency’s position on the issue. 

46. The Wasatch-Cache National Forest should discount research conducted by 

environmental groups. 

Response: We generally use research from scientific journals. When information is 

used from non-scientific journals it is cited as such. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 38 

Trust and Integrity 

47. The Wasatch-Cache National Forest should deal honestly with the public. 

Response: We agree honesty and integrity are vital for good relationships with the 

public. We also recognize that in any communication between two people there’s a 

chance each may interpret conversations differently. Public feedback on these 

issues helps us recognize where we may communicate more clearly. 

Collaboration 

Public Partnerships and Volunteers 

48. The Wasatch-Cache National Forest should end all partnerships with private 

outfitters/guides because the forest should not be used for profit. 

Response: Outfitters and guides can help provide opportunities for forest visitors 

where special expertise, experience or equipment may be needed or offered to those 

without an outdoor skill base. We agree that outfitted opportunities must always be 

evaluated in light of public demands for an activity. Criteria to be used when 

considering outfitter and guide services can be found in the Appendix X describing 

Implementation Guidance. 

49. The Wasatch-Cache National Forest should provide environmental education 

programs in partnership with the Stokes Nature Center. 

Response: We agree. The Logan District staff is currently holding discussions with 

Utah State University and Stokes Nature Center regarding joint efforts concerning 

environmental education. We are open to proposals and are always looking for 

partners to deliver appropriate messages concerning and stewardship. 

50. The Wasatch-Cache National Forest should not refuse offers for volunteer 

programs from motorized groups. 

Response: While each volunteer opportunity needs to be evaluated on its own 

merits, user groups can offer opportunities for peer education and contribute to 

proper resource management. We are willing to work together in a cooperative 

setting to promote an accurate, consistent message. 

Interagency Collaboration – State 

51. The Final EIS should discuss the Collaborative Approach for Reducing 

Wildland Fire Risks to Communities and the Environment document. 

Response: Please see Revision Topic 10 where we have discussed this long-term 

program to deal with wildland fire and hazardous fuels situation.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 39 

52. The final Forest Plan should provide greater detail about how collaboration 

with other government entities will be implemented by creating an interagency 

working group. 

Response: The Forest Plan is a broad framework for the management of a National 

Forest. How further collaboration could be enhanced and expanded is more 

appropriately left for future implementation efforts. 

53. The Wasatch-Cache National Forest should work with the State of Utah to 

enlarge the recreational motorized vehicle tag format so that the public can 

read license numbers of violators. 

Response: We agree that enforcement issues related to ATVs are important; 

however, your suggestion is outside the scope of our authority.

54. The Wasatch-Cache National Forest should work with the State of Utah to 

coordinate motorized recreation management with the use of the state trail 

ranger programs. 

Response: We coordinate extensively with the Division of Parks and Recreation. 

We have competed successfully numerous times for trail-building grants. In the 

wintertime we work together on providing snowmobile opportunities through 

grooming projects. 

55. The Wasatch-Cache National Forest should remove the incorrect statement 

that wildlife reintroductions are carefully and openly planned. 

Response: The sentence you refer to is from the desired condition section of the 

forest plan. Because the Forest Service has the responsibility to prevent damage to 

resources on national forest system lands, it is our intent to work more closely with 

the Division of Wildlife Resources as they plan wildlife introductions that affect 

national forest system lands. We endorse public involvement for wildlife 

reintroductions.

56. The final Forest Plan should require independent scientific review of native 

wildlife determinations conducted by state agencies. 

Response: Your request is outside of our authority as determined in Forest Service 

Manual 2641: The state has the responsibility to make the determination as to which 

wildlife and fish species are native or indigenous.

57. The Wasatch-Cache National Forest should only cooperate with the Utah 

Division of Wildlife Resources when management is science-based. 

Resource: We recognize that sometimes science is not definitive and differing 

opinions exist. Because our responsibilities are so intertwined, cooperation with 

state agencies is necessary and desirable. 

58. The Wasatch-Cache National Forest should work with the state wildlife agency 

to eliminate the use of lead shot in the forest. 

Response: Your request is outside of our authority. However, for your information 

according to 2002-2003 Utah Waterfowl Proclamation, only nontoxic shot may be 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 40 

in possession or used while hunting waterfowl or coot in any area of the state and 

federal refuges (R657-9-10 and CFR 20.21(j)). 

59. The Wasatch-Cache National Forest should work with the State Division of 

Wildlife and Natural Resources to monitor and encourage wolf migration onto 

the forest. 

Response: A wolf that was trapped in 2002 in the Cache Box Elder Management 

Area indicates the possibility of more wolves migrating to Utah. If wolves return to 

Utah they will be under the control of the U.S. Fish and Wildlife Service (FWS) and 

managed as a threatened species. All activities concerning the wolf would be done 

through the consultation process with the FWS as outlined in the Endangered 

Species Act, Section 7. Protection of the regionally significant wildlife corridor as 

provided in Alternatives 1, 2 3, 6, and 7 makes it possible for many different 

species to migrate 

Interagency Collaboration – County and Local 

60. The final Forest Plan should include a goal stating the Forest Service’s intent 

to comply with local zoning regulations. 

Response: It is our policy to work with local governments and make very effort to 

meet the intent of zoning ordinances even though we are not legally required to do 

so. 

61. The Wasatch-Cache National Forest should eliminate the bias established due 

to cooperating agency status for Uinta County. 

Response: Uinta County was granted cooperating agency status because they had 

special expertise to provide to the planning effort. They have been granted the 

rights as afforded them in the CEQ regulations implementing NEPA. 

62. The Wasatch-Cache National Forest should prioritize the cooperating agency 

status for Uinta County. 

Response: See Response 61. 

Interagency Collaboration – Multi-Jurisdictional 

63. The Wasatch-Cache National Forest should work with other land managers 

and adjacent landowners to restore the entire region to properly functioning 

condition. 

Response: We agree and to the extent we can have been working towards that goal. 

As an example we have been working with an adjacent landowner, Deseret Land 

and Livestock, in a joint prescribed burn project. The State of Utah also has large 

blocks of land that lend themselves to joint projects. 

64. The Wasatch-Cache National Forest should coordinate management activities 

with state and private landowners. 

Response: Yes, we agree and will continue to do so at the project level. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 41 

65. The Wasatch-Cache National Forest should work with the state Division of 

Natural Resources and county commission to eliminate hunting in the TriCanyon area, especially of moose. 

Response: This is a decision that is outside of the scope of Forest Planning (see 

chapter 1 of the FEIS). Members, of the Wildlife Board, set hunting regulations. 

Representatives from public land management agencies participate on Regional 

Advisory Councils who then make recommendations to the Wildlife Board. It is 

through this avenue hunting in the Tri-canyon area is regulated. 

Multi-Jurisdictional Planning with Adjacent National Forests 

66. The Wasatch-Cache National Forest should reanalyze the High Uintas 

Roadless Area as one contiguous planning area in conjunction with the Ashley 

National Forest.

Response: Ideally the planning efforts for both forests would have been scheduled 

during the similar time frames. Each forest had its own set of unique circumstances 

that dictated when each would undertake forest plan revision. We have brought 

forward the direction from the High Uinta Management Plan that was completed 

jointly with the Ashley National Forest in 1994. 

67. The Wasatch-Cache National Forest should work with particular national 

forests. 

 67.1 Work with the Caribou National Forest toward wilderness designation 

for Franklin Basin 

67.2 Work with the Uinta National Forest toward recommended extensions to 

the Lone Peak Wilderness 

67.3 Work with the Uinta National Forest to establish consistent requirements 

for the Snowbird Ski area 

Response: Within the range of alternatives analyzed in the Caribou EIS and in the 

Uinta EIS, recommendations for additional wilderness in Franklin Basin and Lone 

Peak respectively were considered. In the revised Plans the Uinta and Wasatch do 

not provide for permit boundary additions in Lone Peak. A sliver of 400 acres north 

of Mt. Naomi to the state boundary is recommended for wilderness consistent with 

the wilderness recommended by the Caribou National Forest. 

Coordination between the Uinta and Wasatch-Cache for Snowbird Ski Area is best 

conducted at the Master Development Plan stage. 

68. The Wasatch-Cache National Forest should work with all adjacent forests to 

assure consistent management prescription categories and allocations to 

achieve landscape-level wildlife connectivity. 

Response: The three adjoining forests that are currently revising their forest plans 

all have very similar management prescriptions. Their application to the ground 

varies because of the differing capabilities of the landscape and the needs and 

values of the distinctive populations each serves. Also see Response to 59. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 42 

69. The Wasatch-Cache National Forest should work with all adjacent forests to 

assure consistent travel management plans. 

Response: We did to the extent appropriate given the often-differing set of 

circumstances unique to each forest. 

Relationship to Other Planning and Rulemaking Processes 

Roadless Area Conservation Rule 

70. The Wasatch-Cache National Forest should issue a supplement to the Draft 

EIS to explain new Roadless Area Conservation Rule interim directives. 

Response: The interim directives simply include the Chief’s instructions that Forest 

Plan revisions consider, as appropriate, the long-term protection and management 

of unroaded portions of inventoried roadless areas. The Forest has considered the 

values of each roadless area in the FEIS.

71. The final Forest Plan should protect roadless areas in a manner consistent with 

the Roadless Area Conservation Rule. 

71.1 Regardless of the Rule’s status 

71.2 On the Logan Ranger District

Response: We are applying the Chief’s June 7, 2001 direction (incorporated into 

interim directives) as the overarching guidance for managing inventoried roadless 

areas in the Revised Forest Plan. It has applied protection similar to the Rule, to 

some roadless areas while others it has not. On the Logan Ranger District the 

majority of roadless areas are managed to maintain or mostly maintain roadless 

values. 

72. The Wasatch-Cache National Forest should not manage roadless areas 

according to Roadless Area Conservation Rule direction. 

Response: The terms of the Roadless Area Conservation Rule are not applied to 

Alternatives 3, 4, 5 and 7. Other alternatives consider the protection and 

management of inventoried roadless areas by applying terms of the Rule. All give 

full consideration of the values of inventoried roadless areas on the forest. 

73. The final Forest Plan should adopt the “outside roadless area” use tables. 

Response: See Response 71. 

74. The final Forest Plan should define “likelihood” of degrading roadless 

characteristics in a scientific manner. 

Response: Display of effects to roadless area values has been expanded in the final 

EIS. A programmatic analysis such as that in forest planning cannot analyze any 

specific on the ground effects. This disclosure must come at the project level 

analysis when a site-specific action is proposed. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 43 

75. The final Forest Plan should explicitly state whether road construction is 

permitted by management area prescription in the allowable use tables. 

Response: The Revised Forest Plan includes standards and guidelines by 

management prescription that state whether or road construction is allowed. 

76. The final Forest Plan should establish its own strong protection of roadless 

areas independent of the national roadless rule by assigning all areas to 1.5, 

2.6, or 4.1. 

Response: The Revised Forest Plan protects inventoried roadless area values to 

varying degrees. Please refer to Table RW-9 under Topic 5 in Chapter 3 of the 

FEIS. 

77. The final Forest Plan should state that it is not required to comply with the 

Roadless Area Conservation Rule pending resolution of legal challenges. 

Response: In Chapters 1 and 2 of the FEIS we have explained the current status of 

the Roadless Area Conservation Rule. In Alternative 7 that has been developed as 

the Revised Forest Plan, we are applying the Chief’s June 7, 2001 direction as the 

overarching guidance for protecting inventoried roadless areas. This direction has 

been incorporated into Forest Service Interim Directive No. 1920-2001-1. Once a 

judicial ruling has been made or some further regulations for roadless area 

management decided upon, we would follow that direction. 

78. The final Forest Plan should state that inventoried roadless areas will not be 

subject to any restrictions beyond the assigned management prescription 

category. 

Response: They will be subject to management direction contained in the revised 

Forest Plan and any applicable agency policy.

79. The final Forest Plan should comply with the Chief’s interim directives. 

Response: It does. The Chief has instructed forests to ensure that Forest Plan 

revisions consider, as appropriate, the long-term protection and management of 

unroaded portions of inventoried roadless areas. He also stated in the policy that as 

a general rule inventoried roadless areas should be managed to preserve their 

roadless characteristics until a forest scale roads analysis is completed and 

incorporated into a forest plan. This has been done. Inventoried roadless areas are 

protected in Alternatives 1, 2, and 6. Other alternatives consider the protection and 

management of inventoried roadless areas by varying degrees. All give full 

consideration of the values of inventoried roadless areas on the forest.

Legal and Administrative Framework 

80. The final Forest Plan should include standards that define whether categorical 

exclusions can be used when extraordinary circumstances are present. 

Response: An agency final interim directive was published in the Federal Register 

on August 23, 2002 that addressed this issue. Direction such as this is most 

appropriately addressed in agency handbooks and manuals.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 44 

The Forest Planning Process 

Purpose, Need, and Significant Issues 

Revision Topics 

81. The Wasatch-Cache National Forest should expand the roadless area issue 

discussion to emphasize ecological integrity and inherent values because 

recreation is over-emphasized. 

Response: The examination of roadless areas was expanded considerably between 

the Draft and Final EIS to consider each area’s values individually, in broader 

contexts, and for values in addition to recreation. See Appendices C-1, C-2 and the 

Topic 5 discussion in the FEIS. 

Decisions Made in Forest Planning 

Scale of Decisions 

82. The final Forest Plan should clearly define the difference between significant 

and non-significant Forest Plan amendments. 

Response: Forest Service Manual section 1922.5 defines the difference between 

non-significant (1922.51) and significant (1922.52) amendments. These sections 

are cited below and further define more general direction established in the 

planning regulations, 39 CFR 219.10 (f). 

1922.51 - Changes to the Forest Plan That Are Not Significant. Changes to the 

forest plan that are not significant can result from: 

 1. Actions that do not significantly alter the multiple-use goals and objectives for 

long-term land and resource management; 

 2. Adjustments of management area boundaries or management prescriptions resulting from further on-site analysis when the adjustments do not cause 

significant changes in the multiple-use goals and objectives for long-term land and 

resource management; and 

 3. Minor changes in standards and guidelines. 

 4. Opportunities for additional management practices that will contribute to 

achievement of the management prescription. 

The Forest Supervisor must prepare an amendment to the forest plan to 

accommodate a change determined not to be significant. Appropriate public 

notification is required prior to implementation of the amendment. 

1922.52 - Changes to the Forest Plan That Are Significant. The following examples 

are indicative of circumstances that may cause a significant change to a forest plan: 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 45 

 1. Changes that would significantly alter the long-term relationship between 

levels of multiple-use goods and services originally projected (36 CFR 219.10(e)); 

and 

 2. Changes that may have an important effect on the entire forest plan or affect 

land and resources throughout a large portion of the planning area during the 

planning period. 

When a significant change needs to be made to the forest plan, the Forest 

Supervisor must prepare an amendment. 

Documentation of a significant change, including the necessary analysis and 

evaluation should focus on the issues that have triggered the need for the change. 

In developing and obtaining approval of the amendment for significant change to 

the forest plan, follow the same procedures as are required for developing and 

approving the forest plan (36 CFR 219.10(f) and 36 CFR 219.12). 

Management Direction 

83. The Wasatch-Cache National Forest should produce a high-quality, strong 

Forest Plan in order to face real issues in the region. 

Response: We believe that through this planning process the key issues for forest 

plan development at this time and place have been identified, and that the resulting 

plan presents strategies for their treatment. The degree of detail with which the 

revised forest plan treats these issues through allocation to prescriptions, standards 

and guidelines, goals and objectives and monitoring is intended to be at appropriate 

scales given the nature of the issues and affected resources. We think the revised 

forest plan is a high quality product, but at the same time is by no means perfect. 

We think that the forest planning process is continuous, and that amendments will 

be needed and welcome as new information is developed and new issues arise. 

84. The Wasatch-Cache National Forest should remedy its failure to shift from 

emphasizing utilitarian values to ecosystem preservation and recreation values 

to mirror changes in society. 

Response: We recognize the diverse opinions related to how the forest should be 

used. Different segments of society have different values and interests. Strong 

opinions are expressed by majorities or minorities, of the overall population, on 

various issues. However, the planning and NEPA process are not a referendum or 

vote, and we have no accurate information on the numbers of people who take up 

opposite positions on issues. The forest plan is a complex set of decisions intended 

to serve all of society, while protecting the values of the federal lands and their 

elements as required by law. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 46 

85. The Wasatch-Cache National Forest should use the precautionary principle in 

the final Forest Plan because of lack of species trend data. 

Response: The FEIS has added analysis and information beyond what was 

provided in the DEIS. Consideration of lynx and other species is expanded in the 

FEIS. Additionally, Lynx Analysis Units (LAU) have been mapped and were 

considered along with other information on lynx in the FEIS. These LAU maps are 

on file with the forest. Some species of carnivores are not considered in as great 

detail (egg. pine marten and black bear) either because they are not at risk or their 

distribution is limited on the forest and local issues related to them are not critical. 

New information on individual species is presented in Appendix J – to the FEIS on 

Management Indicator Species. Information on presence/absence and some trend 

information are presented. Decisions in the forest planning process use the best 

information available. 

86. The Wasatch-Cache National Forest should be proactive in addressing the 

immediate overuse problems facing the Tri-Canyon area and write a separate 

crisis plan for this area. 

Response: Forest leadership and forest plan interdisciplinary team carefully 

considered a specific objective to plan focused on the Tri-Canyon area; see 

Forestwide Objective 19 in the Proposed Forest Plan (May 2001, pg. 4-20.) This 

objective did not survive in the revised forest plan given hard choices for where to 

emphasize future work. However, several identified objectives in the revised forest 

plan will add proactively to Tri-Canyon management, to bring vegetation within 

historic range of variation, to treat urban-interface fuels, to better manage dispersed 

camping, and to continue development of the Bonneville Shoreline and Great 

Western Trails. Also, considerable additional focused direction for the Tri-Canyon 

area in provided in the desired future conditions section on the Central Wasatch 

Management Area.

87. The Wasatch-Cache National Forest should write strict standards and 

guidelines specifically addressing the Tri-Canyon Forest in the new Forest 

Plan to avoid degradation from lack of management. 

Response: The forest wide standards and guidelines for soil and watershed in the 

revised forest plan, the Clean Water Act, and state and county standards for water 

provide substantial limits on how much degradation is possible. We think that the 

Tri Canyon area, while directly adjacent to and used by a large urban population, 

can be protected adequately by these standards. 

88. The Wasatch-Cache National Forest should frame management direction of 

the Logan Ranger District on watershed and critical wildlife corridor values in 

order to meet the purpose and need. 

Response: Much of the desired future condition section for the Cache-Box Elder 

Management Area was developed with the protection of the Logan River watershed 

and north-south Bear River Range wildlife corridor in mind. See Watershed and 

Wildlife Habitat sections in that part of Chapter 4 in the revised Forest Plan. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 47 

89. The Wasatch-Cache National Forest should verify that final Forest Plan 

language reflects the management direction of the new Administration. 

Response: The Wasatch-Cache National Forest and Intermountain Region receive 

direction and policy updates from our Forest Service Washington Office (WO) and 

the current administration on a regular basis. Draft forest planning documents are 

reviewed by the regional and WO prior to making a final decision, and forest 

policies must be compatible with direction from these management levels and the 

current administration. 

Forest Plan Elements General 

90. The Wasatch-Cache National Forest should clarify and strengthen vague 

direction in the proposed plan to reduce excessive management flexibility. 

Response: The revised forest plan has tried to identify a trim and realistic set of 

management direction that can guide future management and set user expectations 

as to how management will operate. As the comment infers, some management 

flexibility and local ad hoc decision-making authority are recognized as essential to 

any organization that must plan project work, do daily work or respond to crises. 

The forest plan includes several kinds of management direction (DFCs, standards, 

guidelines, goals, objectives, and monitoring) all of which must be integrated and 

considered in implementing overall management for all or part of the forest. The 

revised forest plan sets standards where needed to protect key resources from 

overuse and so that desirable resource trends can be established. Standards that are 

perceived by some as tying the hands of local managers can be seen as excessive 

management flexibility to others. 

91. The final Forest Plan should provide detailed descriptions of desired future 

conditions in order to meet ecosystem goals. 

91.1 For each management area 

91.2 For all habitat types and resources 

Response: DFCs are written for each management area and forestwide for an array 

of resources and uses; see Chapter 4 in the revised Forest Plan. Similarly, the 

forestwide goals for different resources identify longer-term situations and settings 

that the plan intends to trend toward. Included in for the management area DFCs 

and in the goals are statements regarding uses, vegetation settings, wildlife habitats, 

watershed and soils, and other items. 

92. The Wasatch-Cache National Forest should more effectively integrate desired 

future conditions for each resource to those for management areas as a whole. 

Response: Desired future conditions (DFC) statements were written for 

management areas in the DEIS to apply to Alternative 6, and were rewritten as 

needed in the Final Plan. Forestwide resource DFCs were also rewritten as needed 

to make the whole plan more integrated. While management areas are not as large 

as the whole forest, they still are major tracts of the forest. Our rationale is that 

these management areas have some integrity from both social and physical 

geographic perspectives. The amount of detail and specific foci in a desired future 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 48 

condition statement is related to several factors, some of which are: the decisions 

the forest plan is making, the issues for the management area and related larger and 

smaller contexts of consideration (forestwide or larger), scientific and management 

perspectives of the team writing the DFC. We recognize that the DFCs as written 

may seem like overkill to some (too narrowly defining of what may occur in an 

area), and lacking to others (not detailed enough regarding particular drainages, 

issues, development opportunities or prohibitions), both from social or 

physical/natural perspectives. We think, however, that the forestwide resource 

DFCs and management area DFCs provide enough emphasis on desired social and 

physical conditions related to the issues which need resolution, for managers and 

the public to see where management emphases for the planning period (next decade 

or more) should be. If more detailed definition of broad management is DFCs are 

needed, or if focus on subparts of the management area is needed, subsequent area 

assessments and planning may be undertaken. 

93. The Wasatch-Cache National Forest should more effectively link desired 

future conditions to anticipated management actions by placing more focus on 

commodity resource values. 

Response: The forest plan makes several decisions – desired future conditions, 

goals, objectives, standards, guidelines, management prescriptions, monitoring, 

timber allowable sale quantity, suitable rangelands, and makes recommendations 

for wilderness. The Forest Plan objectives stated in Chapter 4-A. 4 probably come 

closest to defining what management actions are likely to be taken in the near 

future. The forest plan is not required to provide detail on how these objectives or 

the other decisions will be implemented. In other words it states the “what and 

why” for the Wasatch-Cache over the next several years, but it does not state 

“how”. “How” these several decisions will be implemented is largely left up to the 

discretion of the forest supervisor and district rangers as they propose projects, 

(subject to NEPA process and with public involvement) and undertake daily 

activities to narrow the gap between the current condition and what is desired in the 

future. 

Alternative 5 in the FEIS was provided for the decision maker to consider one that 

would emphasize commodity outputs. 

Goals and Objectives, Standards and Guidelines General 

94. The Wasatch-Cache National Forest should add specific and measurable 

standards throughout the final Forest Plan to reduce excessive management 

flexibility. 

Response: See response to 90. 

95. The final Forest Plan should list prescription-specific standards and guidelines 

separately from forest-wide direction. 

Response: In the revised Forest Plan prescription-specific standards and guidelines 

have been developed for timber harvest, prescribed fire, wildland fire use, 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 49 

snowmobiling, livestock grazing, road, trail and recreation construction, and other 

activities. See Chapter 4 B- Forestwide Allocations, Management Prescription 

Categories. 

96. The Wasatch-Cache National Forest should vary standards and guidelines by 

alternative and monitoring criteria. 

Response: We chose to keep standards and guidelines constant across alternative 

for three reasons. First, we think of standards as thresholds beyond which there 

should not be further use, i.e. limits to reasonable use beyond which adverse effects 

are likely. As such, standards ought not to vary for soil compaction, vegetation loss, 

etc. – regardless of what general goals or desired futures there are for an area. 

Second, varying standards across alternatives would have made the analysis of 

alternatives even more complex than it has already become, without much 

perceived benefit. Third, keeping standards equal across alternatives allows 

standards to be a controlled constant across the analysis. 

97. The Wasatch-Cache National Forest should change the frequency of visitor 

satisfaction surveys in Objective 23 to two-year intervals. 

Response: The objectives in the revised Forest Plan have changed considerably 

since the DEIS and proposed Forest Plan were distributed in May 2001. Objective 

23 has been dropped, and no other objective addresses frequency of visitor 

satisfaction surveys. The Forest Service has recently developed a national program 

for monitoring and sampling recreation use and satisfaction. The survey of 

Wasatch-Cache recreation will commence in the fall of 2002 and run for 1 year. 

Results of this yearlong survey should be available in early 2003. It is expected that 

this recreation survey will be conducted every five years to develop long-term 

information on recreation. 

Management Prescription 

Management Prescription Category Development General 

98. The Wasatch-Cache National Forest should develop a broader range of 

management prescription categories to better manage individual activities to 

include a back-country designation. 

Response: Management prescriptions 4.1 and 4.3 both can be considered 

“backcountry” recreation prescriptions. Management Prescription 4.1 is a nonmotorized prescription, while the 4.3 prescription allows motorized use. For full 

descriptions on these management prescriptions see Chapter 4 in the revised Forest 

Plan. 

99. The Wasatch-Cache National Forest should place the greatest emphasis on 

management prescriptions instead of management areas. 

Response: Management prescription categories have been used by several regions 

in the Forest Service to generally describe what activities might occur or be limited 

on subareas of forests. They are a “shorthand” tool for looking at management for 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 50 

delimited areas. The application of these prescriptions is a forest plan decision. 

Interpretation of how the prescription should be implemented through particular 

projects is specific to the site characteristics and local issues related to the 

implementation. Management prescriptions are only one part of overall plan 

direction, and should not be considered without also thinking about how standards 

and guidelines apply in the local setting, how the prescription relates to the goals 

and objectives of the plan and the desired future conditions for the management 

area. An analogy: Think of management prescriptions as a fork. It’s hard to do a 

thorough and neat task of eating a meal (the forest) without also having a plate 

(management areas), spoon (goals and objectives), knife (standards and guidelines) 

and a napkin (monitoring.) 

Management Prescriptions General 

100. The Wasatch-Cache National Forest should eliminate the word “generally” 

from all management prescription category descriptions to reduce excessive 

management flexibility. 

Response: We have eliminated the use of the word “generally” in our management 

prescription definitions to try to more clearly state what is allowed and what is not. 

101. The Wasatch-Cache National Forest should reduce specificity in the 

management prescription categories to increase management flexibility. 

Response: Management prescription definitions have been rewritten to clarify what 

is allowed and what is not. Prescriptions are applied to an area of land to better 

help the local manager and public understand what practices should be applied and 

what uses and characteristics can be expected on a given landscape. In the 1985 

Forest Plan no prescriptions were applied, providing little, if any direction for how 

subareas of the forest ought to be managed. The application of management 

prescriptions helps define the future of an area, but still leaves considerable 

implementation flexibility available to the manager and to an involved citizenry. 

102. The Wasatch-Cache National Forest should re-evaluate management 

prescription categories on a district-by district basis to enable maximum 

flexibility. 

Response: We have reviewed management prescription on a district-by-district 

basis and believe that the range of alternatives, as cited in the FEIS, was sufficient 

to provide a high level of flexibility. The individual rangers and their staff also 

reviewed alternative 7. They believe that this alternative provides the flexibility 

they need to accomplish the Goals and Subgoals of the Forest Plan. 

Allocation of Management Prescription Categories General 

103. The Wasatch-Cache National Forest should avoid using restrictive 

management categories. 

103.1 Wilderness 

103.2 Unroaded, roadless, or non-motorized 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 51 

Response: We understand that many users are not in favor of any protection of 

roadless values, non-motorized recreation, or wilderness recommendations on the 

Wasatch-Cache. Some alternatives provide for wilderness recommendations and 

maintenance of roadless values and others do not. No Wilderness is recommended 

in Alternatives 4 and 5. The discussion in Chapter 3, Topic 5 in the FEIS compares 

the extent to which roadless values are protected in each alternative. The decisionmaker will have to weigh what is the best mix of winter motorized and nonmotorized, protected roadless, and wilderness settings for the future. 

104. The Wasatch-Cache National Forest should overcome the institutional bias 

against wilderness designation that is evident throughout the draft Forest Plan. 

Response: The Forest Service must evaluate roadless areas for their Wilderness 

potential as required by laws and implementing direction. Public and internal 

opinions regarding the capability, availability, and need for more wilderness are 

weighed in the overall evaluation. 

105. The Wasatch-Cache National Forest should redesign allocations on the North 

Slope to eliminate the patchwork of conflicting uses. 

Response: Alternative 7 has been added to the array of alternatives after receiving 

comments on the DEIS. Other alternatives provide a range of possibilities designed 

to address the issues associated with this forest plan revision and guide the forest on 

different trajectories. What may appear in some alternatives to be a patchwork of 

conflicting uses to some is likely to be seen a good multiple-use programmatic 

direction to others. Projections of outputs from the different alternatives are 

provided that give a sense of what might be expected under management from the 

alternatives. 

Implementation and Monitoring 

Implementation and Monitoring General 

106. The Wasatch-Cache National Forest should measure and report specific results 

toward Forest Plan goals. 

Response: Forest plan monitoring is intended to show whether management under 

the plan is successfully moving the Wasatch-Cache closer toward the desired future 

conditions that are stated, or if there are problems. Our Chapter 5 section on 

Monitoring will focus on the extent to which the objectives identified in the forest 

plan are being accomplished, and whether that accomplishment is helping the forest 

trend as intended. Annual forest plan monitoring reports have been provided to the 

regional office. In the future some revamping of these of these reports is 

anticipated and they will be made available to the public on our website. 

107. The final Forest Plan monitoring section should include specific standards to 

define success or failure for each measurement indicator. 

Response: The forest plan monitoring section has been substantially changed since 

the publication of the DEIS and proposed Forest Plan in May 2001. In Chapter 5 of 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 52 

the revised Forest Plan monitoring questions, measurement indicators, frequency of 

monitoring, and other monitoring criteria are identified. It is important that forest 

plan monitoring and project level monitoring be distinguishable. While there are 

clear relationships between the two, forest plan level monitoring is more 

programmatic and generally concerned with broader scale, while monitoring at 

project level is mostly likely more specific and focused. 

108. The Wasatch-Cache National Forest should collect adequate monitoring data 

to meet cumulative effects analysis requirements. 

Response: The choices made for monitoring items in the monitoring section are 

intended to provide a framework which can be further defined in response to 

changing conditions in annual monitoring and completed given available funding. 

Cumulative effects analysis in the FEIS is based on best available and applicable 

data at the time the document was prepared. 

109. The Wasatch-Cache National Forest should incorporate the cost of monitoring 

into all projects or refuse to approve them if funding isn’t available. 

Response: We agree that project monitoring is an important responsibility, and its 

costs should be anticipated and budgeted during project development. 

110. The Wasatch-Cache National Forest should monitor the same activities under 

different environmental conditions rather than just once. 

Response: We do monitor BMPs and other indicators and standards under a broad 

variety of project situations. Part of our monitoring plan will be to sample a variety 

of projects in different areas of the forest to see if the forest is implementing 

direction as directed and trending as intended under the direction in the forest Plan. 

See the Monitoring section in Chapter 5 of the revised Forest Plan for details. 

111. The Wasatch-Cache National Forest should monitor the extent to which 

standards and guidelines are applied annually. 

Response: It is intended that all standards and guidelines are applied consistently. 

Many standards and guidelines are monitored annually, or regularly as 

implemented. Other forest plan monitoring and reporting are done at intervals of 

several years. Part of our monitoring plan will be to sample a variety of projects in 

different areas of the forest to see if the forest is implementing standards, 

guidelines, and other direction and trending as intended. The revised Forest Plan 

monitoring section in Chapter 5 details the frequencies of monitoring different 

items. 

112. The final Forest Plan should better define how desired future conditions will 

be achieved and how monitoring will be done for the western Uintas. 

Response: Chapter 4. A. 4. of the revised Forest Plan details several objectives in 

that will be undertaken over the course of the plan to move the forest toward DFCs. 

The detail for how these and other actions will be approached will be based on 

individual project proposals to implement the plan. Questions about how DFCs will 

be attained for vegetation, watershed, recreation, wildlife and other items defined in 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 53 

the management area statements must be answered over time through project level 

implementation and monitoring both projects and overall performance under the 

plan. 

Volunteers 

113. The Wasatch-Cache National Forest should make better use of volunteer labor 

from recreationists. 

113.1 Off-road vehicle users 

113.2 Mountain Bikers 

Response: The Wasatch-Cache does have an active program to incorporate 

volunteer work to enhance accomplishment of forest work. Volunteers have 

worked in recreation and trails projects, heritage resource (PIT) projects, range 

administration and monitoring, and a variety of other tasks. We welcome 

volunteers; their work takes time to supervise and coordinate, but it is of great value 

to us and worthy service to the community and for public lands. Volunteers may 

call the main desk at the Wasatch-Cache to inquire about opportunities. 

114. The Wasatch-Cache National Forest should make better use of volunteer labor 

for monitoring non-recreational impacts. 

Response: See response 113. 

Funding and Fees 

Funding 

115. The Wasatch-Cache National Forest should secure adequate funding for 

certain purposes. 

115.1 For the Avalanche Forecast Center 

115.2 For environmental analysis 

Response: Funding for a variety of functions that are closely linked to the WasatchCache is often needed for their viability. Several partners including the Forest 

Service, Friends of Utah Avalanche Forecast Center, Utah State University, Salt 

Lake County, the State of Utah and others, fund the Utah Avalanche Center. Each 

of these partners recognizes the valuable service that is provided, and strives to 

apply support when at all possible. 

Similarly, environmental analysis, in advance projects or planning, as required by 

law, is needed for quality work, and can take substantial funding to achieve. Often 

project proponents pay for environmental analysis, and partnering with other 

agencies to bear this cost is a good idea. The Forest Service is always looking for 

to bear the costs of project planning. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 54 

116. The Wasatch-Cache National Forest should increase funding for seasonal 

ranger positions to add weekend shifts and Spanish speaking rangers. 

Response: Seasonal employees are a key to successful management of the forest. 

Funding for them is tight, and seems to be getting tighter as overhead costs go up. 

We do have Spanish-speaking seasonal employees working for us in recreation as 

well as other disciplines. These individuals are valued for their ability to 

communicate with the Spanish-speaking community and users. Hiring, 

deployment, and scheduling work for these individuals and other personnel actions 

are not part of forest plan decisions. 

117. The Wasatch-Cache National Forest should consider the financial impacts of 

wilderness designation on the state parks and recreation division. 

Response: To our knowledge, a decrease in licensing fees paid to a state for atvs 

and snowmobiles has not been linked to recommendations for wilderness in any 

state. In the State of Utah the numbers of these vehicles has continued to rise. 

118. The Wasatch-Cache National Forest should use oil and gas revenue for road 

maintenance. 

Response: Revenues from oil and gas development are committed to the treasury 

and to the states by laws, which define the mechanisms for their distribution and 

allocation. The Wasatch-Cache has no authority over how this is done. 

119. The Wasatch-Cache National Forest should work with the State of Utah to 

assure that off-road vehicle gas tax receipts are used directly for off-road 

vehicle recreation. 

Response: The Wasatch-Cache often applies for funding from the State of Utah to 

develop plans and funding for trails. The state has awarded monies nearly every 

year when the forest has projects that fall within their funding criteria. These 

monies are applied to both motorized and non-motorized recreation trails. 

120. The final Forest Plan should identify specific funding sources to meet its 

recreational site maintenance goals. 

Response: While general guidelines to seek partnerships or other means for funding 

or to decrease costs of administration, maintenance, operations, and monitoring may 

be appropriate in a forest plan, we think that identifying specific sources is not 

necessary and not within the scope of forest plan decisions. 

121. The final Forest Plan should identify specific funding sources to meet its range 

monitoring requirements. 

Response: See response 120. 

122. The Wasatch-Cache National Forest should allocate money to monitor the use 

of wilderness areas. 

Response: While budgets are always limited, some funding is spent each year to 

monitor wilderness use, both in the summer and winter. Additionally, a national 

visitor recreation use monitoring survey is being undertaken this year to improve 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 55 

our understanding of recreation use on the forest (and in designated wildernesses.) 

Forest Plan level monitoring, see Chapter 5 of the revised Forest Plan, does identify 

questions that relate to recreation use and the extent of impacts to resources from 

recreation. 

123. The Wasatch-Cache National Forest should require all individuals and 

corporations profiting from forest lands to pay the full cost for management 

associated with their use. 

Response: Individuals and corporations that are permitted to operate on the national 

forest for profit are charged a use fee that is calculated based in part on the revenues 

of their operation. The agency is not required to cover the full costs of 

administration of the use, not would that always be desirable. Permit fees and 

administration are not within the scope of the decisions made in forest plan 

revision. 

Fees 

Fees General 

124. The Wasatch-Cache National Forest should charge parking fees at lots. 

Response: The forest could elect to charge for parking at developed lots, which 

provide some services or meet some minimum development levels. While this 

might be desirable and return some money to the treasury and the forest, it is not a 

forest plan decision. 

 

125. The Wasatch-Cache National Forest should request a larger share of off-road 

vehicle registration fees for enforcement and mitigation. 

125.1 Rather than new trail construction 

Response: See response 119. 

126. The Wasatch-Cache National Forest should address the fairness of imposing 

fees only on motorized recreationists. 

Response: We recognize the frustration of some motorized recreation users, who 

feel they are bearing a larger burden because of licensing fees associated with their 

vehicles. However, the question of fees for parking or licensing is outside the scope 

of forest plan decisions. 

127. The Wasatch-Cache National Forest should charge user fees according to the 

activity’s impact. 

Response: Fees for grazing use are set by Congress and changing them is not 

within the authority of the Wasatch-Cache National Forest. Mitigation of impacts 

can be required in definition and administration of permits. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 56 

Fee Demonstration Program 

128. The Final EIS should disclose more detailed accounting information on fee 

demonstration program receipts and expenditures. 

Response: Fee demo program decisions and the administration of the fee demo are 

not covered by the forest plan, and as such are not dealt with in this effects analysis 

or Forest Plan. 

Detailed accounting for the fee demo program is provided on an annual basis, and 

reports are prepared which can be made available to the public. General summaries 

have been prepared for the Intermountain Region, and project by project reports are 

available on the forests. 

129. The Final EIS should analyze the effects of the fee demonstration program on 

low-income users. 

Response: See response 128. 

130. The Wasatch-Cache National Forest should expand the fee demonstration 

program locally as long as subsidized grazing is eliminated.

 Response: See response 128. 

131. The Wasatch-Cache National Forest should only extend the fee demonstration 

program to heavily used areas. 

 Response: See response 128. 

132. The Wasatch-Cache National Forest should require all users, including nonmotorized ones, to pay a license fee. 

 Response: The establishment of use fees for areas or uses is not a decision that is 

within the scope of the issues related to this forest plan revision. 

133. The Wasatch-Cache National Forest should revamp the fee demo program. 

133.1 Establish a sliding fee scale for lower income people 

133.2 Create one annual pass in partnership with adjacent forests

 Response: See response 128. 

134. The Wasatch-Cache National Forest should implement the proposed fee demo 

site at Mueller Park. 

 Response: See response 128. 

135. The Wasatch-Cache National Forest should make Big and Little Cottonwood 

Canyons fee areas. 

 Response: See response 132. 

136. The Wasatch-Cache National Forest should not use Mirror Lake Highway fee 

demo funds to harden impacted dispersed camping sites because it encourages 

further damage.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 57 

 Response: The hardening of dispersed sites for resource protection or for recreation 

experience is a site-specific implementation decision that can be related to more 

general forest plan decisions (e.g. perhaps allocation of recreation management 

prescriptions or application of soil standards). Assessment of the relationship of 

damage, use, and local site conditions are all related to the side-specific condition of 

the case at hand and are not forest plan decisions. Paying for any hardening project 

can be done out of whatever funding is available and legal. 

137. The Wasatch-Cache National Forest should exempt campers at developed sites 

from fee demo charges. 

 Response: See responses 128 and 132. 

138. The Wasatch-Cache National Forest should eliminate the fee demonstration 

project. 

Response: See response 128. 

Tollbooths 

139. The Wasatch-Cache National Forest should install tollbooths at Big and Little 

Cottonwood Canyons. 

139.1 To improve public environmental sensitivity 

139.2 To educate the public about watershed protection 

139.3 To help control the litter epidemic 

 Response: Suggestions to increase sensitivity for environmental protection are 

valid and we believe education is a key element in an overall strategy for successful 

forest management. The Chapter 4 of the Forest Plan provides an objective that is 

specifically designed to deal with concerns regarding environmental sensitivity and 

enforcement, and several other objectives have public education elements within 

them. Tollbooths could be good contact points for dissemination of information 

about appropriate behavior on the forest. However, these are quite site-specific 

recommendations and are outside the scope of forest plan decisions. 

140. The Wasatch-Cache National Forest should install tollbooths at Big and Little 

Cottonwood Canyons to be operated during the summer season. 

140.1 With a special access pass for residents and employees 

140.2 With a portion of each ski lift ticket contributed in the winter 

 Response: The recommendations are interesting but outside the scope of the forest 

plan decisions. These are site-specific and fee demo or cost recovery suggestions 

that are handled under different authorities and decisions. 

141. The Wasatch-Cache National Forest should redesign the tollbooth at Mirror 

Lake Highway to improve enforcement of the user fees. 

 Response: See responses 139 and 140. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 58 

Alternatives 

Alternative Development 

Range of Alternatives 

142. The Wasatch-Cache National Forest should provide an adequate range of 

alternatives. 

Response: The 7 Alternatives presented in this FEIS encompass a spectrum of 

approaches to resolving issues and needs for change topics identified through public 

involvement and environmental analysis during the Forest Plan revision process. 

Between Draft and Final, several changes were made to Alternatives in response to 

public comments. These are described in the FEIS section titled “Alternative 

Development, Range of Alternatives” in Chapter 2. 

142.1 By including an alternative that emphasizes multiple use. 

Response: All Alternatives in this FEIS are consistent with the Multiple Use 

Sustained Yield Act. FEIS Appendix D-1 includes an explanation of how 

Management Prescriptions applied to all Alternatives are consistent with MultipleUse and other laws. However, that Act allows for broad discretion and there is a 

wide range of opinions about that mix of goods and services constitute “multiple 

use”. The 7 Alternatives in this FEIS represent that range. 

142.2 By including an alternative that emphasizes scientific management. 

Response: The analysis of environmental effects provided in FEIS Chapter 3 

provides disclosure of the projected results of implementing each of the 7 

Alternatives based on the best available science. Each of the Alternatives provides 

for a different combination of constraints and management of resources that 

respond to both scientific and social concerns. There is a wide range of opinions 

about what would constitute scientific management. With regard to withdrawing 

inventoried roadless areas from harvest, FEIS Appendix CII provides an evaluation 

of values of each inventoried roadless area. Alternative 7 was designed to take these 

values into account when applying management prescriptions in contrast to 

Alternatives 1,3,and 6 that apply the Roadless Area Conservation Rule. 

142.3 By including a balanced range of non-motorized winter recreation 

designations. 

Response: The range of alternatives for non-motorized winter recreation is 

displayed in this FEIS in Chapter 3 under Topic 4, Table REC-12. The relative 

percentages of non-motorized winter opportunity are based on mapping of specific 

areas for non-motorized winter uses considering accessibility as well as 

incorporating decisions made through wilderness designation. The Alternatives 

respond to specific comments about particular areas for non-motorized use in winter 

rather than on a mathematically even spread of acres among alternatives. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 59 

142.4 By including an alternative that further restricts motorized access. 

Response: The decision not to entertain site-specific changes to existing Travel 

Management Plans for summer is explained in the FEIS, Chapter 2, under the 

section titled “Alternatives Considered but Eliminated From Detailed Study”. This 

decision is within the discretion of the Forest Supervisor (36 CFR 219.12(b)). 

However concerns raised between Draft and Final about the implications of 

Recreation Opportunity Spectrum Mapping for future Travel Management Planning 

have now been addressed through clarifying language added in FEIS Chapter 2, 

Common Characteristics of Alternatives, Appendix D, and in the Revised Forest 

Plan Chapter 4. 

 

142.5 By including an alternative that has no roadless or non-motorized 

Designations. 

Response: Update of the roadless area inventory and evaluation of roadless areas 

for potential wilderness recommendation are required components of Forest Plan 

Revision (36 CFR 219.17(a)). Alternatives 4 and 5 recommend no roadless areas 

for wilderness, which would add to non-motorized acres 

142.6 By including an alternative that recommends all roadless areas as 

wilderness. 

Response: This was not considered to be reasonable because not all inventoried 

roadless areas have high quality wilderness characteristics. FEIS Appendix CI 

provides an evaluation of each roadless area for wilderness recommendation. 

142.7 By including a wide range of alternatives for wilderness 

recommendation. 

Response: The FEIS range of Alternatives includes from 0 to 388,900 acres of 

recommended wilderness or 0 to 64% of inventoried roadless areas. Several areas 

were added to recommended wilderness in Alternative 1 in response to public 

comment about specific roadless areas with high quality wilderness characteristics. 

Given that not every inventoried roadless area has these characteristics, the range of 

reasonable alternatives area provided. FEIS Appendix CI provides an evaluation of 

each roadless area for wilderness recommendation. 

142.8 By including an alternative that eliminates timber harvesting and 

grazing. 

Response: FEIS Alternative 1 eliminates timber harvesting. Elimination of 

grazing was not included for reasons explained in FEIS, Chapter 2 under the 

heading “Alternatives Considered But Eliminated From Detailed Study.” 

142.9 By including a full range of alternatives for grazing. 

Response: We have added additional suitability criteria in Alternative 2 to be 

responsive to the concern about the range of alternatives for grazing. See FEIS 

Chapter 2, Alternative 2 and Comparison of Alternatives. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 60 

142.10 By including alternatives indicating reductions in animal unit months 

to reflect current demand. 

Response: The FEIS provides a discussion of animal unit months and demand 

variables in Chapter 3, Topic 7, under the heading “Livestock Grazing Levels”. 

142.11 By maintaining the current range of alternatives for grazing. 

Response: See Response 142.9. 

142.12 By including an alternative with large carnivores as management 

indicator species. 

Response: FEIS Chapter 2 under the heading “Alternatives Considered but 

Eliminated From Detailed Study” provides a discussion of the appropriateness of 

large carnivores as MIS. FEIS Chapter 3, Topic 2, Wildlife provides a discussion 

of MIS and why they were selected. 

142.13 By including an alternative that protects biodiversity and emphasizes 

ecosystem services. 

Response: Within the range of reasonable alternatives, Alternatives 1 and 2 were 

designed to emphasize protection of biodiversity and ecosystem services such as 

clean water, air and diverse habitats. 

Adequacy of Alternatives 

143. The Wasatch-Cache National Forest should reject all six alternatives until it 

provides further guidelines defining financial, social, and access impacts. 

Response: The FEIS displays the expected effects of 7 Alternatives including 

social, economic and access. See Chapter 2 Comparison of Alternatives, Chapter 3, 

Topic 3 Roads Access Management, and Social and Economic Analysis. 

144. The Wasatch-Cache National Forest should revise alternatives to more 

adequately plan for an increase in off road vehicle use and associated impacts. 

Response: The Revised Forest Plan includes Objectives for OHV and NonMotorized Travel Management as well as for Education and Enforcement. Also 

See Response 142.4 

145. The Wasatch-Cache National Forest should eliminate Alternatives 1 and 5 

because both are too extreme to be acceptable 

Response: While some may view Alternatives 1 and 5 as extreme, they were 

developed in direct response to public comment and provide for disclosure of 

effects for a range of reasonable alternatives as required under NEPA. Selection of 

Alternative 7 reflects the Forest Service desire to provide for some balance between 

these ends of the spectrum. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 61 

Comparison of Alternatives 

146. The Wasatch-Cache National Forest should compare the effectiveness of 

Alternatives 1 and 6 in meeting stated goals for preserving ecosystem values 

and wildlife. 

146.1 With respect to management prescriptions.

Response: FEIS Chapter 3, Topic 2, Wildlife provides improved information on 

the effects of each of the Alternatives, their mapped management prescriptions, and 

the allowed activities on groups of wildlife species. Effects on ecosystem values 

for each Alternative are displayed in FEIS Chapter 3, Topic 1, Watershed Health 

and Topic 2, Vegetation. Table VEG-7 summarizes how each of the 7 alternatives 

affects ecosystems in terms of properly functioning conditions. The Record of 

Decision explains why Alternative 7 was selected given its relative effects on 

ecosystem values and wildlife. 

146.2 With respect to motorized recreation. 

 Response: Each of the 7 Alternatives in the FEIS provides for a different mix of 

uses and protections. FEIS Chapter 3, Topics outlined above in Response 146.1 

provide disclosure of effects of motorized recreation on ecosystem values and 

wildlife. The Record of Decision explains why Alternative 7 was selected given 

its’ relative effects on ecosystem values and wildlife. 

146.3 With respect to winter recreation. 

 Response 146.3: See Response 146.2 

146.4 With respect to scenic quality. 

 Response: FEIS Chapter 3, Topic 4, Scenery Management includes a display of 

differences between the 7 Alternatives with regard to scenic integrity. 

146.5 With respect to ecosystem protection. 

 Response: See Response 146.1 

147. The Wasatch-Cache National Forest should compare the alternatives with 

respect to risk of uncharacteristic wildfire, insects, and disease. 

 Response: FEIS Chapter 3, Topic 2, Vegetation under the headings “Effects on 

Vegetation Communities from Fire Management” and “Effects on Vegetation 

Communities from Insects, Disease, and Noxious Weeds” provide an improved 

discussion of the effects of the 7 Alternatives with respect to these topics. FEIS 

Appendix B-1 includes a discussion of vegetation modeling used to compare results 

of alternatives on factors influencing wildfire, insects, and disease. 

148. The Wasatch-Cache National Forest should provide resource outputs for each 

alternative. 

 Response: The DEIS clearly displayed outputs in DEIS Chapter 2, Comparison of 

Alternatives, Table 2-2. Again, in FEIS Chapter 2, Comparison of Alternatives, 

Table 2-2 shows projections of outputs for each alternative. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 62 

149. The Wasatch-Cache National Forest should compare the alternatives with 

respect to forest health. 

 Response: The best approximation of this comparison is provided in the FEIS, 

Chapter 3, topic 2 vegetation, table VEG-7. 

150. The Wasatch-Cache National Forest should explain why Taylor Canyon is 

better protected under Alternative 5 than under Alternative 6. 

 Response: This question resulted in clarification of the intent of management 

prescriptions for watershed emphasis (3.1 and 3.2). The management prescription 

applied to Taylor Canyon in Alternative 7 protects Taylor Canyon by not allowing 

road construction. 

Suggestions for New Alternatives 

151. The Wasatch-Cache National Forest should evaluate new alternatives. 

The CUFF Alternative.

 Response: We believe within the range of the 7 Alternatives presented in this 

FEIS, most of the CUFF Alternative components are included and analyzed. 

Alternative 5 includes the suggested prescriptions for suitable timber that ignore 

inventoried roadless areas and allow range and timber production on the same areas. 

Alternatives 2-7 allow timber harvest in prescription category 8. All Alternatives 

make varying degrees of use of prescription 3.2 and 5.1, which are similar to the 

CUFF suggested 5.3. Concerns about big game winter range are addressed through 

both management prescriptions 3.2 and through winter recreation mapping. Visual 

Quality is addressed in all Alternatives through the Scenery Management System. 

The exception is that none of the 7 Alternatives allow for summer cross-country 

motorized travel (CUFF prescription 4.3.1). In the State of Utah, summer 

motorized travel is legal only on routes and areas designated as such. 

151.1 The Balanced Alternative (Alternative 7). 

 Response: We believe within the range of the 7 Alternatives presented in this 

FEIS, the Balanced Alternative components are included and analyzed. Some are 

adopted in Alternative 7. Since the Balanced Alternative starts with Alternative 5 

and adjusts it to incorporate aspects of other Alternatives (such as the commercial 

timber harvest more like Alternative 4, grazing at current levels like Alternative 3, 

watershed protection that is more like Alternative 6, and winter motorized area 

similar to the current Travel Plan for Logan Ranger District like in Alternative 3), 

the analysis has provided for disclosure of effects similar to those of the Balanced 

Alternative. Increased potential for summer motorized trails on the east half of the 

Bear River Range is incorporated into Alternative 7 through management 

prescriptions that allow new trail construction as well as clarification of the 

relationship between ROS and future Travel Management Planning. Alternative 3 

applies the suggested 5.1/6.1 Prescription to the Gibson and Swan Creek IRA’s. 

Portions of the specific suggestions for the Mount Naomi IRA are encompassed by 

the 7 Alternatives in the FEIS however none are exactly as suggested. Alternative 7 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 63 

uses 2.6 rather than the suggested 3.1, providing additional protection of watershed 

and roadless area values. Alternative 3 uses 6.1 for a portion though not all of the 

area consistent with this suggestion. Alternative 3 applies a 3.2 rather than the 

suggested 3.1 to Mount Logan North IRA but these prescriptions have identical 

allowed activities in this Alternative. Alternatives 2, 3, 6, and 7 apply the suggested 

3.2 to the Mount Logan West IRA. Alternatives 2 and 6 apply the suggested 3.1 to 

portions of the Mount Logan South IRA, Alternative 7 applies 3.1 as suggested, and 

Alternatives 3 and 6 apply the suggested 5.1/6.1 to at least part of the remainder of 

these areas although not the entire area. There are a very large number of 

combinations of alternative prescription arrangements possible. The range of the 7 

Alternatives analyzed in the FEIS provides for disclosure of the spectrum, although 

not all potential prescription combinations, of options for each roadless area. 

151.2 To create a travel plan alternative. 

 Response: The FEIS includes a range of reasonable alternatives developed in 

response to issues and public comments on Forest Plan revision. Travel 

Management Planning is recognized as an important component of forest 

management and existing Travel Management Plans were assumed to be adequate 

as a baseline for summer travel opportunities in all Alternatives. The Revised 

Forest Plan includes an Objective to address needs for inventorying current trail 

opportunities and completing a roads analysis for maintenance levels 1 and 2 roads 

as well as updating the Salt Lake, Ogden, and Logan Ranger District summer 

Travel Management Plans. Reasons for not analyzing site-specific Travel 

Management decisions within Forest Plan revision analysis are explained in FEIS 

Chapter 2 under the heading “Alternatives Considered But Not Analyzed in Detail.” 

152. The Wasatch-Cache National Forest should create a combined alternative of 1, 

2, and 6, with overall zoning closer to Alternative 1 to ensure appropriate 

wilderness protection. 

 Response: We believe the range of 7 Alternatives analyzed in this FEIS provides 

for a reasonable number of examples covering the full spectrum of options for 

wilderness protection. 

Alternatives Considered in Detail 

Alternative 1 

Select Alternative 1 

153. The Wasatch-Cache National Forest should select Alternative 1 

153.1 Because it emphasizes wilderness protection 

153.2 Because it protects habitat 

153.3 Because it reduces motorized recreation 

153.4 Because it preserves recreational opportunities 

153.5 Because it protects the environment 

153.6 Because it prohibits other development
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 64 

 Response: Thank you for expressing your views on this Alternative. All views 

were carefully considered during development and evaluation of the existing 

Alternatives. 

154. The Wasatch-Cache National Forest should select Alternative 1 as the 

Preferred Alternative. 

 Response: See Response 153. 

Do Not Select Alternative 1 

155. The Wasatch-Cache National Forest should not select Alternative 1. 

155.1 Because it restricts recreational opportunity 

155.2 Because it promotes wilderness above other uses 

155.3 Because it restricts use 

155.4 Because it harms wildlife habitat

 Response: See Response 153. 

Modify Alternative 1 

156. The Wasatch-Cache National Forest should modify Alternative 1. 

156.1 To allow management

 Response: We agreed that Alternative 1 should be clarified to include active 

rehabilitation of areas damaged by recreation or other uses. The description of this 

Alternative in FEIS Chapter 2 has been modified and effects of this Alternative 

discussed in FEIS Chapter 3 have been adjusted accordingly. 

156.2 To allow heli-skiing 

 Response: There is an infinite combination of Alternative elements possible. The 

FEIS includes 7 Alternatives, 4 of which allow heli-skiing. Given the extent of 

recommended wilderness in the Central Wasatch for Alternative 1, the addition of 

heli-skiing to this alternative would be incompatible. 

Alternative 2 

Select Alternative 2 

157. The Wasatch-Cache National Forest should select Alternative 2 

157.1 Because it is a fair compromise 

157.2 Because it preserves the land 

157.3 Because it protects the environment 

157.4 Because it has the least impact on air quality 

157.5 Because there are already enough roads on the forest

 Response: See Response 153. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 65 

Do Not Select Alternative 2 

158. The Wasatch-Cache National Forest should not select Alternative 2. 

158.1 Because it restricts recreational opportunities 

158.2 Because it promotes wilderness above other use 

158.3 Because it harms wildlife habitat

 Response: See Response 153. 

Modify Alternative 2 

159. The Wasatch-Cache National Forest should modify Alternative 2 to address 

motorized uses of the forest. 

 Response: There is an infinite combination of Alternative elements possible. The 

FEIS includes 7 Alternatives, each with different approaches to motorized uses. 

We believe the range of 7 Alternatives analyzed in this FEIS provides for a 

reasonable number of examples covering the full spectrum of options for motorized 

uses of the forest. 

Alternative 3 

Select Alternative 3 

160. The Wasatch-Cache National Forest should select Alternative 3 because it is 

well balanced 

 Response: See Response 153. 

161. The Wasatch-Cache National Forest should select Alternative 3 as the 

Preferred Alternative. 

 Response: See Response 153. 

Do Not Select Alternative 3 

162. The Wasatch-Cache National Forest should not select Alternative 3. 

 Response: See Response 153. 

Alternative 4 

Select Alternative 4 

163. The Wasatch-Cache National Forest should select Alternative 4. 

163.1 Because it maintains existing uses 

163.2 Because it is a fair compromise

 Response: See Response 153. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 66 

Alternative 5 

Select Alternative 5 

164. The Wasatch-Cache National Forest should select Alternative 5. 

164.1 Because it is well balanced 

164.2 Because it has wide public support 

164.3 Because it preserves recreational access 

164.4 Because it allows active management 

164.5 Because it allows local control 

164.6 Because it maintains existing uses 

164.7 Because it allows for conversion of natural resources into commodities 

164.8 Because it allows needed flexibility in timber management 

164.9 Because it preserves social values 

164.10 Because more wilderness is not needed 

164.11 Because it will allow ski area expansion 

164.12 As long as it does not interfere with the growth of vegetation

 Response: See Response 153. 

165. The Wasatch-Cache National Forest should select Alternative 5 as the 

Preferred Alternative. 

 Response: See Response 153. 

Do Not Select Alternative 5 

166. The Wasatch-Cache National Forest should not select Alternative 5. 

166.1 Because it allows too much off-road vehicle abuse 

166.2 Because it allows too much development

 Response: See Response 153. 

Modify Alternative 5 

167. The Wasatch-Cache National Forest should modify Alternative 5. 

167.1 To add the big game closure between Little Bear/Logan Canyon Face 

and Right hand Fork 

167.2 To reduce timber harvest outputs 

167.3 To more adequately address extractive activities, restoration, and 

monitoring 

167.4 To coincide with the travel plan

 Response: The range of Alternatives analyzed in this FEIS includes each of the 

suggested components. Since there are an infinite number of combinations of 

alternative elements that could be analyzed, the FEIS includes a spectrum to 

disclose the differences in potential effects. Alternative 7 was developed with 

careful consideration of suggestions for modifications to the 6 Alternatives 

presented in the DEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 67 

Alternative 6, The Preferred Alternative 

Select Alternative 6 

168. The Wasatch-Cache National Forest should select Alternative 6. 

168.1 Because it is a fair compromise 

168.2 Because it protects recreational opportunities 

168.3 Because it preserves heli-skiing 

168.4 Because it protects the environment

 Response: See Response 153 

Do Not Select Alternative 6 

169. The Wasatch-Cache National Forest should not select Alternative 6. 

169.1 Because it will reduce funding 

169.2 Because it will reduce motorized recreation opportunities 

169.3 Because it will reduce timber harvesting 

169.4 Because it leans too far toward extreme preservation

 Response: See Response 153 

Modify Alternative 6 

170. The Wasatch-Cache National Forest should modify Alternative 6. 

 170.1 To more adequately protect the environment 

 170.2 To protect wildlife corridors 

 170.3 To protect Canadian lynx habitat 

 170.4 To address carbon sequestration 

 170.5 To increase recommended wilderness 

 170.6 To include the High Uinta Roadless Area in proposed wilderness 

designations 

 170.7 To preserve motorized recreation opportunities 

 170.8 To address recreational conflicts 

 170.9 To create less restrictions

 Response: See Response 167. 

Forest Plan Direction 

Management Prescription Categories 

Management Prescription Category Allocations General 

171. The Wasatch-Cache National Forest should provide a more equitable 

distribution of acres by management prescription categories. 

 Response: The seven alternatives in the FEIS provide a range of management 

prescription category distributions across the landscapes of the WCNF. The 

prescriptions were mapped based on both the capabilitiy and sensitivity of the land 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 68 

and the approach of the particular alternative toward resolving the issues identified. 

See Table 2-1 in FEIS Chapter 2 Comparison of Alternatives to review the range of 

prescription assignments. 

172. The Wasatch-Cache National Forest should allocate acreage in inverse 

proportion to the degree of impact of each activity using a rating scale based 

on impacts. 

 Response: Alternative 1 provides a distribution of management prescriptions that 

comes closest to accomplishing this suggestion since it places the most acres under 

the most restrictive prescriptions. See Comparison of Alternatives, FEIS Chapter 2. 

173. The Wasatch-Cache National Forest should default to Management 

Prescription Categories 5.1/6.1 in roadless areas. 

 Response: Prescriptions were mapped for each alternative based on the capabilities 

and sensitivities of the land along with the approach of the particular alternative for 

resolving the identified issues. Alternative 3 has the highest acreage of these 

prescriptions although it does not specifically target roadless areas. Acres of 

Prescriptions applied to each roadless area are displayed in FEIS Appendix C2. 

 

174. The Wasatch-Cache National Forest should designate more areas to 

Management Prescription Category 1.5 or 2.6 to protect values associated with 

undeveloped areas. 

 Response: Alternative 1 is the alternative that prescribes 1.5 and 2.6 for the most 

acreage of any alternative and effects of this are disclosed in Chapter 3 of the FEIS. 

175. The Wasatch-Cache National Forest should apply the protections of 

Management Prescription Category 3.0 to all areas of the forest to protect 

habitats and watersheds. 

 Response: Prescriptions were mapped for each alternative based on the capabilities 

and sensitivities of the land along with the approach of the particular alternative for 

resolving the identified issues. Alternatives 6 and 7 apply 3 prescriptions to the 

most acres among the alternatives presented in the FEIS and effects of these are 

disclosed in FEIS Chapter 3. To apply these prescriptions to the entire forest would 

not provide for resolution of some of the issues identified and therefore an 

alternative that did this was not analyzed in detail. Emphasis of other prescriptions 

was needed to provide a balance across the Forest. 

176. The final Forest Plan should clarify that the AHWE management prescription 

category does not apply to private inholdings. 

 Response: The Revised Forest Plan management prescriptions do not apply to 

private inholdings. Non-National Forest lands are shown in gray on maps and 

discussed under management prescription 7 in the Revised Forest Plan. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 69 

Modifications to Management Prescription Categories 

177. The final Forest Plan should eliminate the differential management 

prescription category activities permitted in inventoried roadless versus nonroadless areas. 

 Response: Alternative 7 does this. 

178. The Wasatch-Cache National Forest should adjust allowed motorized activities 

in different management prescription categories. 

 Response: Although some of the prescriptions that are focused on recreation do 

have a motorized or non-motorized emphasis, the majority of this is determined and 

displayed based on Travel Mangement Plans, and Recreation Opportunity Class 

Mapping for both winter and summer. The prescription maps do not address 

motorized/non-motorized activities. 

179. The Wasatch-Cache National Forest should prohibit grazing in Management 

Prescription Category 3 where there is a gross negative impact. 

Response 179: Capability and Suitability for livestock grazing is based on criteria 

described in FEIS Appendix B9. The only Prescription that inherently is classified 

as not suited for livestock grazing is 2.4 Research Natural Areas. Specific areas of 

land that are in unsatisfactory condition were removed from the suitable for grazing 

land base in Alternatives 1,2,6, and 7. These lands occur in Prescription Category 3 

as well as other prescriptions so there was no way to tie suitability based on this 

criterion directly to a Prescription Category. The remainder of the Allotments in 

which these unsatisfactory condition lands occur is still classified as suitable for 

livestock grazing. 

180. The Wasatch-Cache National Forest should omit the word “generally” from 

Management Prescription Category 4.2. with regard to non-motorized emphasis. 

 Response: This has been done. 

181. The Wasatch-Cache National Forest should clarify what is permitted under 

management prescription categories. 

 Response: In the Revised Forest Plan, Chapter 4.A.5 Management Prescriptions 

have been edited for clarity and Standards and Guidelines have been added to 

clarify the intentions for each of the allowed activities. 

182. The Wasatch-Cache National Forest should redefine Management Prescription 

Categories 3.1 and 3.2. 

 Response: The request to redefine these Categories so that they prohibit road 

construction, motorized recreation, and recreational development is already 

displayed and analyzed in the FEIS in Alternatives 1,2,3, and 6. In Alternative 7, 

Category 3 Prescriptions have been further subdivided to include areas where these 

activities are allowed and not allowed. See FEIS Chapter 2 Alternatives and 

Allowed Activities Tables. 

 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 70 

183. The Wasatch-Cache National Forest should clarify the status of Management 

Prescription Category 7.0. 

 Response: The status of Prescription Category 7 is explained and clarified in the 

Revised Forest Plan Chapter 4.A.5. 

184. The Wasatch-Cache National Forest should define the difference between 

Management Prescription Categories 2.6 and 4.1. 

 Response: The Revised Forest Plan provides descriptions of these Prescription 

Categories in Chapter 4.A.5. Key differences are now highlighted with standards 

and guidelines. 2.6 does not allow vegetation/fuel treatments nor new trail 

construction, but does allow summer motorized recreation on designated routes 

while 4.1 does allow vegetation/fuel treatment, and new trail construction, but does 

not allow summer motorized recreation. 

Management Prescription Category Allocations – Roadless/Proposed Wilderness 

Areas 

185. The Wasatch-Cache National Forest should assign more protective 

management prescription categories to all roadless acres. 

185.1 By utilizing Management Prescription Category 2.6 

185.2 By utilizing Management Prescription Categories 1.5 or 2.6. 

185.3 By utilizing Management Prescription Categories 2.4-2.7 

185.4 By utilizing Management Prescription Categories 2.6 or 4.1

 Response: FEIS Chapter 3, Topic 5, under the heading “Management Prescriptions 

and effects on roadless values” provides an evaluation of the degree to which 

roadless areas are protected by alternative through assignment of Prescription 

Categories- see Table RW-9. The range of alternatives evaluated each provide 

varying degrees of protection. 

186. The Wasatch-Cache National Forest should use non-timber yielding 

management prescription categories in roadless areas. 

 Response: Alternatives 1,2, and 6 do not allow timber harvest in roadless areas. 

Management Prescription Category Allocations – Site-Specific Requests 

Cache Box Elder Management Area 

187. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for Water Canyon to Management Prescription 

Category 1.5. 

 Response: See response 188. 

188. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for Green Canyon to Management Prescription 

Category 1.1 or 1.2 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 71 

 Response: Alternative 1 places the 1.5 prescription in Green Canyon (except the 

canyon bottom which is not qualified for Wilderness because of water 

development). Categories 1.1 and 1.2 are only applied to already Congressionally 

designated wildernesses not areas being recommended. 

189. The Wasatch-Cache National Forest should change the boundary of 

Management Prescription Category 4.3 in Green Canyon. 

 Response: The boundary of this prescription was placed specifically to incorporate 

the recreational uses there now with the remainder of the area emphasizing 

watershed (3.1). Should the proposed development take place in the mouth of the 

canyon and dispersed camping discontinued in the upper portion, the prescription 

map could be changed and the Forest Plan amended to reflect that site-specific 

decision. 

 

190. The Wasatch-Cache National Forest should change the proposed management 

prescription categories in Mount Naomi Wilderness to Management 

Prescription Category 1.1 

 Response: Category 1.1 is by definition an “unmodified natural environment”. 

Alternatives 1,2,3, and 5 show all areas within Mount Naomi Wilderness except 

existing trails (which cannot qualify as 1.1) as a 1.1 Prescription. 

 

191. The Wasatch-Cache National Forest should change management direction for 

the Mount Naomi Inventoried Roadless Area. 

 Response: Portions of the specific suggestions for this IRA are encompassed by 

the 7 Alternatives in the FEIS however none are exactly as suggested. Alternative 7 

uses 2.6 rather than the suggested 3.1, providing additional protection of not only 

watershed but roadless area values. Alternative 3 uses 6.1 for a portion though not 

all of the area consistent with this suggestion. There are an very large number of 

combinations of alternative prescription arrangements possible. The range of the 7 

Alternatives analyzed in the FEIS provides for disclosure of the spectrum, although 

not all potential prescription combinations, of options for this roadless area. 

192. The Wasatch-Cache National Forest should implement proposed management 

prescription categories for the Mount Naomi area by Utilizing Management 

Prescription Category 2.6 

 Response: Alternative 7 does this. 

193. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for the Mount Naomi area. 

193.1 To Management Prescription Category 1.5 

193.2 To Management Prescription Category 4.1

 Response: Alternatives 1,4, and 3 apply these Prescriptions and disclose the effects 

of this on the Mount Naomi roadless area. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 72 

194. The Wasatch-Cache National Forest should adopt the management 

prescription categories proposed in Alternative 1 for the Logan Canyon and 

Mount Naomi areas. 

 Response: See Response 153. 

195. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for the area surrounding White Pine Lake to 

Management Prescription Category 1.5 

 Response: Alternative 1 does this and discloses the effects. 

196. The Wasatch-Cache National Forest should change management direction for 

the Gibson Inventoried Roadless Area. 

 Response: Alternative 3 applies the suggested 5.1/6.1 Prescription to this area. 

This allows for the suggested roading, timber harvest, and trail construction. All 

alternatives allow for road reconstruction/realignment to reduce resource impacts. 

Suggestions about future motorized routes in this area can be considered during 

Travel Management Plan updates. See the Revised Forest Plan Chapter 4.A.6 for a 

discussion of the relationship between Recreation Opportunity Class mapping and 

Travel Management Planning. 

197. The Wasatch-Cache National Forest should change management direction for 

the Temple Peak Inventoried Roadless Area. 

 Response: Alternative 5 applies the suggested 5.2/6.2 Prescription to this area. 

This allows for the suggested roading, timber harvest, and trail construction. All 

alternatives allow for road reconstruction/realignment to reduce resource impacts. 

Suggestions about future motorized routes in this area can be considered during 

Travel Management Plan updates. See the Revised Forest Plan Chapter 4.A.6 for a 

discussion of the relationship between Recreation Opportunity Class mapping and 

Travel Management Planning. The suggestion for winter motorized is displayed in 

Alternative 3.

198. The Wasatch-Cache National Forest should change management direction for 

the Right Hand Fork Logan Inventoried Roadless Area. 

 Response: Alternative 3 applies the suggested 5.1/6.1 Prescription to this area, 

which also allows for the suggested roading, timber harvest, and trail construction. 

All alternatives allow for road reconstruction/realignment to reduce resource 

impacts. Suggestions about future motorized routes in this area can be considered 

during Travel Management Plan updates. See the Revised Forest Plan Chapter 

4.A.6 for a discussion of the relationship between Recreation Opportunity Class 

mapping and Travel Management Planning. The suggestion for winter motorized is 

displayed in Alternatives 3 and 5. 

199. The Wasatch-Cache National Forest should implement proposed management 

prescription categories in the Mount Logan area by utilizing Management 

Prescription Categories 3.1/3.2 

 Response: Alternative 7 does this. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 73 

200. The Wasatch-Cache National Forest should change management direction for 

the Mount Logan (West) Inventoried Roadless Area. 

 Response: Alternatives 3 and 7 apply the suggested 3.2 Prescription and ROS of 

SPNM; however, neither allows for the suggested timber harvest and roading. 

Alternatives 4 and 5 apply prescriptions that allow these. All alternatives allow for 

road reconstruction/realignment to reduce resource impacts. 

201. The Wasatch-Cache National Forest should change management direction for 

the Mount Logan (South) Inventoried Roadless Area. 

 Response: Alternative 3 applies the suggested 3.2 Prescription and Alternatives 4 

and 5 apply a 6.2 (rather than 5.1/6.1) providing for a spectrum of options in this 

area though not exactly the Prescriptions suggested. This spectrum allows for the 

suggested roading and timber harvest. All alternatives allow for road 

reconstruction/realignment to reduce resource impacts. Suggested ROS is partially 

though not entirely encompasses by Alternatives 5 and 7. New trail construction is 

allowed in Alternatives 7,6,5, and 4. Additional suggestions about future motorized 

routes in this area can be considered during Travel Management Plan updates. See 

the Revised Forest Plan Chapter 4.A.6 for a discussion of the relationship between 

Recreation Opportunity Class mapping and Travel Management Planning. The 

suggestion for winter motorized is displayed in Alternative 3. 

 

202. The Wasatch-Cache National Forest should change the proposed management 

prescription categories in Logan Canyon. 

202.1 To Management Prescription Category 1.5

 Response: Alternatives 1 and 2 display this option for the area. 

202.2 To a 3.x Management Prescription Category 

 Response: None of the Alternatives apply the suggested Prescription to this area 

although the 2.6 Prescription applied in Alternative 7 provides for the watershed 

protection but with less flexibility than a 3.0 Prescription and more than the 1.5 

from which the respondent wanted to see a change. 

203. The Wasatch-Cache National Forest should change management direction for 

the Mahogany Range Inventoried Roadless Area. 

 Response: Alternatives 3,6, and 7 apply the suggested 3.2 Prescription to this area 

however these Alternatives do not allow for the suggested roading and timber 

harvest. Alternatives 4 and 5 apply prescriptions that do allow for these activities. 

All alternatives allow for road reconstruction/realignment to reduce resource 

impacts. None of the Alternatives has this area as SPM for summer but Alternative 

4 does apply Roaded Natural. Suggestions about future motorized routes in this 

area can be considered during Travel Management Plan updates. See the Revised 

Forest Plan Chapter 4.A.6 for a discussion of the relationship between Recreation 

Opportunity Class mapping and Travel Management Planning. The suggested 

Winter Non-motorized class is applied to this area in Alternatives 1,2,6, and7. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 74 

204. The Wasatch-Cache National Forest should change management direction for 

the Boulder Mountain Inventoried Roadless Area. 

 Response: Alternatives 4 and 5 apply the suggested 5.2/6/2 Prescription to this 

area allowing the suggested roading, timber harvest, and new trail construction. All 

alternatives allow for road reconstruction/realignment to reduce resource impacts. 

None of the Alternatives has this entire area as SPM for summer but Alternative 4 

does apply Roaded Natural. Suggestions about future motorized routes in this area 

can be considered during Travel Management Plan updates. See the Revised Forest 

Plan Chapter 4.A.6 for a discussion of the relationship between Recreation 

Opportunity Class mapping and Travel Management Planning. Alternatives 3,4,5,6 

and 7 apply the suggested Winter Motorized class to this area. 

205. The Wasatch-Cache National Forest should implement proposed management 

prescription categories south of Hardware Ranch. 

205.1 By utilizing Management Prescription Category 2.4 

205.2 By utilizing Management Prescription Category 3.1/3.2

 Response: Thank you for expressing your views in support of these Prescriptions 

applied in this area in DEIS Alternative 6. All views were carefully considered 

during development and evaluation of the existing Alternatives. 

206. The Wasatch-Cache National Forest should implement proposed management 

prescription categories in the Wellsville Mountains by utilizing Management 

Prescription Category 3.2. 

 Response: Thank you for expressing your views in support of this Prescription 

applied to this area in DEIS Alternative 6. All views were carefully considered 

during development and evaluation of the existing Alternatives. 

207. The Wasatch-Cache National Forest should change the proposed management 

prescription categories in the Wellsville Mountains to Management 

Prescription Category 1.5 

 Response: Alternative 1 applies Prescription 1.5 to the suggested parcel at the 

northern end of the Wellsville Mountains. Either this or the 3.2 applied in other 

alternatives can provide needed spring protection for wildlife. 

208. The Wasatch-Cache National Forest should implement proposed management 

prescription categories for the Northern Central Bear River Range by utilizing 

Management Prescription Category 3.2 

 Response: Thank you for expressing your views in support of this Prescription 

applied to this area in DEIS Alternative 6. All views were carefully considered 

during evaluation of the existing Alternatives and development of Alternative 7. 

209. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for the Northern Central Bear River Range to 

Management Prescription Categories 3.1 and 2.1-2.3 

 Response: FEIS Alternative 7 applies Prescription 3.1A to all streams with known 

populations of Bonneville Cutthroat Trout. Suggested Prescriptions 2.1-2.3 have 

not been applied to the Wasatch-Cache National Forest at this time because no 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 75 

suitability determination has been completed for Wild and Scenic River 

designation. Beaver Creek was found eligible in the inventory but until such time 

as a suitability analysis is completed, the Wild and Scenic Prescriptions will not be 

applied. 

210. The Wasatch-Cache National Forest should implement proposed management 

prescription categories on the Mid Bear River Range. 

210.1 By utilizing Management Prescription Category 3.1/3.2 

210.2 By utilizing Management Prescription Category 2.5

 Response: Thank you for expressing your views in support of these Prescriptions 

applied to these areas in DEIS Alternative 6. All views were carefully considered 

during evaluation of the existing Alternatives and development of Alternative 7. 

211. The Wasatch-Cache National Forest should change the proposed management 

prescription categories on the Mid Bear River Range to Management 

Prescription Category 3.1/3.2. 

 Response: Alternative 2 applies the suggested Prescriptions to this area displaying 

the effects of this option in the FEIS. 

212. The Wasatch-Cache National Forest should change the proposed management 

prescription categories in Dry Canyon to Management Prescription Category 

1.5. 

 Response: None of the Alternatives applies a 1.5 Prescription to the Mount Logan 

North Roadless Area. Alternative 1 was developed to reflect one end of the 

spectrum of wilderness recommendations but even it does not recommend all 

roadless areas. Given the existing motorized road and trail intrusions in this area as 

well as the proximity of the already designated Mt. Naomi and Wellsville Mountain 

Wildernesses, this area was not included in the range of alternatives. 

213. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for the Mount Watson area to Management 

Prescription Category 1.5. 

 Response: Alternatives 1 and 2 apply Prescription 1.5 to this area displaying the 

effects of this option in the FEIS. 

North Wasatch Ogden Valley Management Area 

214. The Wasatch-Cache National Forest should implement proposed management 

prescription categories for the Upper South Fork Ogden River to Management 

Prescription Category 1.5. 

 Response: See Response 208. 

215. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for Upper South Fork Ogden River to Management 

Prescription Category 1.5. 

 Response: See Response 208. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 76 

216. The Wasatch-Cache National Forest should change the management 

prescription category in the Burch Creek area to Management Prescription 

Category 4.2 or 4.5. 

 Response: Alternative 5 applies Prescription 4.4 which allows new recreation 

development such as the suggested gondola. 

217. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for the Francis Inventoried Roadless Area to 

Management Prescription Category 2.6. 

 Response: Alternative 2 applies this prescription to the area and displays the 

effects of this option in the FEIS. 

218. The Wasatch-Cache National Forest should change the management 

prescription category in the Wheeler Creek area. 

218.1 To Management Prescription Category 2.6

 Response: Alternative 7 applies Prescription 3.1W to this area. Prescription 3.1W 

does not allow road construction or recreation development regardless of whether 

the area is inventoried roadless. 

218.2 To Management Prescription Categories 3.1/3.2 

 Response: The sliver of Prescription 4.5 along the old Snow Basin Road which 

was of concern to this respondent has been removed in Alternative 7 and the 

suggested Prescription 3.1 applied to this area. 

219. The Wasatch-Cache National Forest should change the management 

prescription category in the Morgan/Davis county line area to Management 

Prescription Category 2.6. 

 Response: Alternative 2 applies the suggested prescription. Concern about 

motorized uses in the area, both summer and winter is better addressed with 

Recreation mapping rather than Prescription Categories. 

Central Wasatch/Tri-Canyon Area 

220. The Wasatch-Cache National Forest should implement proposed management 

prescription categories in the Tri-Canyon area by utilizing Management 

Prescription Category 4.5 

 Response: Thank you for expressing your views in support of this Prescription 

applied to this area in DEIS Alternative 6. All views were carefully considered 

during evaluation of the existing Alternatives and development of Alternative 7. 

 

221. The Wasatch-Cache National Forest should change management prescription 

categories in the Tri-Canyon area. 

221.1 To Management Prescription Category 1.5

 Response: Alternatives 1 and 2 do this and display the effects of this option in the 

FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 77 

221.2 To Management Prescription Category 2.6 

 Response: Alternative 2 applies a 2.7 Prescription to this area with very similar 

effects to a 2.6 application although the specific direction to protect the Special 

Area (2.7) values would still need to be developed under this Alternative 

221.2 To Management prescription Category 4.5 

 Response: As suggested, all Alternatives apply Prescription 4.5 to the existing ski 

area permit boundaries. 

222. The Wasatch-Cache National Forest should reassess its designation for Little 

Cottonwood Creek. 

 Response: The Management Prescription applied to Little Cottonwood Creek is 3.1 

in Alternatives 1-6 and 3.1A in Alternative 7 emphasizing aquatic habitat and 

watershed values. All management prescriptions in the Revised Forest Plan apply 

ONLY to National Forest System lands. Private and other ownerships are shown in 

gray on maps and are clearly outside the jurisdiction of the Forest Service and the 

Forest Plan. 

 

223. The Wasatch-Cache National Forest should change management prescription 

categories for Mount Aire.3 

223.1 To Management Prescription Category 1.5

 Response: Alternative 1 applies the suggested Prescription 1.5 to this area and 

displays the effects of this option in the FEIS. 

223.2 To Management Prescription Category 4.1 

 Response: Alternative 3 applies the suggested Prescription 4.1 to this area and 

displays the effects of this option in the FEIS. 

224. The Wasatch-Cache National Forest should implement the proposed 

management prescription category for Cardiff Fork, Big Cottonwood Canyon 

by utilizing Management Prescription Category 4.1. 

 Response: Alternative 3 applies the suggested Prescription 4.1 to this area and 

displays the effects of this option in the FEIS, however concerns about motorized 

recreation are not completely addressed by Prescriptions. The Recreation 

Opportunity Maps (both summer and winter) and Travel Management Plans 

provide direction for recreation and access. The word “generally” has been 

removed from the description of Prescription 4.2 in reference to non-motorized 

designation. 

225. The Wasatch-Cache National Forest should change management prescription 

categories for White Pine Canyon to Management Prescription Category 4.5. 

 Response: Alternative 5 applies the suggested prescription to this area. Other 

Alternatives applying Prescription 4.1 do not allow new recreation development but 

do allow new trail construction which might allow for limited expansion of the 

adjacent ski area. Alternative 7 applies prescription 2.6 which does not allow either 

new recreation development or new trail construction. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 78 

226. The Wasatch-Cache National Forest should change management prescription 

categories for Mill D North Trail to Management Prescription Category 2.6. 

 Response: To provide the watershed protection emphasis you stated, we have 

identified this area as 3.1W for watershed emphasis. This better fits your concern 

than a 2.6 management prescription.

227. The Wasatch-Cache National Forest should change the management 

prescription category in east Mill D North to 2.6 to accommodate continued 

mountain bike access. 

 Response: All Alternatives with the exception of Alternative 1 allow mountain 

bike access in this area. 

Bear Management Area 

228. The Wasatch-Cache National Forest should change management direction for 

the Swan Creek Inventoried Roadless Area. 

 Response: Alternatives 4 and 5 apply the suggested 5.2/6.2 Prescriptions to this 

area, which also allows for the suggested roading, timber harvest, and trail 

construction. All alternatives allow for road reconstruction/realignment to reduce 

resource impacts. Alternative 5 also applies the suggested Summer ROS SPM and 

Winter Motorized Classes for the area. Suggestions about future motorized routes 

in this area can be considered during Travel Management Plan updates. See the 

Revised Forest Plan Chapter 4.A.6 for a discussion of the relationship between 

Recreation Opportunity Class mapping and Travel Management Planning. 

229. The Wasatch-Cache National Forest should implement the proposed 

management prescription categories in Garden City Canyon by utilizing 

Management Prescription Category 3.2. 

 Response: Thank you for expressing your views in support of this Prescription 

applied to this area in DEIS Alternative 6. All views were carefully considered 

during evaluation of the existing Alternatives and development of the Alternative 7. 

230. The Wasatch-Cache National Forest should change the proposed management 

prescription categories for Garden City Canyon to Management Prescription 

Category 2.7. 

 Response: Without a specific set of reasons why this Canyon should be designated 

a Special Interest Area, the 7 Alternatives do not include this Prescription applied to 

this area. Alternative 1 does apply Prescription 2.6 which has maximum protection 

for the area short of wilderness designation. 

231. The Wasatch-Cache National Forest should implement the proposed 

management prescription categories near Bear Lake Overlake to Management 

Prescription Category 2.5. 

 Response: See Response 229. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 79 

232. The Wasatch-Cache National Forest should implement the proposed 

management prescription categories south of Highway 89 by utilizing 

Management Prescription Category 5.1. 

 Response: See Response 229. 

Stansbury Mountains 

233. The Wasatch-Cache National Forest should change the management 

prescription category on lands north and south of the existing Deseret Peak 

Wilderness to Management prescription Category 1.5. 

Response: Alternatives 1 and 2 apply the suggested Prescription to this area and 

display the effects of this option in the FEIS. 

Uinta Mountains 

234. The Wasatch-Cache National Forest should change the management 

prescription category in the Uinta Mountains 

234.1 To Management Prescription Category 1.5. 

 Response: Alternative 1 applies the suggested Prescription to most of the area and 

Alternative 2 applies it to some of the area with both of these Alternatives 

displaying the effects of these options in the FEIS. 

234.2 To Management Prescription Categories 2.6 or 4.1 

 Response: Alternatives 2,3,and to a lesser degree 6 and 7 apply these Prescriptions 

to parts (mainly upper adjacent to existing Wilderness) but not all of the suggested 

area down to the trailheads. Alternative 2 provides the best display of effects of this 

option in the FEIS. 

235. The Wasatch-Cache National Forest should change the management 

prescription category in the Lakes backcountry to Management Prescription 

Category 1.5. 

 Response: Alternative 1 applies the suggested Prescription to all and Alternative 2 

to most of the area and effects are displayed in the FEIS. 

236. The Wasatch-Cache National Forest should change the management 

prescription category for Boundary Creek to Management Prescription 

Category 1.5. 

 Response: Alternative 1 applies the suggested Prescription to this area and 

displays the effects of this option in the FEIS. 

237. The Wasatch-Cache National Forest should change the management 

prescription category in Middle Fork Blacks Fork to Management 

Prescription Category 1.5. 

 Response: See Response 236. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 80 

238. The Wasatch-Cache National Forest should change the management 

prescription category in Hayden Fork and Upper Main Fork to Management 

Prescription Category 1.5. 

 Response: See Response 236. 

239. The Wasatch-Cache National Forest should change the management 

prescription category for Black’s Fork and Henry’s Fork to Management 

Prescription Category 1.5. 

Response: The boundaries of the 1.5 Prescription for these two areas were drawn 

based on the inventoried roadless area boundary that excludes existing roads. 

Recreation Opportunity Spectrum 

Recreation Opportunity Spectrum General 

240. The Wasatch-Cache National Forest should explain how roadless areas can 

include roaded natural, rural, and urban Recreation Opportunity Spectrum 

categories. 

Response: See appendix B-6 for definitions of the physical setting and the criteria 

used to establish evidence of humans, size, and remoteness. In some instances the 

remoteness or size criteria will delineate ROS categories that overlap inventoried 

roadless areas because of a buffer from an adjacent motorized road. In these cases 

the user experience is being affected by the adjacent activities such as motorized 

use or communities. 

241. The Wasatch-Cache National Forest should add more semi-primitive 

motorized areas. Page 3-31, Content Analysis. 

Response: See FEIS, Chapter 2 / Elements Common to All Alternatives / Past 

Decisions Not Being Revisited in Plan Revision / Travel Management Planning, 

“Although this forest plan revision addresses winter motorized use, the designated 

routes open for summer motorized use remain in place consistent with current 

Travel Plans for all alternatives.” Although, ROS categories identify areas on the 

maps it does not mean that the entire area is open to motorized use, it means that an 

area is being affected by motorized use. Motorized use should occur on designated 

motorized travel routes only. 

See Table 12.2 Comparision of Miles of Motorized Travel ways by ROS Category, 

FEIS, Chapter 3 / Topic 4 Recreation and Scenery Management, Environmental 

Consequences, Dispersed Recreation – Summer. 

242. The Wasatch-Cache National Forest should recognize that semi-primitive nonmotorized designations can be impacted by motorized designations on adjacent 

lands from the noise. 

Response: See Appendix B – 6 for remoteness and size criteria. 

Because of the capability of the existing GIS layers available at the time of the 

planning process a standard distance criteria was used for remoteness buffers. The 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 81 

buffer distance was not modified to conform to natural barriers topography and 

vegetative screening, or other relevant features of local topographic relief and 

vegetative cover using GIS for the existing condition mapping. In some 

alternatives, District personnel did make modifications to the buffer based on 

personal knowledge or hard copy mapped data. See appendix B-6 Recreation 

Opportunity Spectrum and Winter Recreation Existing Condition and Alternative 

Mapping Process. Since the beginning of the planning process more updated layers 

have been developed for vegetation, and topography. This information will be 

incorporated into the final selected management direction. 

243. The Wasatch-Cache National Forest should develop four winter recreation 

classes: wilderness, non-motorized, motorized, and motorized heli-ski to allow 

development of more accurate travel plan maps. 

Response: We agree see appendix B–6, Recreation Opportunity Spectrum and 

Winter Recreation Existing Condition and Alternative Mapping Process. 

244. The Wasatch-Cache National Forest should change management prescriptions 

and Recreation Opportunity Spectrum determinations. 

Response: See Appendix B6 ROS process and Appendix B-5 for MPC process. 

244.1 So that managers can manage the current and future demand for 

motorized recreation. 

Response: See FEIS, Chapter 2 / Elements Common to All Alternatives / Past 

Decisions Not Being Revisited in Plan Revision / Travel Management Planning, 

“Although this forest plan revision addresses winter motorized use, the designated 

routes open for summer motorized use remain in place consistent with current 

Travel Plans for all alternatives.” Except for Alternatives 1 and 2 where the 

Roadless rule was applied and motorized routes were affected. Since travel 

management planning did not occur during the plan revision motorized ROS 

classifications where only applied to motorized travel ways. As District Travel 

Management Plans are updated in the upcoming planning period, ROS 

classification may need to be amended to reflect the decision made there. 

244.2 By not using roadless area boundaries for determining Recreation 

Opportunity Spectrum categories. 

Response: Roadless area boundaries were not used to delineate ROS 

classifications in any of the alternatives. In alternatives that applied the roadless 

rule or MPC 1.5 motorized travel ways were converted from SPM to SPNM. If 

adjacent polygons were SPNM, buffer lines created by the SPM were dropped 

creating a larger polygon of SPNM that could seem to appear to follow Roadless 

area boundaries. 

245. The Wasatch-Cache National Forest should address the applicability of the 

Recreation Opportunity Spectrum to mountain biking because mountain 

biking has increased in popularity since the Recreation Opportunity Spectrum 

was created. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 82 

Response: The ROS system was developed in the 1980’s. Nationally the system is 

in the process of being updated to recognize new technologies and their effects on 

the recreation experience. Although, mountain biking trails are identified, (see 

table REC-7) ROS does not add or eliminate mountain biking use on travel ways 

the District travel management plan address mountain bike use on travel ways. 

 

246. The Wasatch-Cache National Forest should clarify Recreation Opportunity 

Spectrum designations in Green Canyon. 

Response: See response to comment 241 and appendix B-6 description of ROS 

process. 

Recreation Opportunity Spectrum – Site-Specific Designations 

247. The Wasatch-Cache National Forest should give some areas a summer 

Recreation Opportunity Spectrum designation of semi-primitive motorized. 

247.1 All Roadless Areas 

247.2 Certain areas in the Logan Ranger District.

Response: All alternatives have areas of SPM, see table REC-11. 

248. The Wasatch-Cache National Forest should reallocate the area north of the 

High Uintas Wilderness to a winter use that is open to over-the-snow vehicles, 

seasonally, from December 1 to May 1. 

Response: For motorized winter recreation the area north of the High Uinta 

Wilderness is considered as open in Alternative 5. See Winter Recreation maps 

Alternative 5. 

249. The Wasatch-Cache National Forest should apply or extend semi-primitive 

motorized corridors to trails. 

Response: See response to comment concern statement 241. 

249.1 For Alternative 1 on the logan Ranger District, Richards Hollow, Seep 

Hollow and Cart Hollow Trails. 

Response: We agree the change has been made to the ROS map of Alternative 1. 

249.2 For Alternative 2 on the Logan Ranger District, Richards Hollow, Seep 

Hollow and Cart Hollow Trails 

Response: We agree the change has been made to the ROS map of Alternative 2. 

249.3 For Alternatives 1, 2, 3, 5, and 6 on the Logan Ranger District, Sink 

Hollow Trail 

Response: We agree the change has been made to the ROS maps of Alternative 1, 

2, 3, 5, and 6 on the Logan Ranger District. 

249.4 For Alternative 1 on the Ogden Ranger District, Skyline Trail from 

North Ogden Pass 

Response: We agree the change has been made to the ROS map of Alternative 1. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 83 

249.5 For Alternative 2 on the Ogden Ranger District, Skyline Trail from 

North Ogden Pass 

Response: We agree the change has been made to the ROS map of Alternative 2. 

249.6 For Alternative 6 on the Ogden Ranger District, Skyline Trail from 

North Ogden Pass, 

Response: We agree the change has been made to the ROS map of Alternative 6. 

Affected Environment 

Environmental Values General 

Management General 

250. The Wasatch-Cache National Forest should effectively manage forest lands. 

250.1 By providing balanced management 

250.2 By managing for the long term 

Response: This plan is focused on managing for the long-term by moving forested 

ecosystems toward properly functioning conditions and maintaining them into the 

future. We feel that a balance between various uses and outcomes has been an 

important factor in the development of this Forest Plan. 

251. The Wasatch-Cache National Forest should preserve natural resources. 

252.1 Before excessive impacts take place 

251.2 While also balancing recreational demands 

251.3 By writing a mission statement which emphasizes protection of 

resources 

Response: We have focused on allowing activities on the Forest, while not 

adversely impacting the natural resources that occur. We have enhanced the public 

education direction in our Forest Plan. 

252. The Wasatch-Cache National Forest should recognize that environmental 

damage is irreversible. 

Response: While some impacts on the forest are irreversible, especially where soil 

loss has occurred or where development of roads and infrastructure are in place, 

other impacts can be mitigated or reversed. The Forest Plan, with its focus on 

properly functioning conditions, and with recommendations for wilderness, Special 

Interest Areas, and Research Natural Area expansions, recognizes the value of the 

resources we manage. 

253. The Wasatch-Cache National Forest should recognize and respond as needed 

to natural ecological changes over given forest landscapes. 

Response: Because of our past management actions, especially fire control, many 

of the ecosystems we manage vary moderately to greatly from historic conditions 

(see Table VEG-2, Topic 2 – Biodiversity and Viability, Vegetation). One of the 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 84 

primary focuses of this plan is to move toward the historic range of variation, so 

that these ecosystems can function in a more natural state. 

254. The Wasatch-Cache National Forest should provide protection to all 

representative natural communities. 

 Response: While most acres in wilderness areas of the Wasatch-Cache National 

Forest protect high elevation ecosystems, many of these areas range in elevation 

and protect a variety of plant communities and wildlife habitat. The Deseret Peak 

Wilderness Area ranges in elevation from near the bottom of Skull Valley up to 

Deseret Peak and includes various varieties of sagebrush as well as pinyon-juniper 

as well as Douglas-fir and limber pine and bristlecone pine. The Wellsville 

Wilderness Area ranges in elevation from near the valley floors in Cache Valley to 

the east and near Brigham City and Honeyville to the west. Juniper, maple, and 

sagebrush communities, as well as Douglas-fir and aspen communities are present. 

This plan proposes one new wilderness area near Causey Reservoir that includes a 

variety of elevations and no alpine areas. In addition, we are including an extension 

of the Morris Creek Research Natural Area east of Farmington, Utah that would 

include oak and mahogany communities at lower elevations, to Douglas-fir, aspen, 

and subalpine fir communities at the upper elevation. The Logan Canyon Special 

Interest Area, which is proposed because of its botanical resources (primarily rare 

plants, but also Douglas-fir, maple and juniper communities). Existing Research 

Natural Areas (Red Butte and Mollens Hollow) are primarily mid- to low-elevation 

ecosystems and provide additional protection. 

255. The Wasatch-Cache National Forest should continue the current forest 

management system because forest health has improved under the current 

plan. 

Response: While some characteristics of the Forest have quite clearly improved, 

some ecosystems are still far from functioning properly. Fire controls, historic 

livestock grazing, and some past timber harvest techniques pushed conditions far 

away from those that occurred historically. This plan focuses on moving more 

closely toward properly functioning conditions. 

256. The Wasatch-Cache National Forest should recognize that roadless areas and 

watersheds are sufficiently protected under the proposed plan. 

Response: We have added new analysis of each roadless area (Appendix C) and 

feel that under this proposed plan that we have focused on varying levels of 

protection and the different values of each roadless area. 

Adequacy of Analysis 

257. The Wasatch-Cache National Forest should clarify its criteria for range and 

watershed condition improvement. 

 Response: The criteria for range improvement (ground cover, desired conditions, 

and rate of improvement) are included in the 1998 Rangeland Health Amendment, 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 85 

which is carried forward in this plan. Because of the various resource values and 

economic effects, Alternative 2, was not chosen as the preferred alternative. 

Funding 

258. The Wasatch-Cache National Forest should not use lack of funding as a 

justification for inadequate resource protection. 

 Response: While inadequate resource protection is undesirable, the Forest cannot 

control the amounts and kinds of funding we receive each year. We are required by 

law to work as funded.

Protection of Specific Areas 

259. The Wasatch-Cache National Forest should protect the Tri-Canyon area to 

preserve solitude. 

Response: Demands on the Tri-Canyon area are indeed intense and diverse. 

Comments on the Draft Preferred Alternative (6) caused us to reexamine the 

management direction developed for this area and to strengthen protection. 

Alternative 7 applies a 3.1w watershed emphasis management prescription to much 

of the non-wilderness, non-ski resort areas of the canyons. This prescription 

includes standards and guidelines that limit activities to protect watersheds which in 

turn provides for wildlife needs. The Revised Plan also has an Objective to 

emphasize education with a focus area on watershed protection so we can engage 

forest users in conserving this resource. The Revised Plan allows no new ski 

resorts and no ski resort boundary expansions during the planning period (10-15 

years). The matter of solitude and human crowding is a difficult one given the 

proximity to the urban population of the Wasatch Front. Recreation opportunity 

classes have been mapped for the area and include semi-primitive non-motorized 

areas. These have user density numbers defined as thresholds. The monitoring 

strategy for these areas is to monitor user densities and when thresholds are 

approached, to initiate a public process for determining whether and how to limit 

user numbers. 

260. The Wasatch-Cache National Forest should protect non-ski area lands in the 

Tri-Canyon area to balance ski resort development. 

Response: See response 259. 

261. The Wasatch-Cache National Forest should protect the Uinta Mountains. 

Response: The FEIS displayed a range of alternatives and their expected 

consequences for the Uinta Mountains. Alternative 7 places management 

prescriptions to allow for some types of uses and development in certain areas while 

protecting other areas from any type of development. Some of the lower elevation 

lands in the Uinta Mountains are managed for timber production and oil and gas 

leasing, much is managed for backcountry recreation uses and wildlife habitat 

protection. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 86 

262. The Wasatch-Cache National Forest should protect the Mount Watson 

wilderness for future generations. 

Response: The range of alternatives considers varying degrees of protection for 

this area. Alternative 7 protects this area through application of management 

prescriptions 1.5 and 2.6 neither of which allow any development. 

263. The Wasatch-Cache National Forest should develop a management plan for 

Millcreek Canyon. 

Response: The Revised Forest Plan puts in place broad management direction 

including mapped management prescriptions, recreation opportunity maps, and a 

desired future condition description for the Central Wasatch Management Area 

which includes Mill Creek Canyon. However, given that the plan must address the 

entire Wasatch-cache National Forest, it does not provide for very detailed and 

specific items for Mill Creek. Such a plan would need to be developed locally and 

that plan could be guided by the direction of the Revised Forest Plan. 

Effects of Activities/Disturbance 

264. The Wasatch-Cache National Forest should prohibit activities that damage the 

environment until it can provide adequate monitoring and enforcement. 

Response: The Revised Forest Plan includes mapping of management prescriptions 

and recreation opportunities. We have tried to draw boundaries that are manageable 

and that take into account limited resources to monitor. In some cases, as we 

implement we may find that boundaries need to be adjusted to improve 

manageability and we can readily do that through amendment of the Plan. The Plan 

also sets Objectives specifically for education and enforcement with focus areas in 

OHV, user ethics, and watershed protection, and an Objective specifically to focus 

on improved management of grazing. These objectives and the desired future 

condition descriptions in the Plan emphasize gaining assistance from organized user 

groups to monitor, add enforcement presence, and improve our ability to educate 

forest users so they can assist in conserving the resources of the Forest. 

265. The Wasatch-Cache National Forest should reduce use levels to minimize 

human impacts. 

Response: Limits on numbers of people using the Forest is not directly decided by 

the Forest Plan. However, given the concerns expressed about this issue, we have 

identified some recreation opportunity classes (semi-primitive) that have user 

density thresholds. When monitoring shows we are approaching these thresholds, 

we will initiate a public process to decide whether and how to limit numbers of 

users in these areas. 

266. The Wasatch-Cache National Forest should prevent littering. 

 Response: While the Forest cannot prevent littering. Environmental education is 

identified under numerous subgoals within the Forest Plan. Litter prevention is one 

component of this broad program.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 87 

Ecosystem/Restoration Management 

Ecosystem/Restoration Management General 

267. The Wasatch-Cache National Forest should preserve public lands in their 

natural state. 

267.1 To prevent costly mitigation 

267.2 For future generations 

267.3 For their intrinsic value 

267.4 For educational values 

Response: An important focus of this Forest Plan is to move ecosystems toward 

properly functioning conditions, while providing various goods and services. As set 

in law, the mission of the Forest Service is to achieve quality land management 

under the sustainable multiple-use management concept, rather than through 

preservation, to meet the diverse needs of people. Timber harvest, where it is 

allowed, will follow best management practices to ensure watershed protection, 

nutrient cycling, and wildlife habitat diversity. Existing and proposed wilderness 

areas will focus on the natural functioning of the ecosystems within them. Existing 

and proposed Research Natural Areas and Special Interest Areas will be available 

for both educational uses and for research to help us understand the functioning of 

their ecosystems. These will benefit existing as well as future generations. 

268. The final Forest Plan should redefine properly functioning ecosystems to 

reflect their dynamic nature and they should reconsider need for vegetation 

treatments. 

Response: We use the Intermountain Region definition of properly functioning as 

it relates to historical range of variation in composition, structure (age class), and 

patterns on the landscape. These systems are dynamic and do not exist in a static 

state. Because of historic management and fire protection, most of the forested and 

non-forested types are skewed more toward the older age classes. And because of 

these factors, an estimated loss of approximately 65 percent of the aspen forests to 

conifer forests has occurred (O’Brien and Pope 1997). It will require a variety of 

tools, such as prescribed fire, wildland fire use, as well as some timber harvest, to 

help these ecosystems move toward the historic range of variation. 

269. The Wasatch-Cache National Forest should not rely on intensive management 

to preserve forest resources. 

 Response: While the proposed plan does allow the use of timber harvest as one 

tool to help move the forested ecosystems of the Wasatch-Cache National Forest, 

other tools such as prescribed fire and wildland fire use will do much more to help 

these ecosystems to move toward properly functioning conditions. As illustrated in 

FEIS Table VEG-3 (Topic 2 – Biodiversity and Viability, Vegetation) only 5 

percent of the acres treated would be treated through the use of timber harvest. 

Nearly 73 percent would be treated through prescribed fire and approximately 22 

percent would be mechanically treated (oak fuels treatment). 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 88 

270. The Wasatch-Cache National Forest should minimize human interference to 

preserve undeveloped lands. 

Response: We agree that one of the biggest existing challenges and one that will 

continue in the future is population growth and its effects on our resources and 

resource conditions. We recognize that humans are a component of these 

ecosystems, and we want to allow activities that sustain healthy resource conditions 

into the future. Therefore levels of use must be managed for this to occur. By 

establishing desired future conditions, goals, subgoals, and objectives we feel that 

we have laid the framework from which future management decisions can address 

these issues. 

271. The Wasatch-Cache National Forest should develop a comprehensive plan for 

ecosystem health and species viability. 

 Response: Guideline 14 in the proposed plan lists, by cover type, the landscape 

structure and patterns of “healthy” or properly functioning conditions. Table VEG4 in FEIS, Chapter 3, Topic 2 – Biodiversity and Viability, Vegetation identifies the 

acres of different vegetations that would be treated through various actions to help 

move these ecosystems toward these desired conditions. See R 269 for additional 

information. 

272. The Wasatch-Cache National Forest should address how land will be protected 

to maintain ecological function. 

 Response: The Forest Plan focuses on moving toward properly functioning 

conditions, which include composition, structure, patterns and function of various 

ecosystems at a broad scale. The means to achieve and maintain ecological 

function are outlined through desired conditions, goals, subgoals, standards, and 

guidelines outlined in the Forest Plan. 

273. The Wasatch-Cache National Forest should consider noise pollution, erosion, 

and safety when protecting ecosystems. 

 Response: We have not addressed noise pollution in this Forest Plan, but 

watershed protection is one of the factors we have addressed through a Watershed 

Health Goal, various subgoals, standards and guidelines. Human safety remains 

foremost in our concerns with users on the Forest. 

274. The Wasatch-Cache National Forest should define the term “ecological 

legacies.” 

 Response: The term “ecological legacies” has been added to the Forest Plan 

glossary. 

Restoration 

275. The Wasatch-Cache National Forest should protect and restore ecological 

integrity. 

275.1 To offset the impacts of development on surrounding lands 

275.2 To ensure clean water, clean air, and temperature management 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 89 

275.3 For their intrinsic value 

275.4 By restoring degraded and damaged areas 

Response: The direction provided in this Forest Plan puts primary focus on 

Properly Functioning Conditions of ecosystems across the Forest. We have taken 

into consideration, actions that occur on adjacent lands (federal, state, private, etc.) 

and viewed the role that this Forest plays in the context of surrounding land uses. 

The plan includes Forestwide direction (desired future conditions, goals and 

subgoals, objectives, and standards and guidelines) on managing the biological 

(plant and animal), physical (soil and water) and social resources that occur on the 

Forest. Restoration is integrated throughout management direction for many 

resources. 

276. The Wasatch-Cache National Forest should aggressively restore the historic 

range of variability. 

 Response: This Forest Plan is focused on movement toward properly functioning 

conditions, which are those within the historic range of variability. 

277. The Wasatch-Cache National Forest should have timber harvest workers 

perform restoration work. 

 Response: Various tools, including timber harvest, prescribed fire, and wildland 

fire use are identified as treatment methods to move various plant communities 

toward properly functioning condition. 

Effects of Activities/Disturbance 

278. The Wasatch-Cache National Forest should allow activities only to the extent 

that they do not impair ecological integrity. 

 Response: The focus of this Forest Plan has been to move the variety of plant 

communities toward properly functioning conditions and to allow activities that 

help achieve, or that do not interfere with reaching, those desired conditions. 

279. The Wasatch-Cache National Forest should recognize that fires, erosion, and 

landslides are normal. 

Response: Historically, fires, erosion and landslides occurred naturally on the 

landscape. However, because of various factors such as fire prevention many 

vegetation cover types have moved from fire condition classes 1 and 2 to condition 

classes 2 and 3, respectively (FEIS, Chapter 3, Topic 10 – Fire Management). 

There has been an increase in fuels to carry fires beyond their historic frequency 

and intensity. And because of increased human access, unnatural fire starts are 

more common. Various uses such as historical overgrazing and various early 

management actions have resulted in accelerated erosion and landslides that are 

outside the historic range of variation. 

Active Management 

280. The Wasatch-Cache National Forest should allow active forest management. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 90 

280.1 To preserve forest health 

280.2 To achieve an increase in water yield 

280.3 To achieve multiple use objectives 

280.4 To address the issue of carbon sequestration 

280.5 To ensure firefighter safety 

Response: Active management is proposed to help improve forest health by 

moving various ecosystems toward properly functioning conditions, including a 

broader array of age class diversity among the different forested types. A result of 

this will likely be an increase in water yield where conifer communities are replaced 

by aspen. This management will allow for a broader compliment of habitat for 

wildlife, forest health, as well as forest products. Forest wide subgoals, and 

guidelines for large or coarse woody materials to provide for habitat and nutrient 

cycling are included in the Plan. More age class diversity within the forested types 

will reduce fire intensity and help to reduce the need for firefighters. 

Multiple Use Management 

Multiple Use Management General 

281. The Wasatch-Cache National Forest should adequately address the impacts of 

multiple use management. 

Response 281: Impacts of multiple use management (specifically motorized uses 

in this comment) are addressed in this FEIS to the degree that they can be for the 

broad land areas and required decisions to be made in Forest Plan revision. The 

FEIS displays broad sets of effects for each resource from each type of use. For 

summer motorized travel, site-specific environmental analysis is needed to change 

current Travel Management Plans for each Ranger District. The Revised Plan 

identifies as a priority Objective (see Revised Plan Chapter 4.A.3.) the need to 

update these specifically for the Ogden, Salt Lake, and Logan Ranger Districts 

because of issues raised here. It also includes criteria to be used during Travel 

Management Planning. In addition, the issue of education and enforcement was 

heard by the Forest Service and the Revised Plan sets specific priority Objectives 

for increasing these. For winter, the Revised Plan sets direction through Winter 

Recreation Class Maps to separate motorized and non-motorized uses in key areas 

in order to reduce conflicts between users and protect areas of critical big game 

winter ranges. 

282. The Wasatch-Cache National Forest should recognize that the proposed Forest 

Plan allows for balanced recreation and multiple use. 

Response 282: Thank you for expressing your support of the Proposed Forest Plan 

as an attempt to balance many competing uses. 

283. The Wasatch-Cache National Forest should recognize that the multiple use 

mandate has been met because there are enough areas that provide motorized 

use. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 91 

Response 283: The range of alternatives in this FEIS provides for display of the 

differing effects of various options for winter motorized and non-motorized use 

areas. We believe the multiple use mandate has been met. Alternative 7 attempts to 

achieve some balance while providing for the growing demands for each type of 

use. Travel Management Plans provide the details of routes designated as open to 

motorized uses in summer. These are reflected as they currently exist in Recreation 

Opportunity Class Maps for the Revised Forest Plan. Based on many concerns 

about the adequacy of Travel Plans for some Ranger Districts, the Revised Plan 

includes a priority Objective to update these Plans as well as an Objective to 

increase education and enforcement. 

284. The Wasatch-Cache National Forest should recognize the cumulative impact of 

lost multiple use and recreation opportunities. 

Response 284: The FEIS addresses closure of roads in Chapter 3, Topic 3, under 

the heading “Road Maintenance and Decommissioning”. The effect of this on 

recreation and access is addressed in the FEIS in Chapter 3, Topic 4, under the 

heading “Effects on Recreation from Roads and Access Management.” 

285. The Wasatch-Cache National Forest should address the social, economic, and 

fairness issues related to exclusive use management. 

Response 285: The FEIS addresses the wide range of views about how the 

Wasatch-Cache National Forest should be managed through development, analysis 

and display of a broad range of “reasonable” alternatives and their effects on social 

and economic conditions as well as environmental conditions. These Alternatives 

incorporate various degrees of different uses, different types of access, and various 

levels of active management of the land and commodity production, while 

maintaining the basic productivity of that land. The degree of polarization among 

those who commented on the Plan is reflective of the wide diversity of people who 

use and care about the Forest. “Exclusive use” is not intended and is specifically 

addressed in Revised Forest Plan Chapter 4A.5. under the heading “Multiple Use 

and its application in Management Prescriptions”. The Revised Forest Plan has 

been designed to be consistent with the myriad of Laws that apply. Also, see 

Revised Forest Plan Chapter 1 for a discussion on how the Plan is guided by the 

2002 Forest Service Strategic Plan (required under the Government Performance 

and Results Act). 

Follow Traditional Multiple Use Management 

286. The final Forest Plan should include the definition of multiple use used in the 

Black Hills Forest plan. 

Response 286: The suggested definition of multiple use was clearly displayed both 

in the DEIS (Appendix D-1) and in the Proposed Plan (Chapter 4B). It is also 

displayed again in the FEIS (Appendix D-1) and in the Revised Forest Plan 

(Chapter 4.A.5). 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 92 

287. The Wasatch-Cache National Forest should continue traditional multiple use 

management. 

287.1 To comply with congressional mandates 

287.2 Because there are already enough wilderness areas 

287.3 To allow the constructive use of resources 

287.4 Because Forest Service experts are not adequately informed 

287.5 To follow the will of the public 

287.6 To prevent environmentalists from pushing their exclusive agenda 

287.7 Rather than restricting uses 

Response 287: See Response 285. 

288. The Wasatch-Cache National Forest should continue traditional multiple use 

management for environmental reasons to achieve forest health. 

Response 288: See Response 285. 

289. The Wasatch-Cache National Forest should continue traditional multiple use 

management for recreational purposes. 

289.1 To preserve the diversity of recreational opportunities 

289.2 To accommodate heli-skiing 

289.3 To accommodate motorized recreation 

289.4 To accommodate hunting 

289.5 To resolve use conflicts 

Response 289: Conflicts between different types of recreationists was identified 

early in the planning process as and issue that would need an array of different 

alternatives to address. Each of the 7 Alternatives included in the FEIS includes an 

explanation of how it addresses this issue. See FEIS Chapter 2 under the heading 

“Alternatives Considered in Detail” for this explanation. FEIS Chapter 3, Topic 3, 

Recreation provides a discussion of the effects of each alternative on various 

recreation uses. 

290. The Wasatch-Cache National Forest should continue traditional multiple use 

management for social reasons. 

290.1 To protect family unity 

290.2 To preserve remaining open spaces 

290.3 To accommodate experiences for stress relief 

290.4 To provide funds for education 

290.5 To protect heritage resources 

290.6 To preserve western culture 

Response 290: See Response 285. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 93 

Topic 1: Watershed Health Management 

Soils, Water, and Geologic Resources 

Soils Management General 

291. The Wasatch-Cache National Forest should restore full riparian function and 

soil storage capacity to protect water quality and quantity.

Response: Thank you for your comment. The forest-wide desired condition for 

riparian areas as described under the Forestwide Desired Conditions in the revised 

Forest Plan states that riparian areas have a range of vegetative structural stages that 

are at or moving toward properly functioning condition (PFC). In this same section, 

the forest-wide desired condition is for soils have to have at least minimal 

protective ground cover, soil organic matter, and coarse woody material. It is 

expected that water quality and quantity are enhanced when riparian conditions are 

at PFC and soil productivity and quality are maintained or restored. 

292. The Wasatch-Cache National Forest should revise soil disturbance guidelines 

to incorporate scale and environmental sensitivity. 

Response: The scale is considered in the definition of an activity area which is 

described in the Glossary and Acronyms section of the DEIS. 

293. The Wasatch-Cache National Forest should revise the standard SI to include a 

clause based on potential soil erosion by soil classification on slopes between 20 

and 40 percent. 

Response: The scale of soil mapping on the WCNF currently does not delineate 

slope groups between 20 and 40 percent. Because of this a forest-wide standard 

would not be appropriate. Clauses based on slope are best applied when more 

detailed site-specific soil information is obtained during project level analysis. 

294. The Wasatch-Cache National Forest should reduce the standard for soil 

displacement in an activity area. 

Response: The 15 percent standard is based on an estimate of the normal amount of 

natural variability and anything greater than 15 percent is assumed to be outside of 

this range and is most likely due to man’s activity. 

295. The Wasatch-Cache National Forest should recognize that maintaining 

existing soil productivity and water quality is unattainable under the proposed 

plan. 

Response: As defined in the Glossary, the Multiple Use Sustained Yield Act of 

1960 guides the management of the WCNF in that the surface resources of the 

national forests is to be utilized in a combination that will best meet the needs of the 

American people without impairment of the productivity of the land. This act and 

the regulations guiding the mission of the Forest Service recognizes that some site 

specific effects to the land and water resources may occur from multiple use 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 94 

activities but the overall productivity of the land and quality of the water is not 

degraded. 

Special Soil Communities 

296. The Wasatch-Cache National Forest should adequately consider cryptogamic 

crusts. 

Response: There is very limited information on the distribution of cryptogamic 

crusts and their role on the Wasatch-Cache National Forest. Additional analysis has 

been completed on the potential occurrence of, and impacts to, cryptogamic crusts 

and is included in Chapter 3, Botanical Resources. This new analysis and 

assessment identified areas of the Forest with the greatest potential for cryptogamic 

crusts and the effects from different uses in each alternative on those crusts. The 

Stansbury Mountains have the greatest potential for cryptogamic crusts because of 

the soil and vegetation characteristics. Because there is not a great difference in 

how the Stansbury Mountains are managed between alternatives with regard to 

livestock grazing and road and trail construction and subsequent unauthorized ORV 

use, there is little difference in potential impacts among alternatives to cryptogamic 

soil crusts. 

297. The Wasatch-Cache National Forest should avoid disturbing tundra and talus 

soils. 

Response: Most of the alpine communities on the Wasatch-Cache National Forest 

occur in designated wilderness. Talus slopes can occur at any elevation, but many 

of these also occur within designated wilderness. The greatest potential for 

additional impacts is in the upper portions of ski areas on the Forest. Site-specific 

assessments and analyses of any activities in these areas will be done to determine 

their potential impacts. We agree that the alpine ecosystems are fragile and that 

they warrant greater protection than most other ecosystems on the Forest. Talus 

communities at higher elevations provide important habitat for some wildlife 

species as well and impacts to associated rare plants and animals will be avoided. 

Geologic Resources Management 

298. The Forest Plan should adequately and consistently discuss geologic units. 

298.1 By adding an appendix on geologic units

Response: We agree that geological information is important for mineral potential. 

However, for the decisions made at the Forest Plan scale, broad-scale geological 

information is used. It is the intent of the Forest Plan revision analysis to focus its 

attention on the major issues relating to Forest Planning. Detailed geological 

information is used in site-specific, project-level analysis when issues relating to 

geology are identified. 

298.2 By providing a map showing where geologic units exist 

Response: Although geology is not directly referenced in the DEIS, we relate 

occurrence of vegetation communities in terms of ecological subregions that uses 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 95 

geology as a basic foundation. For a detailed description of the geology of 

ecological subregions, see McNab and Avers (1994) that is referenced in the section 

Broad Scale North-South Coniferous Corridor in the Affected Environment section 

of Topic 2- Biodiversity and Viability of the DEIS. 

Aquatic Resources Management General 

299. The Wasatch-Cache National Forest should protect riparian areas to preserve 

water quality. 

Response: The proposed Forest Plan protects riparian areas through the use of 

standards such as those under Standards and Guidelines for Watershed Health and 

Biodiversity and Viability. Site-specific projects and mitigation such as placing 

troughs a distance from a spring would be analyzed through a project analysis and 

is not addressed at the planning level. 

For example, in the Standards for Road/Trail and Access Management in Forest 

Management Direction section of the proposed Forest Plan, a standard states that 

‘summer motorized and mechanized access is managed on an “open on designated 

routes” basis’. This standard is carried through the more site-specific analysis for 

Ranger District Travel Plans where decisions regarding management of motor 

vehicle access and areas where motorized use is allowed are identified on specific 

areas. For example, the Salt Lake District travel plan states that all areas and routes 

are closed to motorized use unless designated as open. The travel plan allows motor 

vehicles on designated roads and trails, but not off of these routes, thereby 

protecting riparian areas. The Standards for Road/Trail and Access Management in 

Forest Management Direction section of the proposed Forest Plan, also provides 

protection for riparian areas through the use of Best Management Practices during 

construction and maintenance of roads, trails, and facilities. 

Water Quality 

300. The Forest Plan should state that the Forest Service will not impose more 

regulations regarding water quality than are already legally imposed by Salt 

Lake City.

Response: The WCNF recognizes the states of Utah and Wyoming has regulatory 

authority over water quality within the respective states. Although the WCNF is 

not considering imposing more stringent or inconsistent regulations regarding water 

quality, we don’t feel that we need to explicitly state this. 

301. The Wasatch-Cache National Forest should provide reference to more 

information on aquatic resources and water quality conditions and trends, 

including streams that are impaired and/or in need of improvement.

Response: In addition to listing state assessed impaired water bodies under the 

section Water Quality in Topic 1, Watershed Health of the DEIS, watersheds 

containing resource concerns are listed in the section Watershed Condition 

Assessment that include streams that need improvement. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 96 

302. The Wasatch-Cache National Forest should protect water quality from nitro 

aromatic compounds. 

Response: On 04/10/2002, Charles Condrat, WCNF hydrologist talked to Ryan 

Rowland and Dave Naftz of the US Geological Survey regarding the nitroaromatic 

compound (NAC) study. They said the work done was a preliminary study that 

sampled NAC s in snow, soil, and lake sediments. He said that the snow and soil 

samples contained measureable amounts of NACs but not NACs were found in lake 

sediments. They said the study has a very small amount of data and that there is not 

enough information in which to set standards. Since there is very little data to 

support setting standards, standards for NACs in the Forest Plan would not be 

appropriate. 

303. The final Forest Plan should include critical nitrogen load standards, based on 

research protocols developed for Colorado wilderness areas. 

Response: The WCNF has a water quality monitoring program in cooperation with 

the State of Utah as described in the Water Quality section on Topic 1, Watershed 

Health of the FEIS. Nitrogen is one of the parameters analyzed in the water quality 

monitoring program and has not been found to exceed State standards in water 

bodies sampled on the WCNF. Setting critical load standards for nitrogen is not 

needed on the WCNF at this time. 

304. The Wasatch-Cache National Forest should recognize the negative effects of 

sediment on the treatment of surface water. 

Response: The WCNF has a cooperative water quality program with the State of 

Utah and samples are analyzed for sediment. Turbidity measurements have been 

effective for monitoring site-specific projects. For forest planning, water quality is 

assessed at a broad scale in order to plan actions to protect, maintain, or improve 

water quality. 

305. The Wasatch-Cache National Forest should adequately address the issue of 

sewage spills into drinking water. 

Response: In response to your comment, Florence Reynolds, water quality 

administrator for Salt Lake City (SLC), was contacted regarding sewage overflows 

that have occurred in the sewer systems in the canyons east of SLC. Florence said 

that since sewer systems have been operating, SLC has had two sewage overflows 

that were caused by ground surface activities near the sewer lines. Both were 

caused by dirt and gravel dumped into the sewer that caused a backup of sewage. 

The sewage overflows were caused by a construction project and by road 

maintenance. SLC water treatment plant was shut down immediately after being 

notified of the spills and operations resumed after the potential for contamination of 

the treatment plant had passed. The pipe itself is in good condition but it is other 

activities that have affected the sewer. Water quality has been very good before and 

after the sewer was installed in spite of the increase in the use and development of 

the canyons. The waste that has been taken out of the canyon through the sewer 

system contributes to the constant very high water quality in the canyons. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 97 

306. The final Forest Plan should assure non-degradation of state category 1 

streams to comply with Utah State Code R317-2-3.2.

Response: The WCNF is required by State law to meet anti-degradation 

requirements. The Forest Plan has many standards and guidelines that provide 

means to meet anit-degradation requirements such as standards 1 through 5, 16, 17, 

19, and guidelines1 through 10 in the FEIS. 

307. The Wasatch-Cache National Forest should specify whether lakes listed with 

water quality problems are reservoirs. 

Response: Pineview Reservoir is a reservoir, China Reservoir and Tony Grove 

Lake are natural lakes with a dam to raise their water level. Bridger Lake, Marsh 

Lake, Lyman Lake, and Mirror Lake are natural lakes. 

Water Quantity 

308. The Wasatch-Cache National Forest should enhance water production. 

308.1 By studying rivers, streams, and watersheds for maximum ouput and 

benefits 

308.2 By not recommending management prescription categories or 

wilderness designations that would detract from enhancing water production 

Response: Enhancement of water yield form the WCNF is discussed under the 

section Effects on Soil and Water Resources from Timber Harvest/ Vegetation 

Treatments and in the cumulative effects section of Topic 1, Watershed Health. 

The effects analysis discusses limitations on enhancing water yield and the Forest 

Service has carefully considered water yield increases with other resource needs. 

Increasing water yield on the WCNF is one of many strategies to address water 

needs in Utah and Wyoming. The cumulative effects section describes that State 

water development plans include several strategies for meeting water needs in Utah 

and Wyoming. 

309. The Wasatch-Cache National Forest should recognize the potential for 

increased water yield and resulting channel degradation from certain 

activities. 

Response: See response 308. 

310. The Wasatch-Cache National Forest should adequately address the issue of 

decreased water yield associated with declining aspen stands and growing 

conifer stands. 

Response: In response to your comment a general statement regarding reduction in 

water yield is included in section Surface Water under Topic 1, Watershed Health. 

A detailed water yield analysis is not appropriate for the Forest Plan revision 

because forest planning is at a broad scale, which has many limitations as described 

in the section Effects on Soil and Water Resources from Timber Harvest/ 

Vegetation Treatments in Topic 1, Watershed Health. 
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Wasatch-Cache National Forest A - 98 

Watershed Health Management General 

311. The Forest Plan should recognize the Department of Interior’s withdrawal of 

specific National Forest System lands for the purposes of the Provo River 

Project and the Provo River Channel Revision. 

Response: The Forest Service recognizes that the Department of Interior withdrew 

lands for purposes of the Provo River Project and recognizes the right of the Provo 

River project to operate its lands and facilities. The Forest Plan Revision DEIS and 

Proposed Plan never intended to alter the operations of the PRWUA and that 

nothing in the proposed plan revision is expected to restrict the PRWUA from 

managing its operations within their authority. 

312. The Wasatch-Cache National Forest should protect watersheds. 

Response: Thank you for your comments. Watershed concerns are identified in 

Issue #5 and considered in alternatives in the FEIS and in desired future conditions, 

goals, and standards and guidelines in the revised Forest Plan. 

312.1 From the pressures of population growth 

Response: Population growth is a factor that is considered in the cumulative effects 

section of Topic 1, Watershed Health in the FEIS. 

312.2 To preserve the water supply for a growing population 

Response: Thank you for your comment. The canyons east of Salt Lake City are 

important public supply watersheds and are recognized as such in the section Water 

Quality and in the cumulative effects section under Topic 1, Watershed Health. 

312.3 To protect groundwater supplies 

Response: Thank you for your comment. 

312.4 To hold water for continuous flow 

Response: Thank you for your comment. The ability of land to hold water and 

provide water flow during drier periods of the year is described in section Wetlands, 

Riparian Areas, and Floodplains in Topic 1, Watershed Health. 

312.5 By designating sensitive or damaged watersheds and directing future 

management accordingly 

Response: The FEIS identifies watersheds and resource concerns in Table WA-2 

and the revised Forest Plan identifies priority areas for management activities to 

address livestock grazing impacts under the section Forest Objectives. 

312.6 By prohibiting any activities that degrade watershed health 

Response: Thank you for your comments. The WCNF provides for multiple use 

and the FEIS recognizes that some activities have impacts on Watershed Health. 

The ten Watershed Health guidelines, with the exception of Guideline 9, are 

guidelines because they are not binding limitations placed on management 

activities, but are preferred or advisable actions. Deviation from these guidelines 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 99 

will be documented in the appropriate analysis. In the FEIS, G9 is changed to a 

standard because, by definition, Soil and Water Conservation Practices are required 

during project implementation. 

312.7 Rather than focusing on recreation management 

Response: The WCNF provides for multiple use and recreation is a very important 

activity in the Tri-Canyon area. The alternatives provide a range of uses on the 

WCNF including those in the Tri-Canyon area. 

313. The Wasatch-Cache National Forest should rehabilitate existing watershed 

problems rather than increase uses on roadless lands. 

Response: Thank you for your comment. The reason for the subgoal “identify 

watersheds not in properly functioning condition” is that resource problems in 

individual watersheds are very site-specific and cause specific and more detailed 

information on the ground is needed to evaluate solutions to the resource problems. 

314. The Final EIS should provide a map depicting current watershed status. 

Response: Thank you for your comment. A map of watersheds has been added to 

the FEIS. 

315. The Wasatch-Cache National Forest should consider adding the Mount Aire 

drainage to the Salt Lake City watershed. 

Response: Thank you for your comment. The cumulative effects section describes 

activities at a broad scale on lands adjacent to the WCNF including Salt Lake City 

Watershed Plan. 

316. The Final EIS watershed section should reference the Federal Multi-Agency 

Source Water Agreement. 

Response: Thank you for your comment. This reference has been included in the 

FEIS. 

Adequacy of Analysis 

317. The Wasatch-Cache National Forest should establish benchmark landscape 

level watersheds as research control areas. 

 Response: Various uses on the Forest, including livestock grazing and OHV use 

among others, have had and continue to have impacts on vegetation and associated 

watershed conditions. An assessment of wildlife habitats is only done at a broad 

scale with this plan revision. While the forest has some information on forest 

structure and how it relates to goshawk habitat, we have not collected detailed 

monitoring data on vegetation undergrowth characteristics that could affect 

goshawk habitat. The understanding of unaffected conditions would be aided by 

the use of existing and proposed Research Natural Areas (RNAs) and Special 

Interest Areas (SIAs) as well as some areas within wilderness or proposed 

wilderness. We have proposed an expansion of the Morris Creek RNA and have 

proposed new SIAs for botanical purposes and for restoration ecology research. We 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 100 

have also identified other areas as possible additions to the RNA/SIA system in 

FEIS, Chapter 3, Topic 8. 

318. The Wasatch-Cache National Forest should provide detailed strategies 

regarding water management in the final Forest Plan. 

 Response: Water Planning is a statewide issue and the FEIS references the state of 

Utah and Wyoming in the cumulative effects section. State planning describes 

several management strategies for providing water. Additional information on 

water yield opportunities and limitations are discussed in the section Effects on Soil 

and Water Resources from Timber Harvest/ Vegetation Treatments. 

319. The Wasatch-Cache National Forest should determine the current regime for 

watershed management before measuring the degradation of those regimes. 

 Response: Thank you for your comment. Additional information will need to be 

obtained for site-specific projects that may affect these resources. 

320. The Wasatch-Cache National Forest should provide an adequate analysis of 

erosion processes in canyon streams. 

 Response: The section Geologic Hazards in Topic 1, Watershed Health of the 

FEIS, Utah is among eight states with a “severe” landslide hazard rating. The 

reference by Harty describes debris flows after intense thunderstorm events as 

exiting steep canyons such as those in Davis County and near Willard, Utah. In 

order to clarify the meaning, the term “flash flood” is changed to “debris flow” in 

the section Current Conditions under Revision Topic 1, Watershed Health in 

Chapter 2 of the Revised Forest Plan. Alluvial fans are formed by debris flows 

exiting steep canyons and depositing on a on a lower gradient slope in the valley. 

This is shown in Harty’s publication in a figure showing debris flow deposit 

forming an alluvial fan at the mouth of a steep canyon. 

321. The Wasatch-Cache National Forest should provide a more detailed discussion 

of the effects of Alternative 2 on watershed condition to answer feasibility 

questions. 

 Response: The effects described in section Effects on Soil and Water Resources 

from Livestock Grazing under Topic 1, Watershed Health in the DEIS refer to 

effects on soil and water resources from livestock grazing. From comments on the 

DEIS, the effects were again reviewed and the conclusion made that effects from 

livestock grazing would be similar between most alternatives. These effects are 

described in the FEIS. Assumptions on budget are in FEIS Chapter 2, under Forest 

Plan revision outputs and services. The Forest Plan gives broad-scale planning for 

the WCNF and does not make site-specific decisions. A detailed description of 

effects on individual flora and fauna is not appropriate at this scale of planning 

because no site-specific actions are proposed or specific actions decisions are made. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 101 

Effects of Activities/Disturbance 

322. The Wasatch-Cache National Forest should adequately analyze the effects of 

ski resort trash accumulation and avalanche control activities on watershed 

health.

 Response: The Forest Plan revision addresses broad-scale planning for the entire 

WCNF. The issues you raise are best addressed during project-level planning 

and/or during review of ski area annual operating plan when site-specific actions 

can be identified to remedy the problem. 

323. The Wasatch-Cache National Forest should recognize that road building and 

grazing cause more erosion than off-road vehicles. 

 Response: Road building, grazing and ATV use can cause erosion and the amount 

of erosion is dependent upon many factors including the amount of use, slope 

steepness, type of soil, soil conservation measures in place to reduce erosion. The 

FEIS describes these effects on a broad-scale. However, at the Forest Planning 

scale it is not appropriate to make general statements about one use resulting in less 

erosion than another because of the many factors involved. Differences between 

amount of erosion due to different activities is more appropriate at the site–specific 

project level scale of analysis. 

324. The Wasatch-Cache National Forest should recognize that the magnitude of 

sediment transport attributable to reasonable use by motorized recreationists 

is relatively insignificant compared to the magnitude of natural sediment 

transport. 

 Response: Motorized recreation use can cause erosion and the amount of erosion is 

dependent upon many factors including the amount of use, slope steepness, type of 

soil, soil conservation measures in place to reduce erosion. The FEIS describes 

these effects on a broad-scale. However, at the Forest Planning scale it is not 

appropriate to make general statements about the amount of erosion from motorized 

recreation compared to natural since many factors are involved in the analysis that 

is appropriate at the site–specific project level scale of analysis. 

325. The Wasatch-Cache National Forest should recognize the benefits of flooding 

on streams. 

 Response: Thank you for your comment. The benefits of floodplains are 

recognized in the section Wetland, Riparian Areas, and Floodplains in Topic 1, 

Watershed Health. 

326. The Wasatch-Cache National Forest should prohibit snowmaking. 

 Response: The decision to permit snowmaking at Alta was made after a sitespecific analysis of the Alta master development plan. This is the appropriate 

analysis for a decision on allowing snowmaking because it is site-specific. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 102 

327. The Wasatch-Cache National Forest should adequately study the effects of 

snowmaking activities on instream flows. 

 Response: The decision to approve withdrawals of water for snowmaking is based 

on a site-specific analysis using the expertise of hydrologists and fisheries 

biologists. In the record of decision for the Solitude Master Development Plan 

Update, an instream flow study is required as part of mitigation for effects of 

snowmaking withdrawals on Big Cottonwood Creek. 

328. The Wasatch-Cache National Forest should restrict the importation of water 

from outside sources to enhance private development in the Tri-Canyon area. 

 Response: Thank you for your comment. 

329. The Wasatch-Cache National Forest should amend the Forest Plan and EIS to 

reflect the fact that the impacts of diversions through the Duchesne Tunnel are 

not significant. 

 Response: We understand that there is disagreement regarding the significance of 

the impacts from the Provo River Project. We feel that the Provo River Project has 

had significant effects on the Duchesne River below the Duchesne Tunnel 

Diversion and on the Provo River below the outlet of the Duchesne Tunnel. 

Although the Upper Provo River Easement Maintenance Plan reaches the 

conclusion that no significant effects have occurred, based primarily on a 

hydrologic and hydraulic study, many other effects of increased flows are not 

discussed such as effects of movement of channel substrate on river organisms and 

the effects of stream bank erosion on downstream channel stability. These are a 

couple examples of many effects that have been identified in augmented water 

channel systems. However, the Forest Plan revision process addresses broad-scale 

planning for the entire WCNF and not site-specific projects such as the PRP. Since 

it was never the intent of the Forest Plan revision to make a decision affecting the 

current management of the PRP, it is not appropriate to conduct a detailed analysis 

of the PRP for the Forest Plan Revision. 

330. The Wasatch-Cache National Forest should explain the environmental and 

economic impacts of any reduction in Duchesne tunnel diversions. 

 Response: The Forest Service recognizes that the Duchesne Tunnel diversions as 

an important source of municipal, industrial, domestic, and irrigation water for 

more than one million people. DEIS does not explain the environmental and 

economic impacts of any reduction in Duchesne Tunnel diversions because the final 

Plan does not restrict operations of the Provo River Project. 

331. The Wasatch-Cache National Forest should clarify plans to implement 

alternative methods of water diversions. 

 Response: The Forest Plan revision addresses broad-scale planning for the entire 

WCNF. There are many factors that affect the decision on snowmaking, water 

withdrawals, dams, construction, transbasin diversions, and the authority of the 

Forest Service. Some of these factors are location of withdrawal point, amount of 

flow, amount of withdrawal needed, water right, ownership of land, and 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 103 

environmental effects. These factors are very site specific and vary depending upon 

the location of the point of withdrawal and where or if it crosses Forest System 

Lands. The issues you raise are best addressed during project-level planning when 

site-specific alternatives and mitigation can be identified to come up with the best 

solution. 

Access to Utility Infrastructure 

332. The final Forest Plan should allow continued motorized access to alpine lakes 

that supply water to the Ogden area.

 Response: See response 335. 

333. The final Forest Plan should recognize the Provo River Water User’s 

Association’s right-of-way from the Mirror Lake Highway to the Duchesne 

Diversion. 

 Response: The Forest Service recognizes PRWUA’s right to continued year-round 

motorized access along the gravel road that extends from the Mirror Lake Highway 

to the Duchesne Diversion. In addition, the Forest Service recognizes PRWUA 

need to have access to existing repeater sites. 

334. The final Forest Plan should not restrict motorized access to any Provo River 

Water User’s Association infrastructure. 

 Response: The Forest Service recognizes PRWUA’s need for continued winter 

access to a variety of locations within the Wasatch-Cache Forest by helicopter, 

snowmobile and snow cat on very short notice for the purpose of monitoring 

snowpack conditions and forecasting snow melt runoff. 

335. The final Forest Plan should explicitly mention the Central Utah Water 

Conservancy District’s motorized access rights to its dam facilities in the 

Upper Provo drainage. 

 Response: The Forest Service recognizes the need for access to Federal facilities 

for which you have contractual obligations with the US Bureau of Reclamation. The 

Forest Plan does not intended to alter your operations and nothing in the plan is 

expected to restrict you from managing your existing operations. 

336. The final Forest Plan should not restrict motorized access to any Bureau of 

Reclamation projects. 

 Response: See response 335. 

337. The final Forest Plan should not restrict year-round motorized access to any 

hydroclimatic snow survey data stations. 

 Response: See response 335. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 104 

Other 

338. The Forest Plan should acknowledge and present the reconstruction of the 

Trial, Lost, and Washington dams and the resulting stabilization of 12 

connected lakes. 

 Response: This Information is summarized in the FEIS in the section under 

Western Management Area Descriptions under Topic 1, Watershed Health. 

Air Resources 

Air Resources Management General 

339. The Wasatch-Cache National Forest should recognize that the desired 

condition regarding smoke emissions is not attainable. 

 Response: As described under the section Resource Protection Measures under 

Topic 1, Air Resources, the WCNF coordinates with the State of Utah Department 

of Air Quality to mitigate the effects on public health, public safety, and visibility. 

These efforts should be adequate to meet State air quality standards. 

Adequacy of Analysis 

340. The Wasatch-Cache National Forest should calculate off road vehicle 

emissions and obtain an air permit under the Clean Air Act.

 Response: Additional information on effects of 2-stroke engines on air quality has 

been included on the FEIS in the section Effects on Air Quality from Snowmobiles 

under Topic 1, Air Resources. This analysis assumes that the air quality conditions 

due to snowmobiles in the Yellowstone study is worse than those on the WCNF 

because the overall amount of use and the uses in concentrated areas is less on the 

WCNF than at Yellowstone. It is expected that the conclusions in the section 

Effects on Air Quality from Snowmobiles also apply to ATVs and dirt bikes since 

air quality conditions in Utah are generally worse in the winter than in the summer. 

Effects of Activities/Disturbance 

341. The Wasatch-Cache National Forest should recognize that off road vehicles 

don’t cause major air pollution problems.

 Response: Additional information on effects of 2-stroke engines on air quality has 

been included on the FEIS in the section Effects on Air Quality from Snowmobiles 

under 

342. The Wasatch-Cache National Forest should restore trees in valley areas to 

mitigate the effects of global warming.

 Response: Thank you for your comments. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 105 

343. The Wasatch-Cache National Forest should recognize that humans cause only 

5 percent of greenhouse gases.

 Response: Thank you for your comments. 

Topic 2: Biodiversity and Viability Management 

Biodiversity and Viability Management General 

Management General 

344. The Final EIS should include a strong standard of viability to ensure the 

sustainability of all native species. 

 Response: NFMA requires the FS to “provide for diversity of plant and animal 

communities based on the suitability and capability of the specific land area in order 

to meet overall multiple-use objectives” (NFMA Sec.6(g)(3)(B). This translates 

into 36CFR 219.19’s requirement to “maintain viable populations of existing native 

and desired non-native vertebrate species in the planning area.” These requirements 

make a specific standard unnecessary. 

345. The Wasatch-Cache National Forest should revise the definition of viability. 

 Response: We have revised the definition in the glossary to match the intent of 

36CFR 219.19 that states, “A population which has the estimated numbers and 

distribution of reproductive individuals to insure its continued existence is well 

distributed in the planning area.” It must be realized, however that there are some 

species such as the yellow-billed cuckoo that the state has identified as not breeding 

in the state that will be classified as not viable on the Forest because of this 

definition. These are species where the Forest is on the edge of their range and 

distribution across the Forest and/or breeding will not likely ever occur as is written 

in the definition. 

346. The Wasatch-Cache National Forest should give priority to biodiversity and 

species viability. 

 Response: This commenter was pleased that the Forest was giving priority to 

biodiversity and species viability. Thank you for your comment. 

347. The Wasatch-Cache National Forest should adequately discuss disturbance 

ecology and ecosystem resiliency. 

 Response: A section on districution ecology and ecosystem resiliency has been 

added to the Topic 2 – Biodiversity and Viability Section, Vegetation section.

348. The final Forest Plan should include actions to ensure viability of biological 

communities. The Forest should add specific goals, objectives, standards, 

guidelines and mitigation measures. 

 Response: We have goals, objective, standards, and guidelines to ensure the 

viability of biological communities. MIS are used to see if we are moving in the 

right direction with the management of those communities. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 106 

349. The final Forest Plan should improve the discussion of historic range of 

variation. Recognizing that climate change precludes reestablishment of many 

native ecosystems 

 Response: While we recognize that climate changes are occurring, to date we have 

not seen any of our native ecosystems fail to reestablish following disturbance, 

unless those disturbances have been extreme and outside historic levels. 

Adequacy of Analysis 

350. The Wasatch-Cache National Forest should conduct microsurveys of flora and 

fauna. 

350.1 To identify geographical components of biodiversity. 

 Response: Table VEG-1 in the FEIS displays different cover types by ecological 

sections on the Forest. 

350.2 To maintain healthy ecosystems. 

 Response: While microsurveys could improve our understanding of biodiversity 

and ecosystem functions, we have not had the ability to conduct them and feel that, 

at the forest plan level, direction is provided that will manage for healthy 

ecosystems and for biodiversity. 

Effects of Activities/Disturbance 

351. The Wasatch-Cache National Forest should assess continuing impacts of 

specific activities and compensate for them to effectively ensure population 

viability. 

 Response: The purpose of MIS is to assess impacts of activities on wildlife 

populations. If population trends of MIS decrease on the Forest all activities that 

might affect the decline will be assessed to determine the cause and appropriate 

action taken. 

352. The Wasatch-Cache National Forest should establish controls on grazing 

and motorized recreation in research forest areas to ensure research results on 

silviculture are not distorted.

 Response: The Forest recognizes that silviculture treatments recommended as a 

result of research conducted on one part of the Forest should not be applied to all 

ecosystems across the Forest. We also recognize that research has evolved and will 

continue to change in the future. We can only use the most recent and best 

information we have to make resource management decisions. We will continue to 

manage grazing and motorized recreation to limit their impacts to experimental 

forests. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 107 

Wildlife 

Wildlife General 

353. The Wasatch-Cache National Forest should address wildlife management. 

353.1 By not allowing human uses of the forest to influence wildlife 

management direction

 Response: By law the Forest Service is a multiple use agency and to that end 

decision makers within the Forest Service strive to find balance to the many uses on 

the Forest. This balance is different from forest to forest and even district to district 

on a given Forest. Knowing that every square foot cannot be managed for every 

use prescriptions have been assigned to different areas on the Forest where a 

particular use will be emphasized but not used exclusively for that prescription. 

With this approach we can better work with state wildlife agencies to help meet 

their management direction. 

353.2 By taking an active role in managing wildlife, especially in managing 

non-native species. 

 Response: The Forest Service role in wildlife management including the 

management of non-native species is outlined in 36 CFR 219.19 and Forest Service 

Manual 2600. 

353.3 By addressing conflicts between guidelines for management of specific 

species 

 Response: We have tried to eliminate any conflicts between guidelines for 

management of specific species and continue to look for any remaining conflicts. 

353.4 By making recommendations regarding the appropriateness of wildlife 

transplants 

 Response: This is done through a Memorandum of Understanding with the Utah 

Division of Wildlife Resources according to direction in Forest Service Manual 

2640. 

353.5 By considering predator control and the reintroduction of bighorn sheep 

 Response: Predator control is conducted by APHIS-Wildlife Services. Their 

Environmental Assessment for Northern Utah allows work to protect wildlife after 

transplant or on important use areas, such as fawning areas, at the request of the 

Utah Division of Wildlife Resources. 

354. The final Forest Plan should include actions to ensure species viability by 

adding specific goals, objectives, standards, guidelines and mitigation 

measures. 

 Response: See response 344 above. 

355. The Wasatch-Cache National Forest should increase monitoring requirements 

for species population and habitat trends. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 108 

355.1 By adding protocols and numbers of sites

 Response: Protocols and number of sites for management indicator species are 

discussed in Appendix J. Other species and species groups are monitored with 

accepted protocols with the number of sites that the budget allows. The Forest also 

uses inventory and monitoring information from other agencies such as the Utah 

Division of Wildlife Resources. 

 

355.2 By increasing frequency and site requirements for threatened and 

endangered and management indicator species 

 Response: Monitoring threatened and endangered species is done in coordination 

with the Fish and Wildlife Service and the State. Management indicator species are 

monitored as identified in Chapter 5 of the Revised Forest Plan and in Appendix J 

of the FEIS. 

356. The Wasatch-Cache National Forest should clarify its criteria for wildlife 

introductions. 

 Response: Wildlife introductions are covered in Forest Service Manual 2640. 

357. The Wasatch-Cache National Forest should recognize that the presence of 

humans pushes out other species. 

 Response: We recognize this. This is why we have prescriptions assigned to 

different areas of the Forest that limits certain activities within the prescription area. 

See the Revised Forest Plan, Chapter 4 (B) Forestwide Allocations for the 

discussion and definition of prescription areas. 

358. The Wasatch-Cache National Forest should protect humans over wildlife. 

 Response: Forest Service policy puts human safety above wildlife. The Standard 

is listed under Fire and Fuels Management in Chapter 4 of the Revised Forest Plan 

Adequacy of Analysis 

359. The Wasatch-Cache National Forest should add supporting data and habitat 

analysis to the viability section of the Final EIS. 

 Response: This has been done. 

360. The Wasatch-Cache National Forest should conduct appropriate data 

collection for the species viability analysis and potentially use modeling. 

 Response: This is done opportunistically as budgets allow. The other approach to 

viability is ecological sustainability and this is discussed in Appendix 2-B. 

Regulations do not specify how viability is to be dwelt with, only that we must 

manage habitat to “maintain viable populations of existing native and desired nonnative vertebrate species in the planning area.” 

361. The Final EIS should include an analysis of anticipated changes in habitat 

components and discuss quantity, quality, and distribution. 

 Response: This has been done. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 109 

362. The Wasatch-Cache National Forest should consider the effect of possible 

mortality of wildlife in oil pits. 

 Response: The only pits used in oil and gas operations on the Forest are settlling 

ponds for water used in the drilling of new wells. After use they are buried and 

rehabilitated. There are no oil pits on the Forest. 

363. The Wasatch-Cache National Forest should clarify the benefits of reduced tree 

density to wildlife. 

 Response: The section on “The Effects on Terrestrial Wildlife From Oil and Gas 

Activities has been rewritten and the statement is no longer in the document. 

364. The Wasatch-Cache National Forest should revise the section regarding effects 

to terrestrial wildlife from roads management by adding an explanation that 

some species of wildlife are more sensitive to disturbance than others. 

 Response: The words, “...and the species of wildlife,” have been added to the 

second sentence along with another sentence of further explaination. 

Wildlife Habitat 

365. The Wasatch-Cache National Forest should determine acres of high quality 

habitat by vegetation type. 

 Response: The question is, “high quality habitat” for what species? Goshawk and 

snowshoe hare both use the same vegetation type but different age classes. To 

identify “high quality habitat” one enters into single species management, which is 

not practical both from the number of species that have habitat on the forest and 

from the budget aspect. These are reasons why we chose a coarse filter ecological 

sustainability approach in dealing with species-at-risk. 

366. The Wasatch-Cache National Forest should protect critical habitat. 

366.1 By providing adequate direction for wildlife habitat management

 Response: This has been done. 

366.2 By giving priority to actions that enhance habitat 

 Response: This is done through management goals and objectives that guide 

management in the direction of properly functioning condition within the historic 

range of variability. 

366.3 By preserving large tracts of land 

 Response: The Forest presently has 310,500 acres of wilderness which is 40% of 

all Forest Service administered wilderness in the state of Utah. Alternative 7 

recommends another 61,400 which, if Congress chooses to act, would bring the 

total acreage on the Forest to 371,900 acres which would be 45% of wilderness on 

National Forest System lands in Utah. There are also roadless areas and Research 

Natural Areas that protect important habitats. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 110 

366.4 By tying the monitoring of aquatic resources to specific management 

implementation 

 Response: Aquatic resources are monitored on a Forest wide basis through a 

revolving schedule outside of Forest Plan implementation monitoring. 

366.5 By maintaining aquatic habitat through the application of Management 

Prescription Category 3.1 

 Response: Management Prescription 3.1 has been applied wherever it was 

determined to be the most important prescription for an area. We thank you for 

your comment. 

367. The Wasatch-Cache National Forest should establish habitats as Sanctuary 

Preserve areas to protect specific species. 

 Response: Refer to Appendix B for a discussion of species-at-risk and the 

measures taken to protect them and ecosystem sustainability. 

368. The Forest Plan should include the information in the Utah Division of Wildlife 

Resources’ databases regarding wildlife habitats and streams to protect and 

enhance wildlife habitat. 

 Response: The Forest has used information from the UDWR in the planning 

process and is continually coordinating with them on individual project proposals. 

Wildlife Corridors 

369. The Wasatch-Cache National Forest should preserve wildlife habitat corridors. 

369.1 By restoring wildlife habitats within the context of eco-regional planning.

 Response: The Forest is moving in this direction by working for properly 

functioning condition for all vegetation types within the historic range of 

variability. 

369.2 By protecting habitat corridors between forest areas 

 Response: See 369.1 above. 

369.3 By protecting national forest lands sufficiently to offset adverse effects 

caused by management practices on private lands 

 Response: The Forest does this where possible. In the Bear River Range, 

however, approximately 2/3 of the lands within the Congressional boundary are of 

other ownership which severely limits any offsetting adverse effects. 

369.4 By prohibiting extractive uses, motorized vehicles, and grazing in wildlife 

corridors 

 Response: By law the Forest Service is a multiple use agency. The Forest Plan is 

designed to help decision makers find the proper balance of uses in the management 

of the National Forest. The Management Prescriptions discussed in Chapter 4 of 

the Revised Plan and their application to Management Prescription Maps show 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 111 

where certain uses will be emphasized. Management Prescriptions, however, do 

not denote exclusive use since the law mandating multiple use still applies. 

370. The Wasatch-Cache National Forest should adequately address the effects of 

habitat fragmentation on native wildlife populations. 

 Response: This has been done in Chapter 3 of the FEIS. 

371. The Wasatch-Cache National Forest should address the effects of wildlife 

corridor protection on grazing allotments. 

 Response: With standards and guidelines for forage utilization, management 

direction that leads to properly functioning condition within the historic range of 

variability, and proper management of livestock through allotment management 

plans corridors (both local between winter and summer range, and the large regional 

corridor that has been identified) can be maintained with livestock grazing in place 

along with other aspects of multiple use. 

372. The Wasatch-Cache National Forest should close big game migration routes 

during the winter months. 

 Response: Protection of big game migration routes and important winter ranges is 

covered in Travel Management Plans. 

373. The Wasatch-Cache National Forest should not manage for wildlife corridors, 

because corridor preservation limits multiple use. 

 Response: See the response to 371 above. 

Native and Non-Native Species 

374. The Forest Service should make native biodiversity the primary goal and 

organizing paradigm of management. 

 Response: Native biodiversity is very important to the Forest and we work with 

other agencies within the scope of 36 CFR 219.19 and Forest Service Manuals to 

this end. 

375. The Wasatch-Cache National Forest should adequately address the 

management of non-native wildlife. 

375.1 By removing non-native species

 Response: Forest Service policy on non-native species is set in 36 CFR 219.19 and 

Forest Service Manual 2640. 

375.2 By prohibiting the introduction of non-native species 

 Response: Forest Service policy on non-native species is set in 36CFR 219.19 and 

Forest Service Manual 2640. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 112 

376. The Wasatch-Cache National Forest should recognize mountain goats as a nonnative species. 

 Response: Whether native or non-native, mountain goats are present and have 

been since placed in the Twin Peaks area of Little Cottonwood Canyon in 1967. 

With them being present the Forest follows Forest Service Manual (2642) direction. 

377. The Wasatch-Cache National Forest should clarify its actions regarding nonnative goats. 

 Response: See response on # 376, above. 

Game Species 

378. The Wasatch-Cache National Forest should protect big game species on an 

equal basis with other species. 

 Response: The desired condition of the wildlife resource is found in Chapter 4 of 

the Revised Forest Plan and addresses all species of wildlife without regards to any 

special classifications such as “big game.” Where certain components of a 

“groups” or a species habitat is not in properly functioning condition and/or outside 

of its historic range of variability they may be addressed in specific goals, 

objectives, standards, and guidelines. 

379. The Wasatch-Cache National Forest should protect and enhance big game 

winter ranges by closing big game winter migratory routes to human uses. 

 Response: This has been done on different areas on the Forest and is accomplished 

through travel plans. 

380. The Wasatch-Cache National Forest should recognize the impact of elk on deer 

populations. 

 Response: Wildlife numbers, composition, and distribution are the responsibility 

of the individual States, are as the number of hunting permits issued. The Forest 

participates in the public input opportunities offered by the States in making 

recommendations that will help prevent adverse effects on the habitat that is within 

the National Forest System. 

Predators 

381.The Wasatch-Cache National Forest should address predator management. 

381.1 By implementing predator management practices to meet population 

objectives 

381.2 By maintaining authority over predator control 

 Response: Wildlife population objectives are set by the States. By law (The 

Animal Damage and Control Act of 1931, as amended), predator management is 

under the authority of APHIS-Wildlife Services (WS). Funding for the program 

comes from the Federal Government, the State, and the permitttees. The Forest is 

involved with input into WS NEPA process and having annual operating plan 

meetings with WS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 113 

382. The Wasatch-Cache National Forest should not reintroduce predators, because 

they are not compatible with humans. 

 Response: There have been no official proposals to reintroduce any predators on 

the Wasatch-Cache National Forest. The policy on reintroductions is contained in 

Forest Service Manual 2640. 

383. The Wasatch-Cache National Forest should permit the passage of wolves to the 

Uinta Mountains. 

 Response: If wolves return to Utah they will be under the control of the U.S. Fish 

and Wildlife Service (FWS) and managed as a threatened species. All activities 

concerning the wolf would be done through the consultation process with the FWS 

as outlined in the Endangered Species Act, Section 7. 

384. The Wasatch-Cache National Forest should prevent the treeing of cougars with 

motorized vehicles. 

 Response: The hunting and pursuing of cougars is set and controlled by State law. 

385. The Wasatch-Cache National Forest should protect the lynx. 

385.1 By protecting lynx habitat

 Response: The Forest has identified “linkage habitat” and “core habitat” in 

consultation with the FWS and Utah Division of wildlife resources. Lynx Analysis 

Units have been identified in the core habitat as outlined in the “Canada Lynx 

Conservation Assessment and Strategy” and appropriate standards and guidelines 

are contained in the Revised Forest Plan. 

385.2 By recognizing the wide variety of factors influencing the status of the 

lynx 

 Response: These factors have been considered and worked with in mapping of 

core habitat and linkage habitat. Standards and guidelines have been developed to 

work within these habitats as well as working with the U.S. Fish and Wildlife 

Service through the consultation process on all proposed projects. 

385.3 By developing goals and objectives or standards and guidelines 

specifically designed to mitigate impacts on the lynx 

 Response: This has been done in the revised Forest Plan. 

386. The Wasatch-Cache National Forest should recognize that the need for a lynx 

corridor has not been established. 

 Response: The concept of wildlife corridors is well established and the importance 

of the Bear River Range (specifically addressed in this comment) is well shown by 

referring to McNabb’s “Ecological Subregions of the United States: Section 

Descriptions.” This corridor applies not only to lynx but to all mammals that have 

large movement areas and neo tropical avian migrants that depend on forested 

conditions. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 114 

387. The Wasatch-Cache National Forest should reevaluate any management 

prescription, management designation, or alternative selection made based on 

the Canadian lynx. 

 Response: The lynx was listed as a threatened species by the FWS over its 

historical range, which included Utah, and until the FWS changes that we work 

with them in meeting the intent of the law. 

388. The Wasatch-Cache National Forest should recognize that studies on lynx 

management are inconclusive. 

 Response: See response to # 387 above. 

389. The Wasatch-Cache National Forest should recognize that the lynx can survive 

along with multiple use activities. 

 Response: This is recognized and that is why the Revised Plan emphasizes 

properly functioning condition, historic range of variation, and ecological 

sustainability. However, when a species is federally listed under the Endangered 

Species Act we are put into a single species management situation that dictates 

some management emphasis outside of the multiple use arenas. Standards and 

guidelines that are specifically for lynx or other single species in most cases act as 

mitigation measures that make it possible for other multiple use activities to 

continue. All proposed projects on the Forest require some level of consultation 

with the FWS when federally listed species have been identified by the FWS as 

being present or having habitat on the Forest. 

390. The Wasatch-Cache National Forest should remove the phrase “to the extent 

possible” regarding lynx management from the Draft EIS. 

 Response: This has been done. 

391. The Wasatch-Cache National Forest should not close access to land because of 

possible lynx habitat. 

 Response: This has not been proposed. 

Other Wildlife Species 

392. The Wasatch-Cache National Forest should monitor beaver and snowshoe 

hares. 

 Response: Both beaver and snowshoe hare have been identified as management 

indicator species. 

393. The Wasatch-Cache National Forest should reintroduce beaver. 

 Response: Where this is not a Forest Plan decision, the Forest has and will 

continue to discuss the reintroduction of beaver, in appropriate locations, with the 

Utah Division of Wildlife Resources. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 115 

394. The Wasatch-Cache National Forest should protect bats. 

 Response: Two bats, the spotted and Townsend’s big-eared are Regional Forester 

designated sensitive species and are considered in biological evaluations required 

on all proposed projects. Others bats are considered when proposed projects may 

affect their habitat.

Fish 

395. The Wasatch-Cache National Forest should protect native cutthroat trout by 

restoring and expanding its habitat. 

Response: We recognize the role the Forest has in providing habitat for sensitive 

species and appreciate your support. Goals, subgoals, standards, guidelines and the 

identification of management prescription 3.1a provide for the protection of 

cutthroat trout habitat on the forest. In regards to the seven populations that may 

become extirpated with in next 15 years (FEIS, Table AQ-2) additional information 

has been provided. 

Some actions are outside the jurisdiction of the Forest Service. Fish stocking and 

setting harvest limits are under the direction of the Utah Division of Wildlife 

Resources or the Wyoming Game and Fish Department, for Utah and Wyoming 

respectively. 

396. The Wasatch-Cache National Forest should address the impacts of non-native 

fish species on native cutthroat trout 

Response: See response for comment 395. The Forest is active in participating in 

the cutthroat trout conservation agreements and strategies identified in Appendix B 

of the FEIS. Coordination with the states are an important part of any conservation 

work. 

397. The Wasatch-Cache National Forest should include the monitoring of trout 

habitat along with monitoring of condition indices to understand the ability of 

a given stream to support larger trout populations. 

Response: We agree that habitat conditions are important to monitor. Habitat 

parameters are collected during fish sampling efforts. Habitat surveys will also 

continue to be conducted although; they are not identified in Chapter 5 of the Forest 

Plan. Chapter 5 of the plan identifies that surveys will be conducted in at least one 

subbasin (4th level HUC) per year. 

398 The Forest Plan should de-emphasize non-native fish species 

Response: It’s important to understand that Native species are all species of plants 

and animals naturally occurring, either presently or historically, in any ecosystem of 

the United States. This is defined in the glossary and is taken from Executive Order 

11987, 42 FR 26949, 1977 WL 23618 as directed by the President of the United 

States, May 24, 1977. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 116 

It is Forest Service Policy (FSM 2640.3) to: 

2640.3 - Policy. It is Forest Service policy to: 

 1. Provide habitat for stocked species and assist in stocking and introduction 

operations to restore locally extinct indigenous species, to recover threatened and 

endangered species, and to introduce new species in coordination with State and 

Federal agencies. 

 2. Provide a variety of fishing, hunting, trapping, viewing, studying, and 

photographing opportunities and experiences in cooperation with the State fish and 

wildlife agencies. 

 3. Emphasize the protection, enhancement, and maintenance of habitats for 

production of wildlife and fish. Introductions or stocking of species may be made 

to restore resources following environmental changes, to provide recreation 

opportunities where reproduction is insufficient to meet demand, or to introduce 

new species desired by the public. 

 4. Favor native or desirable non-native species over new exotic species in stocking 

and introductions. 

399 The Wasatch-Cache National Forest should define “undesirable fish.” 

Response: Undesirable fish are those where a joint agreement, between the State 

fish and wildlife agency and the Forest Service, cannot be reached when proposal to 

introduce a species has been made. Undesirable fish may also include species 

found on the Forest where joint agreement has been reached, between the State fish 

and Wildlife agency and the Forest Service, and the determination made that the 

species is undesirable. 

2640.41 - Regional Forester. The Regional Forester shall: 

 1. Reach joint agreement with the appropriate State fish and wildlife agencies on 

proposals for introductions of the following fish and wildlife on National Forest 

System lands: 

a. Exotic and non indigenous fish and wildlife to a National Forest where they do 

not presently occur. 

b. Federally listed endangered and threatened species. 

 2. Coordinate exotic and Federally listed species introduction proposals with the 

Fish and Wildlife Service. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 117 

 3. Coordinate recommendations on hunting, fishing, or trapping regulations to 

State and Federal fish and wildlife agencies in States with more than one 

Supervisor's Office. 

2642 - INTRODUCTION OF INDIGENOUS AND NONINDIGENOUS 

WILDLIFE AND FISH. Occasionally, areas and conditions are found that would 

best suit fish or wildlife that are not indigenous to a forest. Introductions of wild 

turkeys in certain western forests are an example. Once introduced, further 

introductions are considered stocking and an environmental analysis is not required 

unless the action is determined to be controversial. 

400 The Wasatch-Cache National Forest should clarify Table AQ-1 to state that it 

refers to historic rather than current presence of fish species. 

Response: Thank you for your comment. This table has been corrected. 

Amphibians 

401 The Wasatch-Cache National Forest should clarify its management plan for 

amphibians 

Response: Invertebrate Species Considered section of the FEIS appendix B gives 

the direction for invertebrate species where little information is know. The Provo 

River, below Soapstone Creek, was identified as Management Prescription 3.1A to 

provide protection for known spotted frog populations on Forest. Beaver Creek is 

also designated as 3.1a to provide for aquatic species, which would include historic 

habitat for spotted frogs. 

No known monitoring is occurring in the Red Butte Research Natural Area for 

boreal toads. It is believed that if the boreal toad persists in the drainage the 

population is secure given the direction of management in RNAs. 

Management and reintroduction of species will be done in accordance with Forest 

Service Direction identified in response 399. 

 

402 The Wasatch-Cache National Forest should place amphibians on the priority 

list by adequately monitoring amphibians. 

Response: See response to 401 and 402. The forest is working with the State fish 

and wildlife agencies to better understand current distribution of amphibians on the 

forest and provide for their conservation. 

403. The Wasatch-Cache National Forest should recognize that the spotted frog is a 

historically occurring species 

Response: Thank you for your comment. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 118 

Birds and Raptors 

404. The Wasatch-Cache National Forest should incorporate the U.S.Fish and 

Wildlife Service’s raptor guidelines into all management activities. 

 Response: Although not specifically referred to in the Plan or FEIS the forest uses 

these guidelines whenever it is appropriate in project planning. 

405. The Wasatch-Cache National Forest should protect critical habitat for sensitive 

raptor species. 

 Response: Habitat for Regional Forester designated sensitive species is addressed 

and mitigation proposed in Biological Evaluations for site-specific projects. When 

other raptor species are identified within a proposed project area their presence, 

habitat needs, and mitigation measures to protect them are covered in the NEPA 

document. 

406. The Wasatch-Cache National Forest should adequately address goshawk 

management. 

406.1 By following recommendations in Conservation Strategy and Agreement 

for the Management of Northern Goshawk Habitat in Utah (HCS). 

 Response: In March 2000 the 1984 Forest Plan was amended to incorporate 

recommendations from the HCS. This has carried into the new plan and is covered 

by several standards and guidelines. 

406.2 By addressing livestock impacts to its habitat and prey base 

 Response: Livestock impacts are addressed in individual allotment management 

plans and covered in the standards and guidelines. 

Management Indicator Species 

407. The Wasatch-Cache National Forest should not dismiss a species from 

consideration as a management indicator species because it is difficult to 

monitor. 

 Response: One of the criteria used in selecting MIS was, “The MI is relatively 

easy to monitor, i.e. highly visible and in adequate numbers.” To fulfill the purpose 

of MIS there is no need to choose species that are difficult to monitor. The process 

and MIS should be those that meet the requirement and intent of the regulations. 

MIS are discussed in Appendix J. 

408. The Wasatch-Cache National Forest should improve its management of 

management indicator species. 

408.1 By prescribing goals, objectives, standards, guidelines, and mitigation 

measures for all management indicator species.

Response: The purpose of MIS is not to manage the species but to monitor it to 

help determine the effects of projects on a broader group of species. MIS are 

protected under regulations on diversity and viability. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 119 

408.2 By developing an adequate monitoring program for management 

indicator species. 

 Response: Monitoring of MIS is covered in Chapter 5 of the Forest Plan and 

Appendix J of the FEIS. 

408.3 By adequately monitoring macro-invertebrates as management indicator 

species. 

 Response: The Forest is not using macro-invertebrates as MIS in the new plan. 

Cost of analyzing samples was one of the main factors that could preclude doing the 

monitoring. Using the coefficient of condition for cutthroat trout will provide 

needed information on the aquatic health of the system (See the discussion in 

Appendix J of the FEIS). 

408.4 By monitoring management indicator species no more than once a year. 

 Response: Appropriate monitoring techniques and time intervals are identified in 

Chapter 5 of the Forest Plan and in Appendix J of the FEIS. 

408.5 By identifying habitat that is capable of supporting management 

indicator species. 

 Response: This is done in Appendix J of the FEIS. 

408.6 By adequately analyzing the relationships between management 

indicator species, habitat, and other species. 

 Response: The reasons for picking particular MIS and available habitats for them 

are found in Appendix J. CFR 219.19(6) indicates that analyzing the relationships 

between MIS and habitat changes is part of the monitoring report.

408.7 By identifying management indicator species for aquatic ecosystems and 

for botanical resources. 

 Response: The Forest is following Regional direction is the selection of MIS. 

408.8 By selecting additional terrestrial animals as management indicator 

species. 

 Response: The Forest picked species and the number of species needed to monitor 

the terrestrial and aquatic resources identified. 

409. The Forest Plan should provide a detailed discussion of targeted management 

indicator species. 

 Response: MIS are discussed in detail in Appendix J of the FEIS. 

410. The Wasatch-Cache National Forest should include predators as management 

indicator species, such as the wolverine and the mountain lion.

Response: See discussion on selecting MIS in Appendix J of the FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 120 

411. The Wasatch-Cache National Forest should rely more heavily on birds as 

management indicator species. 

Response: See Appendix J or the FEIS for the discussion of the selection of MIS.

412. The Wasatch-Cache National Forest should include neo-tropical migratory 

birds within the MIS/SAR category. 

Response: Neo-tropical migratory birds do not fit the selection criteria for MIS 

because the do not remain in the area year round and changes in population trends 

may be caused by factors outside of the control of the Forest. The subjects of MIS 

and SAR are distinctly different and have been split into two separate areas in the 

final EIS. SAR are discussed in Appendix B and MIS in Appendix J. SAR do 

include neo-tropical migrants where appropriate. 

413. The Wasatch-Cache National Forest should designate the sage grouse as a 

management indicator species instead of the vesper sparrow. 

Response: Sage grouse were considered but are not evenly distributed across the 

sage steppe habitat type on the Forest to be an effective MIS. The vesper sparrow 

has also been dropped. See discussion in 412 above.

Threatened, Endangered, and Sensitive Species 

Threatened, Endangered, and Sensitive Species General 

414. The Wasatch-Cache National Forest should revise the definition of sensitive 

species 

 Response: The Regional Forester is responsible for identifying which species will 

be identified as sensitive as directed by Forest Service Manual 2670. 

2672.11 - Identification of Sensitive Species. Regional Foresters shall identify 

sensitive species occurring within the Region. They shall examine the following 

sources as possible candidates for listing as sensitive species: 

 1. Fish and Wildlife Service or National Marine Fisheries Service candidates for 

Federal listing (categories 1 and 2) under Federal Register Notice of Review. 

 2. State lists of endangered, threatened, rare, endemic, unique, or vanishing species, 

especially those listed as threatened under State law. 

 3. Other sources as appropriate in order to focus conservation management 

strategies and to avert the need for Federal or State listing as a result of National 

Forest management activities. 

The changing of the definition and/or the addition or removal of species to or from 

this list is outside the scope of this analysis and decision. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 121 

415. The Wasatch-Cache National Forest should provide a full range of standards 

and procedures for the selection of sensitive species. 

 Response: See response to comment 414. 

416. The Wasatch-Cache National Forest should manage all threatened, 

endangered, and sensitive species in the context of the overall, functional 

ecosystem 

 Response: Thank you for your comment. The plan tries to address biodiversity. 

See issue 3 in the Plan. 

417. The final Forest Plan should include actions to restore habitat for threatened 

and endangered species such as the Lynx. 

 Response: In the eleven counties in Utah that the U.S. Fish and Wildlife Service 

(FWS) has identified as lynx counties the Forest has consulted with the FWS on 

ongoing activities. In the Forest Plan Revision, standards and guidelines have been 

incorporated to deal with Federally listed species including the lynx. The Plan also 

emphasizes management that moves the forest toward properly functioning 

condition and the historic range of variability which is the habitats and age classes 

that the lynx existed in over time. 

418. The Wasatch-Cache National Forest should improve monitoring of threatened, 

endangered, and sensitive species 

418.1 By increasing the plan objectives for non-project related monitoring of 

threatened and endangered species

 Response: See the monitoring section in the Forest Plan. These species will be 

monitored as projects that could potentially impact them are planned and 

implemented. 

418.2 By including clear monitoring requirement for threatened, endangered, 

and sensitive raptors 

 Response: See the monitoring section in the Forest Plan. These species will be 

monitored as projects that could potentially impact them are planned and 

implemented. The Forest will continue to work with the U.S. Fish and Wildlife 

Service and the States in these efforts. 

418.3 By monitoring threatened, endangered, and sensitive plants 

 Response: See the monitoring section in the Forest Plan. In addition to broadscale inventory and monitoring of TES plants, these species will also be monitored 

as projects that could potentially impact them are planned and implemented. 

419. The Wasatch-Cache National Forest should include specific and individual 

conservation and recovery plans for all threatened and endangered species 

including the western boreal toad. 

 Response: The development of conservation and recovery plans is outside the 

scope of this analysis and decision. A number of the species are currently covered 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 122 

by conservation agreements and strategies (see Conservation approaches for 

species-at-risk to maintain existing populations in Appendix B of the FEIS). 

See also response to comment 402. 

420. The Wasatch-Cache National Forest should include specific and individual 

conservation and recovery plans for all threatened and endangered species 

 Response: Individual species were reviewed along with potential threats. 

Standard and guidelines were then reviewed and/or developed to reduce the threats 

to the species at risk. Site-specific analysis and the development of implementation 

actions will be required to further reduce the potential threats to T, E, and S species. 

These site-specific analyses are beyond the scope of this analysis and decision. 

Adequacy of Analysis 

421. The Wasatch-Cache National Forest should conduct surveys for sensitive 

species before allowing certain activities 

 Response: As part of the site-specific planning process, Threatened, Endangered 

and Forest Service Sensitive species are reviewed and an analysis conducted to 

determine potential impacts. This information is maintained in a Biological 

Assessment and Biological Evaluation. 

422. The Wasatch-Cache National Forest should recognize that the reconstruction 

of the Red Butte Reservoir dam and its subsequent maintenance plans to 

provide a refuge for the June sucker are premature 

 Response: This desired future is recognizing Public Law 106-65 dated October 5, 

1999. This law directs the Secretary of the Army to convey Red Butte Dam, 

Reservoir and other improvements to the Central Utah Water Conservancy District. 

423. The Wasatch-Cache National Forest should add Botrychium linear to 

Table B-4-1 

 Response: This plant has been added to Table B-4-1 and additional information 

on this species is in Chapter 3, Topic 2, Biodiversity and Viability, Botanical 

Resources, FEIS Appendix F, and in the Forest Plan, Chapter 4C under the Central 

Wasatch Management Area. 

424. The Forest Plan should include a discussion of threatened and endangered 

species in the Environmental Consequences section 

Response: This has been done. Thank you for your comment.

425. The Wasatch-Cache National Forest should add a sentence to the Endangered 

Species Act description stating that each federal agency will ensure that their 

actions are not likely to jeopardize threatened and endangered species 

 Response: This is covered under manual direction: 

Forest Service Manual 2670.11 - Endangered Species Act. Section 2 of the 

Endangered Species Act of 1973, as amended 1978, 1979, 1982 and 1988 (16 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 123 

U.S.C. 1531 et seq.; hereinafter referred to as the act) declares that ". . . all Federal 

departments and agencies shall seek to conserve endangered species and threatened 

species and shall utilize their authorities in furtherance of the purposes of this Act." 

Vegetation 

Vegetation General 

426. The Wasatch-Cache National Forest should clarify vegetation management. 

 Response: The forest will be managed for a range of conditions that occurred 

historically, and not for any static state. Should climates change dramatically, the 

conditions the forest would be managed for would evolve accordingly. We have 

not seen, however, these kinds of dramatic changes within a planning period (10-15 

years). 

427. The Wasatch-Cache National Forest should clarify its finding of greater 

vegetative diversity in the Wasatch Mountains. 

 Response: No greater inventories have been conducted in the Wasatch Mountains 

than on any other portion of the Forest. In fact, other portions of the Forest have 

been inventoried to a much greater extent because of the timber and livestock 

production that occurs there. The greater diversity has been recognized through 

general observations and recent vegetation mapping which shows that this area 

includes a large variety of vegetation types because of the geological differences, 

which result in different soil characteristics, as well as the annual precipitation. 

428. The Wasatch-Cache National Forest should provide a mix of vegetative age 

classes to maintain biodiversity. 

 Response: Guideline G14 and the associated table describe the desired mix of age 

classes for dominant cover types of the Forest. Alternative 7 is focused on moving 

the vegetation cover types toward properly functioning condition. Table VEG-3 in 

FEIS Chapter 2, Topic 2 – Biodiversity and Viability, Vegetation shows that 

Alternative 7 treats (harvest, prescribed fire, and mechanical treatments) an average 

of nearly 9,000 acres per year to move toward properly functioning conditions. 

This will help maintain biodiversity. 

429. The Wasatch-Cache National Forest should maintain more old growth forest 

to protect threatened and endangered species. 

 Response: The direction outlined in the Forest Plan under Guideline G14, 

illustrates a variety in age classes by cover type; these range from about 20 percent 

in forested communities, to 20-40 percent in oak and mahogany communities. 

Forest wide Standard S13 has been modified to reflect this change in the minimum 

amount of old growth. It states that at least 20 percent of each forested cover type 

within each ecological section of the Forest “shall be maintained with old forest 

landscape structure”. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 124 

430. The Wasatch-Cache National Forest should ensure adequate amounts of snags 

and downed wood. 

 Response: Guideline 16 and the associated table describe the amount of snags and 

coarse woody debris that is desired following timber harvest activities. Additional 

management direction for snags and coarse woody debris can be found in Forest 

Service Manual 5150 and FSM 2550. 

431. The Wasatch-Cache National Forest should use the wetlands Standard as a 

starting point for the development of an alpine vegetation standard. 

 Response: A modification has been made to Guideline 9 that includes avoiding 

soil-disturbing activities in alpine areas as well as on steep, erosive, and unstable 

slopes, and in riparian, wetlands, floodplains, and wet meadows. 

432. The Wasatch-Cache National Forest should act to reverse aspen decline. 

 Response: The decision alternative focuses on such a reverse by treating 

approximately 3,700 acres of aspen, conifer, and conifer with aspen each year. 

Many conifer treatments would be focused in areas that historically had aspen and 

that still have the ability to be dominated by aspen following treatment. At this rate, 

aspen would return to its properly functioning condition within 8 decades. 

433. The Wasatch-Cache National Forest should classify the treatment in conifer 

and aspen stands for increased water output as a vegetative treatment. 

 Response: One benefit of replacing conifers with aspen, as a part of treatments to 

increase age class diversity in aspen communities (See response 432), is that water 

yield may also increase. The extent of this increase is not easily identified, but 

some research has shown this to occur. 

Increased water yield is considered a secondary benefit for primary treatment needs 

such as vegetative treatments to restore properly functioning condition and timber 

harvest for commercial purposes. The FEIS section on Effects on Soil and Water 

Resources from Timber Harvest/ Vegetation Treatment under Topic 1, Watershed 

Health states that the realities of generating significant water yield are limited 

because of land ownership, land allocation, vegetation type, variable elevations and 

aspects, and multiple resource needs. This is why the Forest Plan FEIS does not 

propose increasing water yield as primary output. 

434. The Wasatch-Cache National Forest should maintain sagebrush communities. 

 Response: As noted in the FEIS, (Chapter 3, Topic 10 – Fire Management), 

sagebrush communities are currently classified as being in either Fire Condition 

Class 2 (Moderate alterations to the historic disturbance are clearly evident, such as 

one or more missed fire return intervals) and Condition Class 3 (The disturbance 

regime has been significantly altered) with a fire return interval of 0-35 years. 

Given that fires played an important historical role in the ecology of these 

sagebrush communities on the Forest, we propose to treat approximately 3,000 

acres a year of sagebrush and pinyon-juniper that occurs on lands historically 

dominated by sagebrush to begin to return these communities to properly 

functioning conditions. As a result some of these areas will produce forage for 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 125 

livestock, but all acres will provide for a greater variety of wildlife habitat as well 

as maintaining or improving watershed conditions. 

435. The Wasatch-Cache National Forest should protect the habitat for five unique 

species of wildflowers. 

 Response: Guideline G23 has been modified and provides for protection for 

populations of rare plant species across the forest. 

436. The Wasatch-Cache National Forest should revegetate with seed from native 

plants. 

 Response: The Forest Plan provides Guideline G22, which directs the use of native 

seed in revegetation efforts. 

437. The Wasatch-Cache National Forest should preserve nonvascular plant 

species. 

 Response: We noted the value of non-vascular plants in FEIS, Chapter 3, Topic 2 

– Biodiversity and Viability, Botanical Resources. Additional information has been 

added on the distribution and value of cryptogamic crusts to this chapter. Difficulty 

of identification of many of these non-vascular plants makes the development of 

species-specific management more difficult. 

Adequacy of Analysis 

438. The Wasatch-Cache National Forest should investigate the causes of tree 

mortality and mortality in old growth trees. 

 Response: The dominant cause of tree mortality is an overall aging of exiting 

forest communities as a result of successful fire exclusion. Because of this, age 

classes are skewed toward the older age classes, which means many more acres of 

trees susceptible to disease. There is a lack of diversity in age classes across the 

landscape, a build up of associate fuels, and increased disease, which have 

increased the acres in fire condition class 3 as described in FEIS, Chapter 3, Topic 

10 – Fire Management. 

Noxious Weeds 

439. The Wasatch-Cache National Forest should adequately address noxious weed 

management. 

439.1 By fairly evaluating the spread of noxious weeds 

439.2 By developing a guideline which prohibits certain activities in areas 

where noxious weeds occur 

 Response: We have added information on the location of noxious weeds in FEIS 

Appendix H. A guideline (G25) for the management of noxious weeds has been 

added and Forest Plan Appendix III has been updated. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 126 

440. The final Forest Plan should include a clear definition and list of noxious 

weeds to prevent removal of desirable species. 

 Response: A list of Utah and Wyoming Noxious Weeds found in the different 

ecological sections of the Wasatch-Cache National Forest has been added to FEIS, 

Appendix H. A definition of noxious weed has been added to the Forest Plan and 

FEIS Glossaries. 

441. The Wasatch-Cache National Forest should disclose the locations that are 

currently affected by noxious weeds. 

 Response: See response to 439. 

442. The Forest Plan should include all Standards and Guidelines applied by 

vegetative community. 

 Response: The standards and guidelines in Appendix B2 were incorrectly 

displayed and have been removed from that Appendix and have been replaced with 

those in the Forest Plan. 

Effects of Activities/Disturbance 

443. The Wasatch-Cache National Forest should fence off representative vegetation 

areas from human and livestock use to study the effects of use. 

 Response: Exclosures have been used in the past to study areas with relatively 

little disturbances. While some of these exclosures have been maintained and some 

new exclosures established within the past 10 years, others have fallen into 

disrepair. Those exclosures that have not fallen into disrepair will likely continue to 

be maintained. In addition, proposed and existing Research Natural Areas are 

available for such studies and additional exclosures may be established on a sitespecific scale to study the effects of various uses and management actions on 

different vegetation types. 

444. The Wasatch-Cache National Forest should not spray herbicides or synthetic 

chemicals. 

 Response: This plan does not address the treatment methods allowed for noxious 

weeds and these will be addressed through future analysis. While we feel that, 

while the use of herbicides should be limited, the ecological impacts of the spread 

of noxious weeds may outweigh the ability to control them with other methods 

alone. 

445. The Wasatch-Cache National Forest should not apply snow-stabilizing 

chemicals such as ammonium over ski runs in alpine habitats because the 

chemicals may lead to noxious plant invasion. 

 Response: The use of snow stabilizing chemicals on ski runs in alpine habitats has 

not resulted in noxious weed invasions on the Forest and such invasions are not 

anticipated. We will continue to monitor these areas for such invasions. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 127 

446. The Wasatch-Cache National Forest should prohibit plant collection. 

 Response: Plant collection for sustainable cultural uses is described in a Forestwide subgoal in the Forest Plan. Other direction for the collection of plants is also 

described in Guidelines 31 and 32 in the Forest Plan. These collections will 

ultimately benefit the management and knowledge of plant species on the Forest. 

447. The Wasatch-Cache National Forest should adequately address plant 

collection in the Forest Plan. 

 Response: See Response to 446. 

Topic 3: Road and Access Management 

Infrastructure General 

Adequacy of Analysis 

448. The Wasatch-Cache National Forest should use 2001 as a benchmark for peak 

traffic congestion targets in the Tri-Canyon area Because 2000 was a weak ski 

season. 

 Response: Thank you for your comment. The wording has been adjusted to set 

parking at 2000 levels not refer to congestion levels. 

Trailhead Access and Parking 

449. The Wasatch-Cache National Forest should actively encourage mass transit as 

proposed in the Draft EIS. 

 Response: Thanks for your comment. See the desired future condition for the 

Central Wasatch Management Area Roads/Trails/Access. 

449.1 By limiting the number of cars 

 Response: See the desired future condition for the Central Wasatch Management 

Area Roads/Trails/Access. We are setting parking space limits. 

449.2 By providing shuttle bus services 

 Response: See the desired future condition for the Central Wasatch Management 

Area Roads/Trails/Access. We are setting parking space limits. 

450 The Wasatch-Cache National Forest should work actively with other agencies 

and parties to develop a comprehensive transportation system for the TriCanyon area and by developing a ride and ski pass. 

 Response: See the desired future condition for the Central Wasatch Management 

Area Roads/Trails/Access. 

451. The Wasatch-Cache National Forest should work with the Utah Department of 

Transportation and Snowbird to add a bus pull-out lane and bus stops at the 

White Pine Canyon trailhead. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 128 

 Response: See the desired future condition for the Central Wasatch Management 

Area Roads/Trails/Access. See response 496. 

452. The Wasatch-Cache National Forest should adopt the proposed parking 

capacity limit to encourage mass transit. 

 Response: Thank you for your comment. 

453. The Wasatch-Cache National Forest should change the parking lot guideline to 

a standard and reword it. 

 Response: Thanks for your comment. This has been changed. 

454. The Wasatch-Cache National Forest should provide more parking. 

Response: We believe we are at a maximum parking capacity for the Tri-canyon 

area. Other modes of transportation can still be explored. 

 

454.1 By permitting additional resort parking 

 Response: See the desired future condition for the Central Wasatch Management 

Area Roads/Trails/Access. 

454.2 By providing additional parking areas only at the mouths of canyons 

 Response: See “Outside Framework Level of Analysis” as identified in the FEIS. 

This is outside the scope of this analysis. 

454.3 By adding more winter trailhead parking 

 Response: This can best be dealt with during travel management planning. 

Travel management planning is part of the objectives of the Forest Plan. See 

“Outside Framework Level of Analysis” as identified in the FEIS. 

455. The Wasatch-Cache National Forest should state in the Forest Plan that it will 

not impose greater parking regulations than those already imposed in 

Snowbird’s Master Development Plan Record of Decision. 

 Response: We believe that we need to maintain flexibility to take appropriate 

action to protect or improve water quality and watershed condition, as more 

information become available. 

456. The Wasatch-Cache National Forest should develop separate parking areas for 

snowmobilers and skiers In Franklin Basin. 

 Response: See response 454.3 The citation listed for Franklin Basin (Draft Plan 

4-73) is the desired future. It is the Forest’s desired future that in the Franklin Basin 

that parking for both motorized and non-motorized winter dispersed recreation use 

is provided and that conflicts between these uses have been minimized through 

some separation of used, clearly marked areas, user cooperation and additional law 

enforcement. Again this is the desired future and does not currently exist. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 129 

Trailhead Facilities and Signs 

457. The Wasatch-Cache National Forest should reconsider placement of High 

Uintas Wilderness trailheads. 

 Response: See response 454.3 

458. The Wasatch-Cache National Forest should provide garbage cans at 

trailheads. 

 Response: This is outside the scope of the Revised Forest Plan, but will forward 

the information to the responsible managers for their consideration. 

459. The Wasatch-Cache National Forest should provide rest room facilities at 

trailheads for year-round recreationists. 

 Response: See response to concern statement 458. 

460. The Wasatch-Cache National Forest should focus accessibility efforts on 

developed recreation facilities, rather than providing more motorized 

opportunities. 

 Response: We are trying to make our developed recreational facilities more 

handicap accessible are these facilities are upgraded. This is also the direction for 

the Forest wide goal under recreation 

461. The Wasatch-Cache National Forest should improve signage 

461.1 By replacing existing trail markers with more visible ones 

 Response: The Forest is following the existing National direction in this area as 

identified in “Sign and Poster Guidelines for the Forest Service, Engineering Staff, 

Washington, DC 1998. Publication EM-7100-15”. Trail and road signing; closing, 

leaving open or adjusting road objectives and parking are developed during travel 

management planning. Travel planning is one of the objectives to be dealt with 

during this next planning period. See also “Outside Framework Level of Analysis” 

as identified in the FEIS. 

461.2 By adding more wilderness trail signs 

 Response: See response to 461.1. 

461.3 By adding signs at lakes that list restrictions 

 Response: See response to 461.1. 

461.4 By changing informational signs at trailheads so as not to imply that 

motorized users cause greater damage 

 Response: See response to 461.1. 

461.5 By creating a standard signing convention for travel restrictions to 

reduce confusion. 

 Response: See response 461.1. 

461.6 By making signs larger and using more colors 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 130 

 Response: See response 461.1. 

462. The final Forest Plan should specify use of ACQ lumber in on-forest 

construction projects instead of copper-chromium-arsenate-treated lumber 

due to toxicity concerns. 

 Response: See response 461.1. 

Trailhead – Site-Specific 

463. The Wasatch-Cache National Forest should add more parking lots at specific 

trailheads in the Beaver and Sinks areas 

 Response: See response 461.1. 

464. The Wasatch-Cache National Forest should develop a trailhead at Norway 

Flats. 

 Response: See response 461.1. 

465. The Wasatch-Cache National Forest should add a sign for the Mineral Fork 

Trailhead 

 Response: See response 461.1. 

Road System Management 

Adequacy of Analysis 

466. The Final EIS should include an expanded discussion of road impact 

mitigation. 

 Response: See response 461.1. Additional information is also provided in the 

roads analysis found in the FEIS Appendix B-5. 

467. The final Forest Plan should specify how maintenance workers will apply the 

Watershed Conservation Practices. 

 Response: See response 461.1. Additional information is also provided in the 

roads analysis found in the FEIS Appendix B-5. The training of personnel is 

outside the scope of this analysis. 

468. The Final EIS should include a comparison of the effects of single-track 

motorized trails and roads. 

 Response: Many of the effects from access and travel management, be it from 

roads or trails, are similar. Some of the analysis however did recognize the 

difference in affects as identified in the Aquatic Diversity and Viability section of 

Appendix B in the FEIS. Appendix II in the Forest Plan identifies mitigation efforts 

to reduce sediment runoff from roads and trails. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 131 

Legal Considerations 

469. The Final EIS should evaluate direct and cumulative impacts of road closures 

on Revised Statute 2477 routes 

 Response: See the FEIS under RS2477 road assertions of counties in the Outside 

of Forest Service Authority section. 

470. The Wasatch-Cache National Forest should recognize Revised Statute 2477 

road rights-of-way claimed by local governments for all routes in existence 

prior to 1976. 

 Response: See response 469. 

471. The Wasatch-Cache National Forest should recognize that, by definition, 

Revised Statute 2477 road rights-of-way invalidate roadless areas. 

 Response: See response 469. 

Road Construction and Reconstruction General 

472. The Wasatch-Cache National Forest should not expand the road and off-road 

vehicle trail network. 

 Response: See response to 461.1. 

473. The Wasatch-Cache National Forest should build roads to the center of 

wilderness areas. 

 Response: See response to 461.1. 

474. The final Forest Plan should allow temporary road construction and 

potentially design them for later recreational use. 

 Response: Temporary roads are permitted under the Forest Plan. See also 

response to 461.1. 

475. The Wasatch-Cache National Forest should reconstruct road and trail 

segments that are causing environmental impacts rather than close them. 

 Response: See response 461.1. 

476. The final Forest Plan should prohibit roads across amphibian travel routes 

and prohibit new construction. 

 Response: See response to 461.1. 

477. The Wasatch-Cache National Forest should avoid constructing roads in tundra 

and talus ecosystems due to the environmental sensitivity of these areas. 

 Response: Guidelines 7 and 9 addresses this. 

478. The Wasatch-Cache National Forest should delete the first two sentences in the 

second paragraph on page 4-89 of the proposed plan because motorized route 

construction requires separate National Environmental Policy Act analysis. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 132 

 Response: This is the desired future for the North Wasatch, Ogden Valley 

Management Area. It is believed that the analysis of the roads in the Public Grove 

area is important to define the future uses in the area. 

Road Construction and Reconstruction in Roadless Areas 

479. The Wasatch-Cache National Forest should allow road realignment and 

reconstruction in roadless areas 

 Response: See Allowed Activities Explanation. “Where Road construction is not 

allowed by Management Prescription the responsible official may authorize road 

construction or reconstruction when: . . . d. Realignment is needed to prevent 

irreparable resource damage by a classified road.” 

480. The Wasatch-Cache National Forest should allow temporary road 

construction in roadless areas and design them for later recreational use. 

 Response: See the roadless area evaluation in Appendix C. of the FEIS and 

response 461.1. 

481. The final Forest Plan should redefine road construction so that trail 

construction in inventoried roadless areas is clearly allowed 

 Response: This is now clearly identified in Chapter 2 of the FEIS. 

482.1 The Wasatch-Cache National Forest should prohibit road construction 

in roadless areas. 

 Response: This is within the range of alternatives as identified in the FEIS. 

 

482.2 Mount Naomi area 

 Response: This is within the range of alternatives as identified in the FEIS. 

482.3 South of the North Slope Road 

 Response: This is within the range of alternatives as identified in the FEIS. 

Road Construction and Reconstruction – Site-Specific 

483. The Wasatch-Cache National Forest should build a loop trail starting at state 

road sheds in Logan Canyon. 

 Response: Trail and road signing; closing, leaving open or adjusting road 

objectives and parking are developed during travel management planning. Travel 

planning is one of the objectives to be dealt with during this next planning period. 

See also “Outside Framework Level of Analysis” as identified in the FEIS. 

484. The Wasatch-Cache National Forest should build an interlink trail for off-road 

vehicles parallel to Highway 152 in Big Cottonwood Canyon. 

 Response: See response 483. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 133 

485. The Wasatch-Cache National Forest should prohibit road construction in 

Public Grove 

 Response: See response 483. 

Road Maintenance 

486. The Wasatch-Cache National Forest should act to address its road 

maintenance backlog 

 Response: See response 483. 

487. The Wasatch-Cache National Forest should be more efficient with road 

maintenance funds and personnel. 

 Response: See response 483. 

488. The Wasatch-Cache National Forest should raise road maintenance and 

construction standards to lessen environmental impacts. 

 Response: A number of the roads that are adjacent or that pass through the Forest 

are interstate, U.S. or State highways. Counties also own some of these roads. We 

can work cooperatively with the agencies that manage these roads and their rightof-ways but cannot control their activities. Such is the case with State Route 152 up 

Big Cottonwood Creek or US Highway 89 up Logan Canyon. Standards 2 and 19 

provide direction to reduce or eliminate sediment from entering water bodies from 

Forest roads. 

489. The Wasatch-Cache National Forest should rewrite S-17 to apply to all roads 

and trails, not just decommissioned ones to ensure proper drainage. 

 Response: Standards 2 and 19 address your concern. 

490. The Wasatch-Cache National Forest should remove all culverts and replace 

them with bridges across permanent streams. 

 Response: It is unrealistic and we believe unnecessary to replace all culverts with 

bridges. We do identify that the broad Forest subgoal is to “Maintain and/or restore 

stream channel integrity, channel processes, and sediment regimes . . .”. We are 

also trying to meet the Forestwide Goal for Toad/Trail and Access Management. 

These goals, as defined in Forestwide Direction, are desired conditions to be 

achieved in the future. They are normally expressed in broad, general terms and are 

timeless. They may not be achieved on every site due to site-specific factors or 

existing condition. 

 

491. The Wasatch-Cache National Forest should increase bridge maintenance. 

 Response: See response 488. 

492. The final Forest Plan should address minimizing the impacts of road 

maintenance near stream channels. 

 Response: See response 488. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 134 

493. The Wasatch-Cache National Forest should implement designated access 

points to streams. 

 Response: We appreciate your support in this area. 

494. The Wasatch-Cache National Forest should not close roads currently being 

maintained by volunteers. 

 Response: We believe that we need to maintain flexibility to take appropriate 

action to protect water quality and watershed health to meet the goals and desired 

future conditions as stated in the Forest Plan. This may require that roads currently 

being maintained through agreement with special user groups would need to be 

closed. Such closures would be identified through site-specific analysis during 

travel management planning. See also “Outside Framework Level of Analysis” in 

the FEIS. 

Road Maintenance – Site-Specific 

495. The Wasatch-Cache National Forest should increase road maintenance in 

roadless areas on the Logan Ranger District. 

 Response: ATV vehicle registration fees are collected and distributed by the 

states. They are not generally transferred to the Forest to maintain Forest roads and 

trails for ATV use. Money used to maintain Forest roads and trails are allocated 

from the Federal and not state funds. 

496. The Wasatch-Cache National Forest should grade Forest Road 041 or restrict 

it to off-road vehicles and motorcycles. 

 Response: To address this individual concern through the Forest Plan is outside 

the scope of this analysis and is best dealt with through site-specific analysis during 

travel management planning as identified in the Forest Plan objectives. See also 

“Outside Framework Level of Analysis” in the FEIS and the roads analysis in the 

planning documents. 

497. The Wasatch-Cache National Forest should plow the Tony Grove Lake access 

road in the winter. 

 Response: See response 496. 

498. The Wasatch-Cache National Forest should not oil the Sinks Road. 

 Response: See response 496. 

Road Closure 

499. The Wasatch-Cache National Forest should only use signs to close roads rather 

than gates or traps. 

 Response: Roads are closed for a variety of reasons. Some are closed and 

retained in maintenance level 1 standard because administrative access is still 

required. Others are closed are rehabilitated because the no longer deemed 

necessary. The local forests do not establish fines for closure violations. These are 

set at a National level. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 135 

500. The Wasatch-Cache National Forest should not place tank traps where winter 

motorized users may get stuck in them. 

 Response: See response 496. 

501. The Wasatch-Cache National Forest should close roads in environmentally 

sensitive areas. 

 Response: See response 496. 

502. The Wasatch-Cache National Forest should close roads strategically in order 

to link roadless areas to increase connectivity. 

 Response: See response 496. 

Road Removal and Obliteration 

503. The Wasatch-Cache National Forest should reduce the miles of roads on the 

forest. 

 Response: See response 496. 

504. The Wasatch-Cache National Forest should follow through with closure and 

reclamation of roads after timber projects are complete because cumulative 

environmental effects are occurring. 

 Response: See response 496. The correction of newly created unauthorized roads 

is dealt with in Standard S3, which closes unclassified roads and trails. 

505. The Wasatch-Cache National Forest should continue converting roads to 

single-track trails, but do not restrict bicycling to those routes only. 

 Response: See response to 496. 

506. The Wasatch-Cache National Forest should consider an alternative that 

converts the backlog of unmaintained roads to motorized trails. To provide 

challenging recreation opportunities at lower costs. 

 Response: See response 496. 

507. The Wasatch-Cache National Forest should prioritize restoration efforts for 

environmentally damaging roads and ways. 

 Response: See response 496. 

508. The Final EIS should accurately address the environmental consequences of 

obliterating roadways. 

 Response: See response 496. 

Road Removal and Obliteration – Site-Specific 

509. The Wasatch-Cache National Forest should decommission and restore roads 

and ways in the Bear Management Area. 

 Response: See response 496. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 136 

Ways and Unclassified Roads 

510. The Final EIS should clarify the origin of unclassified roads. 

 Response: We agree that the best way to handle road closures is through sitespecific analysis. See response 496. 

511. The Final EIS should disclose how many miles of ways will be obliterated by 

alternative. 

 Response: Currently there is no set number of roads identified in the Forest Plan 

to be obliterated. This will be dealt with through Objective for OHV and nonmotorized travel management planning when implemented. See also response 496. 

512. The final Forest Plan should include specific road density limits of no more 

than 1 mile per square mile to address ongoing habitat fragmentation. 

 Response: Road density was a factor identified in the roads analysis in the FEIS. 

See response 496. 

513. The Wasatch-Cache National Forest should not allow unclassified roads to be 

added to the Wasatch-Cache National Forest system. 

 Response: Standard 3 has been added to avoid the adding of unclassified roads 

and trails. 

514. The Wasatch-Cache National Forest should prioritize rehabilitation and 

closure of ways. 

 Response: See response 513. 

515. The Wasatch-Cache National Forest should increase funding to continue to 

reclaim off-road vehicle-created roads. 

 Response: Thank you for your comment. Funding for road decommissioning has 

been a Nation emphasis the past few years. 

516. The Wasatch-Cache National Forest should balance the obliteration of 

redundant ways with recreational opportunity values. 

 Response: See response 496. 

517. The Final EIS should discuss the impacts and mitigation of the growing 

problem of braided trails. 

 Response: See response 496. 

Scenic Byways 

518. The Wasatch-Cache National Forest should not upgrade the scenic byway 

between Red Bank and Beaver to accommodate higher speeds. 

 Response: See response 488. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 137 

519. The Wasatch-Cache National Forest should design the proposed Bear Lake 

overlook rest area to minimize impacts to campers at the Sunrise 

Campground. 

 Response: To address this individual concern through the Forest Plan is outside 

the scope of this analysis and is best dealt with through site-specific. See also 

“Outside Framework Level of Analysis” in the FEIS. 

Trail System Management 

Trail System Management General 

520. The final Forest Plan should specifically address non-motorized trail system 

management and work in coordination with local user groups. 

 Response: Public involvement continues to play an import part in planning 

efforts at the local and Forest levels. This is part of the National Environmental 

Policy Act. See Appendix A of the FEIS. 

521. The Wasatch-Cache National Forest should develop a comprehensive trails 

plan with local governments and user groups on the Logan Ranger District. 

 Response: See response 496. 

522. The final Forest Plan should retain emphasis on trail system planning in the 

Tri-Canyon area to balance use with watershed protection. 

 Response: See response 496. 

523. The Wasatch-Cache National Forest should remove the “mostly derived from 

existing routes” language from Roads/Trails/Access Desired Condition 

descriptions in the proposed Forest Plan. 

 Response: We have improved the discussion about trails in the management 

prescription areas of the plan and FEIS. The management prescriptions in most 

cases allow for the construction of new trails. However in area of concern for 

wildlife (MPC 3.2) no net increase in trail density is desirable (G3.2D-3). See also 

response 496. 

Trail Construction and Reconstruction General 

524. The Wasatch-Cache National Forest should meet trail construction and 

reconstruction targets in the Forest Plan. 

 Response: The ability of a forest to implement a forest plan is dependent on 

budgetary constraints. The Forest was very optimistic in the 1986 plan. We have 

tried to be more realistic in this plan. 

525. The Wasatch-Cache National Forest should provide sufficient summer 

motorized use zones to allow expanded trail systems. 

 Response: With the clarification of allowing or not allowing trail construction 

identified in the FEIS, trail construction is allow in Alternative 5 in all management 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 138 

prescriptions with the exception of existing wilderness, research natural areas, and 

undeveloped areas. Alternative 1 provides the other perspective. We believe this 

provide a sufficient range of new trail development opportunities for the analysis. 

526. The Wasatch-Cache National Forest should adopt the Recreation Opportunity 

Spectrum map in Alternative 7 submitted by the public. 

 Response: See response 525. 

527. The Wasatch-Cache National Forest should expand the motorized trail 

network. 

 Response: See response 496. 

527.1 By taking advantage of existing snowmobile parking lots and trail 

corridors 

 Response: See response 496. 

527.2 By reopening some old logging roads as off-road vehicle trails 

 Response: See response 496. 

528. The Wasatch-Cache National Forest should not expand the motorized trail 

network because there is already sufficient opportunity. 

 Response: See response 525. 

529. The Wasatch-Cache National Forest should first maintain and streamline the 

existing motorized trail system before constructing new trails. 

 Response: See response 525. 

530. The Wasatch-Cache National Forest should provide more motorized loop trail 

systems to reduce damage and user-created trails. 

 Response: See response 496. 

531. The Wasatch-Cache National Forest should develop motorized loop trail 

systems at the completion of timber sales to compensate for loss of opportunity 

due to road closures. 

 Response: See responses 525 and 496. 

532. The Wasatch-Cache National Forest should spend more money to build 

durable off-road vehicle trails. 

 Response: See response 496. 

533. The Wasatch-Cache National Forest should build more single-track 

motorcycle and mountain bike trails. 

 Response: See response to concern statements 525 and 496. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 139 

534. The Wasatch-Cache National Forest should not designate single use trails to 

prevent increases in trail density 

 Response: See response 525. 

Trail Construction and Reconstruction in Roadless Areas 

535. The Wasatch-Cache National Forest should allow motorized trail construction 

in roadless areas should be consistent with the Roadless Area Conservation 

Rule. 

 Response: See response 525 

536. The Wasatch-Cache National Forest should not build motorized trails in 

roadless areas because there are enough trails already. 

 Response: See response 525 

Trail Construction and Reconstruction – Site Specific 

537. The Wasatch-Cache National Forest should complete the Bonneville Shoreline 

Trail. 

 Response: The Bonneville Shoreline Trail is identified as one of the objectives in 

the Forest Plan. 

538. The final Forest Plan should include some means of accommodation for 

routing of the Bonneville Shoreline Trail through roadless and wilderness 

areas. 

 Response: Law sets wilderness designations. It is outside the scope of this 

document to make such recommendation in regards to the Bonneville Shoreline 

Trail until an analysis to address this site-specific concern is completed. 

 

539. The Wasatch-Cache National Forest should expand Objective 20 to assure that 

completion of the Bonneville Shoreline and Great Western trails will not 

adversely impact protected species. 

 Response: We will be following the response to the concern statement 425 in this 

area. 

540. The Wasatch-Cache National Forest should reconstruct the Pfeifferhorn 

hiking route. 

 Response: See response 496. 

541. The Wasatch-Cache National Forest should reconstruct the trail to the top of 

Mount Ogden for public safety. 

 Response: See response 496. 

542. The Wasatch-Cache National Forest should extend the North American Trail. 

 Response: See response 496. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 140 

543. The Wasatch-Cache National Forest should complete the Great Western Trail. 

Adopt proposed Alternative 7 to facilitate future additions. 

 Response: The completion of the Great Western Trail is identified as one of the 

Forest Plan Objectives. 

544. The Wasatch-Cache National Forest should adjust prescription boundaries to 

increase motorized acreage on the Logan Ranger District so that developing an 

off-road vehicle trail system is possible in the area. 

 Response: See response 525. 

545. The Wasatch-Cache National Forest should not adjust prescription boundaries 

in order to develop a motorized trail system on the Logan Ranger District. 

 Response: See response 525. 

546. The Wasatch-Cache National Forest should create a trail between the Iron 

Mine Trail and the Murdock Basin trail system. (43310) 

 Response: See response 496. 

547. The Wasatch-Cache National Forest should establish a Pullen Creek Trail. 

(43310) 

 Response: See response 496. 

548. The Wasatch-Cache National Forest should create parallel two-track trails in 

the Norway Flats area. 

 Response: See response 496. 

549. The Wasatch-Cache National Forest should extend the trail system in the 

Monte Cristo area on the Ogden Ranger District. 

 Response: See response 496. 

Trail Maintenance 

550. The Wasatch-Cache National Forest should increase trail maintenance to 

prevent damage caused by rerouting. 

 Response: The Forest tries to balance the management of resources within 

budgetary constraints. Standard 3 directs the Forest to close unauthorized trails and 

roads. 

551. The Wasatch-Cache National Forest should invest more resources in trail 

maintenance due to damage caused by increasing off-road vehicle and hiking 

use. 

 Response: See response 550.1 

552. The Wasatch-Cache National Forest should clear trails early in the season to 

prevent damage caused by rerouting. 

 Response: Thanks for your comment. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 141 

553. The Wasatch-Cache National Forest should adopt trail maintenance methods 

to reduce stream sedimentation. 

 Response: Thank you for your comment. 

554. The Wasatch-Cache National Forest should redesign problem trails rather 

than close them to user groups whenever possible. 

554.1 Mountain bikes 

 554.2 Motorized 

Response: Thank you for your suggestion. See response 496. 

555. The Wasatch-Cache National Forest should improve the safety of trails used 

by horses. 

 Response: See response 496. 

556. The Wasatch-Cache National Forest should increase winter grooming and 

snowplowing. 

 Response: See response 496. 

557. The Wasatch-Cache National Forest should begin using conveyor belt rubber 

for water bar construction. 

 Response: Thank you for your suggestion. 

Trail Closure for Wildlife 

558. The Wasatch-Cache National Forest should use seasonal rather than 

permanent closures for wildlife wherever possible. 

 Response: Thank you for your suggestion. See response 496. 

559. The Wasatch-Cache National Forest should only close trails to motorized use if 

negative wildlife impacts are specifically documented. 

 Response: We appreciate your opinion but will continue to provide for wildlife 

through seasonal closures as deemed necessary on a site-specific basis. See 

response 496. 

Trail Removal and Obliteration 

560. The Wasatch-Cache National Forest should not rip and brush double-track 

trails to convert them to single track. 

 Response: See response 496. 

561. The Wasatch-Cache National Forest should prevent user-caused conversion of 

single-track trails to off-road vehicle trails through closures and enforcement. 

 Response: See response 496. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 142 

562. The Wasatch-Cache National Forest should relocate any routes that would 

otherwise be closed by timber, mining, or grazing activities. 

 Response: See response 496. 

563. The Wasatch-Cache National Forest should restore the obliterated section of 

the trail seven miles from Oakley starting from the Weber Canyon Road. 

 Response: See response 496. 

Travel Management – Planning 

Adequacy of Analysis 

564. The Wasatch-Cache National Forest should inventory and ground-truth all 

roads and trails during the travel management planning process. 

 Response: See response 496. 

565. The Wasatch-Cache National Forest should add an estimate of the number of 

miles and locations of user-created trails to the Final EIS. 

 Response: See response 496. 

566. The Wasatch-Cache National Forest should add a column to Draft EIS Table 

2-2 for the number of miles of trails closed to mountain bikes by alternative 

listing specific trail closures. 

 Response: The column has been added as table REC-13 in the FEIS. We have 

tried to list individual trail closures in the description of alternative in the FEIS. 

567. The Wasatch-Cache National Forest should add a column for motorized 

recreation to tables that define allowed activities by management prescription 

category. 

 Response: We believe that this is better identified during travel management 

planning. Many management prescription categories allow travel on existing roads 

through the MPC but do not allow new trail construction. A yes or no in the 

description for motorized use allowable activities would not fully address the 

complexity of travel management by management prescription category. 

568. The Wasatch-Cache National Forest should improve the cumulative effects 

analysis in the Final EIS. 

 Response: See response 496. 

568.1 By assessing the number of miles and acres of motorized closures 

 Response: See response 496. 

568.2 By analyzing the cumulative effects of foundation funding of 

environmental groups on motorized access 

 Response: This is beyond the scope of this analysis. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 143 

569. The travel management plan should fully consider the issues found in 

publication FS-643, Roads Analysis and evaluate specific questions. 

 Response: The roads analysis, for maintenance level 3-5 roads, has been 

completed and the findings are in the FEIS. Factors deemed appropriate for the 

Wasatch-Cache were analyzed. See also response 569.1 

570. The Wasatch-Cache National Forest should add more statistics about use 

levels and opportunities for different recreational types. 

 Response: We appreciate your opinion on how an analysis could be done on 

motorized use. We however disagree and have complete what we believe is an 

appropriate level of analysis in the FIES. 

571. The Wasatch-Cache National Forest should conduct more research on 

comparative effects of different uses. 

571.1 Relative impacts of recreational uses 

 Response: Thank you for your comment. As opportunities exist attempts will be 

made to do additional research in this area. 

571.2 Relative non-recreational versus recreational impacts 

 Response: Thank you for express your opinion. 

572. The Wasatch-Cache National Forest should conduct more research on user 

numbers by recreational type to have accurate numbers for allocation 

decisions. 

 Response: A use survey will be conducted on the Wasatch-Cache during fiscal 

year2003 

573. The Wasatch-Cache National Forest should develop a travel management plan 

alternative that better meets motorized recreationists’ needs. 

 Response: See response 496. 

Legal Considerations 

574. The Wasatch-Cache National Forest should ensure that the travel plan 

complies with the Multiple Use Sustained Yield Act by keeping roads and trails 

open to motorized recreation. 

 Response: We believe that the FEIS and the Forest Plan are consistent with the 

Multiple Use Sustained Yield Act as identified in the FEIS. See multiple-use as 

defined in the Forest Plan. 

575. The Final EIS should discuss how Executive Orders 11644 and 11989 interfere 

with multiple use management for motorized recreation. 

 Response: We appreciate your opinion in this area. With these two orders being 

Executive Orders, both being in place for over 25 years, and with Code of Federal 

Regulations 36 CFR 295.2 Planning and Designation for Use of Vehicles Off forest 

Development Roads, we believe the discussion of existing condition provide an 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 144 

adequate description of recreation use on the forest with respect to these two 

executive orders. See also response to concern state 496. 

576. The Wasatch-Cache National Forest should not interpret Executive Orders 

11644 and 11989 to require minimizing user conflicts. Non-motorized users 

who object to motorized uses should stay in non-motorized zones. 

 Response: We appreciate your opinion in this area. However, in the Code of 

Federal Regulations 36 CFR 295.2 Planning and Designation for Use of Vehicles 

Off forest Development Roads, it states: “Off-road vehicle management plans shall 

provide vehicle management direction aimed at resource protection, public safety of 

all users, minimizing conflicts among users, and provide for diverse use and 

benefits of the National Forests.”. It goes on to state, “Areas and trails shall be 

located to minimize conflicts between off-road vehicles use and other existing or 

proposed recreational uses of the same or neighboring public lands, and to ensure 

the compatibility of such uses with existing conditions in populated areas, taking 

into account noise and other factors.” 

We continue to follow national direction provided in the law, Executive Orders, the 

Coder of Federal Regulation and Forest Service Manuals. See also response 496. 

577. The Wasatch-Cache National Forest should not convert sections of the 

Continental Divide Trail to non-motorized use. Because it violates the intent of 

the National Trails System Act. 

 Response: See response 496. 

Travel Management Mapping 

578. The Wasatch-Cache National Forest should correct Recreation Opportunity 

Spectrum mapping errors. 

578.1 Skyline trail 

 Response: Thank you for your comment the change has been made to the ROS 

maps. 

578.2 Lewis Peak spur 

 Response: Thank you for your comment the change has been made to the ROS 

maps. 

578.3 Upper South Fork Roadless Area winter motorized use 

 Response: Thank you for your comment the changes has been made in Winter 

Recreation maps for alternatives 1-6. 

579. The Wasatch-Cache National Forest should improve the quality of travel and 

visitor maps. 

 Response: This is outside the scope of this document but the comment will be 

retained and could be considered during the revising of the travel plans and visitor 

maps 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 145 

579.1 By making the format consistent 

 Response: See response 579. 

579.2 By making the format consistent with Bureau of Land Management 

maps 

 Response: See response 579. 

580. The Wasatch-Cache National Forest should issue route maps with planning 

documents. 

 Response: You are correct. We are not revising the travel plan maps with this 

document. 

581.1 The Wasatch-Cache National Forest should make travel management 

maps more readily available 

 Response: See response 579.2. 

581.2 By adding vending machines 

 Response: See response 579.2. 

Travel Management Allocation Decisions 

582. The Wasatch-Cache National Forest should adjust management prescription 

allocations to match current winter motorized travel maps. 

 Response: The Winter Recreation maps used Management Prescription 

Categories to defined Wilderness and recommended Wilderness and other nonmotorized categories, see all Winter Recreation alternative maps. 

583. The Wasatch-Cache National Forest should adjust non-motorized boundaries 

so that adjacent motorized trails remain open. 

 Response: We have done this to the best of our knowledge. 

584. The Wasatch-Cache National Forest should clarify whether management 

prescription categories are prescriptive or descriptive. By revising Recreation 

Opportunity Spectrum maps and plan to clearly state what is allowed where. 

 Response: The Management Prescription Categories are both prescriptive by 

identifying a list of allowed activities in a particular Management Prescription 

Category and descriptive by describing some of the tools that can be used to 

achieve an objective. See Revised Forest Plan, Chapter 4, Forestwide Allocations, 

Management Prescription Categories. 

The purpose of the Recreation Opportunity Spectrum is to provide way to for 

managers to identify and create recreation settings from Primitive to Urban that 

allow recreationists to choose from a spectrum of recreation opportunities that meet 

the desire experience they are seeking. District Travel Plans, Winter Recreation 

Maps, Management Prescription Category Maps, and Oil and Gas Maps provide the 

framework to identify the location on the Forest for what is allowed. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 146 

585. The Wasatch-Cache National Forest should resolve contradictions between 

Recreation Opportunity Spectrum mapping and management prescription 

category descriptions. This is also true for motorized recreation management 

in Management Prescription Category 2.6. 

 Response: Thank you for your comment. An analysis was conducted to find 

where conflicts occur in all of the alternatives between the Recreation Opportunity 

Spectrum and Management Prescription Categories (MPC). Where Recreation 

Opportunity Spectrum categories could be adjusted to be compatible the MPC 

category they were. Otherwise if there is a conflict between the two allocations 

Management Prescription Categories takes precedence. See Revised Forest Plan, 

Chapter 4, B. Forestwide Allocations. 

There is no conflict with existing motorized use in this Management Prescription 

Category (MPC) as identified in District Travel Plans and Forestwide Winter 

Recreation Travel plans. The Recreation Opportunity Spectrum (ROS) would have 

recognized the existing motorized use and it would have been mapped accordingly. 

See Alternative ROS and MPC maps. 

586. The Wasatch-Cache National Forest should define how conflicts would be 

resolved when Recreation Opportunity Spectrum and management 

prescription categories conflict. 

 Response: Thank you for identifying this potential conflict. As you will notice in 

the introduction to Forstwide Allocations in the Forest Plan we have inserted, 

“However, in the instance of a conflict between direction for a Management 

Prescription and any of the three other layers, the Management Prescription takes 

precedence.” The three other layers identified in the paragraph are Recreation 

Opportunity Spectrum (ROS), Winter Recreation (WR) and the Scenery 

Management System (SMS). 

587. The final Forest Plan should state that the Winter Recreation Opportunity 

Spectrum category will take precedence over the management prescription 

category if there is a conflict. 

 Response: See response 586. 

588. The Wasatch-Cache National Forest should remove prescriptions that can be 

misinterpreted when Recreation Opportunity Spectrum and management 

prescription categories conflict. 

 Response: See response 586. 

589. The Wasatch-Cache National Forest should remove the summer Recreation 

Opportunity Spectrum maps from the final Forest Plan because they make 

site-specific motorized route determinations 

 Response: See FEIS, Chapter 3, Topic 4-Recreation/Scenery Management, 

General Effects, Summer Recreation. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 147 

590. The Wasatch-Cache National Forest should not establish different planning 

processes for summer and winter travel management. The Wasatch Cache 

National Forest should make changes to summer and winter Recreation 

Opportunity Spectrum maps where necessary. 

Response: There was an attempt to use the ROS process for Winter Recreation, 

but it did not address the questions being ask by the public of “When does Winter 

Recreation Management begin and end? Where can I snowmobile? Where can’t I 

snowmobile? and Where is Heli-skiing allowed?” See FEIS, Appendix B-6, 

Recreation Opportunity Spectrum and Winter Recreation Mapping.

See also response to concern state 496. 

591. Travel planning should differentiate between off-road vehicle and motorcycle 

travel management. 

 Response: The FEIS does recognize the difference between motorcycle and ATV 

travel. See the Recreation section in the FEIS. 

Travel Management – Motorized Access to Forest Resources 

Motorized Access to Forest Resources General 

592. The Wasatch-Cache National Forest should keep existing roads and trails open 

for the benefit of livestock producers. 

 Response: See response 455. We recommend that site-specific comments be 

brought up during travel management planning. See also response 496. 

593. The Wasatch-Cache National Forest should allow winter motorized use to 

facilitate predator management. 

 Response: See response 496. 

594. The Wasatch-Cache National Forest should keep existing roads and trails open 

to allow access for scientific study of paleontological resources. 

 Response: We recommend that site-specific comments be brought up during 

travel management planning. See also response 496. 

595. The Wasatch-Cache National Forest should keep existing roads and trails open 

to allow access for ease of fuels reduction and firefighting. 

 Response: See the roads and fire analysis in the FEIS Chapter 3 and 10. 

596. The Wasatch-Cache National Forest should keep existing roads and trails open 

to allow ease of access for hunting. 

 Response: The Forest is accessible. See roads analysis in the FEIS and the Forest 

Plan. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 148 

Adequacy of Analysis 

597. The Final EIS should analyze the effects of motorized travel restrictions on fire 

and timber management. 

 Response: See response 496. 

Motorized Access and Wildlife 

598. The Wasatch-Cache National Forest should only restrict motorized use of 

roads in sensitive big game habitat. 

 Response: See the effects from roads section in chapter 3 of the FEIS. See also 

response 496. 

Travel Management – Roads and Trails 

Roads General 

599. The Wasatch-Cache National Forest should designate dual-purpose roads in 

the travel management plan to allow off-road vehicles to legally use existing 

forest roads. 

 Response: See response 496. 

600. The Wasatch-Cache National Forest should adopt the proposed “closed unless 

posted open” standard because it eliminates the motive to destroy signs. 

 Response: See standard 15. Thank you for your support in this area. 

601. The Wasatch-Cache National Forest should adopt an “open unless posted 

closed” motorized use policy and include reason for closure on signs. 

 Response: We believe that having that designation route for where motorized use 

is allowed is consistent with 36 CFR 295. Direction is given to administratively 

designate and locate specific areas and trails of National Forest System lands on 

which the use of vehicles travel is allowed, restricted, or prohibited. Standard 16 

reaffirms that summer motorized access is managed on an open on designated route 

basis. 

602. The Wasatch-Cache National Forest should restrict all users to designated 

routes. 

 Response: See response to concern statements 601. and 496. 

603. The Wasatch-Cache National Forest should restrict snowmobiles to designated 

roads. 

 Response: Restricting snowmobiles to designated routes only was not considered 

as an alternative because of increased management requirements and that resource 

damage held at a minimum once adequate snow depths are achieved.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 149 

604. The Wasatch-Cache National Forest should better sign areas closed to 

snowmobiles. 

 Response: This is outside the scope of the Revised Forest Plan, but will forward 

the information to the responsible managers for their consideration.

Trails General 

605. The Wasatch-Cache National Forest should identify trail systems by riding 

units rather than individual trail segments. 

 Response: This is a travel management questions that is outside the scope of the 

Forest Plan analysis. Trails are broken down into small segments to track trail 

conditions and maintenance.

606. The final Forest Plan should keep all trails in roadless areas open to motorized 

use. 

 Response: In all alternatives existing motorized trails remained opened, except 

Alternatives 1 & 2 where portions of the Forest were recommended for Wilderness. 

See FEIS, Topic 5-Roadless areas – Effects on Wilderness characteristics and 

roadless area Values, and Wilderness Management for motorized trails that were 

affected by the alternatives. 

607. The final Forest Plan should prohibit motorized travel on all trails due to user 

conflicts and trail damage. 

 Response: Thank you for expressing your feelings. This is beyond the scope of 

the Revised Forest Plan, but we will forward the information to the responsible 

managers for their consideration. 

Specific Roads and Trails 

608. The Wasatch-Cache National Forest should exclude Franklin Basin from a 

summer motorized trail network.

 Response: See response 496. 

609. The Wasatch-Cache National Forest should keep Providence and Millville 

Canyon Roads open. 

 Response: See response 496. 

610. The Wasatch-Cache National Forest should not zone the East Fork Lodge trail 

area as non-motorized. 

 Response: See response 496. 

611. The Wasatch-Cache National Forest should reopen the Turkey Trail to offroad vehicle use. 

 Response: See response 496. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 150 

612. The Wasatch-Cache National Forest should reopen the Leatham Hollow and 

Card Canyon East Trails to motorcycle use. 

 Response: See response 496. 

613. The Wasatch-Cache National Forest should close the Willard Basin Road due 

to continuing erosion in the area. 

 Response: See response 496. 

614. The Wasatch-Cache National Forest should open the North Slope Road to offroad vehicle use. 

 Response: See response 496. 

615. The Wasatch-Cache National Forest should close and block the ford across the 

West Fork Blacks Fork to prevent motorized violations of wilderness area 

boundaries. 

 Response: See response 496. 

616. The Wasatch-Cache National Forest should open Whitney Road (FR22) to offroad vehicle use. 

 Response: See response 496. 

617. The Wasatch-Cache National Forest should not close Bear River Smiths Fork 

Trail 091 to motorized use. 

 Response: See response 496. 

618. The Wasatch-Cache National Forest should close Bear River Smiths Fork 

Trail to motorized use. 

 Response: See response 496. 

619. The Wasatch-Cache National Forest should open specific roads and trails near 

Smith and Morehouse Reservoir to off-road vehicle use. 

619.1 Smith and Morehouse Reservoir to Gardner’s fork road 

 619.2 Smith and Morehouse Reservoir to Little Elk Lake 

 Response: See response 496 

620. The Wasatch-Cache National Forest should open Hoyt Park to the Swift 

Canyon off-road vehicle Trail to off-road vehicle use. 

 Response: See response 496 

621. The Wasatch-Cache National Forest should open Mineral Fork Trail, in Big 

Cottonwood Canyon, to off-road vehicle use. 

 Response: See response 496 

622. The Wasatch-Cache National Forest should keep Mineral Fork road open to 

motorized use. 

 Response: See response 496 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 151 

623. The Wasatch-Cache National Forest should open Dog Lake Trail, in Big 

Cottonwood Canyon, to off-road vehicle use. 

 Response: See response 496 

624. The Wasatch-Cache National Forest should open Cardiff Fork Trail to offroad vehicle use. 

 Response: See response 496 

625. The Wasatch-Cache National Forest should close Tri-Canyon Trails to 

motorized use and enforce the closures. 

Response: See response 496 

626. The Wasatch-Cache National Forest should close Twin Creeks Road as 

proposed in Alternative 1 due to Sensitive soils and Non-motorized 

recreational values. Response: See response 496 

627. The Wasatch-Cache National Forest should reopen the jeep road in South 

Fork Canyon. 

 Response: See response 496 

628. The Wasatch-Cache National Forest should reopen Bunchgrass Road 

 Response: See response 496 

629. The Wasatch-Cache National Forest should reopen roads to the Old Ephraim 

monument. 

 Response: The road up Temple Fork to the area is currently open in the travel 

plan. 

Specific Areas 

630. The Wasatch-Cache National Forest should not limit motorized access in the 

Blacksmith Fork area. 

 Response: See response 496. The selection of an alternative for the management 

of the Forest is one made by the Forest Supervisor. It is not a vote. 

631. The Wasatch-Cache National Forest should allow motorcycle use in Ricks 

Canyon. 

 Response: See response 496 

632 The Wasatch-Cache National Forest should develop an off-road vehicle system 

on the Logan Ranger District. 

632.1 Because it is a requirement under the Recreation Opportunity Spectrum

 Response: We are using ROS as a description of recreational experience. The 

use of this description does not require that all categories be used on any one area. 

See the description of ROS in the Forest Plan and response 496 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 152 

632.2 To meet growing and projected demands 

 Response: See response 496. We recognize that we will not be able to meet the 

demands of all recreational groups on the Wasatch-Cache National Forest. 

633. The Wasatch-Cache National Forest should allow off-road vehicle use in 

Logan Canyon. 

 Response: See response 496. ATV use in Logan Drainage is not closed with this 

FEIS. See the Desired Future Condition as identified in the Forest Plan. 

634. The Wasatch-Cache National Forest should change the Recreation 

Opportunity Spectrum for the Temple Peak Roadless Area (Swan Creek 

Drainage) to allow construction of motorized trails. 

 Response: See response 496 

635. The Wasatch-Cache National Forest should change the Recreation 

Opportunity Spectrum for the Swan Creek Roadless Area to allow 

construction of motorized trails.

Response: Alternative 5 ROS map shows this area as being managed as SemiPrimitive Motorized, but it does not allow the construction of new motorized trails. 

New motorized trail construction is outside of the scope of the Revised Forest Plan. 

Also see response to concern statement 496.

636. The Wasatch-Cache National Forest should change the summer Recreation 

Opportunity Spectrum for the Beaver Mountain area. 

 Response: See response 496 

637. The Wasatch-Cache National Forest should change the Recreation 

Opportunity Spectrum for the Mount Logan South Roadless Area to allow 

construction of motorized trails. 

 Response: See response 496 

638. The Wasatch-Cache National Forest should change the Recreation 

Opportunity Spectrum for the Mount Logan North Roadless Area to allow 

construction of motorized trails. 

 Response: See response 496 

639. The Wasatch-Cache National Forest should change the Recreation 

Opportunity Spectrum for the Gibson Roadless Area to allow construction of 

motorized trails. 

 Response: See response 496 

640. The Wasatch-Cache National Forest should change the Recreation 

Opportunity Spectrum for the Right Hand Fork Roadless Area to allow 

construction of motorized trails. 

 Response: See response 496 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 153 

641. The Wasatch-Cache National Forest should reduce motorized acreage on the 

Logan Ranger District due to environmental and human health impacts 

 Response: See response 496 

642. The Wasatch-Cache National Forest should designate Bunchgrass Hollow 

White Pine Canyon, Steam Mill Canyon, Hells Kitchen Canyon, Steep Hollow, 

Blind Hollow, and Logan Dry Canyon as non-motorized. 

Response: These areas were considered closed to motorized travel in 

Alternatives 1 and 2. See Winter Recreation maps Alternatives 1 and 2. 

643. The Wasatch-Cache National Forest should keep summer motorized closures 

in the Mahogany Ridge Roadless Area for wildlife. 

 Response: See response 496. 

644. The Wasatch-Cache National Forest should change the Recreation 

Opportunity Spectrum for the Mahogany Range Roadless Area to allow 

construction of motorized trails. 

 Response: See response 496. 

645. The Wasatch-Cache National Forest should designate Providence Canyon 

quarry open as a motorized challenge park area. Change management 

prescription category to read “Open on Designated routes and Areas” 

 Response: See response 496. 

646. The Wasatch-Cache National Forest should restrict summer motorized use in 

Public Grove to existing designated routes. 

 Response: See response 496 

647. The Wasatch-Cache National Forest should designate the Lewis Peak Roadless 

Area non-motorized or limit motorized users to alternate days by adding 

language to Forest Plan. 

 Response: See response 496.

648. The Wasatch-Cache National Forest should designate the Willard Roadless 

Area non-motorized. 

 Response: See response to 496. 

649. The final Forest Plan should include new language to allow closure of Willard 

Basin to motorized travel if mitigation of off-road vehicle damage is not 

possible. 

 Response: See response 496. 

650. The Wasatch-Cache National Forest should close Taylor Canyon to motorized 

use and development. 

 Response: See response 496. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 154 

651. The Wasatch-Cache National Forest should leave the area on the West Fork of 

Blacks Forks accessible by vehicles in all of the alternatives. 

 Response: The West Fork of Blacks Fork is accessible by vehicles in all 

alternatives. 

652. The Wasatch-Cache National Forest should prohibit all recreational motorized 

use in the Tri-Canyon area for watershed protection. 

 Response: See response 496. 

653. The Wasatch-Cache National Forest should prohibit all recreational motorized 

use in Mineral Fork in Big Cottonwood Canyon. 

 Response: See response 496. 

654. The Wasatch-Cache National Forest should prevent motorized recreation by 

cabin owners in closed areas of Big Cottonwood Canyon. 

 Response: 

655. The Wasatch-Cache National Forest should open White Pine Canyon to 

motorized vehicle access. 

 Response: See response 496 

656. The Wasatch-Cache National Forest should zone Mineral Basin in American 

Fork Canyon as a summer non-motorized recreational zone. 

 Response: This are is on the Uinta National Forest and is outside the scope of the 

analysis. 

657. The Wasatch-Cache National Forest should allow motorized use in American 

Fork Canyon. 

 Response: This are is on the Uinta National Forest and is outside the scope of the 

analysis. 

Travel Management – Motorized Seasonal Restrictions 

Motorized Seasonal Restrictions General 

658. The Wasatch-Cache National Forest should institute seasonal closures for 

infrastructure along stream corridors. 

 Response: See response 496 

659. The final Forest Plan should institute diurnal closures of existing roads across 

amphibian travel routes during the breeding season. 

 Response: We encourage the commenter to assist in identifying such routes 

during travel management planning. This would allow an interdisciplinary team to 

identify appropriate mitigation measures. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 155 

660. The Wasatch-Cache National Forest should eliminate seasonal closures during 

hunting seasons for hunter safety. 

 Response: We believe we need the flexibility to close roads to prevent resource 

damage. The use of firearms, no matter what the concentration of the public, is 

dangerous. Hunters should be aware of this and take appropriate action. 

661. The Wasatch-Cache National Forest should further restrict mountain biking in 

Millcreek Canyon by limiting the number of days mountain bikes can use the 

Lower Pipeline Trail. 

 Response: See response 496 

662. The Wasatch-Cache National Forest should not close trails to mountain biking 

in the Tri-Canyon area especially Mill D North Trails. 

Response: See response 496 

663. The Wasatch-Cache National Forest should restrict mountain biking in Big 

and Little Cottonwood Canyons. 

 Response: See response 496 

664. The Wasatch-Cache National Forest should restrict mountain biking on the 

east slopes of the Mount Naomi Wilderness by recommending wilderness 

designation. 

Response: This action is considered in Alternatives 1, 2, 3 and 6 in varying 

amounts depending upon the areas considered for Recommended Wilderness. See 

FEIS Chapter 3, Topic 4 Recreation/Scenery Managements, section Effects on 

Recreation from Inventoried Roadless Area Management. 

Motorized Seasonal Restrictions – Site-Specific 

665. The Wasatch-Cache National Forest should seasonally close FR 086 to any 

vehicle over 500 pounds. 

 Response: See response 496 

Travel Management – Winter Motorized 

Winter Motorized General 

666. The Wasatch-Cache National Forest should not override Forest Plan 

management prescription category closures with special winter motorized 

travel maps. 

 Response: Management prescriptions are defined as “management practices, 

intensity selected and scheduled for application on a specific area to attain 

multiple-use and other goals and objectives”. Management Prescription Categories 

provide a general sense of the management or treatment of the land intended to 

result in a particular condition being achieved or set of values being restored or 

maintained. Emphasis as used in these prescriptions is defined as focus or 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 156 

highlighting, not exclusive or “dominant” use. In the event of a conflict between 

uses, resolution will be based on the specific merits of the situation rather than 

assuming that the Prescription implies a “trumping “ of one resource over another. 

The entire Management Direction Package for the area must be considered, not just 

the prescription. This package includes a winter recreation map displaying areas 

open for or closed to motorized use. Most MPC’s do not define whether or not 

winter recreation is allowed. Designated wilderness 1.1-1.4 is the only MPC that by 

definition does not allow motorized use. 

667. The final Forest Plan should adopt clear and enforceable winter motorized 

closures throughout the forest. 

 Response: The Forest Service enforces existing laws and regulations through law 

enforcement and forest personnel. Travel management decisions, similar to all other 

decisions, made in the Forest Plan are based upon a variety of factors such as 

current use and public expectations, watershed and resource protection and 

ecosystem management. Mapping of decisions made in the Forest plan is the first 

step. This will be followed by signing, education and enforcement. The Forest 

Service will continue to work to educate user groups and individuals to prevent 

violations as well as through law enforcement activities. 

Winter Motorized – Site-Specific 

668. The Wasatch-Cache National Forest should close Smithfield Canyon to motorized 

vehicles in the winter. 

 Response: In the Wasatch-Cache Final EIS, Alternatives 1, 6, and 7 close 

Smithfield Canyon to Winter Motorized use. 

 

669. The Wasatch-Cache National Forest should close Smithfield Canyon to winter 

snowmobile use due to damage occurring in low snow conditions. 

 Response: See response 668. The Wasatch- Cache Forest plan establishes a 

minimum snow depth of 12 inches. This snow depth is believed to be enough to 

protect the underlying resources and block most non-over the snow motorized use. 

670. The Wasatch-Cache National Forest should designate Logan Dry Canyon as 

winter non-motorized for safety reasons. 

 Response: The Wasatch-Cache Forest Plan provides for Broad Scale Forest wide 

direction for management of Forest Lands. Specific travel management decisions 

such as this are based upon a variety of factors, including current public use and 

expectations, resource protection safety and compliance with applicable direction. 

Alternatives 1, 2, 6& 7 in the Final EIS close Dry Canyon to Motorized use. 

671. The Wasatch-Cache National Forest should allow winter off-road vehicle use 

on the Hoyt Peak Trail. 

 Response: The Wasatch-Cache Forest Plan provides for Broad Scale Forest wide 

direction for management of Forest Lands. Specific travel management decisions 

such as this are based upon a variety of factors, including current public use and 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 157 

expectations, resource protection and compliance with applicable direction. Every 

Alternative in the Final EIS except for Alternative 1 and 2 allows off road winter 

motorized use on the Hoyt Peak Trail. 

672. The Wasatch-Cache National Forest should allow snowmobile use in the 

Willard area. 

 Response: The Wasatch-Cache Forest Plan provides for Broad Scale Forest wide 

direction for management of Forest Lands. Specific travel management decisions 

such as this are based upon a variety of factors, including current public use and 

expectations, resource protection and compliance with applicable direction. In the 

Final EIS, Alternatives 1 and 2 allow winter motorized use on the existing road in 

the Willard area. In addition, Alternative 3 allows winter-motorized use off road in 

the Willard Area. 

673. The Wasatch-Cache National Forest should not close Tony Grove and adjacent 

areas to snowmobiles because closures are unmanageable due to surrounding 

open areas. 

 Response: Alternatives 3,4 and 5 in the Wasatch-Cache Final EIS allow increased 

motorized use in the Tony Grove area. 

674. The Wasatch-Cache National Forest should close Tony Grove area to winter 

snowmobile use. This would also make the wilderness boundary 

enforceability. 

 Response: Alternatives 1&2 in the Final EIS close the Tony Grove area winter 

motorized use in this area. The Mt. Naomi Wilderness Boundary is well mapped 

and properly signed. It is every one’s responsibility using this area to know where 

the wilderness boundary is and to obey the rules and laws governing that area’s use. 

675. The final Forest Plan should increase winter non-motorized zones to protect 

the yurt system on the Logan Ranger District from snowmobile intrusions. 

 Response: Alternatives 1 & 2 close this area for motorized use. Alternative 7 in 

the Wasach-Cache Final Environmental Impact Statement does not allow motorized 

use in a specific area between the Bunchgrass and Steep Hollow drainages within 

the Mt. Naomi roadless area. Please refer to the winter recreation maps in the 

Revised Forest Plan. 

676. The Wasatch-Cache National Forest should close the area from Tony Grove 

turnoff to the Idaho border to winter motorized use. 

 Response: Winter motorized use along with non-motorized use will continue to be 

allowed. The Wasatch-Cache National Forest provides many types of recreational 

opportunities, one being snowmobile use. There will be areas of winter motorized 

use and areas of winter non-motorized use identified on winter recreation maps. 

Refer to response 675. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 158 

677. The Wasatch-Cache National Forest should close the area west of Franklin 

Basin Road to winter motorized use so that boundaries follow terrain features 

for ease of enforcement. 

 Response: Please refer to responses 675 & 676. 

678. The Wasatch-Cache National Forest should create a ski-only trail in Franklin 

Basin. 

 Response: Please refer to responses 675 & 676. 

679. The Wasatch-Cache National Forest should close Garden City Canyon and the 

adjacent area to winter motorized use. 

 Response: Please refer to responses 675 & 676. 

680. The Wasatch-Cache National Forest should close the area west of Highway 89 

in Sink Hollow to winter motorized use because Skiing and Snowmobiling are 

incompatible uses. 

 Response: Winter motorized use along with non-motorized use will continue to be 

allowed. The Wasatch-Cache National Forest provides many types of recreational 

opportunities, one of them being snowmobile use. Please refer to winter ROS maps 

in Revised Forest Plan that show areas which are open and which areas are closed 

to winter motorized use. 

681. The Wasatch-Cache National Forest should not close the area in Sink Hollow 

to winter motorized use. 

 Response: Refer to response’s 676 and 680. 

682. The Wasatch-Cache National Forest should expand winter non-motorized 

zones in the Logan area. 

 Response: Alternatives 1 & 2 in the Wasatch-Cache Final EIS reduce the amount 

of motorized use on the Forest. Alternative 4 leaves the amount of motorize use the 

same. Alternative 6 does not allow motorized use in recommended Wilderness. 

Please refer to the Winter ROS maps in the Revised Forest Plan that show which 

areas are open and which areas are closed to winter motorized use in the Logan 

area. 

682.1 Into areas with adequate snow coverage. 

 Response: There will be areas of winter motorized and winter non-motorized use 

mapped on the winter recreation maps as part of the Forest Plan and on District 

Travel Plans. 

682.2 Into less hazardous terrain for avalanche safety reasons. 

 Response: There is a large amount of terrain in the Logan area mountains that has 

low slope angles and low avalanche hazard and is open only to winter nonmotorized use. Alternative 7 in the Wasatch-Cache Final EIS makes the area from 

the Bunch Grass through the Steep Hollow drainages open to non-motorize use. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 159 

683. The Wasatch-Cache National Forest should keep Green Canyon closed to 

snowmobiles. 

 Response: The Revised Forest Plan keeps Green Canyon closed to Motorized use. 

684. The Wasatch-Cache National Forest should allow snowmobiles in Green 

Canyon. 

 Response: The Revised Forest Plan keeps Green Canyon closed to Motorized use 

to allow for easily accessible non-motorized opportunity. 

685. The Wasatch-Cache National Forest should close the Temple drainage to 

winter motorized use due to conflicts with skiers. 

 Response: The Forest Plan provides for broad scale management prescriptions and 

direction on how various areas will be managed. Areas of winter-motorized use 

along with areas of non-motorized use will continue to be allowed across the Forest. 

In Alternatives 1 & 2, winter motorized use is limited to existing roadways only 

with no off road use. Please refer to the Winter Recreation maps in the Forest Plan. 

Alternative 7 closes the Temple Fork drainage to winter motorized use to protect 

critical wildlife winter range. Areas of winter-motorized use along with areas of 

non-motorized use will continue to be allowed in specific areas of the Forest. The 

Forest will continue to look for ways to reduce conflicts with skiers. 

686. The Wasatch-Cache National Forest should keep the Twin Creeks area closed 

to snowmobile use. 

 Response: In Alternatives 1, 2 & 6 of the Final Wasatch-Cache EIS, the Twin 

Creeks area is closed to winter motorized use. 

687. The Wasatch-Cache National Forest should close the Amazon Basin area to 

snowmobile use with one travel corridor for snowmobiles. 

 Response: In Alternatives 1 & 2 of the Final Wasatch-Cache EIS, Amazon Basin 

is closed to winter motorized use. 

 

688. The Wasatch-Cache National Forest should change proposed winter motorized 

areas near the Wellsville Wilderness Area to non-motorized. 

 Response: Winter motorized use along with non-motorized use will continue to be 

allowed. The Wasatch-Cache National Forest provides many types of recreational 

opportunities, one being snowmobile use. There will be areas of winter motorized 

use and areas of winter non-motorized use designed through management 

prescription allocations. Please refer to the Winter ROS maps in the Revised Forest 

Plan that show which areas are open and which areas are closed to winter motorized 

use in the Ogden area. 

689. The Wasatch-Cache National Forest should ban snowmobiles in Public Grove 

or restrict them to alternate days. 

 Response: There will be areas of winter motorized use and areas of winter nonmotorized use designed through management prescription allocations. Please refer 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 160 

to the Winter ROS maps in the Revised Forest Plan that show which areas are open 

and which areas are closed to winter motorized use in the Logan area. 

690. The final Forest Plan should adopt the proposed snowmobile closure in the 

Lewis Peak area. 

 Response: The Wasatch-Cache National Forest provides many types of 

recreational opportunities, one of them being snowmobile use. Winter motorized 

use along with non-motorized use will continue to be allowed. The Forest Service 

will continue to work to provide an appropriate mix of recreational uses in this area. 

Please refer to the Winter ROS maps in the Revised Forest Plan that show which 

areas are open and which areas are closed to winter motorized use in the Logan area 

mountains. 

691. The Wasatch-Cache National Forest should prohibit snowmobiling in the 

Snowbasin Land Exchange lands to offset the loss of cross-country skiing 

opportunities on the traded lands. 

. 

 Response: Alternatives 1 & 2 significantly reduce the amount of snowmobile use 

across the forest including the Snowbasin Land Exchange lands. The cross-country 

skiing opportunities have likely increased with the addition of approximately 

10,000 acres of private lands becoming public lands as a result of the Snowbasin 

Land Exchange. 

692. The Wasatch-Cache National Forest should adopt Winter Travel Plan 

Alternative 3 for the Evanston District. 

 Response: The Wasatch-Cache Final EIS covers a broad range of Alternatives 

affecting winter motorized travel across the Forest. Alternative 7 was chosen to 

provide a even balance between motorized and non-motorized use while trying to 

reduce conflicts between user groups. 

 693. The Wasatch-Cache National Forest should close the area south of North Slope 

Road and the Lakes Roadless Area to snowmobile use in the absence of 

monitoring and complete lynx effects analysis. 

 Response: There will be areas of winter motorized use and areas of winter nonmotorized use mapped on the Evanston-Mountain View Ranger District. The 

Endangered Species Act directs all government agencies to protect species listed as 

threatened and endangered. This includes habitat. Eleven counties in Northern 

Utah are included as Lynx habitat by the US Fish and Wildlife Service (FWS). The 

Forest will work closely with the FWS on all mitigation requirements outlined for 

this species. 

694. The Wasatch-Cache National Forest should adopt the High Uinta Preservation 

Council’s modified winter Recreation Opportunity Spectrum map for the 

North Slope which will reduce wilderness violations while leaving large open 

areas. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 161 

 Response: Alternatives 1, 2 & 6 in the Final EIS do not allow winter-motorized 

use in roadless areas. 

695. The Wasatch-Cache National Forest should open the North Slope of the High 

Uintas to snowmobiling. 

 Response: Many areas of the North Slope of the High Uintas are already open to 

snowmobiling. 

695.1 Because the need statements are unsupported 

 Response: Please refer to the Travel Management Section in the Wasatch-Cache 

EIS. 

695.2 Because lynx habitat requirements are not proven 

 Response: The Endangered Species Act directs all government agencies to protect 

species listed as threatened and endangered. This includes habitat. 11 counties in 

Northern Utah are included as lynx habitat by the US Fish and Wildlife Service 

(FWS.) This includes the North Slope. The Forest will work closely with the FWS 

on all mitigation requirements they outlined for this species. 

696. The Wasatch-Cache National Forest should close the north end of the Upper 

South Fork Roadless Area to snowmobile use along with FR 073 and 201. 

 Response: Please refer to the Winter ROS maps in the Revised Forest Plan that 

show which areas are open and which areas are closed to winter motorized use in 

this area. 

697. The Wasatch-Cache National Forest should prohibit winter motorized 

recreation in the Wasatch Front Range. 

 Response: Winter motorized use along with non-motorized use will continue to be 

allowed in selected areas along the Wasatch Front. The Wasatch-Cache National 

Forest provides many types of recreational opportunities, one being snowmobile 

use. There will be areas of winter motorized use and areas of winter non-motorized 

use designed through management prescription allocations. Please refer to the 

Winter ROS maps in the Revised Forest Plan that show which areas are open and 

which areas are closed to winter motorized use in this area. 

698. The Wasatch-Cache National Forest should prohibit winter motorized 

recreation in the Tri-Canyon area. 

 Response: The only land where snowmobiling is allowed in the Tri-Canyon area is 

Guardsman’s Pass. Nearly all of the land in the Guardsman’s Pass area, which is 

open to snowmobiling, is private. The Forest Service has no jurisdiction on private 

lands. 

 

699. The Wasatch-Cache National Forest should prohibit winter motorized use in 

the Guardmans Pass area to protect the watershed. 

 Response: The Forest Service has no jurisdiction over private lands. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 162 

700. The Wasatch-Cache National Forest should prohibit snowmobiling in roadless 

areas. 

 Response: The Wasatch-Cache Final EIS covers a broad range of Alternatives 

covering winter motorized use. Alternatives 1, 2 & 6 of the EIS prohibits motorize 

use in roadless areas. 

701. The Wasatch-Cache National Forest should allow snowmobiling in roadless 

areas. 

 Response: The Wasatch-Cache Final EIS covers a broad range of Alternatives 

covering winter motorized use. Alternative’s 3 & 5 of the EIS allows motorize use 

in roadless areas. 

Travel Management – Mechanized 

Mechanized – Site-Specific. 

702. The Wasatch-Cache National Forest should keep the Big Water Trail open to 

mountain bikes. 

 Response: The Wasatch-Cache National Forest provides many types of 

recreational opportunities including mountain biking. Please refer to the Salt Lake 

Ranger District Travel Management Plan for specific areas that are open to 

mountain biking. Trail managers at the Salt Lake Ranger District will continue to 

evaluate the existing trail system and will implement strategies to better manage the 

increasing use. 

Topic 4: Recreation and Scenery Management 

Recreation and Scenery Management 

General Management 

703. The Wasatch-Cache National Forest should promote recreation as a primary 

goal of the Forest Plan. 

 Response: Recreation is recognized as one of the primary uses on the WCNF. 

Goals for recreation are found in the Forest Plan Chapter 4, 2. Forestwide Goals and 

Subgoals. 

704. The Forest Service should include new language to emphasize providing 

beneficial recreation experiences in Guideline 41. 

 Response: “Beneficial recreation experiences” was added to the Recreation 

Guideline. See Chapter 4 Revised Forest Plan, Recreation, Guidelines for 

Recreation Management. 

 

705. The Wasatch-Cache National Forest should implement the Forest Plan because 

it provides balanced recreation opportunities. 

 Response: Thank you for your comment. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 163 

706. The Wasatch-Cache National Forest should responsibly manage recreation 

and other forest uses. 

 Response: See the Revised Forest Plan, Chapter 4, Forest Management Direction. 

This direction is intended to take the broad conceptual goals, allocations, standards 

and guidelines for a number of resources and uses and fit them together in a clear 

complementary way, given a particular area’s land capabilities, needs and 

opportunities. 

706.1 In a balanced manner 

 Response: See response 706.1. 

706.2 By making agency-authorized changes in forest policy. 

 Response: The Forest is making agency-authorized changes in forest policy to 

responsibly managing recreation and other forest uses by following the NEPA 

process. See FEIS Chapter 1 Purpose and Need. 

706.3 By developing strict and enforceable standards to prohibit increased 

human use of the forests 

 Response: The alternatives of the FEIS displays a range of human uses on the 

WCNF based on concerns such as recreation use conflicts, biodiversity and 

viability. The Forest Plan contains standards and guidelines that sets limits or 

courses of action to protect Forest resources. The intent of Forest Plan revision is 

not to prohibit increased human use of the Forest but to manage the Forest 

Resources. 

706.4 By recognizing that they do not have the resources to manage and 

mitigate impacts of the recreation based activities they are encouraging 

 Response: Thank you for your comments. The WCNF manages the Forest within 

the funding that is available as described in the Social and Economic analysis 

section of the FEIS. During the Forest Plan revision process, we consider many 

ways to manage the WCNF and we feel that the direction for the management of 

resources and mitigation of impacts is adequate to managing activities on the 

WCNF. 

706.5 By adopting the principle of maximum tolerable impact for each visitor 

day 

 Response: We feel that this type of assessment is appropriate at a site-specific 

analysis and not in Forest Plan revision. This is because Forest Plan revision 

considers the overall broad-scale management of the Forest. Site-specific analysis 

and use of specific methods for determining use or impacts would become so 

detailed that broad-level Forest planning would not be meaningful. Broad level 

Forest planning is the scale expected for Forest Plan revision. 

706.6 By allowing appropriate densities for motorized and non motorized 

routes based on ecological parameters 

 Response: See response 706.5. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 164 

707. The Wasatch-Cache National Forest should treat all user groups fairly. 

 Response: Thank you for your comment. It is the intent of the Forest Plan 

revision process to treat all user groups fairly. 

707.1 By reallocating recreation boundaries to accommodate all recreation 

groups 

 Response: Thank you for your comment. The FEIS presents seven alternatives 

that have various levels of motorized and non-motorized use on the WCNF. Within 

these alternatives a wide variety of recreation experience is being managed for from 

Primitive to Urban. See Table REC-11 for acres of Summer Recreation 

Opportunity Spectrum, Winter Recreation Table REC-12 for acres of Winter 

Recreation and FEIS Chapter 2, Alternatives Considered in Detail. 

707.2 By applying restrictions fairly to all user groups 

 Response: Trail overuse and erosional impacts are usually analyzed at the sitespecific level and the WCNF tries to make decisions on these issues fairly. 

707.3 By considering that favoring wilderness type activities in roadless areas 

only serves a narrow segment of the recreating public 

 Response: The alternatives of the FEIS displays a range of uses allowed on the 

WCNF. The revised Forest Plan takes into account the diverse recreation 

population by allocating areas to different uses and is not intended to favor one 

group over another, but to manage use on the forest to avoid conflicts and manage 

multiple use. 

707.4 Because every activity has an impact 

 Response: Thank you for your comment. 

708. The Wasatch-Cache National Forest should disperse recreational users. 

 Response: The alternatives of the FEIS display a range of allowed uses for 

motorized vehicles. The amount of area allowed for motorized-recreation is 

considered in the decision. 

708.1 To lower the impact on the environment 

 Response: The effects of motorized recreation are analyzed for each alternative 

and are considered in the decision. 

708.2 To lower the impacts on popular areas 

 Response: See response to concern statement 708.2. 

709 The Wasatch-Cache National Forest should not restrict access 

709.1 To avoid elitism 

 Response: It is not the intent of Forest Plan revision to provide opportunities for 

use on public lands for wealthy special interest groups. We feel that the range of 

use allowed on lands within the WCNF as described in the alternatives of the FEIS 

is in response to issues and concerns identified through public participation and 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 165 

does not eliminate the public from public land and is not elitist as indicated by the 

range of alternatives and uses considered in the FEIS. 

709.2 To protect freedom values 

 Response: Thank you for your comment. Forest Plan revision considers both 

motorized and non-motorized uses on the WCNF because Forest System lands are 

managed for multiple-use. The WCNF does not close roads to restrict freedom, but 

may do so for other purposes such as watershed protection or other non-motorized 

uses that are considered important. That is one of the purposes of Forest Plan 

revision, that is, to display alternative uses of Forest System lands based on public 

participation and then decide how to manage the uses. 

710. The Wasatch-Cache National Forest should revise the winter recreation 

section in the Draft EIS to provide a more equitable and logical balance of 

winter recreation opportunities. 

 Response: The FEIS considers the balance of winter recreation use in the range of 

alternatives and Alternative 7 specifically addresses non-motorized recreation in the 

Bear River Range. See Alternative 7 Winter Recreation maps and write-up in 

Appendix B-6 for development of Alternative 7 Winter Recreation maps. 

711. The Wasatch-Cache National Forest should develop winter recreation as one 

of the allocation tools used in the Forest Plan. 

 Response: The WCNF does consider Winter Recreation in its land allocation as 

described in FEIS Appendix D – Allocation Framework D-3. 

712. The Wasatch-Cache National Forest should revise the Roadless Desired 

Condition to accommodate backcountry values, not wilderness values. 

 Response: Roadless Desired Condition description has been revised and states 

that these areas are managed according to the management prescription applied. 

This includes areas where motorized uses are allowed, according to the prescription, 

but no road construction is allowed. 

713. The Wasatch-Cache National Forest should provide opportunities for quiet 

and solitude in ridgeline environments. 

 Response: The alternatives of the FEIS display a range of allowed uses that 

provide opportunities for quiet and solitude. The desire of the public for various 

uses on the WCNF will be considered in the final decision. 

714. The final Forest Plan should adopt a more specific definition of “new 

recreation development.” 

 Response: New recreation development has been changed to “New Campgrounds” 

in Comparison of Alternatives, Chapter 2, FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 166 

715. The Forest Service should include stricter criteria for new recreation 

development in Guideline 41. 

 Response: Since the issuance of the draft Forest Plan, guidelines for recreation 

development have been revised. We thank you for your comment. We feel that if 

these guidelines are tightened substantially, as you suggest, it will make it very 

difficult to manage recreation development for the needs of the public. We feel that 

concerns that are listed in your proposed guideline is best met during site-specific 

project implementation and that the revised Forest Plan should give broader 

guidance for recreation management. 

Adequacy of Analysis 

716. The Wasatch-Cache National Forest should adequately analyze recreational 

impacts. 

 Response: The “Guidelines for Recreation Management” were considered in the 

analysis of effects in the FEIS, Chapter 3 Affected Environment and Environmental 

Consequences. 

716. 1 On wilderness 

 Response: The effects of activities are addressed at a broad level which is the 

appropriate scale for Forest Planning. See response 706.5. 

716.2 By considering the impacts of future or new recreational activities, Such 

as paint ball. 

 Response: See response 706.5. The revised Forest Plan provides direction to 

“Manage use of new recreation technology to reduce effects on the Forest”. 

716.3 By determining, in cooperation with SLPU, what backcountry uses 

adversely impact the environment 

 Response: See response 706.5. 

716.4 By studying all aspects of human impact on the canyons, highway, and 

parking capacity, and all recreation including resort and backcountry use 

 Response: See response 706.5. 

716.5 By addressing the ecological and social impacts that result from each 

type of recreation and deciding which habitat type is suitable for each activity 

 Response: The FEIS identifies ecological and economic and social impacts of 

recreation activities in environmental consequences sections with primary 

discussions under Watershed Health and Biodiversity and Viability and Economic 

and Social Analysis. Regarding the concern of appropriate use of OHVs, the Forest 

Plan has a standard for “summer motorized and mechanized access is managed on 

an open on designated routes”, under Standards for Road/Trail and Access 

Management. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 167 

716.6 By studying ways to control highway traffic and backcountry use 

 Response: See response 706.5. 

716.7 By discarding the flawed Bradford study and using more accurate data 

on dispersed users 

 Response: The analysis that you refer to is part of a previous site-specific analysis 

of heli-skiing and is not part of the analysis in the Forest Plan. Multiple-use of the 

forest resources, including heli-skiing, is an important factor that is considered in 

the decisions that will be made during Forest Plan revision. 

717. The Wasatch-Cache National Forest should conduct a carrying capacity 

analysis. 

717.1 For the entire Wasatch-Cache National Forest 

717.2 For the Wasatch Front Canyons 

717.3 For the Tri-Canyons area 

717.4 For all uses that allow for the protection of the water supply 

717.5 To decide what activities to restrict or encourage 

717.6 To limit the number of canyon users 

717.7 To address use and plan beyond the next 15 years 

717.8 Include the study in the Forest Plan immediately 

717.9 Consistent with restoration and sustainability of wildlife, natural, and 

scenic values 

717.10 Before new developments are allowed

 Response: The WCNF would like to have completed a carrying capacity study for 

the Tri-canyons area and there are many very good reasons for doing so, but chose 

not to for several reasons. A carrying capacity study is a very complex process 

involving many different jurisdictions, partners, landowners, and users on the 

Forest; is mid-level assessment that is much more complicated than broad-level 

Forest Plan assessment; takes a large amount of time for the assessment that would 

take it beyond the time frame for completing the Forest Plan revision; and is not a 

top priority for the WCNF at this time. A carrying capacity study for the entire 

WCNF would be more complicated than one for the Tri-canyon area. 

718. The Wasatch-Cache National Forest should establish recreation use data 

collection points. 

 Response: The Wasatch-Cache will be conducting National Use Visitor Surveys 

beginning in October of 2002, which will be carried through until end of September 

of 2003 and will repeat every 5 years there after. 

718.1 For off-road vehicle users 

 Response: See above response to concern statement 718.1. Part of the process of 

Revising the Forest Plan is to review and analysis existing information that pertains 

to the revision. The knowledge gained from studies such as Off Highway Vehicle 

Use and Owner Preference in Utah (revised) January 18, 2002, Professional Report 

IORT PR2001-02 other reports were used in the development of this analysis. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 168 

Education 

719. The Wasatch-Cache National Forest should educate the public. 

719.1 On how to use and care for the land 

 719.2 About the effects of their activities 

 719.3 On the rules and the trails that are open for their use 

 719.4 On maintaining the 200 foot buffer around riparian areas 

 719.5 On low impact camping ethics 

 719.6 In conjunction with public school systems 

 719.7 Instead of restricting activities 

Response: In response to comments received from the public, environmental 

education is now one of the main objectives of the WCNF in the next planning 

period. Education has always been an important part of the Forest Service 

nationally and locally, and it is emphasized in the revised Forest Plan in Chapter 4, 

Forestwide Direction, Goals and Subgoals. 

720. The final Forest Plan should include specific direction to increase user 

education. 

720.1 Through nature education programs 

 721.2 The Wasatch-Cache National Forest should begin an educational 

campaign to encourage use of quieter motorized recreational vehicles.

 Response: See response 719. 

 

Allow Activities 

722. The Wasatch-Cache National Forest should allow recreational activities for 

environmental reasons by allowing low impact recreational activities. 

 Response: Thank you for your comment. Several alternatives respond to the issue 

of impacts by lowering the amount of impact from activities. 

723. The Wasatch-Cache National Forest should allow recreational activities for 

social reasons. 

723.1 To promote family values 

723.2 To prevent crime 

723.3 To accommodate the growing population 

 Response: Thank you for your comments. The WCNF recognizes the values of 

recreation on the WCNF as shown by the fact that it is one of the main issues raised 

in the Needs for Change and is a main topic in the FEIS and Forest Plan. 

724. The Wasatch-Cache National Forest should allow recreational activities for 

economic reasons because of the economic benefit to adjacent communities. 

 Response: See concern statement 723.1. Economic analysis is contained in the 

Social and Economic Analysis section in the FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 169 

Do Not Allow/Restrict Activities 

725. The Wasatch-Cache National Forest should control/restrict recreational 

activities in order to enhance and maintain other goals. 

 Response: The alternatives in the FEIS display a range of allowed uses in response 

to issues and concerns raised by the public including the amount of certain types of 

recreation on the WCNF. We have also addressed these through the recreation 

opportunity spectrum (ROS) that have a range of recreation opportunities from 

primitive to urban. See ROS maps for each alternative, and alternative descriptions 

and allowed activities for allocations in the FEIS. 

726. The Wasatch-Cache National Forest should control/restrict recreational 

activities for environmental reasons. 

726.1 To protect the environment 

726.2 To protect forest health 

726.3 To protect riparian areas

 Response: See concern statement response 725. 

727. The Wasatch-Cache National Forest should control/restrict recreational 

activities for social reasons because of impacts to quiet and solitude. 

 Response: See concern statement response 725. 

728. The Wasatch-Cache National Forest should conduct seasonal recreational 

closures in the Elkhorn Wildlife Management Area to accommodate multiple 

use while protecting wildlife. 

 Response: We’ve done this where we believe it to be appropriate. If you have sitespecific concerns these can be addressed during travel management planning. 

729. The final Forest Plan should limit major special permit recreational events to 

ski area boundaries and require an EIS for permit approval. 

 Response: Thank you for your comment. We feel that the current language is 

adequate because it is broads enough to cover most events and that issues you raise 

such as substantial light and sound pollution should be addressed at the site-specific 

NEPA analysis. We feel that the level of NEPA analysis should be determined after 

a specific proposal is brought to the WCNF. 

730. The Wasatch-Cache National Forest should prohibit parking lots, commercial 

development, campgrounds or vehicle routes along recreational corridors. 

 Response: Thank you for your comment. The range of alternatives in the FEIS 

addresses your concern. 

731. The Wasatch-Cache National Forest should consider that “larger scale public 

facilities” and “modest and unobtrusive marinas” are not compatible with 

largely primitive and undeveloped shorelines and watersheds. 

 Response: Thank you for your comment. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 170 

732. The Wasatch-Cache National Forest should favor non-noise, non polluting, 

and non fossil fuel using recreational activities. 

 Response: Thank you for your comment. The range of alternatives in the FEIS 

addresses your concern. 

User Conflict/Monitoring and Enforcement 

User Conflicts 

733. The Wasatch-Cache National Forest should address user conflicts. 

 Response: Thank you for your comment. The range of alternatives in the FEIS 

addresses your concern. The WCNF is considering many ways to manage user 

conflicts and travel management it is one of the main objectives in the revised 

Forest Plan. 

733.1 By considering examples of how other forests have reduced winter 

recreational conflicts 

 Response: Thank you for your comment. 

733.2 By protecting forest resources above user groups 

 Response: Thank you for your comment. One of the main sections that protect 

forest resources is the standards and guidelines section of the Forest Plan. 

733.3 By segregating users 

 Response: The range of alternatives in the FEIS addresses your concern by 

presenting a range of allowable uses on the WCNF. 

733.4 By separating hiking trails from all other users 

 Response: See response 733.3. 

733.5 By separating foot and horse travel, motorized recreation, and research 

 Response: See response 733.3. 

733.6 By implementing a variety of solutions to user conflicts before closing an 

area 

 Response: Thank you for the information. We feel this type of information you 

provided could be used as one of many tools for resolving recreation conflicts. 

However, we do not plan to add your recommendation to the revised Forest Plan 

because the WCNF does not want to have only one method in which recreation 

conflicts would be assessed. 

733.7 In the winter 

 Response: Thank you for your comment. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 171 

734. The Wasatch-Cache National Forest should set aside a 1000-2000 acre 

preserve for summer and winter motorized recreation. 

 Response: Thank you for your comment. 

735. The Wasatch-Cache National Forest should not segregate users because 

everyone should have equal opportunity to use public lands. 

 Response: Thank you for your comment. The WCNF recognizes that there are 

conflicts between users and the Forest will try to make the best decision it can given 

the many view points of the users. 

736. The Wasatch-Cache National Forest should recognize that the plan does little 

to resolve user conflict and current Draft EIS designations are likely to 

increase them. 

 Response: Thank you for your comment. 

Monitoring and Enforcement 

737. The Wasatch-Cache National Forest should monitor motorized recreation and 

enforce regulations. 

 Response: The WCNF are conducting visitor use surveys and uses studies such as 

noted in Comment 718.1. The WCNF enforces regulations according to the law. 

737.1 According to executive orders and the National Forest Management Act 

 Response: Recent studies that evaluate motorized use in northern Utah have been 

used in the Recreation effects section of the FEIS. 

737.2 For multiple reasons 

 Response: Thank you for your comment. The range of alternatives in the FEIS 

addresses your concern by presenting a range of allowable uses on the WCNF. 

737.3 To prevent environmental damage 

 Response: Thank you for your comment. See response 733. 

737.4 To prevent ghost roads 

 Response: Thank you for your comment. 

737.5 For both winter and summer recreation 

 Response: Thank you for your comment. 

737.6 Don’t let a few spoil it for the rest 

 Response: Thank you for your comment. 

737.7 Because opening more areas to motorized vehicles will only increase the 

problem 

 Response: Thank you for your comment. See response 733. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 172 

737.8 Instead of restricting motorized activities 

Response: Thank you for your comment. See response 733. 

738. The Wasatch-Cache National Forest should monitor motorized recreation and 

enforce regulations in certain areas. 

738.1 In wilderness and roadless areas 

738.2 Restrict access adjacent to wilderness 

738.3 Enforce Mount Naomi Wilderness Area boundaries 

738.4 In Green Canyon 

738.5 Northern Central Bear River Range 

738.6 East Slopes of Mount Naomi Wilderness 

738.7 Temple Fork area 

 Response: Monitoring for motorized recreation and enforcement of regulations are 

addressed in several areas of the Forest Plan. The Objective for Education and 

Enforcement in the revised Forest Plan intends to integrate key messages that teach 

appropriate behavior while using the forest. The focus areas for key messages 

include OHV use with a purpose of reducing conflicts between recreation users. 

One of the items in the revised Forest Plan monitoring plan is monitoring to 

determine if the WCNF is delivering key education/enforcement messages that 

include OHV use. It also has monitoring to determine whether the WCNF is 

providing recreational opportunities for both motorized and nonmotorized users 

while protecting and restoring watersheds, providing for the needs of wildlife. The 

monitoring section identifies indicators and how to measure the monitoring items 

that includes the use of surveys. When surveys are set up for monitoring, specific 

areas will be identified and the areas described in Comments 738.1 through738.7 

will be considered at that time. 

739. The Wasatch-Cache National Forest should monitor and enforce snowmobile 

regulations. 

 739.1 On public lands 

 739.2 In Cardiff Fork 

 739.3 West of Tony Grove 

 739.4 Issue citations to violators

 Response: See response 738. When surveys are set up for monitoring, specific 

areas will be identified and considered at that time. Forest law enforcement officers 

have the authority to issue citations when people violate the law. This is one of the 

methods the WCNF uses to assist in compliance with the law. 

740. The Wasatch-Cache National Forest should have personnel on the Big Water 

Trail on the no-bike days to monitor illegal use. 

 Response: Thank you for your comment. The Objective for Education and 

Enforcement in the revised Forest Plan intends to address this type of problem. 

Your comment will be sent to the Ranger District and means to address it will be 

considered. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 173 

741. The Wasatch-Cache National Forest should patrol, monitor, and educate 

dispersed campers 

741.1 In the area south of Highway 89 to Temple Fork 

741.2 And minimize inappropriate off-road travel and ghost roads 

Response: Thank you for your comment. The Objective for Education and 

Enforcement in the revised Forest Plan intends to address this type of problem. 

When surveys are set up for monitoring and plans developed for patrolling and 

education, specific areas will be identified and considered at that time. 

742. The Wasatch-Cache National Forest should enforce the Forest Plan by using 

more signs. 

 Response: Thank you for your comment. The Objective for Education and 

Enforcement in the revised Forest Plan intends to address this type of problem. 

Signing is one of the methods by which to meet this objective. 

743. The Wasatch-Cache National Forest should increase enforcement of motorized 

travel rules rather than build new logging roads and motorized trails. 

 Response: Thank you for your comment. The WCNF considers how to allocate 

funds to meet the needs of the forest. 

744. The Wasatch-Cache National Forest should add a monitoring method for 

reducing user conflicts. 

 Response: The revised Forest Plan has included monitoring to address user 

conflicts such as the monitoring item that determines whether the WCNF is 

providing recreational opportunities for both motorized and nonmotorized users 

while protecting and restoring watersheds, providing for the needs of wildlife. 

745. The Wasatch-Cache National Forest should add a monitoring method for 

stewardship education efforts. 

 Response: Monitoring to address this objective is included in the monitoring plan 

of the revised Forest Plan. 

746. The Wasatch-Cache National Forest should not assume non-compliance 

increases with increased user numbers. Some problems can be mitigated. 

 Response: We have seen many more user created ATV trails in just the last couple 

of years and that has happened at the same time as a large increase in numbers of 

ATV users. An objective of the revised Forest Plan is to provide recreational 

opportunities for both motorized and nonmotorized users while protecting and 

restoring watersheds, providing for the needs of wildlife. 

747. The final Forest Plan should not increase its enforcement problems by closing 

additional areas to recreational users. 

 Response: Enforcement and signing are ways to implement the Forest Plan. The 

Forest Plan has an objective of providing recreational opportunities for both 

motorized and nonmotorized users while protecting and restoring watersheds, 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 174 

providing for the needs of wildlife. The alternatives give a range of allowed 

activities that have varying amounts of area closed to certain activities. 

User Regulations 

748. The Wasatch-Cache National Forest should require off-road vehicles to have 

license plates that are readable. 

748.1 In conjunction with the state of Utah 

748.2 To facilitate identification of rule violators 

 Response: Thank you for your comment on ways to help implement the Forest 

Plan. Comments such as yours will be considered when the WCNF considers 

specific ways to assist users in complying with Travel Plans. 

749. The Wasatch-Cache National Forest should impose strict noise standards and 

speed limits. 

 Response: The FEIS addresses the issue of noise by separating the motorized and 

non-motorized uses. Travel planning is the time when these issues should be 

addressed because the large variation across the WCNF makes it not appropriate to 

address at the Forest Plan scale. 

750. The Wasatch-Cache National Forest should impose a 5 mph speed limit near 

campgrounds to minimize dust. 

 Response: Thank you for your comment. A Forest-wide goal is for a roads and 

Trails system that is safe, responsive to public and agency needs. 

751. The Wasatch-Cache National Forest should impose noise and clean engine 

restriction,s rather than close areas to motorized recreation. 

 Response: Thank you for your comment. In the section Effects of Recreation on 

Recreation under Topic Recreation /Scenic Management in the FEIS, the WCNF 

recognizes that new technology is available to make snowmobiles quieter and 

cleaner. This will be considered along with many factors when the decision is 

made. 

752. The Wasatch-Cache National Forest should impose temporary or permanent 

closure of access to areas that result in frequent motorized trespassing. 

 Response: The WCNF recognizes this issue and addresses it with goals to increase 

Forest Service field presence in key areas, improve effectiveness of public 

information on restrictions, and increase participation of individuals and organized 

groups in monitoring uses in the Forest Plan Forestwide Subgoal- Road/Trail and 

Access Management and Forestwide Goal 8– Enforcement. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 175 

Motorized Recreation 

Motorized Recreation General 

753. The Wasatch-Cache National Forest should provide more information about 

motorized recreation opportunities to comply with the requirements of 

environmental justice. 

 Response: Information concerning motorized recreation opportunities are found on 

the ROS maps per each alternative and discussed in the FEIS, chapter 3, Topic 4-

Recreation/Scenery Management. 

754. The Final EIS should address compliance with P.L. 105-359 to improve 

outdoor recreational access for the disabled. 

 Response: This is National direction and the Forest is working to comply with the 

direction. See Revised Forest Plan, Chapter 4, Recreation, Desire Condition. 

Cumulative Impacts on Motorized Recreationists 

755. The Wasatch-Cache National Forest should evaluate the cumulative impact of 

the proposed action and other decisions on environmental justice and the 

standards of living for multiple-use and motorized visitors. 

 Response: See response 753. 

756. The Wasatch-Cache National Forest should evaluate the social and economic 

impact to motorized recreationists of not having recreational opportunities in 

the nearby forests. 

 Response: See response 753. 

757. The Wasatch-Cache National Forest should evaluate the cumulative impacts 

and environmental justice issues surrounding the lack of national motorized 

trails on motorized recreationists. And then, identify and implement measures 

necessary to mitigate these impacts on motorized recreationists. 

 Response: See response 753. 

758. The Wasatch-Cache National Forest should determine the number of miles of 

off-road vehicle trails versus the miles of trails and acres of cross-country 

travel opportunities to address the cumulative effects on motorized 

recreationists. 

 Response: This information on the numbers of roads on the Forest is displayed in 

the affected environment under Topic 3 - Roads and Access management and trails 

under Topic 4 – Recreation /Scenery Management. There currently are no crosscountry travel opportunities since all of the District travel plans allow summer 

motorized use only on designated roads and trails. Motorized cumulative effects is 

addressed in the Cumulative Effects section under Topic 4 – Recreation /Scenery 

Management. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 176 

759. The Wasatch-Cache National Forest should consider the U.S. Department Of 

Transportation document, “Conflicts on Multiple-Use Trails: Synthesis of the 

Literature and State of the Practice.” because it is an excellent resource on 

user conflict and trail sharing. 

 Response: Thank you for this internet reference site. 

Allow Motorized Recreation 

760. The Wasatch-Cache National Forest should allow motorized use.

760.1 In roadless areas 

 760.2 Except in areas where it interferes with wildlife 

 760.3 For tourism 

 760.4 Because motorized use is a legitimate activity 

Response: The WCNF allows motorized use in many areas and the various 

alternatives provide a range of motorized vehicle use that may be considered by the 

decision maker. 

761. The Wasatch-Cache National Forest should not close roads and trails to 

motorized use for environmental reasons because motorized users don’t harm 

the environment. 

 Response: The WCNF must consider the effects of roads and trails based on 

significant issues that are raised, including environmental issues. Most road 

closures are a result of site-specific analysis and during Travel Plan updates at 

which time specific information is reviewed to make a determination on whether to 

close or not close a road. 

762. The Wasatch-Cache National Forest should not eliminate access based on 

premature decisions about lynx, bear, and wolves. The Canada Lynx should 

not be used as an excuse to stop motorized use. 

 Response: See response 753. 

763. The Wasatch-Cache National Forest should open a new motorized route for 

every route closed to avoid further cumulative impacts to motorized 

recreationists. 

 Response: The WCNF considers issues and effects of roads and trails on resources 

and the public when it evaluates whether to close or not close a road. Using criteria 

such as a new motorized route should be opened for every closed route does not 

provide a good process for evaluating issues related to access management. 

Do Not Allow/Restrict Motorized Recreation 

764. The Wasatch-Cache National Forest should prohibit/restrict motorized 

recreation. 

764.1 In roadless areas 

 764.2 In sensitive areas 

 764.3 In riparian areas 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 177 

 764.4 In the backcountry 

 764.5 Because it affects non-motorized users’ quality of experience 

764.6 Because it will be harder to restrict uses in the future 

764.7 Because there are many opportunities elsewhere in Utah 

764.8 For anything but emergency use 

 764.9 Don’t support the use of petroleum products 

Response: Thank you for your comments. The FEIS address these concerns in the 

various alternatives, particularly Alternatives 1 and 2, and the effects are analyzed 

in the section on Environmental Effects of Recreation on Recreation in Topic 4 – 

Recreation /Scenery Management. 

765. The Wasatch-Cache National Forest should proscribe future motorized uses in 

roadless areas where there are no motorized uses now. 

 Response: Thank you for your comments. The FEIS address these concerns in the 

various alternatives, particularly Alternatives 4 and 5, and the effects are analyzed 

in the section on Environmental Effects of Recreation on Recreation in Topic 4 – 

Recreation /Scenery Management. 

766. The Wasatch-Cache National Forest should close large blocks of land around 

roadless and wilderness areas and entire watersheds to protect the 

environment from motorized users. 

 Response: The FEIS address these concerns in Alternative 1 by prescribing large 

areas of the WCNF for ensuring biodiversity and species viability including 

watershed functions. 

767. The Wasatch-Cache National Forest should not allow motorized use right up 

to wilderness boundaries to meet the National Strategic goal. 

 Response: Thank you for your comment and reference to the USFS National 

Strategic Goals. Section 303 of The Utah Wilderness Act of 1984 (Public Law 98-

428) prohibits buffer zones around designated wilderness areas in the State of Utah. 

It states that “ The fact that nonwilderness activities or uses can be seen or heard 

from areas within the wilderness shall not, of itself, preclude such activities or uses 

up to the boundary of the wilderness area.” The WCNF abides by this law when 

managing areas adjacent to wilderness areas in the State of Utah. 

768. The Wasatch-Cache National Forest should limit motorized zones to areas 

where natural features make cross-country travel impossible. 

 Response: Thank you for your comment. During travel planning analysis, 

characteristics of the landscape such as steepness are considered for where 

motorized travel is allowed. Currently, there are no cross-country travel 

opportunities since all of the District travel plans allow summer motorized use only 

on designated roads and trails. The alternatives of the FEIS have a range of areas 

where motorized use is allowed that is based on issues that were raised during the 

Forest Plan revision. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 178 

Motorized Recreation – Off-Road Vehicles 

Motorized Recreation – Off-Road Vehicles General 

769. The Wasatch-Cache National Forest should consider off-road vehicles and 

motorcycles separately. 

 Response: The FEIS and revised Forest Plan revision places motorcycles and 

ATVs in the same category of vehicles because planning is at a broad scale. 

Separating these vehicle types would be appropriate for site-specific analysis during 

District travel planning. 

770. The Wasatch-Cache National Forest should manage off-road vehicles. 

770.1 By developing comprehensive management strategies 

770.2 According to the Motorcycle Industry Council triangle of educationopportunity-law enforcement 

Response: The FEIS and revised Forest Plan recognizes the issue of managing offroad vehicles in section Road/Trail and Access Management under Forestwide 

Subgoals, and in sections Objectives for Education and Enforcement and Objectives 

for OHV and Non-motorized Travel Management under Forest-wide Objectives of 

the revised Forest Plan. The revised Forest Plan sets the goals and objectives of 

developing a plan for addressing these issues but does not develop the specific 

strategies to accomplish it. 

771. The Wasatch-Cache National Forest should develop a travel plan for summer 

motorized vehicles to prevent resource damage. 

 Response: Travel plans have been completed recently for Kamas RD, Salt Lake 

RD, Ogden and Logan RD and the Evanston/Mt. View RD will have a revised 

travel plan very soon. Also, See response 770. 

772. The Wasatch-Cache National Forest should that consider more resources are 

needed to manage motorized recreation because of environmental impacts on 

the Logan Ranger District. 

 Response: See response 770. 

773. The Wasatch-Cache National Forest should conduct public outreach with 

motorized recreationists to fairly present their needs. 

 Response: The WCNF has provided public participation throughout the Forest 

Plan revision process. Many of the people who attended public meetings and who 

gave many comments are motorized recreationists. Through our public 

participation efforts we feel we have given more than adequate ability to express 

opinions and comments on how to manage the WCNF. 

774. The Wasatch-Cache National Forest should manage off-road vehicle use rather 

than close areas because motorized users will ignore closures. 

 Response: See response 770. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 179 

Adequacy of Analysis 

775. The Wasatch-Cache National Forest should conduct a National Environmental 

Policy Act analysis for any off-road vehicle use. 

 Response: The WCNF is required to conduct a NEPA analysis on all proposed 

projects. District travel plans provide the site-specific NEPA analysis for where 

OHV use is allowed on the WCNF. 

Education 

776. The Wasatch-Cache National Forest should alter the Preferred Alternative to 

include more management and education pertaining to off-road vehicle in the 

forest. 

 Response: Thank you for your comment. As a result of comments such as yours, 

the WCNF has developed goals and objectives that focus on education and 

enforcement of OHV use. See response 770. 

777. The Wasatch-Cache National Forest should require all off-road vehicle riders 

to take a course for a permit to ride on the forest. 

 Response: The State of Utah has training courses for operators of OHVs. We feel 

that it is best that the State of Utah and not the USFS be responsible for OHV 

training and certification. 

Allow Off-Road Vehicles 

778. The Wasatch-Cache National Forest should allow off-road vehicles. 

778.1 For multiple use 

778.2 Because the majority of the public supports it 

 778.3 Because off-road vehicle use is increasing 

778.4 Do not make it an illegal activity 

Response: The FEIS addresses the issue of OHV use in the section Effects of 

recreation on Recreation under Topic 4 – Recreation / Scenery Management. The 

alternatives provide a range of allowed uses by OHVs and the decision will 

consider those concerns that you have expressed. Also see response 770. 

779. The Wasatch-Cache National Forest should allow off-road vehicles for 

environmental reasons. 

 779.1 Because all terrain vehicles are environmentally safe and do not impact 

the scenery 

 779.2 To protect wetlands 

 779.3 Do not use sound level to justify motorized closures 

 779.4 Because motorized users don’t harm the environment 

 779.5 Because only those who cause damage should be punished 

 779.6 Because education of motorized users is working 

 779.7 Because motorized access leads to higher public appreciation of nature

 Response: See response 778. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 180 

780. The Wasatch-Cache National Forest should allow off-road vehicles for 

economic reasons. This should be allow in areas where jobs have been lost. 

 Response: The FEIS recognizes the contribution of OHV use to the economy in 

the Social and Economic Analysis. 

781. The Wasatch-Cache National Forest should allow off-road vehicles for social 

reasons. 

781.1 For families 

781.2 For the disabled and elderly 

 781.3 For future generations 

 781.4 For safety or emergency use 

 781.5 For intrinsic values 

Response: Thank you for your comment. The FEIS recognizes that OHV use is 

important to many people for many reasons in the recreation issues, alternatives, 

and effects section Effects on Recreation from Recreation under Topic 4 

Recreation/Scenery Management. 

782. The Wasatch-Cache National Forest should allow off-road vehicles in certain 

areas. 

782.1 In roadless areas 

 782.2 In remote and primitive areas where some degree of challenge is found 

Response: The alternatives in the FEIS contain a range of areas where summer 

motorized recreation is allowed, including alternative with prohibition in roadless 

areas. The revised Forest Plan contains an objective for OHV management that 

includes the need to update Travel plans on some Districts and to provide 

opportunities for OHV use such as loop trails and adequate amount of trails. 

783. The Wasatch-Cache National Forest should allow off-road vehicles by 

maintaining access. 

783.1 By keeping areas open 

 783.2 By keeping the current level of motorized access 

 783.3 By opening more trails to motorized users 

 783.4 By increasing the acreage open to motorized use 

 783.5 By providing equal opportunity for motorized and non-motorized uses 

 783.6 By developing logging and pioneer roads for all off-road vehicles

 783.7 By expanding public areas for play areas and trials bikes 

Response: Thank you for your comment. The alternatives in the FEIS contain a 

range of areas where summer motorized recreation is allowed. This range was 

developed in response to issues raised about the management of the WCNF. Also 

See responses 781 and 782.1. 

Do Not Allow/Restrict Off-Road Vehicles 

784. The Wasatch-Cache National Forest should prohibit/restrict off-road vehicles 

for environmental reasons. 

 784.1 To protect remote areas 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 181 

 784.2 To protect watersheds 

 784.3 To prevent erosion-prone user-created trails 

 784.4 Because of the cumulative impact as a result of the exponential increase 

in numbers of motorized users 

 784.5 Because opening more areas will increase degradation 

 784.6 Because users often inflict more damage over a larger area 

 784.7 Because of noise and air pollution 

 784.8 Because of disturbance to nesting birds 

 784.9 Because of impacts to the reproductive success of birds 

Response: The FEIS recognizes that many people for various reasons feel that 

OHV use should be prohibited or restricted in the section Effects on Recreation 

from Recreation under Topic 4 Recreation/Scenery Management and in Effects on 

Soil and Water Resources from Recreation under Topic 1 Watershed Health. The 

FEIS recognizes that motorized use effects wildlife as described in section Effects 

on Terrestrial Wildlife from Recreation under Topic 2 –Biodiversity and Viability. 

785. The Wasatch-Cache National Forest should prohibit/restrict off-road vehicles 

for social reasons because many elderly people like non-motorized activities. 

 Response: See response 784. 

786. The Wasatch-Cache National Forest should control off-road vehicles through 

restrictions. 

 786.1 By seasonal restrictions 

 786.2 By controlling use during the spring runoff 

 786.3 By restricting to existing paved roads and non-paved roads that 

currently have significant use 

 786.4 By closing/restricting areas until it can be demonstrated that there is no 

environmental impact 

 786.5 By temporarily closing access to areas experiencing use by vehicles off of 

designated routes until further analysis 

 786.6 By either requiring off road vehicles to conform to pollution regulations 

or keeping them out of canyons 

 786.7 By adding a standard to prohibit off-road and off-trail cross country 

travel 

 786.8 By having a trail policy of closed unless posted open 

 786.9 By limiting group size to six to eight 

 786.10 By prohibiting vehicles on dirt roads in the Cottonwood Canyons, 

except for property owners 

 Response: There currently are no summer motorized cross-country travel 

opportunities since all of the District travel plans allow summer motorized use only 

on designated roads and trails. The revised Forest Plan has a standard for “summer 

motorized and mechanized access is managed on an open on designated routes”, 

under Standards for Road/Trail and Access Management. Travel Plans also have 

information on proper OHV use in the Tread Lightly section. Other travel 

management issues should be resolved at the site-specific Travel Plan analysis 

because specific information needs to be analyzed such as access requirements 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 182 

through public land, ski area management needs, and access to campgrounds. See 

also response 770. 

787. The Wasatch-Cache National Forest should not expand public areas for 

activities like rock crawls and trials because it can damage the visual 

environment. 

 Response: See response 786 

Motorized Recreation – Snowmobiles 

Motorized Recreation – Snowmobiles General. 

788. The Wasatch-Cache National Forest should develop a designation other than 

roadless for the type of terrain snowmobilers use because snowmobiles don’t 

use roads. 

 Response: Roadless is inventory not a designation of any type of use. The Forest 

uses the designation winter motorized for terrain that snowmobilers use. 

789. The Wasatch-Cache National Forest should change Guideline G47 to a 

Standard and increase the snow depth required for winter motorized use. 

 Response: Currently, scientific studies are limited on the effects of compacted 

snow due to snowmobiling. These studies have shown there can be some effects. 

Whether or not these effects are significant has not been clearly established. The 

Guideline referring to snow depth is G54. This will remain a Guideline and the 

depth will remain the same. 

790. The Wasatch-Cache National Forest should eliminate bias in the proposed 

Forest Plan toward motorized recreation. 

 Response: The Forest Plan and accompanying EIS cover a broad range of 

alternatives. For example alternatives 1 & 2 significantly reduce the amount of 

roads and terrain open to motorized recreation. Alternative 3 expands the amount of 

roads and terrain open to motorized recreation. 

Adequacy of Analysis 

 

791. The Wasatch-Cache National Forest should address the potential 

environmental impacts of having massive areas of compacted snow due to 

snowmobile use. 

 Response: Currently, scientific studies are limited on the effects of compacted 

snow due to snowmobiling. These limited studies have shown there can be some 

effects. Whether or not these effects are significant relative to normal snow 

compaction has not been clearly established. 

792. The Wasatch-Cache National Forest should re-evaluate whether snowmobile 

use should be allowed when snow cover is less than or equal to 12 inches 

because of environmental impacts. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 183 

 Response: Currently, scientific studies are limited on the effects of compacted 

snow due to snowmobiling. These limited studies have shown there can be some 

effects. Whether or not these effects are significant relative to normal snow 

compaction has not been clearly established. When new, relevant scientific 

evidence indicating adverse effects, the depth and impacts will be re-evaluated. 

793. The Wasatch-Cache National Forest should incorporate new data into travel 

management planning about the effects of 2-stroke engines on the 

environment. 

 Response: Current data has been incorporated in the analysis for the Forest Plan 

and EIS. At such time as new data becomes available it will be looked at and 

analyzed. 

794. The Wasatch-Cache National Forest should evaluate the potential for 

snowmobile pollution, especially evaluate the impacts of pollution to 

watersheds. 

 Response: This topic is discussed in Section 3 under Environmental Consequences 

in the Final EIS. 

795. The Final EIS should include an analysis of the effects of snowmobiling on air 

quality, watersheds, and wildlife habitat. 

 Response: This topic is discussed in Section 3 under Environmental Consequences 

“Effects on air Quality from Snowmobiles.” 

796. The Wasatch-Cache National Forest should adequately evaluate the impact of 

snowmobiling in the Lakes backcountry. 

 Response: This topic was adequately discussed in Topic 3 Roads Access 

Management and Topic 4 Recreation and Scenery Management in the Final EIS. 

797. The Wasatch-Cache National Forest should determine the limits of 

snowmobile use due to impacts on wintering wildlife. 

 Response: The Forest continues to monitor winter motorize use areas. These areas 

are mapped in the Final EIS as well as in the Revised Forest Plan. Please refer to 

these maps for determining the limits of snowmobile use on the Forest. Winter 

motorized use and wildlife winter ranges have been looked at relative to each other 

and adjustments to terrain available for motorized use were made. 

Allow Snowmobiles 

798. The Wasatch-Cache National Forest should allow snowmobiles. 

 Response: The Wasatch-Cache National Forest will continue to provide a wide 

range of recreational opportunities both winter motorized and winter non-motorized 

use through management prescription allocations. Mapping of Winter Motorized 

use terrain is displayed in winter recreation mapping in the Revised Forest Plan. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 184 

798.1 By preserving the level of snowmobiling opportunity that exists today. 

 Response: Alternatives 3 and 5 in the Wasatch-Cache Final EIS increase the 

amount of snowmobiling opportunity available in the Forest EIS, alternative 4 

keeps the level of snowmobiling opportunity the same while Alternative 6 does not 

allow snowmobile use in recommended wilderness. Alternative 7 in the EIS allows 

snowmobile use in recommended wilderness. 

798.2 By providing specific areas for snowmobilers and parking. 

 Response: The Forest does provide areas for snowmobilers and non-snowmobilers 

alike. Please Refer to Topic 4 Recreation Management in the Final EIS for a 

discussion of this issue. In addition, refer to winter recreation maps in the Revised 

Forest Plan. 

798.3 If the final plan recommends additional wilderness. 

 Response: The current plan will allow winter motorized use to continue in newly 

proposed Wilderness in areas where it was allowed previously before the proposed 

Wilderness management prescription. 

799. The Wasatch-Cache National Forest should allow snowmobiles for 

environmental reasons. 

799.1 Because snowmobiles do not cause any environmental damage. 

 799.2 Because the Draft EIS has not proven any measurable impact or coflicts. 

 799.3 Because snowmobiles do not harm wildlife. 

 Response: The Forest will continue to allow snowmobiles in areas designated for 

winter-motorized use. Please refer to the winter recreation maps in the Revised 

Forest Plan showing areas open to winter motorized use. See also response 798.

800. The Wasatch-Cache National Forest should allow snowmobiles for social 

reasons because they are needed for search and rescue. 

 Response: Please refer to Topic 4 Recreation and Scenery Management in the 

Final Environmental Impact Statement and look at table REC-12 for the amount of 

acres open to snowmobiling by alternatives. 

801. The Wasatch-Cache National Forest should allow snowmobiles for economic 

reasons because snowmobilers contribute to the economy and money for trail 

grooming. 

 Response: The Forest will continue to allow snowmobiling. The economic effects 

of snowmobiling are discussed in Appendix B11 of the Final Environmental Impact 

statement. Please refer to the Social and Economics Section of the FEIS for a 

discussion of the economic effects of snowmobiling on local economies. 

802. The Wasatch-Cache National Forest should allow snowmobiles in certain 

areas. 

Response: See response 798 

802.1 In inventoried roadless areas.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 185 

 Response: The Forest Plan and FEIS cover a broad range of alternatives. Some 

alternatives increase the amount of winter motorized acreage such as Alternatives 3 

& 5 and some alternatives decrease the amount of acreage available for winter 

motorized use such as in alternatives 1 & 2. Alternative 6 does not allow 

snowmobiling in recommended Wilderness. Alternative 7, the preferred 

alternative, allows snowmobiles in recommended Wilderness. The final decision 

will try to balance an appropriate mix of winter motorized and winter nonmotorized terrain. 

802.2 In all currently open areas. 

 Response: The Forest Plan and FEIS cover a broad range of alternatives. Some 

alternatives increase the amount of winter motorized acreage and some alternatives 

decrease the amount of acreage available for winter-motorized use. The final 

decision will try to a balance an appropriate mix of winter motorized and winter 

non-motorized terrain. 

802.3 Re-open winter non-motorized areas on the Uinta’s North Slope. 

 Response: See response 802. 

802.4 Open semi-primitive non-motorized areas to snowmobile use seasonally. 

 Response: Areas with a Semi-primitive Non-Motorized ROS Classification will 

remain closed to motorized use. 

802.5 In the Bunchgrass area east of Tony Grove Lake and the area east of 

Swan Peak and south of Swan Lake. 

 Response: The Forest Plan and FEIS cover a broad range of alternatives. Some 

alternatives increase the amount of winter motorized acreage and some alternatives 

decrease the amount of acreage available for winter-motorized use. Alternatives 3, 5 

& 6 allow snowmobiling in this area. 

802.6 In Garden City Canyon. 

 Response: The Forest Plan and FEIS cover a broad range of alternatives. Some 

alternatives increase the amount of winter motorized acreage and some alternatives 

decrease the amount of acreage available for winter-motorized use. Alternatives 3, 5 

& 6 allow winter motorize use in the Garden City Canyon area. 

803. The Wasatch-Cache National Forest should not reduce winter motorized 

acreage because user numbers are increasing. 

 Response: The Forest Plan and FEIS cover a broad range of alternatives. Some 

alternative increase the amount of winter motorized acreage and some alternatives 

decrease the amount of acreage available for winter motorized use. Alternatives 3 & 

5 increase the number of acres available for winter motorized use. Alternative 7, the 

preferred alternative, allows snowmobile use in recommended Wilderness. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 186 

804. The Wasatch-Cache National Forest should not restrict winter motorized use 

because of economic impacts. 

 Response: Snowmobile use, along with many other recreational uses, is and will 

continue to be an allowed form of recreation on the Wasatch-Cache National Forest. 

The Wasatch-Cache National Forest will continue to provide a wide range of 

recreational opportunities both winter motorized and winter non-motorized use 

through management prescription allocations, Recreational Opportunity Spectrum 

(ROS) Classification, and subsequent winter recreation management. 

805. The Wasatch-Cache National Forest should not restrict snowmobiles based on 

the application of the Canadian Lynx Conservation Assessment, until 

conclusive studies have been completed within the appropriate lynx analysis 

units. 

 Response: The Endangered Species Act directs all government agencies to protect 

species listed as threatened and endangered. This includes habitat. Eleven 

counties in Northern Utah are included as lynx habitat by the US Fish and Wildlife 

Service (FWS) The Forest will work closely with the FWS on all mitigation 

requirements outlined for this species. 

806. The Wasatch-Cache National Forest should allow continued winter access to a 

variety of locations by snowmobile, helicopter and snow cat for the purpose of 

monitoring snowpack conditions and forecasting snow runoff. 

 Response: The Revised Forest Plan will continue to allow access for the purpose 

of monitoring snowpack conditions for forecasting snow runoff. 

Do Not Allow/Restrict Snowmobiles. 

807. The Wasatch-Cache National Forest should prohibit/restrict snowmobile use. 

Completely ban all winter motorized vehicles until resources for policing the 

areas can be increased. 

 Response: Snowmobile use, along with many other recreational uses, is and will 

continue to be an allowed form of recreation on the Wasatch-Cache National Forest. 

The Wasatch-Cache National Forest will continue to provide a wide range of 

recreational opportunities both winter motorized and winter non-motorized use 

through management prescription allocations, Recreational Opportunity Spectrum 

(ROS) Classification, and subsequent winter recreation maps. The Forest will 

continue to enforce applicable laws and regulations for winter-motorized use to the 

level allowed by current budgets and personnel available for enforcement tasks. 

808. The Wasatch-Cache National Forest should prohibit/restrict snowmobile use 

for environmental reasons. 

808.1 Because of off-road snowmobiling impacts. 

 808.2 Because of noise and air pollution. 

 808.3 Because of impacts to wildlife. 

 808.4 Because of impacts to threatened, endangered, and sensitive species.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 187 

 Response: This topic was discussed in several areas including Chapter 3-Affected 

Environment, Forest-wide recreation and Environmental Consequences under Topic 

2- Biodiversity and Viability. 

809. The Wasatch-Cache National Forest should prohibit/restrict snowmobile use 

for social reasons. 

809.1 Because it impacts social values. 

809.2 Because it caters to the wealthy. 

Response: Snowmobile use, along with many other recreational uses, is and will 

continue to be an allowed form of recreation on the Wasatch-Cache National Forest. 

The Wasatch-Cache National Forest will continue to provide a wide range of 

recreational opportunities both winter motorized and winter non-motorized use 

through management prescription allocations, Recreational Opportunity Spectrum 

(ROS) Classification, and subsequent winter recreation maps. The Forest will 

continue to enforce applicable laws and regulations for winter-motorized use to the 

level allowed by current budgets and personnel available for enforcement tasks. The 

FEIS examines a range of Alternatives for separation of winter motorized and nonmotorized uses. 

810. The Wasatch-Cache National Forest should prohibit/restrict snowmobile use in 

certain areas. 

810.1 In roadless areas 

 810.2 In the Lily Lake Cross-country Ski Area expansion 

810.3 On the east slopes of Mount Naomi.

Response: All of the Alternatives in the Final EIS restrict snowmobiles to certain 

areas to a great extent. Alternatives 1, 2 & 6 in the Wasatch-Cache Final EIS 

significantly restrict winter motorized use in specific areas across the forest. 

Alternative 1 restricts winter motorized use in roadless areas. Alternatives 1 & 2 in 

the Wasatch-Cache Final EIS restricts use in the Lily Lake Cross-country Ski Area. 

Alternatives 1, 6 and 7 in the Wasatch-Cache Final EIS restricts use on the east 

slopes of Mount Naomi. 

811. The Wasatch-Cache National Forest should control snowmobiles through 

restrictions. 

 Response: There are restrictions on winter motorized use on the Forest. 

811.1 Restrict to currently open areas. 

 Response: Alternative 4 in the Wasatch-Cache Final EIS leaves winter motorized 

use the same. 

811.2 Don’t open new areas 

Alternative 4 in the Wasatch-Cache Final EIS leaves winter motorized use the 

same. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 188 

811.3 Broaden Guideline 34 to allow more flexibility for imposing winter 

recreational closures. 

 Response: Guideline 34 was changed to Guideline 39 in the Revised Forest Plan 

and has remained the same. 

811.4 Impose seasonal restrictions. 

 Response: Winter motorized use is controlled through winter recreation 

management described in the Revised Forest Plan under Forestwide AllocationsWinter Recreation. Winter recreation management begins when there is 12 inches 

of snow present on the ground. 

811.5 Close areas with potential lynx habitat to winter motorized use. 

 Response: The Endangered Species Act directs all government agencies to protect 

species listed as threatened and endangered. This includes habitat. Eleven 

counties in Northern Utah are included as lynx habitat by the US Fish and Wildlife 

Service (FWS). The Forest will work closely with the FWS on all mitigation 

requirements outlined for this species. 

811.6 Regulate user numbers 

 Response: Regulating users is one tool to regulate use. The Forest will continue to 

manage winter motorized use through standards and guidelines, management area 

prescriptions, ROS and winter recreation management strategies. Please refer to 

Chapter 4 of the Revised Forest Plan under Forest Wide Allocations and in 

Management Area Prescriptions for a description on how Winter Motorized use will 

be managed. 

812. The Wasatch-Cache National Forest should not issue a special use permit to 

snowmobilers in Cardiff Fork to access mining claims because snowmobiles 

are not using these permits legitimately. 

 Response: The Forest Service is required to provide “reasonable” access to a 

person owning private land surrounded by National Forest. Special Use Permits 

(SUP) are issued to the private landowner allowing them to cross National Forest so 

that they are able to access their private land. The Forest Service needs to continue 

to make sure all persons who are allowed to access their private land through a SUP 

are complying with the terms and conditions set out in that SUP. Several courses of 

action are available to the SUP administrator if the SUP holder is violating the 

terms of the SUP. 

Motorized Recreation – Heli-skiing 

Motorized Recreation – Heli-skiing General 

813. The Wasatch-Cache National Forest should use the description from the 

Forest Plan to define the area of permitted heli-ski terrain to be exchanged. 

 Response: The terrain where helicopter skiing is allowed is well described in the 

Special Use Permit allowing this activity to occur. In addition, helicopter ski terrain 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 189 

is well described by alternative in the Final EIS and in the Revised Forest Plan 

Winter Recreation Maps. Please refer to the September1999 Environmental Impact 

Statement completed for the helicopter skiing permit renewal. 

Adequacy of Analysis. 

814. The Wasatch-Cache National Forest should explain the issue of eliminating 

recreational helicopter activities to allow eagles to effectively reproduce in the 

Tri-Canyons. 

 Response: A thorough analysis was completed on the effects of helicopter skiing 

on nesting raptors in the September1999 Environmental Impact Statement on 

Wasatch Powderbird Guides helicopter skiing permit renewal. 

Allow Heli-skiing. 

815. The Wasatch-Cache National Forest should allow heli-skiing because it is good 

for everyone. 

815.1 Because eliminating this activity is in contrast to stated forest goals. 

 815.2 For multiple use. 

 815.3 Since the cumulative impacts of the EIS and the Special Use Permit 

(SUP) may have already placed the future of this activity in jeopardy. 

 815.4 By allowing heli-skiing on Sunday and Monday.

 Response: This issue was thoroughly analyzed in the September1999 

Environmental Impact Statement completed for the helicopter skiing permit 

renewal. Wasatch-Powderbird Guides will continue to operate under the terms and 

condition of their 5-year Outfitter and Guide SUP. 

 

816. The Wasatch-Cache National Forest should allow heli-skiing for 

environmental reasons because it does not harm the environment because 

noise is a minimal impact. 

 Response: See response 815. 

817. The Wasatch-Cache National Forest should allow heli-skiing for social reasons. 

817.1 For safety. 

 817.2 For the disabled. 

Response: See response 815. 

818 The Wasatch-Cache National Forest should allow heli-skiing for economic 

reasons because of its impact to the economy. 

 Response: See response 815. 

819. The Wasatch-Cache National Forest should allow heli-skiing in certain areas. 

819.1 In wilderness areas. 

 Response: The Wilderness Act prohibits motorized use in Wilderness areas. 

819.2 In the Cascade area. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 190 

 Response: The Uinta NF allows heli-skiing in the Cascade Ridge area. 

819.3 In Mill Creek Canyon. 

 Response: Helicopter skiing is allowed in the Gobblers Knob area of Millcreek 

Canyon. 

820. The Wasatch-Cache National Forest should allow Wasatch Powderbird Guides 

heli-skiing use. 

820.1 Because they are stewards of the environment. 

820.2 Because they contribute to the economy. 

820.3 Do not discriminate against the Wasatch Powderbird Guides. 

Response: The Revised Wasatch-Cache Forest Plan allows helicopter skiing to 

continue on the Forest under a 5-year SUP. The Forest Service does not 

discriminate against any Outfitter and Guide permittee. 

Do Not Allow/Restrict Helis-skiing 

821. The Wasatch-Cache National Forest should prohibit/restrict heli-skiing. 

821.1 By the year 2004 

821.2 Terminate or phase out helicopter permits. 

821.3 Because there is ample opportunity on private land. 

821.4 If allowed, make them fly farther to avoid areas frequently accessed by 

others.

Response: The Forest Plan provides broad program-level direction for 

management of the land and its resources. The Forest Plan, under Forest Wide 

Allocations, allows helicopter skiing. Wasatch Powderbird Guides (WPG) currently 

operates under a 5-year Outfitter and Guide Special Use Permit. The Revised Forest 

Plan continues to allow WPG to operate under the terms and conditions of their 

current 5-year SUP. 

822. The Wasatch-Cache National Forest should prohibit/restrict heli-skiing for 

environmental reasons because it negatively impacts wildlife because it 

negatively impacts birds. 

 Response: Please refer to the September 1999 Final Environmental Impact 

Statement on Wasatch Powderbird Guides Permit Renewal for a thorough 

discussion of the effects of heli-skiing on wildlife. In this EIS a comprehensive 

mitigation plan was established with the advice and consent of the U.S. Fish and 

Wildlife Service (FWS). Due to WPG’s season of operation, elevations at which 

they operate, the nature of the disturbance they generate, and the mitigation 

measures in place, their potential impact to wildlife is minimal. 

823. The Wasatch-Cache National Forest should prohibit/restrict heli-skiing in 

certain areas. 

823.1 In the canyon areas. 

 Response: The Wasatch-Cache National Forest provides a wide variety of 

recreational uses and opportunities to many user groups. The Forest Plan continues 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 191 

to allow Wasatch Powerbird Guides to operate under the terms and conditions of 

their current 5-year Outfitter and Guide Special Use permit. 

823.2 Along the entire Wasatch Range. 

 Response: The Wasatch-Cache National Forest provides a wide variety of 

recreational uses and opportunities to many user groups. WPG is one use and is 

currently allowed to operate under a 5-year SUP. 

823.3 In the Tri-Canyon area. 

 Response: The Wasatch-Cache National Forest provides a wide variety of 

recreational uses and opportunities to many user groups. WPG is one use and is 

currently allowed to operate in the Tri-Canyon area under a 5- year SUP. 

823.4 In Gobbler’s Knob. 

 Response: The Wasatch-Cache National Forest provides a wide variety of 

recreational uses and opportunities to many user groups. WPG is one use and is 

currently allowed to operate in the Gobblers Knob area under a 5-year SUP. 

823.5 In semi-primitive non-motorized areas. 

 Response: Alternatives 1 & 2 do this. In the Revised Forest Plan helicopter skiing 

will continue to operate as a component of the recreation picture in the Central 

Wasatch. 

824. The Wasatch-Cache National Forest should prohibit. Wasatch Powderbird 

Guides heli-skiing use in the Tri-Canyon area. 

 Response: The Wasatch-Cache National Forest provides a wide variety of 

recreational uses and opportunities to many user groups. Wasatch-Powderbird 

Guides is one use and is currently allowed to operate in the Tri-Canyon area under a 

5-year Outfitter and Guide Special User Permit. 

Other 

825. The Wasatch-Cache National Forest should prohibit scenic commercial 

aircraft overflights. 

 Response: Management of scenic overflights is under the juristiction of the 

Federal Aviation Administration, not the Forest Service. 

Motorized Recreation - Watercraft 

Allow Motorized Watercraft 

826. The Wasatch-Cache National Forest should allow motorized watercraft by 

allowing personal watercraft. 

 Response: The Wasatch-Cache NF does allow boats with 5hp motors on lakes that 

are large enough not create user conflicts. Personal watercraft currently used on 

larger reservoirs would create unacceptable user conflicts on small National Forest 

lakes. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 192 

827. The Wasatch-Cache National Forest should open all lakes to boats with electric 

motors because there is no threat to the environment and this will permit the 

disabled to enjoy lakes. 

 Response: The Wasatch-Cache NF does allow boats with 5hp motors on lakes that 

are large enough not create user conflicts. 

Do Not Allow/Restrict Motorized Watercraft 

828. The Wasatch-Cache National Forest should not allow motorized watercraft. 

 Response: The Wasatch-Cache NF does allow boats with small motors on lakes 

that are large enough not create user conflicts. 

Mechanized Recreation General 

829. The Wasatch-Cache National Forest should manage mountain bikes as a 

distinct form of recreation, separate from motorized activities. 

 Response: The Wasatch-Cache National Forest manages mountain bike use 

appropriately through management prescriptions; travel management plans and 

current trail management guidelines. 

830. The Wasatch-Cache National Forest should recognize the importance of 

singletrack trails to bicyclists. 

 Response: The Wasatch-Cache National Forest does recognize the importance of 

single-track trails to bicyclist. Not all trails are open to Mountain Bike use however. 

831. The Wasatch-Cache National Forest should consider that designating the 

Mount Naomi roadless area as wilderness will lead to increased mechanized 

use and potential for conflict. 

 Response: The Mount Naomi roadless area is not being considered for proposed 

wilderness. 

832. The Wasatch-Cache National Forest should require bikers and hikers to share 

restrictions. 

 Response: Because of safety, conflicts with other users and resources issues, 

mountain bike use requires a higher or more intense level of management and 

therefore requires more restrictions to manage use. 

Allow Mechanized Recreation. 

833. The Wasatch-Cache National Forest should allow mechanized activities. 

833.1 On designated days and on trails that can sustain their travel 

833.2 On roads and trails only. 

 833.3 Allow bikes off of designated trails.

 Response: Mountain bike use will continue to be restricted to trails where it is 

allowed. Please refer the District Travel Management Plans for locations of trails 

open to mountain bike use. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 193 

834. The Wasatch-Cache National Forest should allow mechanized activities for 

environmental reasons. 

834.1 Because mountain bikes do not impact the environment. 

834.2 Because mountain bikes do not affect water quality. 

 Response: The Current Plan allows mountain bike on designated trails. We 

believe that mountain bikes can impact water quality indirectly. 

835. The Wasatch-Cache National Forest should allow mechanized activities for 

social reasons because there is no information to support the claim that the 

presence of bicycles on shared-use trails increases the risk to other trail users’ 

safety. 

 Response: The Forest Plan allows mountain biking to continue on designated 

trails. The Forest Service feels every user’s safety is extremely important. If shared 

trail use creates an unacceptably dangerous situation then that shared use will have 

to be evaluated and mitigated. 

836. The Wasatch-Cache National Forest should allow mechanized activities for 

economic reasons because mountain biking contributes to the local or regional 

tourism economy. 

 Response: The Forest Plan continues to allow mountain biking on designated 

trails across the forest. Please refer to District Travel Plans. 

837. The Wasatch-Cache National Forest should allow mechanized activities in 

certain areas. 

837.1 In wilderness areas 

 Response: The Wilderness Act prohibits mechanized activities in Designated 

Wilderness areas. 

837.2 In limited areas 

 Response: The Forest allows mechanized use on designated roads and trails. Refer 

to District Travel plans and winter motorized use plans to find out where 

mechanized use is allowed. 

838. The Wasatch-Cache National Forest should not restrict mountain biking 

because most users cause no damage. 

 Response: The Forest Plan continues to allow mountain biking on designated 

trails. Refer to District Travel Plans to find out information on where you can 

mountain bike. 

Do Not Allow/Restrict Mechanized Recreation 

839. The Wasatch-Cache National Forest should prohibit/restrict mechanized 

activities because it is dangerous to hikers and the environment. 

 Response: The Wasatch-Cache National Forest will continue to allow mechanized 

and non-mechanized activities in appropriate areas on the Forest. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 194 

Non-Motorized Recreation 

Adequacy of Analysis 

840. The Wasatch-Cache National Forest should consider the displacement effect of 

motorized recreation on non-motorized users. 

 Response: Motorized recreation use will continue to allow motorized activities on 

designated trails. However, the forest will continue to monitor recreational use and 

will re-examine the forest role as a provider of outdoor recreation and plan for ways 

to reduce recreational conflicts between users. The Revised Forest Plan identifies 

recreation use conflicts as a significant issue and will continue to identify areas for 

separation of non-motorized use consistent with growing demand. 

Allow Non-Motorized Recreation. 

841. The Wasatch-Cache National Forest should allow non-motorized activities. 

 841.1 By giving non-motorized users the highest priority. 

 841.2 By designating all remaining roadless areas for non-motorized use. 

 841.3 By designating areas as non-motorized which fulfill non-motorized 

recreation needs. 

 841.4 By setting aside more areas. 

 841.5 By designating/providing areas that meet a variety of non-motorized 

activities. 

 841.6 By resource allocation. 

 841.7 By allowing horses. 

 841.8 By improving trail signs, displays, restroom facilities, and educational 

programs for non-motorized recreationists.

 Response: The Forest has evaluated a wide variety of alternatives when it comes to 

providing for non-motorized activities. Some of the alternative provide for 

increasing opportunities in non-motorized recreation, specifically alternatives 1 and 

2. The Forest is continually improving trail signs, displays and restroom facilities. 

The Forest Service is continually improving educational curriculums it delivers 

through campfire talks, nature walks, avalanche and Ski with the Ranger programs. 

842. The Wasatch-Cache National Forest should allow non-motorized activities for 

social reasons because it is good for health and social values. They should also 

provid more non-motorized recreation opportunities for the disabled. 

 Response: There are many areas the Forest that only allows non-motorized 

activity. The Forest is constantly improving existing campgrounds, picnic areas, 

recreation facilities and trails to better accommodate and serve persons with 

disabilities. 

843. The Wasatch-Cache National Forest should allow only non-motorized 

activities in some areas by allowing off highway foot traffic only. 

 Response: The Wasatch-Cache NF management prescriptions provide for a broad 

range of recreational opportunities. Some areas allow motorized recreation, Some 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 195 

areas do not allow any motorized activities such as in Wilderness. Refer to the 

Final Environmental Impact Statement for comparisons of alternatives by 

management prescription. 

Do Not Allow/Restrict Non-Motorized Recreation 

844. The Wasatch-Cache National Forest should prohibit/restrict non-motorized 

activities 

844.1 By prohibiting any wheeled non-motorized device except bicycles where 

permitted and wheelchairs. 

 Response: The Wasatch-Cache NF management prescriptions provide for a broad 

range of recreational opportunities. Some areas allow motorized recreation, some 

areas do not allow any motorized activities such as in Wilderness. In some areas 

only hiking is allowed. Please refer to the Revised Forest Plan for descriptions of 

management prescriptions and management areas. Also, refer to the Final 

Environmental Impact Statement for comparisons of alternatives by management 

prescriptions. 

844.2 By prohibiting horses. 

 Response: Horses are restricted in the Tri-Canyon and other specific areas for 

watershed protection and/or other reasons. Otherwise horse use is recognized as a 

legitimate recreational use and will continue to be allowed. 

845. The Wasatch-Cache National Forest should prohibit/restrict non-motorized 

activities for environmental reasons. 

845.1 To control environmental impacts

 Response: The Forest Service is continually monitoring impacts to the Forest from 

all activities including non-motorized. 

845.2 Because hikers disturb wildlife more than motorized users 

 Response: The Forest Service will continue to provide a broad range of 

recreational opportunities for all Forest users. There is no credible evidence that 

hikers disturb wildlife more than motorized use. However, there is a substantial 

body of scientific evidence that loud noises created by motorize vehicles like 

ATV’s or four wheelers tend to disturb wildlife significantly more when compared 

to a person walking quietly in the woods. 

Other 

846. The Wasatch-Cache National Forest should develop standards and guidelines 

to manage rock climbing and extreme sports because of environmental 

impacts. 

 Response: Some standards and guidelines have been incorporated in the Forest 

Plan Direct for Climbing. The analysis of extreme sports and their routes are 

beyond the scope of the Forest Plan. Environmental impacts associated with those 

sports will be analyzed and managed on a site-specific basis. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 196 

847. The Wasatch-Cache National Forest should not let sport climbing routes be 

ruined. 

 Response: See response 846. 

Ski Areas 

Ski Areas General 

848. The Wasatch-Cache National Forest should address ski areas in the document 

because this use is important in terms of user days and impacts. 

 Response: The Forest Plan and the Final EIS do address ski areas and their use. 

Please refer to Revised Forest Plan under Forest Wide Desired Future Conditions, 

Forest Wide Allocations and Management Area Descriptions for discussions of this 

issue. 

849. The Wasatch-Cache National Forest should substantially strengthen the 

desired future conditions description for ski areas. 

849.1 To minimize future development and impacts.

 Response: The Revised Forest Plan and Final Environmental Impact Statement 

discuss this issue through a broad range of alternatives and the Ecosystem 

Management Framework and Forest Plan Model. 

849.2 To avoid facility construction designed to divert customers from other 

resorts. 

 Response: This is beyond the scope and context of the Forest Plan. This issue will 

be discussed with site specific ski area proposals. 

850. The Wasatch-Cache National Forest should develop a travel plan to bus people 

from the mouth of the canyon to ski areas. 

 Response: This is beyond the scope of the Forest Plan. The Utah Transit Authority 

already provides public bus service to the four ski resorts in Little Big and Little 

Cottonwood Canyons during the winter months. 

851. The Wasatch-Cache National Forest should make guideline G73 a standard 

and enforce its direction that special uses “meet the tests of prudent, 

reasonable, and absolutely in the public interest.” to prohibit uses that aren’t 

in the best interest of the public. 

 Response: Guideline 73 has been removed. Please refer to G 80 & G 81 for 

guidelines for Special Uses. 

852. The Wasatch-Cache National Forest should include clearly stated visual 

quality standards to avoid further deterioration. 

 Response: The Forest Service has adopted a new tool called the Scenery 

Management System for integrating the benefits, values, desires, and preferences 

regarding aesthetics and scenery for all levels of land management. Though many 

of the terms used in the previous Visual Management System have similar meaning 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 197 

there are different key words being used. Visual quality of the Visual Management 

System is no longer used. The new terms used in understanding how the Forest is 

being managed are Landscape Character Themes, Landscape Character and Scenic 

Integrity Guidelines. See the Revised Forest Plan, Chapter 4, Section 3. Forestwide 

Standards and Guidelines, Scenic Resources for Forestwide Standards and 

Guidelines. 

853. The Wasatch-Cache National Forest should consider that the ‘high’ Scenic 

Integrity Objective within the Resort Natural Setting is an oxymoron. 

 Response: Oxymoron is “a combination of contradictory or incongruous words” as 

stated in the Merriam-Webster Dictionary. Based on this definition you have stated 

you think or feel “high” Scenic Integrity is contradictory or incongruous with a 

Landscape Character Theme of Resort Natural Setting. 

The basis for the use of Landscape Character Themes is to address existing or 

future land use, and the general image of the forest that is being managed. Resort 

Natural Setting Landscape Character theme for the purpose of the Revised Forest 

Plan is confined to the permit boundaries of the resorts. It recognizes that cultural 

modification to mountain is a function of activities and their supporting amenities. 

Scenic Integrity provides a way to measure the degree to which a landscape is 

visually perceived to be complete. The highest scenic integrity rating was given to 

the landscape, which has little or no deviation from the described landscape 

character valued by constituents for its aesthetic appeal. See Revised Forest Plan, 

Chapter 4, Wasatch-Cache National Forest Landscape Character Theme and Scenic 

Integrity Guideline Definition Table. The landscape character of this culturally 

modified landscape is rating integrity of the modifications based on its harmony 

with the surrounding natural appearing landscape setting and provides baseline 

attributes to be able a meet a particular level of integrity. 

If the ski resorts where being managed under another Landscape Character Theme 

and its accompanying landscape character description the Scenic Integrity could be 

lower or higher based on the amount of deviation from the described valued 

landscape character. Therefore the delineated areas on the Forest for each 

Landscape Character Theme must be judged against it own landscape character 

description for the degree of integrity that can be achieved. 

854. The Wasatch-Cache National Forest should add a standard requiring ski areas 

to reseed cuts, runs, and other cleared areas. 

Response: Current Forest Service and County “Best Management Practices” 

require ski areas to reseed cuts, runs and other cleared areas with native species. 

855. The Wasatch-Cache National Forest should require ski area managers to work 

with their staff to change attitudes about wildlife and minimize direct wildlife 

impacts. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 198 

 Response: Ski areas operating on the Wasatch-Cache National Forest work closely 

and carefully with Forest Service Wildlife Biologist and other staff persons to 

minimize potential effects to wildlife. Forest Service personnel accomplishe this 

through environmental reviews of all ski area proposals as well as yearly operating 

plans and through frequent monitoring activities. 

856. The Wasatch-Cache National Forest should require all ski resorts operating 

under special use permits to hire an environmental administrator and have a 

peer review board in order to operate on public lands. 

 Response: Refer to response 855. 

857. The Wasatch-Cache National Forest should request resorts close a half hour 

earlier each night where night skiing occurs for safety and to reduce light 

pollution. 

 Response: This issue is beyond the scope of the Forest Plan. Brighton is the only 

ski resort with a significant night skiing program on the Wasatch-Cache National 

Forest. The effects of night skiing lighting were carefully analyzed and thoroughly 

discussed in the 1999 Brighton Ski Resort Master Plan EIS. 

858. The Wasatch-Cache National Forest should adjust ski area trail widths or 

create new trails to deal with the increase of traffic caused by higher speed and 

higher capacity lifts to keep a competitive edge. 

 Response: This issue is beyond the scope of the Forest Plan. This issue has been 

thoroughly analyzed and discussed in several recent EIS’s completed for local Ski 

Resort Master Development plans. 

 

859. The Wasatch-Cache National Forest should redraw the national forest 

boundary so that Snowbird ski and summer resort is under the jurisdiction of 

one national forest, not two. This would be less confusing and lead to less 

miscommunication. 

 Response: The Wasatch-Cache National Forest administers Snowbirds Special Use 

Permit, allowing them to operate on National Forest System lands. Snowbirds 

permit area boundary encompasses public and private land, crosses county and 

Forest boundaries and includes separate and distinct watersheds. Each County and 

Forest has jurisdictional responsibilities related to Snowbirds operations and each 

will continue exercise those responsibilities. Only Congress has the authority to 

change Forest Boundaries. 

860. The Wasatch-Cache National Forest should address the degradation of 

watershed health due to ski resort expansion and operations. A description of 

the effects of ski resorts on aquatic resources should be included. 

 Response: The Forest Plan discusses watershed management within the framework 

of ecosystem management and sustainability. Please refer to the FEIS, Chapter 3, 

Topic 1 (Watershed Health) and Topic 2 (Aquatic Resources), Wasatch-Cache 

National Forest for a thorough discussion of this issue. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 199 

861. The Wasatch-Cache National Forest should disclose skier density so the public 

can make informed comment on the acceptability of the rapid increase in the 

amount of land allocated per skier. 

 Response: Skier densities are difficult to measure accurately and vary widely 

depending upon time of day, weekday or weekend and time of year, such as a 

holiday weekend, and vary widely from year to year. In addition, skier density can 

vary widely due to run difficulty, snow conditions, grooming conditions etc. 

Consequently, calculating accurate skier densities is extremely difficult and 

unreliable. 

862. The Wasatch-Cache National Forest should estimate the number of skier days 

attributable to snowmaking to differentiate the portion of growth attributable 

to snowmaking because it has no bearing on whether there is demand for more 

terrain for skiing. 

 Response: The Wasatch-Cache National Forest did not calculate the number of 

skier days attributed to snowmaking since reliable data is unavailable. Skier visits 

at individual ski resorts vary annually due to differences in natural snow, marketing 

trends, or factors other than snowmaking. To distinguish between the numbers of 

skier days attributed to snowmaking would be questionable at best. 

863. The Wasatch-Cache National Forest should assess the importance of nonmotorized winter recreation areas and the yurt system. 

 Response: Non–motorized winter recreation is an important component of the total 

recreational use on the forest. Alternatives 1 & 2 of the Wasatch-Cache Final EIS 

discuss the importance of minimizing human interference and reducing motorized 

use. Alternative 7 in the Final EIS and The Revised Forest Plan create a nonmotorized area in the Bunch Grass and Steam Mill peak area in the Logan Area 

Mountains. 

Education. 

864. The Wasatch-Cache National Forest should increase public education about 

the stewardship benefits of ski areas. 

 Response: The Forest Service and Wasatch-Cache ski areas in partnership have 

created Ski With the Ranger Programs and “Ski-Cology.” Both of these programs 

educate forest users on the stewardship benefits of ski areas. 

Skiing 

865. The Wasatch-Cache National Forest should allow skiing. 

865.1 By designating non-motorized winter recreation areas with enforceable 

boundaries or banning snowmobiles from the surrounding areas. 

 Response: All of the alternatives in the Wasatch-Cache Final EIS designate nonmotorized areas with enforceable boundaries to varying degrees. In the 

Alternatives 1 & 2, non-motorize use is emphasized and snowmobiling is banned in 

most areas. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 200 

865.2 By including quality skiing experiences in the Desired Future Conditions 

 Response: Desired Future Condition is an integrated visualization of what the 

forest or management area should look like in the future. Skiing is a recreational 

activity, which people do on the forest. A quality skiing experience whether it 

occurs at a ski area or in a backcountry setting has always been an important 

component of the forests desired future condition for recreation management. 

866. The Wasatch-Cache National Forest should encourage cross-country skiers to 

ski in wilderness areas. 

 Response: The Wasatch-Cache National Forest has always and will continue to 

encourage responsible recreational use that is allowed in Wilderness. 

Ski Area Expansion 

867. The Wasatch-Cache National Forest should address ski area expansion by 

defining year round resort development and requiring that each proposal be 

linked to a need that can only be met in an alpine setting. 

 Response: This is beyond the scope of the Forest Plan. Any ski area expansion 

proposal is thoroughly analyzed through the development of ski area master plans 

an accompanying NEPA review. A needs analysis is a required component of any 

NEPA document. 

867.1 By establishing a reasonable process other than a Forest Plan 

amendment for potential adjustment or expansion of resort permit boundaries 

during the life of this plan. 

 Response: The Revised Forest Plan states: “New resort developments on National 

Forest System land will be confined to the permit area boundaries in effect at the 

time of revision, though small-scale site-specific adjustment could be considered to 

address important management issues.” The process for forest plan amendments 

can be found in Chapter 5 of the Revised Forest Plan. 

867.2 By clarifying that language on page 4-99 of the Forest Plan does not 

prohibit the Forest Service from considering proposals for boundary 

expansion. 

 Response: The Revised Forest Plan on page 4-99 reads, “New resort developments 

on National Forest System lands will be confined to the permit area boundaries in 

effect at the time of revision, though small scale site specific adjustments could be 

considered to address important management issues.” The process for forest plan 

amendments can be found in Chapter 5 of the Revised Forest Plan. 

867.3 By recognizing that the issue of ski area expansion onto private lands is 

still under consideration. 

 Response: The Forest Service has no jurisdiction over private lands. State, 

Counties and Municipalities typically have various types of jurisdictional authority 

over private land. Refer to response above. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 201 

867.4 By suggesting that the ski areas apply better resource management 

while they are open rather than expand. 

 Response: Ski areas operate on public land under a Special Use Permit 

administered by the Forest Service. The Forest Services manages the terms and 

conditions of the SUP, not the day-to-day operation of the resort. 

868. The Wasatch-Cache National Forest should change language in the Forest 

Plan. 

868.1 On page 4-99 regarding ski resort developments.

 Response: The Statement in the Revised Forest Plan reads, “New Resort 

Developments on National Forest System Lands will be confined to permit 

boundaries in effect at the time of revision....” 

868.2 On page 4-99 regarding opportunities that build on public land values. 

 Response: We have chosen not to change the language in the Revised Forest Plan. 

868.3 On pages 53 and 54 because the language pertaining to ski area 

development is too permissive. 

 Response: We were unable to find sentence the statement that was being referred 

to on pages 53 and 54. 

869. The Wasatch-Cache National Forest should explain in the Forest Plan that 

regular maintenance or replacement of existing resort equipment and/or 

facilities are categorically excluded from the National Environmental Policy 

Act analysis. 

 Response: A Forest Plan provides broad program level direction for management 

of the land and its resources. A Forest plan does not contain commitments to 

implement specific projects. All proposed projects involve some level of 

environmental analysis and public involvement and that is where these decisions 

will be made. 

870. The Wasatch-Cache National Forest should write a directive into the TriCanyon Crisis Plan regarding approval for modifications of existing 

developments. 

 Response: All major or significant modifications of existing developments on 

private or public land in the Tri-Canyons require various approvals either from the 

State of Utah, Salt Lake County, Salt Lake City and/or the Forest Service and 

sometimes all four. 

871. The Wasatch-Cache National Forest should address the concern over the total 

number of gallons of petroleum fuel planned to be stored within the Hidden 

Peak expansion. 

 Response: This is beyond the scope of the Forest Plan. This issue was thoroughly 

analyzed in the recent Snowbird Master Development Plan and accompanying 

Environmental Impact Statement. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 202 

Allow Ski Area Expansion 

872. The Wasatch-Cache National Forest should not place restrictions on the ski 

industry based on the speculative possibility that the, or other species, will be 

placed on the endangered species list because a flexible policy will allow the 

Forest Service to react as science develops rather than make premature 

restrictions. 

 Response: The Endangered Species Act directs all government agencies to protect 

species listed as threatened and endangered. This includes habitat. Eleven 

counties in Northern Utah are included as lynx habitat by the US Fish and Wildlife 

Service (FWS). Salt Lake County is one of those counties. The Forest will work 

closely with the FWS on all mitigation requirements they outlined for this species. 

The Forest Plan provides broad program-level direction for management of the land 

and its resources. Future projects carry out the direction in the Forest Plan. Ski areas 

fall into a subset of recreation goals and objectives affecting Forest lands. Within 

the framework of the Forest Plans effort for ecosystem management, these topics 

are adequately addressed. 

873. The Wasatch-Cache National Forest should expand the new swing because it is 

the only environmentally safe way to drop users off without damaging the 

ecosystem. 

 Response: The question cannot be answered as it is worded. 

874. The Wasatch-Cache National Forest should eliminate the visual integrity of 

ridgelines requirement for Mount Ogden to allow gondola construction. 

 Response: This is a Recreation Desired Future Condition for the Snowbasin Ski 

Area and the integrity of the ridgeline would be evaluated on a case-by-case basis 

and is beyond the scope of this analysis. 

Do Not Allow/Restrict Ski Area Expansion. 

875. The Wasatch-Cache National Forest should prohibit/restrict ski area 

expansion and infrastructure development. 

875.1 Do not expand beyond the year 2000 boundaries 

875.2 Do not allow activities resembling expansion beyond current 

boundaries. 

875.3 Do not use public land to subsidize real estate development. 

875.4 Do not justify expansion by claiming to protect backcountry travelers 

from dangers such as avalanches. 

875.5 Prohibit infrastructure development. 

875.6 Because the industry has not experienced significant growth. 

875.7 Because of increased dispersed recreation. 

875.8 Because it is taking away non-motorized areas.

 Response: The expansion issue is addressed in the Revised Forest Plan and 

through the broad range of alternatives displayed in the Final Environmental Impact 

Statement. The Forest Plan in Chapter 4 under the Central Wasatch Management 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 203 

area states: New resort developments on National Forest System lands will be 

confined to the permit boundaries in effect at the time of revision, though smallscale site-specific adjustments could be considered to address important 

management issues. Any proposed ski resort expansion and infrastructure 

development is studied and approved through a site specific Resort Development 

Master Plan. This includes a thorough NEPA review. 

876. The Wasatch-Cache National Forest should prohibit/restrict ski area 

expansion and infrastructure development for environmental reasons. 

876.1 Because of cumulative impacts. 

876.2 Because of the artificial and substantial increases of human impacts. 

876.3 To protect watersheds. 

876.4 To protect wildlife. 

876.5 To protect nesting birds. 

876.6 Because of night sky pollution. 

876.7 Because it affects aesthetic qualities. 

876.8 Have clear language in the Forest Plan setting standards for forest 

preservation. 

876.9 Until provisions are met for monitoring, enforcement, clean up, and 

maintenance.

 Response: The expansion issue is addressed in the Revised Forest Plan and 

through the broad range of alternatives displayed in the Final Environmental Impact 

Statement. The Forest Plan in Chapter 4 under the Central Wasatch Management 

area states, “New resort developments on National Forest System lands will be 

confined to the permit boundaries in effect at the time of revision, though smallscale site-specific adjustments could be considered to address important 

management issues.” Any proposed ski resort expansion and infrastructure 

development is studied and approved through a site specific Resort Development 

Master Plan. This includes a thorough NEPA review. 

 

877. The Wasatch-Cache National Forest should prohibit/restrict ski area 

expansion and infrastructure development for social reasons 

877.1 Because it does not benefit everyone. 

 Response: Alternatives 1 & 2 do this. 

877.2 Because crowding and safety issues do not justify expansion 

 Response: The expansions issue is addressed in the Revised Forest Plan and 

through the broad range of alternatives displayed in the Environmental Impact 

Statement. The Forest Plan in Chapter 4 under the Central Wasatch Management 

area states, “New resort developments on National Forest System lands will be 

confined to the permit boundaries in effect at the time of revision, though smallscale site-specific adjustments could be considered to address important 

management issues.” Alternative 7 in the Final EIS covers this issue. Any proposed 

ski resort expansion and infrastructure development is studied and approved 

through site specific Resort Development Master Plans and accompanying NEPA 

review. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 204 

878. The Wasatch-Cache National Forest should prohibit/restrict ski area 

expansion and infrastructure development in certain areas and specific resorts. 

 Response: The expansions issue is addressed in the Revised Forest Plan and 

through the broad range of alternatives displayed in the Environmental Impact 

Statement. The Forest Plan in Chapter 4 under the Central Wasatch Management 

area states, “New resort developments on National Forest System lands will be 

confined to the permit boundaries in effect at the time of revision, though smallscale site-specific adjustments could be considered to address important 

management issues.” Alternative 7 in the Final EIS covers this issue. Any proposed 

ski resort expansion and infrastructure development is studied and approved 

through site specific Resort Development Master Plans and accompanying NEPA 

review. 

 

879. The Wasatch-Cache National Forest should prohibit avalanche control outside 

of ski resort boundaries and traffic corridors. 

 Response: This issue was analyzed in the final Environmental Impact Statement 

Wasatch Powderbird Guide (WPG) permit renewal. WPG is allowed to use 

explosives for snow stability evaluation as part of the safe operation of their 

business. This use is authorized under the terms of their Special Use Permit. 

880. The Wasatch-Cache National Forest should develop a standard that prohibits 

ski and snowboard area expansions and prohibits development of new 

ski/snowboarding areas on a forest-wide basis. 

 Response: See Response to question 878 

881. The Wasatch-Cache National Forest should prohibit resort building on 

prominent ridges because it alters the viewshed 

 Response: Any proposed ski resort expansion and infrastructure development is 

studied and approved through site specific Resort Development Master Plans and 

accompanying Environmental Impact Statements. This issue is addressed in the 

Forest Plan and through the broad range of alternatives displayed in the Final 

Environmental Impact Statement. 

882. The Wasatch-Cache National Forest should not allow ski resorts to turn into 

all season recreation areas or destination resorts because of impacts to wildlife. 

 Response: See response 876. 

 

883. The Wasatch-Cache National Forest should prohibit the development of trams 

or lifts in roadless areas. 

 Response: The Forest Plan does this. 

884. The Forest Plan should state that lift-served expansion at Snowbasin will be 

discouraged outside current boundaries. 

 Response: The expansion issue is also addressed in the Forest plan and through the 

broad range of alternatives displayed in the Environmental Impact Statement. The 

Forest Plan in Chapter 4 under the Central Wasatch Management area states, “New 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 205 

resort developments on National Forest System lands will be confined to the permit 

boundaries in effect at the time of revision, though small-scale site-specific 

adjustments could be considered to address important management issues.” 

Alternative 7 in the Wasatch-Cache Final EIS covers this issue. Any proposed ski 

resort expansion and infrastructure development is studied and approved through 

site specific Resort Development Master Plans and accompanying NEPA review. 

Ski Area Interconnects 

885. The Wasatch-Cache National Forest should allow ski area interconnects. 

 Response: The Forest Plan provides broad program-level direction for 

management of the land and its resources. The forest plan, in chapter four in the 

Central Wasatch Management Area talks about new resort developments on 

National Forest System lands will be confined to the permit boundaries in effect at 

the time of revision. Any proposed resort expansion and infrastructure development 

within the existing resort boundaries or ski area interconnects will be studied 

through site specific Resort Development Master Plans and accompanying NEPA 

Review. 

886. The Wasatch-Cache National Forest should keep open the possibility of 

allowing future construction of a gondola connecting Ogden City with 

Snowbasin Resort. 

 Response: Any proposed ski resort expansion and infrastructure development is 

studied and approved through site specific Resort Development Master Plans and 

accompanying Environmental Impact Statements. 

887. The Wasatch-Cache National Forest should prohibit interconnection of ski 

areas because they are not needed. 

 Response: The Forest Plan provides broad program-level direction for 

management of the land and its resources. The Forest Plan, in Chapter 4 in the 

Central Wasatch Management Area, states that new resort developments on 

National Forest System lands will be confined to the permit boundaries in effect at 

the time of revision. Any proposed resort expansion and infrastructure development 

within the existing resort boundaries and ski area interconnection will be studied 

through site specific Resort Development Master Plans and accompanying NEPA 

Review. 

888. The Wasatch-Cache National Forest should clarify that the prohibition of ski 

area expansion includes ski area interconnects. 

 Response: The Forest Plan provides broad program-level direction for 

management of the land and its resources. The forest plan, in chapter four in the 

Central Wasatch Management Area talks about how new resort developments on 

National Forest System lands will be confined to the permit boundaries in effect at 

the time of revision. Any proposed resort expansion or infrastructure development 

within the existing resort boundaries and ski area interconnections will be studied 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 206 

through site specific Resort Development Master Plans and accompanying NEPA 

Review. 

Hunting and Fishing 

889. The Wasatch-Cache National Forest should prohibit hunting. 

 889.1 In the Wasatch Range 

 889.2 In the Cottonwood Canyons 

 Response: See response 65. 

Outfitter-Guides/Special Use Permits 

890. The Wasatch-Cache National Forest should allow guided access. 

Response: The need for guided access will be determined by the criteria noted in 

Chapter 5 of the Revised Forest Plan and in conjunction with the Revised Forest 

Plan Goals and Sub-goals and Standards and Guidelines. 

890.1 Because this will bring more funding for motorized trail upkeep 

Response: See response 890.

890.2 For safety reasons 

Response: See response 890. 

891. The Wasatch-Cache National Forest should retain designations for special use 

permit holders. 

 Response: The Forest will continue with current special uses as identified in 

Revised Forest Plan Chapter 4, A.4. Forestwide Standards and Guidelines. 

892. The Wasatch-Cache National Forest should make it easy to obtain guiding 

licenses. 

 Response: See response 890. 

893. The Wasatch-Cache National Forest should consider a permit system for 

wilderness areas when other plans to reduce use are not successful. 

 Response: Thank you for your comment. A permit system could be one of the 

management options for reducing use in the Wilderness. 

 894. The Wasatch-Cache National Forest should document the public demand for 

outfitters/guides. 

Response: See Revised Forest Plan, Chapter 5, and Monitoring. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 207 

Camping 

Camping General 

895. The Wasatch-Cache National Forest should consider that the Preferred 

Alternative best meets the recreation demand b ecause it allows additional 

facility development in the more developed Recreation Opportunity Spectrum 

classes, but emphasizes replacement of current facilities and site hardening. 

 Response: Thank your for your comment. 

896. The Wasatch-Cache National Forest should determine which recreation sites 

need to be hardened to protect the environment and natural landscape. 

Response: Considering site hardening at recreation sites would be completed at the 

project level and is beyond the scope of the Revised Forest Plan analysis.

897. The Wasatch-Cache National Forest should not harden campsites. 

 Response: See response 896. 

898. The Wasatch-Cache National Forest should remove and relocated 

campgrounds in riparian zones and flood plains to upland sites so that riparian 

areas can be reclaimed. 

Response: Removing and relocating campgrounds would be a project level 

decision, which is beyond the scope of the Forest Plan. At the program level 

however, direction is giving in the Revised Forest Plan, MPC 3.1-Aquatic Habitat 

(3.1A) /Watershed (3.1W) where emphasis is on maintaining or improving quality 

of watershed conditions and aquatic habitats. This would be a consideration when 

projects are proposed and one option that could be considered is removal and 

relocation of a campground. 

899. The Wasatch-Cache National Forest should continue using concessionaires to 

encourage small businesses. 

Response: Thank you for your comment the WCNF will continue to 

concessionaires to help in the management of their recreation facilities. 

900. The Wasatch-Cache National Forest should address its management of 

camping areas in Logan Canyon because current management is driving 

people away. 

 Response: This is to specific and beyond the scope of the Forest Plan, but we will 

pass this information on to the managing unit. 

901. The Wasatch-Cache National Forest should allow only minor further 

development of existing campgrounds and picnic sites in Logan Canyon. 

Response: See response 900. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 208 

Allow Camping 

902. The Wasatch-Cache National Forest should provide more areas for camping. 

 Response: New developed recreation facilities are proposed in all alternatives 

except Alternative 1. See Chapter 2 of the FEIS. 

902.1 By keeping campgrounds open 

 Response: See response 900. 

902.2 By providing all season camping areas in Little Cottonwood Canyon 

 Response: See response 900. 

902.3 By extending the camping area in Tony Grove 

 Response: See response to concern statement 900. 

902.4 By allowing natural unplanned campgrounds 

 Response: As per the Revised Forest Plan in Recreation goals and objectives the 

WCNF will inventory and develop concentrated use area plans for recreation where 

site amenities will focus on protection of the Forest resources. This will meet your 

definition of unplanned campgrounds. 

902.5 By allowing larger campsites to accommodate larger camping vehicles 

 Response: See response 900. 

902.6 By creating a horse camp in Franklin Basin 

 Response: See response 900. 

903. The Wasatch-Cache National Forest should maintain present camping 

opportunities and winter and summer recreational activities. 

 Response: Alternative 7 for recreation is very close to the existing condition for 

winter and summer recreational opportunities. 

Do Not Allow/Restrict Camping 

904. The Wasatch-Cache National Forest should prohibit large organizational 

camping groups in the Prove River drainage and Hayden Fork. 

 Response: See response 900.

905. The Wasatch-Cache National Forest should control scout troops. 

 Response: See response 900.

906. The Wasatch-Cache National Forest should confiscate unattended property for 

those who disregard the fourteen-day camping restriction. 

Response: See response 900.
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 209 

Dogs 

Dogs General 

907. The Wasatch-Cache National Forest should address management of dogs and 

the health of the forest 

Response: The issue of managing dogs on the Forest is indeed not addressed in 

the Revised Forest Plan. This issue is an important one at this time primarily in 

the Central Wasatch Management Area (Tri-Canyon) watersheds and is being 

addressed jointly by the Salt Lake County and the Salt Lake Ranger District. It 

was too site-specific to be adequately addressed in the broad environmental 

analysis for Forest Plan Revision. 

Allow Dogs 

908. The Wasatch-Cache National Forest should allow dogs. 

908.1 Allow dogs in all canyons 

908.2 Allow dogs in Millcreek Canyon 

908.3 Implement a permit system to allow dogs in watershed areas 

908.4 Provide for dispersed dog-friendly recreation opportunities 

908.5 Set land aside for off-leash dog areas or conduct studies and open all 

canyons to dogs 

Response: See response 907. 

Do Not Allow/Restrict Dogs 

909. The Wasatch-Cache National Forest should prohibit/restrict dog visits. 

Ban dogs in Mill Creek Canyon 

Incorporate regulations for dogs 

 Response: See response 907. 

Miscellaneous Activities 

910. The Wasatch-Cache National Forest should prohibit concerts and resortsponsored activities because of light and noise pollution. 

 Response: Activities within ski area boundaries are regulated through the Special 

Use Permit and Operating Plans rather than in the broad forestwide direction of the 

Revised Forest Plan. Activities adjacent to ski area permit boundaries will be 

subject to the management prescriptions mapped there in the Revised Forest Plan. 

These prescriptions include standards and guidelines that spell out the types of 

activities that are allowed or not allowed there including new trail construction. 

Outfitter guide services are regulated by the specific Special Use Permit issued for 

that service and are not addressed by the broad direction of the Revised Forest Plan. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 210 

911. The Wasatch-Cache National Forest should manage the people who use the 

national forests to party because they disrupt other people. 

 Response: Management Direction included in the Revised Forest Plan does include 

recreation opportunity class maps that show where one should expect to find 

different degrees of solitude and facility development. In those areas where the 

user densities are expected to be relatively high, interactions between visitors are to 

be expected. The Revised Plan also includes an Objective to increase the amount of 

education and enforcement in order to reduce conflicts between forest users. User 

ethics is an area of focus for the education and enforcement that we expect to 

emphasize over the life of the Plan. 

Scenery 

912. The Wasatch-Cache National Forest should elevate Guideline 52 on page 4-30 

to a standard and modify the wording to maintain scenic integrity. 

Response: The goal states: “Resource management activities should not be 

permitted to reduce Scenic Integrity below Objectives stated for Management 

Prescription Categories.” Because the Scenic Integrity Objectives (SIOs) are 

desired future condition for Forest landscapes a site-specific analysis will need to 

take place to determine the ability of the landscape to maintain the SIO. Being able 

to provide to the public rational for such a deviation would be more in line with a 

desire future condition than to have a binding limitation that would require a Forest 

Plan amendment. 

Topic 5: Roadless Areas/Wilderness Management 

Roadless Areas/Wilderness Management General 

Management General 

913. The Wasatch-Cache National Forest should protect public lands as wilderness 

and roadless areas. 

913.1 Because they provide a high quality of life 

913.2 Because they provide high quality hunting experiences

 Response: We agree. Certain public lands that meet the criteria for Wilderness can 

provide a variety of ecosystem benefits and unique recreation opportunities for the 

public. The forest plan alternatives analyze several possibilities. 

914. The Wasatch-Cache National Forest should adopt suggestions made by the 

High Uintas Preservation Council regarding wilderness and roadless area 

management. 

 Response: The recommendations made by this organization have been considered 

and are included in the range of alternatives for possible wilderness 

recommendations and oil and gas leasing. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 211 

915. The Wasatch-Cache National Forest should focus development in areas that 

are already developed. 

 Response: Already developed areas are allocated to management prescriptions that 

allow further development or redevelopment. In undeveloped areas (roadless areas) 

a range of management prescriptions has been applied across the range of 

alternatives that allow for development, mostly maintain roadless values, or fully 

maintain them. 

Roadless Area/Wilderness Boundaries 

916. The Wasatch-Cache National Forest should adjust the boundaries of roadless 

and wilderness areas in order to provide necessary protection. 

916.1 Burch Creek Roadless Area

 Response: The comments received are very detailed and site-specific proposing 

minor adjustments to roadless area boundaries or recommendations to improve 

manageability for recommended Wilderness. These comments are valuable, and 

can be used to make minor adjustments when, and if a decision to protect the 

roadless or wilderness character is made. Until that time, the comment has 

generally been considered as within the range of alternatives for the allocation of 

management prescriptions and other management direction for the area. 

916.2 High Uintas 

 Response: We recognize your position that much of the area should be 

recommended as Wilderness, and your comment is considered within our range of 

alternatives. These are also very detailed and site-specific, proposing minor 

adjustments to roadless area boundaries or recommendations to improve 

manageability for recommended Wilderness. These comments are valuable, and 

can be used to make minor adjustments when, and if a decision to protect the 

roadless or wilderness character is made. Until that time, the comment has 

generally been considered as within the range of alternatives for the allocation of 

management prescriptions and other management direction for the area. 

 

916.3 Lakes Area 

Response: See response 916.2 

 

916.4 Lone Peak additions 

 Response: See response 916.1 

916.5 Mount Aired 

 Response: See response 916.2 

916.6 Mount Naomi 

 Response: See response 916.2 

916.7 Mount Olympus 

 Response: See response 916.1 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 212 

916.8 Stansbury Management Area

 Response: See response 916.2 

916.9 Upper South Fork Roadless Area 

 Response: See response 916.2 

 

916.10 White Pine

 Response: See response 916.2 

 

Roadless Area Management 

Roadless Area Management General 

917. The Wasatch-Cache National Forest should consider local input when deciding 

how to manage roadless areas. 

 Response: The range of alternatives and Appendices C1 and C2 speak directly to 

the individual values of roadless areas and their potential for wilderness 

recommendation. We believe our range of alternatives and site specific 

considerations of values are responsive to local opinions on how to manage these 

areas. Local input on their management was considered in the planning process 

through public meetings and written and oral input. 

918. The Wasatch-Cache National Forest should add a project level consideration of 

roadless areas. 

 Response: The values of roadless areas are considered by project level proposals. 

While these are not forest plan decisions, interim direction to protect roadless area 

values is in place for project level decisions and is also provided in established 

Forest Service direction on environmental policy and procedures (FSH 1909.15). 

919. The Wasatch-Cache National Forest should protect roadless areas to preserve 

environmental values. 

 Response: We recognize the values of roadless areas both on the Wasatch-Cache 

and elsewhere. Appendix C-2 identifies many of the roadless values present on the 

Wasatch-Cache. The range of alternatives provide for a variety of management 

schemes ranging fro largely maintaining these values or to allowing considerable 

use and development of roadless areas. 

920. The Wasatch-Cache National Forest should maintain roadless area 

characteristics of all inventoried roadless areas. 

920.1 By keeping existing roadless areas roadless 

920.2 By prohibiting all development and motorized recreation

 Response: See response 919. 

 

921. The desired future condition descriptions for Burch Creek and Taylor Canyon 

should specify that special use proposals will not impact roadless 

characteristics of these areas. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 213 

 Response: We recognize your interest in this area and a range of alternatives from 

recommended Wilderness and roadless protection to management that would allow 

considerable development is laid out for these two areas in the FEIS and 

accompanying maps. 

922. The Wasatch-Cache National Forest should not manage roadless areas as nonmotorized. 

 Response: In some alternatives that recommend a lot of wilderness most of the 

roadless areas on the Wasatch-Cache are managed for non-motorized use. In most 

alternatives considerably more of roadless areas is available for either summer or 

winter motorized use. Readers should be reminded that inventoried roadless areas 

are not necessarily non-motorized. The roadless character of an area does not 

prescribe non-motorized trail use. The motorized or non-motorized use of trails is a 

travel management decision, is not dependent on roadless character, and is 

generally outside the scope of the decisions being made in this forest plan revision. 

Winter motorized and non-motorized uses for areas of the forest are decided by the 

forest plan revision and are shown on the Winter Recreation maps. 

923. The Wasatch-Cache National Forest should avoid managing all roadless areas 

the same. 

 Response: Considerable variety in the management of roadless areas is presented 

across the range of alternatives in the FEIS. While Alternatives 1, 2, and 6 applied 

the national roadless rule at the time of their formulation, and still maintain many 

blanket protections for roadless character, the other alternatives provide a different 

set of potential management and uses for roadless areas. In the FEIS, Appendices 

C1 and C2 discuss the potential wilderness and roadless values of roadless areas, 

while the Topic 5 in Chapter 3 looks at alternatives for managing these areas. 

924. The Wasatch-Cache National Forest should eliminate human use of roadless 

areas under any prescription other than wilderness. 

 Response: In the FEIS Alternative 1 essentially falls in this category of 

management. Other alternatives allows different ranges of maintenance of roadless 

area values or potential human uses of roadless areas. Forest management and the 

planning team tried to examine a broad range of alternatives for roadless area 

management. 

Adequacy of Analysis 

925. Public Concern: The Final EIS should clarify exactly how many acres of 

roadless lands exist on the forest and correct discrepancies in the document 

text.

 Response: The Topic 5 in Chapter 3 of the FEIS and Appendices C1 and C2 show 

Wasatch-Cache inventoried roadless areas, their values as wilderness or other 

roadless values and their acreages. Topic 5 in the FEIS and Table C1-1 and related 

text in Appendix C talk to changes in these roadless areas over time provide some 

caveats regarding the accuracy of inventory acreages. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 214 

926. The Wasatch-Cache National Forest should state in the Forest Plan that 

because the plan does not analyze environmental effects of activities in roadless 

areas, an additional EIS will be required for significant federal actions 

affecting roadless areas. 

 Response: Procedural requirements for project environmental analyses are covered 

in departmental regulations and agency policy, and need not be repeated in these 

documents. It is true, however, that project proposals in inventoried roadless areas 

carry with them additional considerations for analysis and disclosures of effects. 

927. The Wasatch-Cache National Forest should remove reference to inventoried 

roadless areas from tables in the Draft EIS. 

 Response: A range of considerations for how to treat roadless areas was 

considered across alternatives. In some alternatives no distinctions between 

allowed activities within roadless areas and outside them was considered. In other 

alternatives there were differences between activities allowed inside or outside 

roadless areas. We think this presented both a reasonable and legal range of 

alternatives. 

Roadless Area Designation General 

928. The Wasatch-Cache National Forest should ground proof the linear route off of 

Red Butte Road before including this area in the roadless inventory. 

 Response: This was done since the publication of the DEIS. The Red Butte Road 

is a cherry-stem into the roadless area to a point where the road is no longer 

maintained or passable by a passenger car. At this point the original “road” is more 

trail-like in its character and not considered a road from a roadless inventory 

perspective as it proceeds further into the area. The Red Butte RNA is closed to the 

general public and not available for recreation. 

Roadless Area Criteria 

929. The Wasatch-Cache National Forest should protect roadless areas that are 

adjacent to wilderness areas. 

 Response: Prescriptions for recommended wilderness, maintenance of roadless 

values or development were applied to roadless areas adjacent to designated 

Wilderness across the alternatives to provide a range of considerations regarding 

potential effects. See the management prescription, ROS, and winter recreation 

maps for the alternatives. 

930. The Wasatch-Cache National Forest should not define areas with roads as 

roadless. 

 Response: The procedures for mapping roadless areas and definitions for what 

constitutes a road are laid out by the Intermountain Region protocol, Roadless 

Inventory and Evaluation Guide (1998), for doing this work. That protocol was 

made available to and reviewed for the public during the roadless inventory public 

open houses in the Fall of 1998. While opinions and definitions related to this work 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 215 

still differ, the definitions, and procedures for our inventory were disclosed publicly 

and are on file. 

 

931. Public Concern:The Wasatch-Cache National Forest should fully evaluate 

roadless areas using additional criteria as established in 219.17 

 Response: Considerable effort was spent between the publication of the DEIS and 

the FEIS on doing more analysis of roadless area values. The criteria for the 

evaluations done in Appendices C1 and C2 of the FEIS are shown there. These 

criteria cover what is legally required in the forest planning process in 36 CFR 

219.17 and go further than that by considering additional criteria also. 

Do Designate Roadless Areas 

932. The Wasatch-Cache National Forest should designate certain areas roadless. 

932.1 Mineral Fork 

932.2 Mueller Park and Red Butte Canyon 

932.3 Swan Peak

 Response: These four areas are included in the roadless inventory. Mueller Park 

and Red Butte were added as roadless areas between the Draft and Final EISs as a 

result of public comments. The values of these areas for wilderness 

recommendation and as roadless areas are considered in Appendices C1 and C2 to 

the FEIS. A range of management types for these areas is also presented in the 

FEIS. 

 

933. The Wasatch-Cache National Forest should designate the watershed areas as 

roadless in the Wheeler Creek Drainage. 

 Response: A range of management prescriptions for the Wheeler Creek Drainage 

are considered in the FEIS, and these can be seen in the maps of those prescriptions 

and interpreted using management prescription definitions found in Chapter 4 of the 

revised Forest Plan. Watershed values among with many other values were 

considered in evaluating roadless areas. The undeveloped area on the WasatchCache including Wheeler Creek did not meet the minimum 5,000 acre size to 

qualify as a roadless area defined by FS Handbook 1909.12. and the draft 

Intermountain Region protocol on Roadless Inventory and Evaluation Guide 

(1998). 

Do Not Designate Roadless Areas 

934. The Wasatch-Cache National Forest should not designate any more land as 

roadless or wilderness. 

 Response: Roadless areas are not “designated”. While this response may seem 

bureaucratic, trifling and based on semantics, the words used are important to us. 

Roadless areas are identified by the Forest Service though a required inventory 

process that is based on published criteria. After its inventory, the Forest Service is 

required by the planning regulations (36 CFR 219) to consider recommendations of 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 216 

appropriate roadless areas to the National Wilderness Preservation System. These 

recommendations eventually go to Congress for its consideration. 

Wilderness areas are “designated”. This is done when Congress passes Wilderness 

acts. Congress reviews the recommendations from the Forest Service, and if it 

senses public opinion, resource, political, and social needs support a choice for 

designation it can deliver these laws and formally “designate” more Wilderness. 

Alternatives 4 and 5 in the FEIS provide for no more Wilderness, and only limited 

protection for roadless area values. See the Topic 5 discussion in Chapter 3 of the 

FEIS. 

Other Designations 

935. The Wasatch-Cache National Forest should develop a Back Country 

Recreation Area designation for roadless areas. 

 Response: See response 98. 

Additionally, your comment has many good suggestions discussing what Congress 

might do and what the BLM has provided for as administrative solutions for dealing 

with roadless area values and user demands for these areas. We also looked into the 

administrative designation of “Primitive Area” which was formerly applied to many 

undeveloped national forest system areas prior to their designation as Wilderness. 

This is apparently not a good solution for us at the moment. Finally, we think that 

the range of alternatives provided in this analysis gives our decision makers a 

number of differing management scenarios for roadless areas and information on 

the effects associated with those choices. 

Wilderness Management 

Wilderness Management General 

936. The Wasatch-Cache National Forest should clarify how wilderness areas will 

be managed. 

 Response: Between the Draft and Final EISs Appendix VI was expanded to 

include standards and guidelines all Wilderness areas on the Wasatch-Cache. 

Similarly, the Desired Future Conditions statements for Wildernesses along the 

Wasatch Front were expanded considerably to clarify public and agency 

expectations for their future management. 

937. The Wasatch-Cache National Forest should manage wilderness areas for nondegradation. 

 Response: This concept is a fundamental premise for managing Wilderness which 

goes back to the Wilderness Act (1964) and is carried forward in the revised Forest 

Plan through the forestwide DFC for Designated Wilderness and Standards and 

Guidelines, as well as management area DFCs that address Wildernesses and 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 217 

individual Wilderness goals, standards and guidelines. Additional direction 

available outside this forest plan on managing Wilderness for non-degradation is 

identified at the beginning of the section on forestwide Wilderness standards and 

guidelines in Chapter 4. A. 3. of the revised Forest Plan. 

 

938. The Wasatch-Cache National Forest should manage lands as wilderness during 

the current Administration. 

 Response: The range of alternatives provided in the FEIS provides choices with 

projected effects for managing the roadless areas on the Wasatch-Cache. Our 

decision makers will review and document their decisions carefully for the long 

term good of these lands and to serve the needs of the American people. 

 

939. The Wasatch-Cache National Forest should prepare wilderness management 

plans in a timely manner. 

939.1 For the Tri-Canyon wilderness 

939.2 For the Uinta Wilderness 

939.3 For the Mount Naomi Wilderness

 Response: In the proposed Forest Plan that was produced with the release of the 

DEIS in May 2001 a schedule of wilderness management planning was identified as 

an objective. This objective is not present in the revised Forest Plan that is being 

released now. Forest leadership looked at the list of potential Forest Plan related 

objectives, and then prioritized that work and developed the current objectives (See 

Chapter 4.A.3.) While active management of Wilderness is a high priority for our 

work, no specific commitment to Wilderness planning is now made. If future 

funding or reprioritization of work and management emphasis on Wilderness 

planning surfaces, this is indeed a possibility. 

Recognizing this change from the DEIS and proposed Forest Plan of 2001, the 

revised Forest Plan provides additional management direction for the six 

Wildernesses along the Wasatch Front in Appendix VI to help meet the need for 

management direction for these Wildernesses. Additional detail in Desired Future 

Conditions statements for these Wildernesses was also completed to give managers 

and the public ideas for their management. 

 

940. The Wasatch-Cache National Forest should restrict access to wilderness areas 

by implementing a permit system. 

 Response: The comment suggests a permit system for heavily used areas of the 

High Uintas Wilderness, citing the Kings Peak area on holidays as overly used. 

While we know that these situations occur, particularly in some areas, this forest 

planning process did not analyze this question, and it was not raised as a driving 

issue during revision. Standards and guidelines for the High Uintas, as well as for 

the other Wildernesses on the Wasatch-Cache (See Chapter 4 and Appendix VI), 

provide direction that could be used limit or redistribute use for resource protection 

and recreational solitude. 

 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 218 

941. The Wasatch-Cache National Forest should use language in the Wilderness 

Act, which calls for no motorized vehicles, to guide wilderness management. 

 Response: Motorized uses are not allowed in designated Wilderness, as required 

by the Wilderness Act and any subsequent regulations or policy. Our management 

prescriptions also prescribe that using motor vehicles or other motorized equipment 

is not allowed as stated in the 1964 Wilderness Act. 

942. The Wasatch-Cache National Forest should clarify that wilderness means nonmanagement. 

 Response: The fact that management in Wilderness is non-traditional, that is, it is 

done with a minimum tool philosophy and without motorized equipment and other 

conveniences normally available out side the Wilderness, does not mean that 

Wilderness is not managed. Contrarily, substantial attention and funding are spent 

on managing Wilderness so that it can meet the intent of Congress, the 

administration and the American people. Development does not necessarily mean 

management. 

Adequacy of Analysis 

943. The Wasatch-Cache National Forest should require that any land 

recommended for wilderness pass a manageability and suitability test. 

 Response: Part of the evaluation done for each roadless area in Appendix C-1 of 

the FEIS is an evaluation of these characteristics. The FS Handbook on Wilderness 

Evaluation (1909.12, Chapter 7) discusses these attributes under section 7.21 

Capability regarding “suitability” and section 7.22 Availability regarding 

“manageability” and our appendix includes these considerations. “Need” is another 

criterion that is identified in that FS Handbook chapter and it is also evaluated for 

each roadless area. 

944. The Wasatch-Cache National Forest should provide data to justify its claim 

that snowmobiling on the outer 42 percent of the Lakes Roadless Area 

precludes its designation as wilderness. 

 Response: We determined that the outer portion of the Lakes roadless area, 

(approximately 42% of it) was more used and more popular for snowmobiling than 

the remaining inner core of the area. We made this determination by interacting 

with members of the snowmobiling community and developing a map of 

snowmobile use there based on these interactions. The resulting map was reviewed 

and adjusted by Forest and Ranger District specialists and converted into a GIS 

layer to develop the information. 

The fact that the outer portion of the Lakes area is used by snowmobiles does not 

preclude it from recommendation as Wilderness. This was one factor among many 

in the consideration of the area and in the development of the alternatives that are 

presented in the FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 219 

945. The Wasatch-Cache National Forest should correct inaccuracies in the Forest 

Plan regarding inventoried roadless areas. 

 Response: The Mt. Logan Roadless area identified in the roadless inventory done 

in 1983 was split into three different roadless areas for the 1999 roadless inventory: 

Mt Logan North, South and West roadless areas. Mapping criteria changed 

between the 1983 and 1999 inventories so that the Providence and Millville Canyon 

roads are now considered roads and dividers between the areas. During the last 

decade or more, the condition of these roads has actually deteriorated, although use 

of the roads may have increased due to improved and more abundant 4WD and 

ATV vehicles and users. 

Wilderness Designation General 

946. The Wasatch-Cache National Forest should consider public demand for 

wilderness areas. 

 Response: The forest is sensitive to public opinions regarding demand for and 

opinions against recommending more Wilderness, but the determination and 

decision to recommend is not based on a poll, referendum, or other counting of 

public opinion on the matter. Lands must first be evaluated using the criteria 

outlined in Appendix C-1 to the FEIS and have substantial capability, availability 

and need. After this some sensing of public demand, need or opinion is also 

appropriate in developing a decision. Information on pubic opinion related to 

roadless area evaluation for Wilderness is included in Appendix C-1. 

947. The Wasatch-Cache National Forest should consider wilderness designation in 

the Rocky Mountain system at the national level. 

 Response: The evaluation for Wilderness in Appendix C-1 does consider in the 

“Need” determination how a particular roadless area might add to the National 

Wilderness Preservation System. The Forest itself is constrained to planning for the 

lands within the Forest boundary, but it does compare to larger scales when 

considering what lands would be most needed in recommending more Wilderness. 

948. The Wasatch-Cache National Forest should make “sustaining wild ecosystems” 

the primary goal for designating wilderness. 

 Response: The goals for Wilderness are primarily set forth in the Wilderness Act 

(1964), which include both protection of wild ecosystems and providing primitive 

human recreation opportunities and solitude. Our forestwide goal for Wilderness 

may not have ordered wild ecosystem protection and appropriate levels of human 

activity in that order, but the goal as written is not intended in any way to 

shortchange the protection of the wild setting for correct levels and types of human 

use. Both are intrinsic to the intent of the law. 

949. The Wasatch-Cache National Forest should carry out other actions before 

recommending any more areas for wilderness designation. 

949.1 Enforce existing wilderness regulations 

949.2 Provide good management and education 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 220 

949.3 Explain the balance of resources and the needs of the people

 Response: All the items identified in this comment are important for successful 

land management and to ensure that future generations can have opportunities 

similar to our own. The revised Forest Plan identifies an objective for enforcement 

and education that is aimed precisely at this mark. It is clear to us also that 

achieving good compliance with special orders and improving backcountry 

behavioral standards is a key to good Wilderness management. Recommending 

additional Wilderness does come with a commitment to manage it. 

Wilderness Criteria 

950. The Wasatch-Cache National Forest should clarify how wilderness 

recommendations are selected. 

 Response: There is no cookbook or scorecard for how recommendations 

developed; rather judgment was used given the following inputs. Appendices C-1 

and C-2 evaluate roadless areas from two different perspectives: 1) potential for 

Wilderness, and 2) roadless area values defined by the criteria. Some conclusions 

may be made about which roadless areas are more valuable as Wilderness by 

reading and comparing these write-ups. Chapter 2 in the FEIS describes how 

roadless area management would be handled in each alternative and the extent to 

which Wilderness recommendations were considered appropriate as part of an 

alternative theme. The interdisciplinary team and forest leadership then mapped the 

different alternatives using this information and personal and professional opinions 

about the areas and their best allocation. 

951. The Wasatch-Cache National Forest should apply the wilderness criteria 

correctly for the Twin Peaks, Mount Olympus, White Pine, and Mount Aire 

proposed additions. 

 Response: The fact that recommendations for Wilderness were and can be made 

in one alternative and not in another has nothing to do with the intrinsic values of 

the lands in question. Rather the recommendation is based on the perspective of the 

alternative on how that land should be used. Final decision-making this Forest 

Plan, and perhaps at some future time, a Congressional Wilderness act designating 

more Wilderness are not linear, but complex process composed of many different 

sets of opinions and perspectives related to the same set of lands and the same 

social system. These complex sets of information and societal desires regarding the 

Wasatch-Cache have been boiled down into the issues and alternatives presented in 

the FEIS. 

952. The Wasatch-Cache National Forest should reexamine the criteria for 

wilderness evaluation and the underlying legislation. 

 Response: The Forest Service has developed its Handbook on Wilderness 

Evaluation (1909.12, Chapter 7) to interpret relationships between the Wilderness 

Act (1964) and National Forest Management Act (amended 1982), and so to help 

planners and the public to work through the contentious process of wilderness 

recommendation. While the Wilderness Act does not specifically identify the 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 221 

criteria used by the Forest Service in its Handbook on Wilderness Evaluation, the 

agency at the Washington Office level legally can and did develop this policy for 

implementing its responsibilities. Individual national forests are then charged with 

the tasks of implementing handbook direction, which can include some 

interpretation, but which should fall within the rubric of the policy. Reexamination 

of this policy will need to come from higher levels in the organization, and is 

outside of the scope of this planning effort. 

953. The Wasatch-Cache National Forest should not use sights and sounds to 

disqualify potential wilderness areas. 

 Response: While the “sights and sounds” of adjacent developed areas are 

discussed for some roadless areas with regard to their potential for Wilderness, 

these were not used to veto or disqualify additions to existing Wildernesses. This 

information along with other inventoried characteristics and alternative theme was 

considered when developing wilderness recommendations across the range of 

alternatives. It is the overall consideration and judgment regarding the qualities for 

and impediments to further recommendations for Wilderness within an alternative 

context that determined its wilderness recommendation. 

954. The Wasatch-Cache National Forest should consider the capability, 

availability, and need of individual roadless areas in determining wilderness 

potential. 

 Response: We did in Appendix C of the DEIS and Appendix C-1 of the FEIS. An 

array of alternative recommendations for Wilderness is presented in the FEIS. 

955. The Wasatch-Cache National Forest should recommend areas for wilderness 

designation under certain conditions. 

955.1 If they are large enough to offer a wilderness experience 

955.2 If they are at least 100,000 acres in size, so that prescribed fire can be 

effectively used as a management tool 

955.3 If they are low-elevation areas 

955.4 Only if they are in danger of exploitation 

Response: We appreciate your perspectives on what constitutes appropriate 

characteristics for Wilderness. These clearly are important considerations in 

developing good management for roadless areas. Generally largeness has been 

considered an important value in preserving of wildland ecosystems. We also are 

learning that allowing fire to approximate natural fire regimes should improve 

ecosystem conditions. We know that low elevation areas are not adequately 

represented in the National Wilderness Preservation System, and development and 

over-exploitation can disrupt or destroy natural systems. These factors are 

considered in the evaluation of roadless areas in Appendix C-2 and for Wilderness 

evaluation in Appendix C-1 to the FEIS. 

956. The Wasatch-Cache National Forest should not recommend areas for 

wilderness designation under certain conditions. 

956.1 If it would detract from water production 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 222 

956.2 If it prohibits grazing 

Response: The Wasatch-Cache recognizes the importance of water production 

from national forest lands. We also know how important grazing livestock can be 

to individuals and communities that depend on it. These two land uses are often 

discussed in the evaluation of individual roadless areas for Wilderness in Appendix 

C-2 in the FEIS, particularly in the describing “Availability” where the potential for 

conflict of Wilderness designation with existing uses is covered. Generally, 

Wilderness recommendation by the agency, or later, designation by Congress has 

had little effect of these aspects of forest use, and wilderness acts passed by 

Congress tend to “grandfather” these uses in. 

Do Recommend Roadless Areas for Wilderness Designation 

957. The Wasatch-Cache National Forest should expand wilderness areas. 

 Response: We recognize your perspective and have provided a range of 

alternatives in the FEIS, some with large areas of recommended Wilderness and 

some with no recommendation. The prescription maps that accompany the FEIS 

show where wilderness recommendations are made; the management prescription 

of 1.5, described in Chapter 4.B.1. of the Forest Plan described allowed and 

prohibited used in recommended Wilderness; and desired future condition 

statements give other information on how these areas might appear in the future. 

958. The Wasatch-Cache National Forest should recommend additional wilderness 

areas to achieve its stated objective 

 Response: The comment suggests that the best way to meet forest concerns for the 

preservation of biodiversity is through recommending most roadless areas of the 

forest as Wilderness. While the biodiversity and viability issue is a key one 

identified in the FEIS (See Chapter 1, Issue 3), it is only one of several that drove 

the planning effort. Most of the other issues, aside from the one on roadless area 

management, had to do with human uses. The solution for the forest plan must be a 

balancing of appropriate levels of use with protection and sustainability of 

ecosystem functioning and components. Several choices for how this solution are 

laid out in the seven alternatives that are analyzed in the FEIS; different 

recommendations for additional Wilderness are provided as part of each alternative. 

959. The Wasatch-Cache National Forest should recommend additional wilderness 

areas for environmental reasons. 

959.1 To link wilderness areas together 

959.2 To protect ecological health 

959.3 To protect watersheds 

959.4 To protect biodiversity 

959.5 To protect wildlife 

959.6 To protect wildlife habitat 

959.7 To protect threatened, endangered, and sensitive species 

959.8 To protect golden eagles 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 223 

959.9 To protect areas from the effects of mining and off-road vehicle 

recreation 

Response: Each of these comments has merit. The FEIS presents a range of 

alternatives from prescribing Wilderness recommendation for large amounts of 

roadless areas or to no recommendation for Wilderness. These recommendations 

are based on the values identified in Appendix C-1 matched with an alternative 

theme. Wilderness recommendation and if Congress acts, designation, can help 

protect each of the values itemized above. However, Wilderness recommendation 

is not the only answer. Values can also be protected with other management 

direction and prescriptions. 

Roadless areas are also considered for maintenance of roadless area values or 

possible allowance of development. (See Appendix C-1 for an inventory of roadless 

values.) Your comments were considered in the development and analysis of the 

alternatives presented in the FEIS. Comments from people who do not share your 

values were also considered, helping to provide the range of alternatives we have 

analyzed. 

 

960. The Wasatch-Cache National Forest should recommend additional wilderness 

areas for social reasons 

960.1 To allow research and education 

960.2 To benefit future generations 

960.3 To preserve the American spirit

 Response: The range of alternatives presented in the FEIS provides 

recommendations of considerable new Wilderness to no new Wilderness. It is true 

that Wilderness can be a setting for sustaining biodiversity that can benefit 

environmental appreciation, research, future generations, and the spiritual sense that 

Americans have that “wild places” still exist in our country and world. We 

recognized these concerns by building some alternatives that recommend most 

roadless areas for Wilderness or provide management prescriptions that do not 

allow much development. The range of alternatives also provides options for the 

development of some of these areas. 

961. The Wasatch-Cache National Forest should recommend additional wilderness 

for economic reasons to benefit the economy. 

 Response: The Loomis and Richardson (2000), reference that is cited in this 

comment does provide information concluding that Wilderness designation can add 

economic value and social values to an area. Some of these economic benefits are 

more easily or tangibly estimated in dollar values. Our Appendix C-1 considers 

how available, capable and needed the roadless areas on the Wasatch-Cache are as 

additional Wilderness. Some considerations of ongoing uses that add dollars to the 

economy are addressed. Our economic analysis has not estimated the dollar value of 

ecosystem benefits, in part because this is not required in our regulations. We do 

recognize the tremendous value of stable watersheds that produce dependable water 

supplies, ecosystems with individual species and functional components intact, and 

wild landscapes that can help energize and invigorate our society either through 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 224 

direct recreation or reflection on their very existence. These aspects of roadless 

areas and potential Wilderness recommendation were considered in presenting our 

range of alternatives. 

962. The Wasatch-Cache National Forest should recommend additional wilderness 

areas. 

962.1 All roadless areas 

962.2 Winter range areas 

962.3 Damaged areas 

 Response: We have examined all inventoried roadless areas for their potential as 

Wilderness. No alternative recommends that all roadless should be Wilderness. 

Our analysis in Appendix C-1 to the FEIS simply did not find that all roadless areas 

had qualities that made them available, capable, or needed enough to be 

recommended. Documentation of the roadless areas that are not considered 

appropriate under any of the analyzed alternatives is part of the planning file. 

The values of winter range are important and are considered with respect to impacts 

from development, use and forage competition in Topic 2, Chapter 3 of the FEIS. 

Winter range was not specifically analyzed as a characteristic across all roadless 

areas for Wilderness consideration. It is true that some lower elevation portions of 

roadless areas that provide winter range could be protected through Wilderness 

recommendation. This same effect may be achieved by tailoring other management 

direction. For instance, protection of winter range on the forest could be more 

specifically addressed through the application of a 3.2 management prescription and 

a management area DFC specifying winter range protection, than through 

recommendation of additional Wilderness. The range of alternatives does 

encompass difference acreages of roadless that are recommended for Wilderness, 

some of which would provide more winter range in recommended Wilderness than 

others; this has not been calculated. 

Roadless areas with minor damage to vegetation or other attributes were considered 

for their potential as Wilderness and that analysis is presented in Appendix C-1. In 

some alternatives, areas with known minor damage were included in 

recommendations for Wilderness while they were considered inappropriate in other 

alternatives. We recognize that some healing of areas can occur when passive 

management and low impact uses are applied to an area, and that for some 

advocates of Wilderness, recommendation of these areas for Wilderness for curative 

reasons could seem appropriate. 

963. The Wasatch-Cache National Forest should support the wilderness 

designations proposed by various groups. 

 963.1 Salt Lake City 

963.2 The Salt Lake City Department of Public Utilities 

963.3 Save Our Canyons

 Response: The recommendations of these three entities are on file with the 

Wasatch-Cache, and they were considered in the development of the alternative 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 225 

Wilderness recommendations that were presented in the FEIS. Each of the three 

presented positions recommending large acreages of roadless in the Tri Canyons as 

Wilderness. These positions are probably best represented in Alternative 1 and 

secondarily by Alternative 2. 

964. The Wasatch-Cache National Forest should designate the forest as a National 

Preserve and Wilderness. 

 Response: This suggestion was not feasible, and not considered with the range of 

alternatives that were analyzed. The Forest simply has too many developed areas, 

and too many ongoing uses on which surrounding communities are dependent to 

preserve the whole or designate it as Wilderness. 

965. The Wasatch-Cache National Forest should create non-motorized buffer zones 

around all wilderness areas to protect ecological and wilderness values. 

 Response: Section 303 of the Utah Wilderness Act of 1984 specifically prohibits 

the placement of buffer zones around Wildernesses designated in the act (all but 

Lone Peak). This section of the act further states, “The fact that nonwilderness 

activities or uses can be seen or heard from areas within the wilderness shall not, of 

itself, preclude such activities or uses up to the boundary of the wilderness area.” 

Do Not Recommend Roadless Areas for Wilderness Designation 

 

966. The Wasatch-Cache National Forest should not recommend any more areas for 

wilderness designation. 

966.1 Because enough area is already designated wilderness 

966.2 Because 80 percent of Utah is already owned by the federal government 

966.3 Because these areas should be kept open to multiple use 

966.4 Because a wilderness designation does not prohibit private landowners 

from using their land in a manner that is incompatible with wilderness values 

Response: We understand the perspective of commenters who do not want 

additional Wilderness recommendations, and have provided Alternatives 4 and 5 

that cover this position. Other members of the public feel that some or much more 

additional Wilderness is desirable, and we have also presented alternatives that 

address these positions. 

The Wasatch-Cache recognizes that large portions of the state are public lands 

(federal, state, and local), and that we must responsibly manage that portion which 

has been entrusted to our care. 

Wilderness management is multiple-use management. Many different uses are 

allowed in designated Wilderness, and framers of Wilderness legislation had to 

consider how the intent of Wilderness could be interwoven with the intent of the 

Multiple-Use Sustained-Yield Act of 1960. Section 4 (a) (1) of the Wilderness Act 

of 1964 states “Nothing in the Act shall be deemed to be in interference with the 

purpose for which national forests are established as set forth in the in the Act of 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 226 

June 4, 1897 (30 Stat. 11), and the Multiple-Use Sustained-Yield Act of June 12, 

1960 (74 stat. 215).” 

We recognize that private landowners can do as they like (within legal limits) with 

their own property, which may be adjacent to designated Wilderness or adjacent to 

roadless areas that must be considered for potential Wilderness. We considered this 

factor as we wrote Appendix C-1 and the alternatives in the FEIS. 

967. The Wasatch-Cache National Forest should not recommend any more areas for 

wilderness designation for environmental reasons. 

967.1 Because these areas can be adequately protected with careful 

stewardship 

967.2 Because a wilderness designation precludes management tools needed for 

forest health 

 Response: We recognize your perspectives regarding Wilderness recommendation. 

We have alternatives presented in the FEIS that both recommend substantial 

Wilderness additions (Alternatives 1, 2, 3, 6, and 7) and recommend none 

(Alternative 4 and 5). It is true that many of the natural and social/recreational 

values of an area can be protected without a Wilderness recommendation, and that 

the application of “minimum” tool philosophy to Wilderness management can limit 

the use of some technology for work in an area. It is, in part, because of your 

perspective that we have developed a range of alternatives for managing roadless 

areas and in our Wilderness recommendations. 

968. The Wasatch-Cache National Forest should not recommend any more areas for 

wilderness designation for social reasons. 

968.1 Because areas should remain open for future generations 

968.2 Because motorized access is needed for the elderly 

968.3 Because it would restrict recreational access 

Responses: There is a range of opinions among the elderly, those with disabilities, 

and all the public regarding motorized access to national forest lands and 

Wilderness recommendations. Your comments that suggest motorized or otherwise 

assisted access into areas is an important value to the public were considered in the 

development of alternatives for Wilderness recommendations. 

 

969. The Wasatch-Cache National Forest should not recommend any more areas for 

wilderness designation for economic reasons because wilderness designations 

hurt the economy. 

 Response: We recognize your perspective that more Wilderness will hurt the 

economy through lessening use and sales of ATVs, snowmobiles, or other 

motorized recreation outdoor equipment. We also have recognized that the 

motorized recreation segment of local economies is “an important contributor to 

local businesses.” (FEIS, Chapter 3, Social and Economic section.) 

Our range of alternatives includes those that recommend more Wilderness and some 

that do not. Additionally, Alternative 7 provides that snowmobiles can be used in 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 227 

recommended Wilderness if existing travel plans allowed winter motorized 

snowmobile use. The Social and Economic section in the FEIS specifically includes 

in the analysis within recreation labor income and employment those sectors of the 

economy that make up motorized recreation (ATV and snowmobile, 4 wheel drive 

and gasoline sales), as well as other related components of recreation. 

Consequently, we think that the range of alternatives and their effects have 

considered your concerns. 

 

970. The Wasatch-Cache National Forest should not create de facto wilderness 

areas. 

970.1 By adding more restrictions to proposed roadless areas 

970.2 By managing recommended wilderness areas for wilderness values 

 Response: Within our range of alternatives there are different allowed activities 

prescribed for recommended Wilderness. Chapter 2 in the FEIS itemizes the 

allowed activities possible in MPC 1.5, Recommended Wilderness. Alternative 1-6 

tend to be about the same with regard to managing 1.5; Alternative 7, developed 

after comments were received on the DEIS has somewhat different allowances 

(including snowmobile access where it existed before recommendation) both for the 

public and for Forest Service management. Alternative 7 management prescriptions 

for 1.5 were developed, in part, with your concerns in mind. 

Site-Specific Wilderness Recommendations 

971. The Wasatch-Cache National Forest should recommend additional wilderness 

areas. 

 Response: We recognize that many people support recommending a large amount 

of additional Wilderness. Alternative 1 recommends the most Wilderness (See 

FEIS, Chapter 3, Topic 5), but additional Wilderness is recommended in 5 of our 7 

alternatives. 

972. The Wasatch-Cache National Forest should recommend additional wilderness 

areas in the Bear Management Area. 

 Response: No Wilderness is recommended in the Bear Management Area under 

any Alternative. Consideration of the values for Wilderness presented in Appendix 

C-1 to the FEIS for capability, availability, and need of additional Wilderness in the 

Swan Creek, Rock Creek-Green Fork, and Sugar Pine roadless areas was relatively 

low for a variety of reasons. Please review FEIS Appendix C-1 for further 

information. 

973. The Wasatch-Cache National Forest should recommend additional wilderness 

areas in the Cache Box Elder Management Area. 

 973.1 Areas Adjacent to Mount Naomi 

973.2 Areas in Logan Canyon 

973.3 Water Canyon 

973.4 Wellsvilles 
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Wasatch-Cache National Forest A - 228 

Response: Alternatives 1 and 2 provide substantial Wilderness recommendations 

for Mt. Naomi Wilderness and some smaller additions in the Wellsville Mountain 

Wilderness. Other alternatives provide less or none. The details of these choices 

and effects are considered in the FEIS under Topic 5 in Chapter 3. 

974. The Wasatch-Cache National Forest should recommend additional wilderness 

areas in the North Wasatch Ogden Valley Management Area. 

974.1 Mollens Hollow 

974.2 Areas near Ogden 

974.3 Burch Creek 

974.4 Francis Roadless area 

974.5 Upper South Fork 

974.6 Lewis Peak 

974.7 Areas surrounding the Bonneville Shoreline Trail 

Response: We inventoried and considered the values for Wilderness of each of 

these areas in Appendix C in the DEIS (Appendix C-1) in the FEIS. Each of the 

commenters suggested that some or all of these areas could be recommended as 

Wilderness. The Forest Plan revision interdisciplinary team looked at each area 

again to consider their character and see if Wilderness recommendation might be 

appropriate. Upper South Fork Roadless is recommended for Wilderness in several 

Alternatives. Additional recommendations for Wilderness were made in Alternative 

1 (changing the management prescription map) beyond what was provided in the 

DEIS for Lewis Peak, and portions of the Willard and Francis roadless areas. The 

interdisciplinary team review of Mollens Hollow roadless area found that it was not 

appropriate for Wilderness recommendation under any of the Alternatives. In the 

development of Alternative 7, the values for Wilderness of these areas were also 

considered, and while these areas were not recommended for Wilderness in the 

alternative, substantial portions of them were placed in MPC 2.6, Undeveloped 

Areas. A review of the MPCs in Chapter 4 of the Forest Plan or Management 

Prescription maps for Alternatives 1 and 7 from the DEIS and FEIS allows one to 

review these situations. 

 

975. The Wasatch-Cache National Forest should recommend additional wilderness 

areas in the Central Wasatch Management Area. 

975.1 Tri-Canyon Area 

975.2 Twin Peaks 

975.3 Gobbler’s Knob 

975.4 Mount Aire 

975.5 Red Butte Canyon and Mueller Park 

975.6 Grizzly Gulch 

975.6 Lone Peak 

Response: As mentioned in response 974 above, we inventoried and considered the 

values for Wilderness of each of these areas in Appendix C in the DEIS (Appendix 

C-1) in the FEIS. Each of the commenters suggested that some or all of these areas 

could be recommended as Wilderness. The Forest Plan revision interdisciplinary 

team looked at each area again to consider their character and see if Wilderness 
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Wasatch-Cache National Forest A - 229 

recommendation might be appropriate. All mentioned areas are within the general 

Tri-Canyon area of the Salt Lake Ranger District. 

Most of Twin Peaks roadless area is recommended for Wilderness in Alternative 1, 

and smaller portions in Alternatives 2 and 3. So this area has been considered as 

Wilderness in the revision process. 

Gobbler’s Knob is found within part of the Mt. Olympus roadless area, and this 

portion of the roadless area is recommended for wilderness in Alternatives 1, 2, and 

3. Consequently, there has been consideration of this area as Wilderness in the 

revision process. 

Most of the Mt. Aire roadless area was recommended for Wilderness in Alternative 

1. Other alternatives did not recommend it. The area is generally perceived as 

marginal potential for Wilderness given presence of substantial Wilderness already 

in the general area and other factors. Appendix C-1 to the FEIS reviews its 

potential for Wilderness. 

Red Butte and Mueller Park roadless areas were added to the roadless inventory 

since the DEIS as a result of this comments, and considered for their values as 

potential Wilderness or for roadless area values. (See Appendices C-1 and C-2.) 

The review of Red Butte and Mueller Park roadless areas determined that neither 

was appropriate for Wilderness recommendation under any alternative. 

Grizzly Gulch, near Alta ski area, is primarily composed of private lands, is not in 

an inventoried roadless area, and is not capable, available, or needed as an addition 

to Wilderness. 

Additions to Lone Peak Wilderness are considered in Alternatives 1 and 2. See 

Appendices C-1 and C-2 to the FEIS. 

976. The Wasatch-Cache National Forest should recommend the proposed Mount 

Olympus wilderness addition. 

 Response: Alternative 1 in the FEIS considers and recommends most of the Mt. 

Olympus roadless area as Wilderness. Two other alternatives (2 and 3) recommend 

about 20% of the roadless area be added as Wilderness. We understand that 

proponents of watershed protection, wildlife species and habitat, threatened 

vegetation, and non-motorized summer and winter recreation have a stake in this 

perspective (as do the values and species they represent), and we have considered 

these positions in our FEIS. 

 

977. The Wasatch-Cache National Forest should exclude certain areas from the 

proposed Mount Olympus wilderness addition. 

 Response: A range of alternatives is presented in the FEIS in Chapter 3, Topic 5 

that recommends most of the Mt. Olympus roadless area as Wilderness in 

Alternative 1, to recommending none of it in 4 alternatives. The decision maker for 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 230 

this roadless area has been given a broad range of alternatives and effects to 

consider in making a decision, and your position has been identified within this 

range of alternatives. 

978. The Wasatch-Cache National Forest should recommend White Pine Canyon 

for wilderness designation. 

 Response: White Pine roadless area is recommended for Wilderness in 

Alternatives 1 and 2. In five other alternatives it is not. Your opinion and the 

opinions of other are considered in the range of alternatives for this area. 

 

979. The Wasatch-Cache National Forest should not recommend White Pine 

Canyon for wilderness designation. 

979.1 Because the area is already sufficiently protected 

Response: White Pine roadless area is not recommended for addition to 

Wilderness in five of the seven alternatives analyzed in the FEIS. With the 

exception of comment 979.2 and 979.5 above, we recognize the perspectives of the 

comments above, and have considered them through these alternative treatments. 

979.2 Because grazing and winter motorized use should be allowed to continue 

Response For 979.2: Grazing is not allowed under any Alternative. It must be 

noted that grazing is not now allowed in the White Pine area as it is within the Salt 

Lake City municipal watershed, and this use has not been allowed for many years; 

winter motorized use, through helicopter skiing is allowed in several alternatives (3-

7), although it is not allowed in Alternatives 1 and 2. 

979.3 Because helicopter skiing should be allowed to continue 

Response: See response 979.1. 

979.4 Because the area contains too many roads and other improvements to be 

considered for wilderness designation 

Response: See response 979.1.

 

979.5 Because it will prevent access to private inholdings 

Response For 979.5: Access to private inholdings must be allowed by law. The 

Forest Service cannot deny access to private property held within national forests. 

This is not a decision that is either within the authority of the Forest Service or 

within the scope of this forest plan. 

 

980. The Wasatch-Cache National Forest should recommend additional wilderness 

areas in the Stansbury Mountains Management Area, ie Stansbury Mountains 

and Deseret Peak Areas. 

 Response: Our range of alternatives for wilderness recommendation in the 

Stansburys goes from recommending nearly all of the local roadless area for 

Wilderness in Alternative 1, to recommending none in four alternatives. The 

inventory of roadless areas for Wilderness values and roadless for other roadless 

area values is contained in Appendices C1 and C-2 respectively in the FEIS. Topic 
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Wasatch-Cache National Forest A - 231 

5 in Chapter 3 of the FEIS discusses the alternatives for Wilderness 

recommendation and roadless values. The decision-maker has been given range of 

choices from which to build a decision for the area and the forest in general. 

981. The Wasatch-Cache National Forest should recommend additional wilderness 

areas in the Western and Eastern Uintas Management Areas. 

981.1 Areas Adjacent to Lakes, and Uintas North Slope 

981.2 Boundary Creek 

981.3 Burnt Fork/Thompson Fork/Kabell Creek 

981.4 Hayden Fork/Main Fork/Stillwater/Boundary Creek 

981.5 High Uintas 

981.6 Lakes Roadless Area/proposed Mount Watson Wilderness 

981.7 Nobletts 

981.8 Stillwater Creek 

981.9 Middle Fork, Blacks Fork, and West Fork Beaver Creek 

981.10 Widdop Mountain 

Response: Many commenters provided general and detailed support for 

recommendations of additional Wilderness in the Uintas Range. The itemized areas 

above were extracted from individual comments in of support for Wilderness 

recommendation for each area. The range of alternatives presented in the FEIS 

provides Wilderness recommendations of almost all of these roadless areas to 

Wilderness in Alternative 1, and lesser amounts in Alternatives 2, 3, 6 and 7. 

Detailed discussions of the values of these areas as Wilderness can be found in 

Appendix C-1 to the FEIS. Discussions of other values associated with their 

roadless character can be found in Appendix C-2. Our range of alternatives 

accounts for situations in which these values might be protected or might be placed 

under prescriptions where more development is allowed. 

982. The Wasatch-Cache National Forest should recommend the Mount Naomi 

Roadless Area for wilderness designation. 

 Response: Most of the Mt. Naomi roadless area is recommended for Wilderness 

in Alternative 1. Alternatives 2, 3, and 6 also make recommendations for several 

1000 acres, while Alternative 7 recommends 500 acres adjacent to recommended 

Wilderness on the Caribou National Forest. Two alternatives, 4 and 5, recommend 

no new Wilderness here or forestwide, satisfying those who have an opposite 

perspective on Wilderness recommendation from your own. 

983. The Wasatch-Cache National Forest should not base its needs assessment for 

additional wilderness solely on recreational criteria for the Mount Naomi 

Roadless area. 

 Response: Alternative 1 recommends most of the Mt. Naomi Roadless area for 

Wilderness, and Alternative 2 recommends much of it. The analysis of the need for 

additional Wilderness analyzed in Appendix C of the DEIS for Mt. Naomi roadless 

area did have several references to the recreation values of the area, but it is clear in 

this inventory that significant wildlife and plants are present that are also considered 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 232 

for potential as Wilderness. We think that the range of Alternatives covers the 

possibilities and analysis that you suggest. 

 

984. The Wasatch-Cache National Forest should extend wilderness designations 

back to the trailheads on every drainage across the North Slope. 

 Response: The range of alternatives developed in the FEIS encompasses situations 

in which larger recommendations for Wilderness would extend wilderness to 

existing trailheads. If large new Wilderness recommendations (Alternatives 1 or 2) 

or even smaller recommendations are decided on (Alternatives 3, 6, or 7) local 

implementation decisions for managing at the edges and interiors of new 

recommended Wilderness will need to be made. Site-specific management at 

trailheads, essentially requiring Wilderness behaviors and uses from trailheads to 

Wilderness boundaries might also be a solution to your concern. 

Topic 6: Suitable Timberlands 

Suitable Timberlands General 

985. The Wasatch-Cache National Forest should modify the standards and 

guidelines related to timber management. 

985.1 To define and further develop “standard restrictions” 

985.2 To protect scenic river eligibility 

985.3 To establish a skidding prohibition at a lower slope than 40 percent 

985.4 To close loopholes for timber sales in Guidelines 58 and 59 

985.5 To protect trails during timber sales and other vegetation management

 Response: The Forest Plan identifies general standards and guidelines that apply 

to all management prescriptions. Project level analysis will determine necessary 

management requirements based on site conditions, and will address protection of 

system trails, scenic river eligibility, and other resource values to be maintained or 

improved. 

 

986. The Wasatch-Cache National Forest should clarify timber management 

prescriptions in the Forest Plan by including species-specific road density 

requirements and management direction. 

 Response: Species-specific road densities is impractical when one considers the 

300+ vertebrate species that may use the Forest. Chapter 3, Topic 3, and Appendix 

B5 in the FEIS discuss roads analysis and densities, as does Topic 3 in the Revised 

Forest Plan. 

987. The Wasatch-Cache National Forest should require the timber industry to 

restore harvested areas. 

 Response: Post-sale activities and requirements/restrictions on logging activity are 

determined during the analysis conducted under NEPA. The contract provisions are 

selected to insure that the identified requirements are implemented on the ground 

during the term of the contract. Timber sales are monitored during the term of the 

contract to insure the purchaser is in compliance with contract specifications. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 233 

988. The Wasatch-Cache National Forest should scientifically manage vegetation 

resources to ensure restoration of biodiversity. 

 Response: Each alternative addresses vegetation management with a combination 

of mechanical treatments and the use of prescribed fire. Restoring biodiversity is an 

objective of most alternatives, but the method used for restoration varies between 

alternatives. Harvest will be used in some areas, but where harvesting is restricted 

by physical, biological or management constraints, prescribed fire is the primary 

tool to restore biodiversity. 

989. The Wasatch-Cache National Forest should review timber suitability per the 

Alternative 7 management prescription category. 

 Response: Timber suitability analysis has been conducted in accordance with 

planning regulations and is included in Appendix B. 

990. The Wasatch-Cache National Forest should consider alternatives to timber 

harvesting to keep roadless areas intact. 

 Response: Thank you for your comment. Roadless areas are addressed in all 

alternatives. Preservation of all existing roadless areas is included in several 

alternatives (1,2,6), and the remaining alternatives protect roadless areas to varying 

degrees through the application of MPCs. 

Adequacy of Analysis 

991. The Wasatch-Cache National Forest should clarify existing tables and provide 

additional tables in the Final EIS that indicate “total suited acres” and 

“tentatively suited lands.” 

 Response: Tables have been reviewed and we have attempted to make them more 

clear and correct inaccuracies. Table TM-2 Chapter 3) presents the suited acres and 

unsuited lands where timber harvest is allowed. 

992. The Wasatch-Cache National Forest should provide a more thorough analysis 

in compliance with the Forest Service Manual. 

992.1 By providing sufficient analyis in the Final EIS 

992.2 By using FORPLAN to calculate allowable sale quantity and long-term 

sustained yield 

992.3 By providing sufficient information in the Forest Plan

 Response: Timber suitability and ASQ information has been reformatted in the 

Forest Plan to include additional information and in the format in the planning 

regulations. This information is included in Appendix B. The planning regulations 

do not require the use of FORPLAN, but require estimating the goods and services, 

activities, and investments to be implemented or produced by decade and display 

them. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 234 

993. The Final EIS should provide a complete analysis of the cumulative effects of 

logging on threatened wildlife, including predators. 

 Response: “Threatened and Endangered” are defined by law in the Endangered 

Species Act (ESA). The Forest has only one threatened predator species, the 

Canada lynx, and one endangered species, the black-footed ferret which is classified 

by the State and the U.S. Fish and Wildlife Service (FWS) as being historical on the 

Wasatch-Cache (and all other areas of the State except the Uintah Basin where it 

has recently been reintroduced. All Federally listed, candidate, and proposed 

species that the FWS has identified for the Forest are discussed in the Biological 

Assessment as required by the ESA and under species-at-risk in Appendix B2 of the 

FEIS. 

994. The Final EIS should disclose the adverse effects of timber sales on atmospheric 

carbon levels in order to comply with the Global Climate Change Prevention 

Act. 

 Response: The Global Change Prevention Act directs the Secretary of Agriculture 

to study global climate change and its affect on farms and forests in the United 

States, and to identify alternative management strategies for temperate and tropical 

forests that may mitigate any negative effects of global climate change. The longterm effects of climate change are beyond the scope of this Forest Plan. 

995. The Wasatch-Cache National Forest should modify the discussion of timber 

suitability in the Final EIS. 

995.1 By including more recent monitoring data 

995.2 By describing timber supply and demand 

995.3 By explaining what triggers a timber sale outside of the timber 

prescription or suitable base 

 Response: There has not been a published monitoring report since 1992. 

However, resource monitoring at the project level has been ongoing since the report 

was issued. The most recent information from this monitoring was incorporated 

into the analysis. Quantifying the demand for timber is difficult because mills 

outside the local area are now purchasing timber from the Wasatch-Cache, and they 

are not totally dependent upon timber from this forest for their supply. We have 

tried to improve the timber demand discussion in an attempt to better describe the 

local market. There is no specific triggering mechanism for timber sales on 

unsuitable lands that permit timber harvest. The purpose for the proposed treatment 

would be identified in the project level analysis. Timber harvest on unsuitable 

lands could be proposed for several purposes, including but not limited to salvage 

of insect or fire-killed timber, maintenance or improvement of wildlife habitat, and 

development of PFC. 

996. The Wasatch-Cache National Forest should better explain statements 

regarding the possible benefits of tree removal on wildlife due to improved 

hunting opportunities. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 235 

 Response: This statement was in regards to oil and gas leasing. The section on 

“The Effects on Terrestrial Wildlife From Oil and Gas Activities has been rewritten 

and the statement is no longer in the document. 

 

997. The Wasatch-Cache National Forest should explain the connection between 

timber harvest and lynx management for each alternative. 

Response: Lynx conservation strategy guidelines specify that management 

activities shall not change more than 15% of a Lynx Analysis Unit to an unsuitable 

condition within a 10-year period. The greatest projected forest-wide harvest level 

(Alternative 5) is about 12,400 acres of suited lands in a decade. It is unlikely that 

this level of activity will exceed the conservation strategy limits for change in a 

decade. However, site-specific analysis will determine the effects of proposed 

harvest, and may dictate a reduction of treatment acres in a particular LAU. We 

have discussed this in more detail in the FEIS. 

998. The Wasatch-Cache National Forest should discuss timber harvest methods in 

the Final EIS. 

998.1 To clarify the different impacts from fire and clearcuts 

998.2 To clarify harvest methods for conifer, lodgepole pine, and aspen 

 Response: The values for water yield in the DEIS are based on a model that 

predicts no reduction in water yield for 15 years after conifer harvest and then 

reduces the water yield to zero linearly from 15 to 60 years after harvest. After the 

DEIS was released for public comment, a different approach was felt to be 

appropriate for the assessment of water yield increases. Since Forest Plan revision is 

broad-level planning, it is felt that it is not appropriate to present specific values of 

water yield based on assumptions and research that was conducted in very small 

watersheds that may or may not apply to the Forest-level scale. Therefore, a 

different analysis presented that is discussed in the section Effects on Soil and 

Water Resources from Timber Harvest/ Vegetation Treatments under Topic 1, 

Watershed Health in the FEIS. 

We agree the referenced harvest method statement is confusing. It has been 

reworded in the FEIS to clarify the meaning. Clearcutting is an even-aged 

silvicultural system, and may be appropriate for lodgepole pine stands and mixed 

conifer stands dominated by lodgepole pine. Uneven-aged systems will be the 

preferred system in spruce-fir and mixed stands dominated by spruce and fir. The 

purpose of clearcutting aspen is to initiate regeneration from root sprouts and 

provide for future mature stands. Mature aspen stands are very desirable and a 

major management emphasis is perpetuating such stands over time. 

999. The Wasatch-Cache National Forest should continue to research best 

management practices for timber harvest methods. 

 Response: Research projects that investigate best management practices and other 

management options are conducted by Forest Service Research Stations on a 

continuing basis. At the Forest level, timber sale areas are monitored during and 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 236 

after harvest to determine effectiveness of prescribed management practices. 

Adjustments in practices are made if monitoring indicates changes are warranted. 

1000. The Wasatch-Cache National Forest should further study aspen ecology 

before continuing to clear-cut to understand the long-term effects and 

regrowth potential of aspen. 

 Response: Past aspen regeneration treatments have been monitored periodically to 

measure response to the treatments and growth of aspen. A considerable body of 

information pertaining to aspen management has been developed through research 

and is reviewed during analysis process. We recognize that some aspen stands are 

self-sustaining; our focus is on treatment of those stands that are in the process of 

conversion. 

1001. The Final EIS should include a map of suitable timberlands which was not 

provided in the previous plan. 

 Response: Suitable timberlands are those forested lands within management 

prescriptions 5.2 and 6.2. They are mapped as such on alternative maps. This 

should make them more identifiable than is the case in the current plan. 

Allow Timber Harvest 

1002. The Wasatch-Cache National Forest should allow timber harvest. 

1002.1 With some areas protected for recreation 

1002.2 For forest health 

1002.3 With no restrictions based on protection of species not sited in the area 

1002.4 With restoration considerations 

 Response: Timber harvest is part of the Forest Service multiple use mission. 

Management prescription categories that define the management emphasis for an 

area of the forest were developed to provide a full spectrum of opportunities such as 

those mentioned. Recreation opportunities, forest health, protection of threatened, 

endangered and sensitive species habitat, and ecosystem restoration are among the 

many considerations in timber sale projects. 

1003. The Wasatch-Cache National Forest should allow public fuel wood 

collection. 

1003.1 To reduce fire hazards, warm households, and finance maintenance 

backlogs 

1003.2 To prevent waste of natural resources 

1003.3 To help clean-up the forest 

 Response: The Wasatch-Cache offers fuelwood to the public every year, but not 

necessarily on every Ranger District. The decision to offer or not rests with the 

individual Ranger Districts, and depends upon the availability of material to offer. 

The need for snags and down woody material for various wildlife species and other 

considerations will influence whether fuelwood permits will be offered, where 

fuelwood cutting will be allowed, how many permits to offer, and when to offer 

them. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 237 

Not Allow/Restrict Timber Harvest 

1004. The Wasatch-Cache National Forest should limit timber harvest. 

1004.1 To preserve forest health, improve habitat, reduce fuels, and support 

water output 

1004.2 To protect wildlife 

 Response: Timber harvest is part of the multiple use mission of the Forest Service. 

Timber harvest from suitable lands may be based on economic reasons. All sales 

from other lands are for other than economic purposes, such as habitat improvement 

and fuels reduction. Alternative 2 addresses the concern that harvesting be limited 

to non-economic purposes. 

1005. The Wasatch-Cache National Forest should prohibit timber harvest. 

1005.1 Until it completes a proper accounting of timber harvest costs 

1005.2 Because of its low economic value in comparison with amenity values 

1005.3 To protect the recreational value of the forests 

1005.4 To protect the scenic and biologic value of the forests 

1005.5 To eliminate damage from timber harvest 

 Response: The multiple use mission of the Forest Service provides a variety of 

goods and services from National Forest lands. The Forest Plan identifies a 

resource emphasis for a given area by means of the management prescription 

categories. These MPCs provide a mix of uses and identify those areas where 

timber harvest is appropriate, and those areas where it is not. Although there is no 

requirement that Forest Service timber sales provide a net return to the Treasury, we 

do consider the economics of timber in the sale planning process. 

1006. The Wasatch-Cache National Forest should prohibit timber harvest in 

roadless areas. 

1006.1 To allow natural forest processes to dominate 

1006.2 To preserve ecosystem values 

1006.3 To protect forest ecosystems from fragmentation 

1006.4 To protect wildlife 

1006.5 To preserve roadless values 

Response: The FEIS includes Alternative 1 which allows no timber harvest, and 

Alternatives 2 and 6 which allow no timber harvest in roadless areas. The 

environmental effects of these alternatives are displayed in Chapter 3 of the FEIS. 

See FEIS Chapter 3 within the Topic for Roadless areas for a display of how each 

alternative affects roadless areas. 

1007. The Wasatch-Cache National Forest should prohibit timber harvest in 

roadless areas on the North Slope. 

 Response: We recognize the importance of roadless areas for all of the above 

values. The plan approaches the decision on disposition of roadless areas by 

providing a range of protection depending upon alternative, including preserving all 

existing roadless. 

 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 238 

1008. The Wasatch-Cache National Forest should not use clear-cutting as a timber 

harvest method. 

 Response: The widest range of options should be available to meet management 

objectives. Clearcutting is an acceptable harvesting system for some species under 

certain conditions. However, whenever clearcutting is prescribed for a stand, it 

must be the optimum method of achieving objectives and the reason for its use 

disclosed in the project analysis. 

1009. The Wasatch-Cache National Forest should stop using the unscientific 

concept of forest health to justify its timber commodity program and recognize 

that insects and disease play vital roles in ecosystem integrity. 

 Response: We agree that insects and disease play vital roles in ecosystem integrity. 

However, the decision on whether or not to treat a stand is based on multiple use 

objectives. Timber harvest may be an effective method to maintain other resource 

values that may be adversely affected by extensive insect and disease caused 

mortality. 

 

1010. The Wasatch-Cache National Forest should not use the threat of insects and 

disease as an excuse to timber harvest. 

 Response: Harvesting is proposed to develop stand conditions that meet 

management objectives, including PFC. While endemic levels of insects are not 

destructive, and may in fact be beneficial, large-scale epidemics can affect the 

desired condition for the forest, and adversely affect other resources such as 

recreation and wildlife. In such cases, harvest can have a role to play in achieving 

the future condition. 

1011. The Wasatch-Cache National Forest should not allow timber harvest levels to 

exceed regenerative capacity. 

 Response: We agree. Care is taken during the planning process and preparation of 

the silvicultural prescription, as well as during the implementation and post-sale 

phases to ensure adequate regeneration is established following harvest. 

Insects and Disease 

1012. The Wasatch-Cache National Forest should not have a policy of keeping 

spruce beetle activity at an endemic level. 

 Response: Thank you for your comment. Decisions on whether to treat insect 

outbreaks are made based on the anticipated impacts on many forest resources. 

Response will vary depending upon location and severity of the outbreak, and the 

threat to forest resources. 

1013. The National Forest should not use synthetic herbicides and insecticides for 

pest management. 

 Response: Thank you for your comment. We feel that we should have a full range 

of options available to address the range of disturbances that are experienced across 

the Forest, and the range of treatment options is reflected in the alternatives. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 239 

Herbicides and insecticides can be effective tools to protect high value trees in 

campgrounds and to control noxious weeds. When used, they are applied directly 

to the plant to be controlled (in the case of noxious weeds) or the tree to be 

protected (in the case of campgrounds), to maximize effectiveness and minimize 

potential effects to non-target species. 

Topic 7: Rangeland Capability, Suitability, and Forage Production 

Rangeland Capability, Suitability, and Forage Production General 

1014. The Wasatch-Cache National Forest should develop improved livestock 

grazing strategies in the final Forest Plan to improve riparian habitats. 

 Response: We have identified in Appendix VII of the Forest Plan, riparian 

classes for streams addressed in the Wild and Scenic River evaluation for the 

Forest. Those classes are managed to specific desired conditions and utilization 

standards. In addition, we have added a new forage utilization guideline (G70) for 

rangelands in unsatisfactory condition (not meeting or moving toward forest plan 

objectives). 

1015. The Wasatch-Cache National Forest should not give grazing a special status 

in the Forest Plan. 

 Response: Please see response to concern statement 61. NFMA regulations call 

for specific decisions to be made regarding grazing on the Forest. We feel that a 

full spectrum of uses are provided for in the revised Forest Plan through the 

establishment of an array of desired future conditions, goals, objectives, standards 

and guidelines that help us manage for many different uses across the forest. 

1016. The Wasatch-Cache National Forest should adopt the Gunnison sage grouse 

guidelines for grazing areas to promote recovery and restoration of sage 

grouse habitat. 

 Response: A minor amount of sage grouse habitat occurs on the Wasatch-Cache 

National Forest and the Gunnison sage grouse guidelines are specific for a 

subspecies of sage grouse that do not occur on the Forest. Broader guidelines for 

managing sage grouse habitats (Connelly and others) are incorporated by reference. 

Adequacy of Analysis 

1017. The Wasatch-Cache National Forest should adequately analyze the impacts 

of livestock grazing. 

1017.1 By analyzing environmental and economic impacts 

1017.2 By analyzing site-specific impacts 

1017.3 By analyzing whether grazing forecloses other forest uses 

1017.4 By documenting the rate of aspen decline 

Response: The environmental effects of grazing are disclosed under various 

resource topics in Chapter 3 of the FEIS and the economic impacts to permittees are 

provided in the Social Impacts Analysis portion of Chapter 3. These analyses have 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 240 

been reviewed and in many cases updated and expanded upon in the FEIS. Sitespecific analyses are outside the scope of the Forest Plan. A section titled 

“Alternative Uses Foregone” has been added to the FEIS. A discussion on the rate 

of aspen decline has been added in Chapter 3 of the FEIS under Topic 2, 

Biodiversity and Viability, Vegetation. It describes the variety of factors involved 

with aspen decline, including fire suppression and livestock grazing. 

1018. The Wasatch-Cache National Forest should analyze the effects of livestock 

grazing against the economic benefits. 

 Response: The effects of livestock grazing are outlined in Chapter 3, Topic 7 – 

Rangeland Capability and Suitability, Livestock Grazing/Range Management. The 

cost for grazing an animal unit month (AUM) is set by Congress, as is our budget to 

manage livestock use on the Forest. While economic suitability is one factor in 

determining rangeland suitability, it is the ecological conditions of the land that are 

more heavily determine whether or not to graze and how much grazing should 

occur, not the economics of livestock grazing. 

1019. The Wasatch-Cache National Forest should clarify the relationship between 

animal unit months and terrestrial conditions. 

 Response: Livestock use is allowed on suitable rangelands as long as those lands 

are at, or moving toward desired conditions. These conditions focus on the longterm sustainability of uses on rangelands and the ability to maintain quality 

watershed conditions, wildlife habitat, and a variety of age classes within those 

vegetation types. 

1020. The Wasatch-Cache National Forest should clarify its discussion of 

permitted grazing levels in the Draft EIS. 

 Response: While at the forest-wide scale we can address permitted numbers 

based on existing and historic use levels, the detailed analysis to revise these 

numbers up or down is beyond the scope of this analysis. We have estimated the 

effects of the different alternatives, however, and these are shown in the revised 

Table RN-2. 

1021. The Wasatch-Cache National Forest should justify its rationale for only 

closing three allotments in the Preferred Alternative. 

 Response: Five additional vacant allotments are closed in the Salt Lake and 

Davis County watersheds in the decision alternative (Alternative 7), for a total of 10 

of the 13 vacant allotments closed. The other three have not been closed because of 

the potential to restock them and/or to use them while other allotments are being 

treated with prescribed fire or wildland fire use. 

1022. The Wasatch-Cache National Forest should verify rangeland condition and 

trend by using verified conditions, not estimates. 

 Response: The Forest has followed accepted protocols in the assessment of range 

conditions, using both verified and estimated condition techniques. Because of the 

vast numbers of acres of rangelands in allotments across the Forest (98 allotments 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 241 

covering over 300,000 capable rangeland acres), it is not possible to verify 

conditions annually on all allotments. 

1023. The Wasatch-Cache National Forest should provide maps indicating suitable 

and capable acres for livestock grazing so that better grazing capability 

determinations can be made. 

 Response: Maps showing the locations of allotments on the Forest have been 

added to FEIS Appendix I. Maps are in the planning record that show the different 

factors used in rangeland capability and suitability analysis, the detail of which is 

too great to put into the EIS document. Capable acres and suitable acres of 

rangelands were determined using processes in the Rangeland Capability and 

Suitability Protocol (USDA Forest Service 2000) and outlined in FEIS Appendix B9. As noted in this appendix, percent slope, minimum forage production, stable 

soils, ground cover, and access by livestock (including distance to water) were the 

factors used in determining capability. In addition, tables are available in FEIS 

Appendix I that illustrate which allotments are open by alternative and maps are 

provided that show where these allotments occur. Only those capable acres within 

these allotments are considered suitable. 

1024. The Wasatch-Cache National Forest should provide maps of vacant and used 

forest allotments including the three sheep allotments, which, if vacated, would 

benefit bighorn sheep, for reviewers to determine whether the proposed 

analysis is consistent with the location of the allotments. 

 Response: Maps showing the location of each allotment on the forest are in 

Appendix I, which has been added to the FEIS. This appendix addresses current 

allotment status (open or closed) and allotment status by alternative as well. 

1025. The Wasatch-Cache National Forest should publish and distribute maps of 

grazing activity throughout the year so recreational users can avoid areas 

where livestock have damaged or closed recreational opportunities. 

 Response: Because areas that are used at any given time during the grazing 

season may vary because of annual weather, soil moisture conditions, and rotation 

systems used on allotments, it would not be possible to accurately display this on 

maps in a meaningful and accurate way. Recreation users may call the District 

offices to receive information on where grazing is occurring and when. 

1026. The Wasatch-Cache National Forest should modify the VEG-1 table in the 

Final EIS to indicate deviations from historic range of variation related to 

stubble heights. 

 Response: The forest uses stubble height as an indicator of when livestock 

should be removed from an allotment and does not relate it to historic ecological 

conditions of rangelands, which is better described by species composition, ground 

cover, and canopy cover of sagebrush species. Stubble height refers to the height at 

the end of the growing season. In some areas where early grazing occurs, these 

heights at the time that livestock leave a pasture may be less that the height 

identified in the utilization standard. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 242 

1027. The Wasatch-Cache National Forest should scientifically determine the 

animal unit months to be produced from capable lands. 

 Response: While animal unit months (AUMs) have been estimated for each 

alternative, the actual AUMs allowed to graze any given allotment is better 

determined through site-specific analysis that assesses, not only the forage 

production within an allotment, but also the areas actually used by livestock at the 

appropriate level of utilization. 

1028. The Wasatch-Cache National Forest should analyze fecal coliform and 

bacterial forms of contamination associated with livestock grazing in the Final 

EIS to protect water quality. 

Response: The effect of increased bacterial concentrations in water from fecal 

wastes of livestock has been included in the section Effects on Soil and Water 

Resources from Livestock Grazing under Topic 1 Watershed Health. Analysis of 

fecal coliform and other bacterial forms of contamination associated with livestock 

grazing is not appropriate in the FEIS because Forest Plan Revision is broad-scale 

planning and decides where livestock grazing is allowed. Site-specific water 

quality problems associated with livestock grazing should be addressed during 

allotment management plan revisions or during annual permit review process. 

Legal Considerations 

1029. The Wasatch-Cache National Forest should indicate compliance strategies 

with the Endangered Species Act with respect to livestock management. 

 Response: A biological evaluation/biological assessment is on file for this Forest 

Plan revision, which includes effects on Threatened, Endangered, and 

Intermountain Region Forest Service Sensitive species. Effects from livestock 

grazing on these and other species at risk have been described in more detail in 

Chapter 3, Topic 2 – Biodiversity and Viability. 

Rangeland Management 

Goals and Objectives 

1030. The Wasatch-Cache National Forest should modify the grazing objectives in 

the Forest Plan. 

1030.1 By completing riparian class assignments and utilization standards for 

all riparian areas on all allotments 

1030.2 By modifying the period for range analyses to be applied to the 

monitoring scheme 

1030.3 By analyzing potential increases in forage availability based on the 

range of potential rates of timber and fire prescriptions

 Response: While we have not completed riparian class assignments for all 

riparian areas of the forest, classes for many of the perennial streams and rivers of 

the Forest has been added to Forest Plan, Appendix VII. These classes were 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 243 

determined through an interdisciplinary team process. Utilization standards for 

each riparian class are identified in the Standards and Guidelines section of the 

Forest Plan. Site-specific adjustments will be encouraged based on the results of ongoing range analysis and monitoring. Timber and fire activities temporarily change 

the availability of forage and are not included in the analyses for grazing potential, 

because of their transitory nature. And while it is permissible to include such range 

in suitable acre calculations, permitted numbers are not adjusted accordingly at the 

forest-wide scale because of the difficulty in properly assessing these conditions 

over the long term. Changes can be made through additional site-specific analysis. 

Standards and Guidelines 

1031. The Wasatch-Cache National Forest should modify standards and guidelines 

for ranges. 

1031.1 By addressing what will be done with vacant allotments 

1031.2 By establishing criteria for maintenance of ground cover, vegetation, 

and soil.

 Response: The disposition of vacant allotments is described in the Alternatives 

portion of the FEIS. Utilization and ground cover standards and guidelines are 

imposed wherever livestock grazing is permitted. These as well as identified 

desired conditions, goals, and subgoals provide direction for maintaining ground 

cover, desired vegetation, and watershed and soil conditions. 

1032. The Wasatch-Cache National Forest should comply with state water quality 

standards within livestock allotments. 

Response: The WCNF is required by State law to meet anti-degradation 

requirements. The Forest Plan has many standards and guidelines that help to meet 

anti-degradation requirements such as those under sections Watershed Health and 

Biodiversity and Viability. The states of Utah and Wyoming make determination of 

whether waters are fully supporting beneficial uses or not. Utah has determined 

that the waters of the WCNF are fully supporting their beneficial uses except for 

those listed in Table WA-1. The only water body on the WCNF that is identified as 

impaired for fecal coliform is Emigration Creek of which Salt Lake County is 

expected to begin assessing in 2003. The FEIS recognizes that impacts from 

livestock grazing occurs and is described in the section Effects on Soil and Water 

Resources from Livestock Grazing under Topic 1 Watershed Health. 

1033. The Wasatch-Cache National Forest should not rely on utilization standards 

to protect stream habitats. 

 Response: Additional direction has been added to the plan (guideline, G74) that 

annual operating instructions (and/or Allotment Management Plans) should be 

evaluated and additional site-specific objectives defined if needed for one or more 

of five different parameters, including stream bank trampling on key reaches. The 

Wasatch-Cache National Forest follows the Society for Range Management 

position statement on utilization dated February 2002 and is quoted below from 

their web page, http://uvalde.tamu.edu/jrm/jrmhome.htm: 
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Wasatch-Cache National Forest A - 244 

The Society for Range Management recognizes and endorses forage utilization and 

residue measurements as useful tools in rangeland monitoring, and acknowledges 

their value in land management. When used with other monitoring information, 

utilization can be employed to design and evaluate management decisions. These 

measurements, when properly timed and conducted using appropriate methods and 

sampling procedures, can be used as an aid in: 

Analyzing distribution of animal use on a management unit. 

Interpreting cause and effect relationships for observed changes in resource 

attributes such as soil cover, species composition, residual cover, etc. 

Adjusting stocking rates and/or timing of grazing when used in conjunction with 

other monitoring information including: long term vegetation or habitat data, 

current and historical stocking records, precipitation records, etc. 

Utilization and residue measurements are not management objectives. They are 

tools to be used with other information in evaluating whether desired resource 

conditions are being achieved. 

Other tools we are using to look at riparian conditions are greenline trend data to 

assess the condition of the riparian communities immediately adjacent to the 

streams. 

 

1034. The Wasatch-Cache National Forest should select species to monitor to 

determine the prescribed utilization standards for livestock grazing. 

 Response: – While we have suggested some species to monitor utilization, this 

can and should be modified on a site-specific scale to meet the definition of a key 

species. As defined, key species, will be indicator species, which show signs of 

utilization first, and are generally more sensitive to grazing pressures. 

1035. The Wasatch-Cache National Forest should require a minimum 8-12 inch 

stubble height for all upland perennial bunchgrasses at the end of the grazing 

or growing season. 

1035.1 To protect ground nesting bird habitat 

1035.2 Management Prescription Categories

 Response: The proper use of forage has been focused on the ability of the grazed 

plants to maintain their viability and to maintain protective ground cover. Habitat 

requirements for ground-nesting birds are highly variable, and while 8-12 inch 

stubble height may be advantageous to some ground nesting species, it may be 

detrimental to others. 

1036. The Wasatch-Cache National Forest should not renew grazing permits in the 

4.x management prescription categories. 

 Response: Grazing is not allowed in developed recreation sites, such as 

developed campgrounds and picnic areas. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 245 

1037. The Wasatch-Cache National Forest should not allow grazing in 

Management Prescription Categories 2.x and 3.x to protect aquatic, terrestrial 

and watershed integrity. 

 Response: – It was determined that livestock grazing was not incompatible with 

Wild and Scenic River status MPCs 2.1, 2.2, and 2.3). Grazing is currently not 

allowed in Research Natural Areas (MPC 2.4). Grazing does occur on the Mirror 

Lake Highway and in portions of Logan Canyon, both Scenic Byways (MPC 2.5), 

but is not incompatible with the values of these areas. Roadless Areas (MPC 2.6) 

have each been evaluated for the values they contain (FEIS, Appendix C-2). 

Special Interest Areas (MPC 2.7) were proposed only where existing livestock 

grazing did not interfere with the values of those areas. Streams and rivers with 

Bonneville or Colorado River cutthroat trout populations (MPC 3.1) have been 

classified as Class 1 streams (Forest Plan, Appendix VII), which have the most 

restrictive grazing management direction. 

Suitability/Capability 

1038. The Wasatch-Cache National Forest should determine suitable and capable 

acres in the final Forest Plan. 

1038.1 In compliance with Forest Service regulations and the National Forest 

Management Act requirements for defining suitability and capability 

1038.2 Per the Management Prescription Category 7.0 changes

 Response: While the determination of both range capability and suitability were 

done in the draft EIS, capable range has been revised based on new information and 

suitable range acres have been revised to address specific concerns raised in public 

comments. These changes can be found in FEIS Appendix B-9, and in Tables RN1 and RN-4 in FEIS, Chapter 3, Topic 7 – Rangeland Capability and Suitability. 

1039. The Wasatch-Cache National Forest should analyze the “economic 

consequences” and “alternative uses foregone” to determine range suitability. 

 Response: See response 1017. Additional information on “alternative uses 

foregone” and “economic consequences” has been added to the FEIS, Chapter 3, 

Topic – 7 Rangeland Capability and Suitability under the Direct and Indirect 

Effects by Alternative, Rangeland Suitability section. The financial efficiency 

analysis and budgetary impacts associated with grazing are displayed in FEIS 

Appendix B9, Table B9-2. 

1040. The Wasatch-Cache National Forest should prohibit grazing on lands 

deemed unsuitable. 

 Response: Within any give allotment there are both lands considered capable and 

not capable, and therefore suitable and unsuitable for livestock grazing. Because of 

the complex nature of landscapes and associated management of these areas within 

allotments, capable or not, may be grazed by livestock because controlling livestock 

movements to that level is not possible. The acres of non-capable rangelands (see 

Appendix B-9), however, are not included in the determination of livestock grazing 

capacity on the forest. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 246 

1041. The Wasatch-Cache National Forest should expand the lands deemed 

unsuitable for grazing to include the categories listed in the Rio Grande 

National Forest Landand Research Management Plan. 

Response: See response 1023. The Rio Grande National Forest was directed to 

reanalyze the suitability of their land base to support livestock grazing. Their new 

analysis used the newly developed Rocky Mountain Region Guidelines for 

Determining Grazing Suitability. We used the Intermountain Region direction that 

was available in June 2000 for assessing capability and suitability, but consulted 

with U.S. Forest Service, Rocky Mountain Region economists and adjusted our 

analysis to more closely follow the methods they recently used for the analysis for 

the Medicine Bow National Forest. 

Conditions and Trends 

1042. The Wasatch-Cache National Forest should implement target range 

conditions. 

1042.1 To ensure grass and browse for wildlife 

1042.2 To allow for quick recovery of rangeland when it is not in properly 

functioning condition

 Response: Desired conditions have been outlined for rangelands. A new grazing 

utilization guideline (30 percent vs. 50 percent for lands in satisfactory condition) 

has been added for rangelands in unsatisfactory condition to improve and move 

toward properly functioning conditions. 

1043. The Wasatch-Cache National Forest should maintain conditions and trends 

and not yield to the current emphasis on utilization rates. 

 Response: Utilization should not be confused with Desired Conditions. The 

forest follows the Society for Range Management (SRM) position on the use of 

forage utilization and residue measurements and uses utilization measurements with 

other monitoring information, to design and evaluate management decisions. We 

use the difference between desired and existing conditions and monitored trends to 

identify site-specific management needs to move toward desired conditions, which 

are described in the Forest Plan under “Desired Conditions – Biodiversity and 

Viability, Vegetation”. Utilization standards and guidelines, based on research, are 

used as a tool to maintain or reach desired conditions on the ground. We agree 

with the Society for Range Management (SRM) statement “Utilization and residue 

measurements are not management objectives. They are tools to be used with other 

information in evaluating whether desired resource conditions are being 

achieved” (SRM web page http://www.srm.org, last updated, February 2002). 

1044. The Wasatch-Cache National Forest should clarify whether it is using 

conditions and trends or utilization standards for grazing management. 

 Response: See response 1043. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 247 

1045. The Wasatch-Cache National Forest should conduct a trend analysis every 

three years. 

 Response: The Rangeland Health Amendment, which is incorporated into this 

revised Forest Plan, identified measuring frequency for any given long-term trend 

study as once every 5 years. Because detectable differences cannot adequately be 

measured on a more-frequent basis, we will continue with this measurement 

frequency. There will, however, be trend studies being done every year in order to 

achieve this frequency on all allotments. 

1046. The Wasatch-Cache National Forest should use the Logan Ranger District as 

an example of good grazing conditions. 

 Response: Example of good grazing conditions can be found across the forest. 

We have chosen to not focus on site-specific areas for this analysis. 

Properly Functioning Condition 

1047. The Wasatch-Cache National Forest should manage grazing to restore 

Properly Functioning Condition for riparian areas and watersheds. 

 Response: The purpose of our ground cover standards, utilization standards and 

newly created utilization guideline for rangelands in unsatisfactory condition is to 

maintain rangelands currently meeting or moving toward forest plan desired 

conditions. The purpose is also to move unsatisfactory condition rangelands (those 

not meeting or moving toward desired conditions) toward desired conditions, which 

are properly functioning conditions. 

1048. The Wasatch-Cache National Forest should report allotments that are not 

within Properly Functioning Condition in the Forest Plan with appropriate 

management actions to restore ecological function. 

 Response: See Response 1047. Regardless of where they occur, rangelands that 

are not properly functioning will benefit from the direction provided in the revised 

Forest Plan. 

1049. The Wasatch-Cache National Forest should restore rangelands to Properly 

Functioning Condition of watersheds, riparian areas, and lands in 

unsatisfactory condition. 

 Response: See response 1047. 

Restoration 

1050. The Wasatch-Cache National Forest should identify and restore areas 

damaged by grazing. 

 Response: Implementation of guidance outline in the Forest Plan (Desired Future 

Conditions, Goals, Objectives, Standards and Guidelines) will help restore 

rangelands in unsatisfactory condition. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 248 

1051. The Wasatch-Cache National Forest should require the restoration of all 

native woody plants in the Forest Plan. 

 Response: Standard 26 notes that no more than 50% of the current year’s growth 

on woody vegetation is to be browsed during one growth cycle. This was based on 

research that determined this to be a proper level of use. 

Monitoring and Enforcement 

1052. The Wasatch-Cache National Forest should monitor and enforce range 

quality standards and allotment management plans. 

1052.1 To protect ecological values 

1052.2 To ensure overgrazing does not occur 

1052.3 To justify grazing at or near current levels 

1052.4 To meet the requirements of the National Forest Management Act 

1052.5 To protect wildlife and forest health

 Response: As noted in Response 1050 above, the implementation of guidance 

outline in the Forest Plan will help restore rangelands in unsatisfactory condition. 

Doing this will protect and improve ecological values; will ensure overgrazing does 

not occur; will adjust grazing levels to those appropriate for conditions and 

capability of allotments; and will protect wildlife habitat and the health of the 

rangelands. We have met the requirements of the National Forest Management Act 

through this revision process. 

Infrastructure 

1053. The Wasatch-Cache National Forest should repair denuded allotments with 

fencing, enclosures, and prescribed fire. 

 Response: Various tools are allowed to manage allotments, including fences, 

enclosures, and prescribed fire. 

1054. The Wasatch-Cache National Forest should develop a better-managed 

fencing system. 

 Response: Fencing systems are more appropriately determined at the sitespecific scale, which is outside the scope of this revision process. 

1055. The Wasatch-Cache National Forest should set grazing fees sufficient to 

cover fencing for sensitive riparian areas. 

 Response: Grazing fees are set nationally and cannot be altered by the Forest. 

1056. The Wasatch-Cache National Forest should not fence areas such as Steel 

Creek Park because this park is a non-grass growing area and money would be 

better spent on other forms of forest maintenance. 

 Response: Site-specific proposals are not addressed in the FEIS or Forest Plan. 

1057. The Wasatch-Cache National Forest should not allow livestock to use the 

recreational infrastructure. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 249 

1057.1 With penalties for violation 

1057.2 To avoid user conflicts 

1057.3 Allotments and Permits 

1057.4 Allotments

 Response: Range suitability is addressed in FEIS, Chapter 3, Topic 7 – 

Rangeland Capability and Suitability and further described in FEIS Appendix B9. 

While livestock are not allowed in developed recreation areas, they are still allowed 

to graze within permitted allotment boundaries. Regardless of recreation uses, as 

long as rangelands continue to be in satisfactory conditions or are moving toward 

desired conditions, this is allowed to continue. 

1058. The Wasatch-Cache National Forest should reduce the number of grazing 

allotments available to protect resources. 

 Response: The number of open allotments has been reduced by 10, with the 

potential for additional closures if permits are voluntarily waived without 

preference. 

1059. The Wasatch-Cache National Forest should not reduce the number of 

grazing allotments available. 

 Response: Only vacant allotments are closed and only those that conflict with 

bighorn sheep health and habitat in the Uinta Mountains and municipal watersheds 

in Salt Lake and Davis Counties. Other allotments in the upper elevations of the 

Uinta Mountains would be closed only if permits were voluntarily waived without 

preference. All allotments and their status are identified in FEIS, Appendix I. 

1060. The Wasatch-Cache National Forest should close vacant grazing allotments 

in the High Uintas. 

 Response: See response 1059. 

1061. The Wasatch-Cache National Forest should modify the Forest Plan to 

indicate vacant allotments will remain vacant until an environmental analysis 

can be completed. 

 Response: See response 1059. 

1062. The Wasatch-Cache National Forest should allow voluntary/permanent 

allotment retirements. 

Response: See response 1059. 

1063. The Wasatch-Cache National Forest should measure the benefits of 

introducing non-native species, which threaten livestock grazing allotments 

against the economic impact of those introductions. 

 Response: Bighorn sheep were historically present in the Uinta Mountains. Only 

vacant allotments are closed on the eastern portion of the Forest. Bighorn sheep 

would not be used as a reason to close an allotment. Other allotments in the upper 

elevations of the Uinta Mountains would only be closed if permits in bighorn sheep 

habitat were voluntarily waived without preference. As such, no direct economic 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 250 

impacts would occur because of bighorn sheep. However, impacts to communities, 

either local or otherwise, may occur. It is difficult to predict whether or not any of 

these permits would be voluntarily waived during the planning period. And 

because a permit can be issued to anyone meeting the basic requirements, wherever 

they may live, impacts in any given community are unknown. 

1064. The Wasatch-Cache National Forest should review management allotment 

plans for the Bear Management Area and reduce livestock numbers. 

 Response: This site-specific analysis is outside the scope of this revision process. 

1065. The Wasatch-Cache National Forest should close the Gilbert Creek, Henry’s 

Fork, and Smith’s Fork allotments. 

 Response: The Gilbert Peak, Henry’s Fork-Hessie Lake, and Red Castle 

allotments would be closed if permits are waived without preference. Gilbert Creek 

and West Fork Smiths Fork allotments do not pose threats to bighorn sheep health 

and are not proposed for closure. 

1066. The Wasatch-Cache National Forest should phase out over 10 years the 

Gilbert Creek, Henry’s Fork, and Smith’s Fork allotments. 

1066.1 To protect the North Slope 

1066.2 To protect big horn sheep

 Response: See response 1065. 

Permits 

1067. The Final EIS should state the number of grazing permit holders on the 

forest to correct the misstatement that there are a “large number” of them. 

 Response: There are approximately 150 permit holders on the Forest. This 

number has replace “large number” in the FEIS under the social-economic section. 

Of these, approximately 52 grazing permits are on the north slope of the Uinta 

Mountains accounting for about 39 percent of all cattle grazed on the WasatchCache and about 40 percent of all sheep grazed. 

1068. The Wasatch-Cache National Forest should honor existing grazing leases but 

allow the leases to phase out. 

 Response: While not applied Forest wide, most allotments in the upper 

elevations of the Uinta Mountains will be closed if permits are voluntarily waived 

without preference. 

1069. The Wasatch-Cache National Forest should allow permittees to voluntarily 

waive grazing permits to protect wildlife and watershed values. 

 Response: Permits may be voluntarily waived without preference. Restocking 

all allotments other than those identified in the upper elevation of the Uinta 

Mountains, would be addressed on a site-specific basis because no overriding 

wildlife issues are present elsewhere on the Forest. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 251 

1070. The Wasatch-Cache National Forest should include an accountability clause 

in grazing permits with conditions for reductions if permit terms are not met. 

Response: The Term Grazing Permit (FSM 2230) provides the equivalent of an 

accountability clause. 

Subsidies 

1071. The Forest Service should not subsidize grazing because it harms the 

environment and livestock produced on public lands does not contribute 

significantly to America’s food supply. 

Response: As noted in response 1055, grazing fees are set nationally and cannot 

be altered by the Forest. 

Grazing 

Allow Grazing 

1072. The Wasatch-Cache National Forest should allow grazing. 

1072.1 With appropriate management to protect forest resources 

1072.2 For the benefit of forest resources

 Response: The forest continues to allow grazing, while providing direction that 

protects rangeland resources and moves unsatisfactory rangelands toward desired 

future conditions. 

1073. The Wasatch-Cache National Forest should allow grazing in roadless areas. 

 Response: An evaluation of each individual roadless area has been added to 

FEIS, Appendix C. Grazing has not been removed from any roadless area. 

1074. The Wasatch-Cache National Forest should allow grazing because it 

contributes to the economy. 

1074.1 For rural counties in Utah 

1074.2 For the ranching industry

 Response: Because only some vacant allotments are closed, the impacts to the 

existing economy will not be adversely affected. 

1075. The Wasatch-Cache National Forest should support grazing and allow 

managers to assess future conditions by selecting Alternatives 3 or 5. 

 Response: Only broad desired future conditions are identified at the Forest wide 

scale, and these do not vary by alternative. These should be refined at the sitespecific scale to identify those species that should occur and other characteristics 

that should be managed for. 

Do Not Allow/Restrict Grazing 

1076. The Wasatch-Cache National Forest should phase out grazing. 

1076.1 To return to properly functioning condition 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 252 

1076.2 To allow vegetation to be restored 

1076.3 To prevent economic, ecologic, and aesthetic impacts 

1076.4 To protect bighorn sheep

 Response: See responses 1068 and 1069. Our newly defined utilization 

guideline (G70) will help improve the rate at which these rangelands move toward 

desired condition. Regarding bighorn sheep habitat, see response 1063. 

1077. The Wasatch-Cache National Forest should eliminate grazing wherever 

necessary to protect at-risk plant communities. 

 Response: Grazing on the Wasatch-Cache National Forest has not been shown to 

negatively effect the rare plants that occur here. Most species that could be affected 

by grazing do not occur in grazing allotments. 

1078. The Wasatch-Cache National Forest should eliminate grazing in areas closed 

to motorized recreation. 

 Response: Livestock and vehicles each have different effects on wildlife and their 

habitats. Possible livestock/wildife conflicts are generally indirect. While livestock 

use of forage may occur on the same plant species that wildlife use, our stocking 

rates take wildlife needs into consideration. Motorized vehicle use can disrupt 

wildlife directly altering their distribution and ability to access their preferred 

habitat. 

1079. The Wasatch-Cache National Forest should restrict grazing. 

1079.1 Until condition and trend are verified 

1079.2 To protect water and aquatic resources 

1079.3 To preserve recreational experiences 

 Response: Our determination of range condition covers approximately 80 

percent of rangeland acres within allotments on the Forest. Of these acres, 

approximately 7 percent have conditions that have been verified, 93 percent 

estimated. As noted in Response to concern statement 1022, the Forest has followed 

accepted protocols in the assessment of range conditions, using both verified and 

estimated techniques. Because of the vast numbers of acres of rangelands in 

allotments across the Forest (98 allotments covering over 300,000 suitable 

rangeland acres), it is not possible to verify conditions annually on all allotments. 

The riparian class evaluation has been applied to all river and stream segments 

evaluated for wild and scenic river status and is included in Forest Plan Appendix 

XII. The most restrictive grazing standards and guidelines apply to those segments 

that have either Bonneville or Colorado cutthroat trout. Grazing has been 

eliminated in the Salt Lake and portions of the Davis County watersheds. Water 

quality for all those watersheds used for public drinking water supply do not exceed 

State water quality standards as a result of livestock use. Conflicts between 

livestock and recreational uses on the Forest are recognized and livestock use has 

only been eliminated from developed recreation areas. Because of wide ranging 

values for different uses on the Forest it is difficult to maintain one experience at 

the expense of another. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 253 

1080. The Wasatch-Cache National Forest should reduce grazing throughout the 

Forest. 

1080.1 By 25 percent 

1080.2 To reach biodiversity goals 

1080.3 To prevent topsoil erosion, ground terracing, and vegetation 

destruction 

1080.4 To restore streams for fishing 

 Response: Grazing numbers throughout the Forest are better determined through 

site-specific analyses of conditions, trends, and the relationship of rangelands to the 

desired conditions of those lands. The utilization standards and guidelines are 

based on research that maintains the health and reproductive capability of rangeland 

plant species. In addition, they are designed to help rangelands move toward 

desired conditions for plant and animal communities, prevent soil erosion and to 

maintain or improve riparian areas, including habitat for fish. 

1081. The Wasatch-Cache National Forest should not allow grazing levels to exceed 

regenerative capacity. 

 Response: See Response 1080. 

1082. The Wasatch-Cache National Forest should prohibit grazing. 

1082.1 To preserve ecological values 

1082.2 To reduce fire hazard 

1082.3 To prevent the spread of noxious weeds 

1082.4 To preserve scenic quality

 Response: Implementation of the grazing utilization standards and the guidelines 

added for rangelands in unsatisfactory condition, will help move these areas toward 

desired conditions. Grazing has been shown to reduce fire hazard in some 

rangelands, although those where cheatgrass dominates the understory remain high 

fire hazard areas because of the flashy nature of the associated fuels. On the 

Wasatch-Cache National Forest, it has been determined that most noxious weeds 

occur along highways, roads, and trails, indicating that noxious weed spread, while 

associated to some degree with livestock use, is more associated with human travel 

ways. There are areas of the forest where livestock grazing has affected the scenic 

quality. In general, these areas are also ecologically unsatisfactory and will be 

managed to move toward desired conditions. As these sites move toward desired 

ecological condition, visual qualities will improve as well. 

1083. The Wasatch-Cache National Forest should prohibit grazing because of its 

introduction of Tubifex, a host for the whirling disease parasite of trout

 Response: We recognize the importance of trying to reduce the spread of 

whirling disease on National Forest Lands. We also recognize the part the tubifex 

worm plays in the life cycle of this parasite that causes this disease. We realize that 

as habitat for the worm increases the potential for increasing the tubifex population 

increases. So far in Utah we have not seen major mortalities from whirling disease. 

We believe that as we implement the grazing standards and guidelines identified in 

the FEIS, the in-channel and riparian habitat will be maintained or improved thus 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 254 

reducing the habitat for the tubifex worm and the threat of whirling disease 

outbreaks. 

1084. The Wasatch-Cache National Forest should prohibit grazing in certain areas. 

1084.1 In the entire forest 

1084.2 In roadless areas 

1084.3 In wilderness areas 

1084.4 Near Wild and Scenic Rivers 

1084.5 In severely impacted riparian areas and stream banks 

1084.6 In watersheds and riparian areas 

1084.7 In areas with aspen and conifer stands 

1084.8 In Logan Canyon 

1084.9 In the North and Middle Forks of High Creek, Cottonwood and Blind 

Hollow, Spawn Creek, Bunchgrass Drainage, Steam Mill Canyon, and Steep 

Hollow, Smithfield Dry Canyon, Birch Canyon, and the T.W. Daniels Forest 

1084.10 Along the Mirror Lake Highway and the upper wetlands of the Provo, 

Duchesne, Weber, and Bear Rivers 

1084.11 In the western drainage of Mount Naomi Wilderness and south-facing 

drainage in Logan Canyon 

1084.12 On the east slopes of Mount Naomi Wilderness 

1084.13 In the Mid Bear River Range 

1084.14 South of Hardware Ranch 

 Response: Site-specific decisions to allow or not allow livestock grazing are 

outside the scope of this analysis. 

1085. The Wasatch-Cache National Forest should prevent overgrazing in 

watersheds by alternating grazing by location and year.

 Response: We encourage rotation systems, either rest rotation where entire 

pastures within allotments are rested each year, or deferred grazing where the order 

in which pastures within allotments are grazed is rotated from year to year. This, 

coupled with utilization standards and guidelines, will help move rangelands toward 

desired conditions. 

1086. The Wasatch-Cache National Forest should not allow motorized access for 

grazing purposes to protect wilderness areas. 

 Response: The 1984 Utah Wilderness Act 1984 states, “Grazing of livestock in 

wilderness areas established by this Act, where established prior to the date of the 

enactment of this Act, shall be administered with section 4(d)(4) of the Wilderness 

Act and section 108 of Public Law 96-560.” Forest Service Manual 2320 direction, 

under Exhibit 1, Congressional Grazing Guidelines, is consistent with this Act. The 

Manual states, “Where practical alternatives do not exist, maintenance or other 

activities may be accomplished through the occasional use of motorized 

equipment.” It goes on to describe the conditions and gives examples of 

appropriate uses of motorized vehicles in wilderness. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 255 

Topic 8: Special Designations 

Special Designations General 

1087. The Wasatch-Cache National Forest should designate more lands for 

protection. If the final decision allows more landscape impacts than the 

Preferred Alternative. 

 Response: The revised forest plan provides direction for assessing the possible 

addition of two Research Natural Areas; one near Ben Lomond Peak for its Tall 

Forb plant communities and one on the western portion of the Deseret Peak 

Wilderness for its Great Basin plant communities and the potential to study 

cryptogamic soil crusts. In addition, within the Tri-Canyons area east of Salt Lake 

County there is the potential for the identification and establishment of one Special 

Interest Area. 

1088. The Wasatch-Cache National Forest should continue to make special 

designations for Research Natural Areas and Wild and Scenic Rivers. With no 

consideration for political positions. 

 Response: The Forest can only recommend rivers for Wild and Scenic River 

designation. As with wilderness, Congress has the authority for designating Wild 

and Scenic Rivers. We have proposed additions to the existing Morris Creek 

Research Natural Area (RNA) and have proposed additional areas be investigated in 

the future for RNA status (see response to concern statement 1087). It is the value 

of these areas that are the primary consideration in their recommendations and 

establishment. 

Research Natural Areas 

1089. The Wasatch-Cache National Forest should identify in the Forest Plan 

potential areas that could contribute to diversity in the Research Natural Area 

system. 

 Response: See Response 1087. 

1090. The Wasatch-Cache National Forest should selectively expand Research 

Natural Areas. The Mollen’s Hollow Research Natural Area is one of these. 

 Response: The Mollen’s Hollow RNA boundary includes the best of the 

conditions that occur in that area as well as the most manageable boundary. As 

noted in the response to concern statement 1089 above, the Morris Creek RNA is 

proposed for expansion and is explained in more detail in the FEIS Chapter 3, Topic 

8 – Special Designations. 

1091. The Wasatch-Cache National Forest should designate additional Research 

Natural Areas. 

1091.1 To gain a better understanding of forest function 

1091.2 Temple Fork and Spawn Creek watersheds and Right Hand Fork of 

the Logan River watershed. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 256 

1091.3 Willow Creek Canyon east of Cowley Canyon and the small canyon by 

the SNC

 Response: Portions of Right Hand Fork and Logan Canyons have been identified 

as Special Interest Areas, rather than Research Natural Areas (RNAs), because 

some of the recreation and livestock grazing uses in these areas are incompatible 

with characteristics typically associated with RNAs. These areas do, however, 

provide many of the same research opportunities because of the near-pristine 

conditions and the high number of rare plant species in the area. Most of the areas 

mentioned do not meet the basic objectives for RNA establishment outlined in the 

Forest Service Manual 4060: 

4063.02 - Objectives. The objectives of establishing research natural areas are to: 

1. Preserve a wide spectrum of pristine representative areas that typify important 

forest, shrubland, grassland, alpine, aquatic, geological, and similar natural 

situations that have special or unique characteristics of scientific interest and 

importance that, in combination, form a national network of ecological areas for 

research, education, and maintenance of biological diversity. 

2. Preserve and maintain genetic diversity. 

3. Protect against serious environmental disruptions. 

4. Serve as reference areas for the study of succession. 

5. Provide onsite and extension educational activities. 

6. Serve as baseline areas for measuring long-term ecological changes. 

7. Serve as control areas for comparing results from manipulative research. 

8. Monitor effects of resource management techniques and practices. 

1092. The Wasatch-Cache National Forest should use the Red Butte Research 

Natural Area to study Properly Functioning Condition and Range of Natural 

Variability. 

 Response: The upper portion of the existing Red Butte RNA has been and 

continues to be a focus of much research because of its relatively undisturbed 

nature. The lower portion, because of its relatively high amount of introduced 

species is proposed as a Special Interest Area and will emphasize restoration 

ecology research and environmental education. 

1093. The Wasatch-Cache National Forest should not open the Red Butte Canyon 

Research Natural Area to tourism. 

 Response: While we propose to change the designation in the lower portion of 

Red Butte Canyon to that of a Special Interest Area (SIA), research will remain the 

highest purpose for this area. Because conditions in this portion of the RNA are 

less than natural, it was felt that this area could more appropriately be used for 

restoration ecology research. We also feel that existing trails in the area should be 

maintained and that environmental education should be an additional focus of this 

SIA. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 257 

Special Interest Areas 

1094. The Wasatch-Cache National Forest should designate a Special Interest Area 

in Logan Canyon to protect endemic cliff plants. 

 Response: An SIA is proposed in this area for this purpose as well as to focus on 

environmental education and protection of reference ecosystems. 

1095. The Wasatch-Cache National Forest should designate the lower part of the 

Red Butte Research Natural Area as a Special Interest Area to allow for 

restoration and education below the dam. 

 Response: See response 1093. 

Special Areas 

1096. The Wasatch-Cache National Forest should manage lands as Special Areas 

to prevent impacts that will be harder to reverse. 

 Response: Special Areas, Special Interest Areas, and Research Natural Areas are 

identified in areas where historic management and impacts from various activities 

have not had significant impacts. These designations are applied to maintain these 

relatively low disturbance conditions. 

1097. The Wasatch-Cache National Forest should consider forming additional 

Special Areas for botanical, geological, or archeological interests. 

 Response: While we have not identified additional Special Areas, we have 

identified new potential Special Interest Areas, which are noted in Chapter 3, Topic 

8 – Special Designations, of the FEIS. These areas were primarily focusing on 

biological/botanical purposes. Other geologic or archaeological areas, while not 

identified at this time, can be added through future amendments. 

Wild and Scenic Rivers 

1098. The Wasatch-Cache National Forest should involve the public in making 

wild, scenic, and recreational designations. 

 Response: In the future we need to do a suitability study on the rivers that were 

found to be eligible in 1999 for the National Wild and Scenic Rivers System 

(NWSRS). At that time the public will be given opportunities for input into the 

study process. However, the Wasatch-Cache does not designate these rivers in the 

NWSRS, that is the responsibility of Congress, which, of course, can be influenced 

by public sentiments and opinions. 

1099. The Wasatch-Cache National Forest should provide interim protection for 

eligible Wild and Scenic Rivers, by ensuring proposed activities are compatible 

with protection and designation.

 Response: Protection for rivers that are eligible as Wild and Scenic Rivers is 

provided in Appendix VIII in the revised Forest Plan, which includes a list of the 

eligible rivers. Appendix VIII has guidelines for protection of eligible wild, scenic, 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 258 

or recreational rivers from activities, which might be proposed that, could alter their 

free-flowing character or outstanding values. Protection is afforded until a 

suitability study is completed. If found suitable, eligible rivers would continue to 

be protected. If not found suitable, a river would no longer be eligible, and 

protection could not be provided under the Wild and Scenic Rivers Act. Identified 

river values and free flowing character could be protected under other authorities. 

1100. The Wasatch-Cache National Forest should consider that the description of 

the Standards for Recreational rivers structures is too broad and allows too 

many new developments and communities. 

 Response: The standards used for Wild, Scenic, and Recreational rivers are 

national standards taken from the Forest Service Handbook, 1909.12 Land and 

Resource Management Planning, Chapter 8, Wild and Scenic River Evaluation. As 

such the standards were developed at the national level. We chose to apply these 

national standards, as they are adequate to protect the existing conditions on the 

eligible streams to which they are applied. 

1101. The Wasatch-Cache National Forest should designate additional Wild and 

Scenic Rivers. 

1101.1 To protect aquatic habitats and their diversity. 

1101.2 Multiple rivers (38 rivers were listed in the comment.) 

1101.3 Logan River

 Response: The Forest Service does not “designate” Wild and Scenic Rivers. 

Congress usually does this. 

We protected aquatic habitats eligible for the NWSRS when they met the criteria 

established by the federal land management agencies in the State of Utah. 

A comment suggested that many additional rivers on the Wasatch-Cache should be 

examined for eligibility or were eligible for the NWSRS. In order to be included in 

the inventory, river segments had to meet certain criteria identified in the inventory 

process. The interdisciplinary team evaluated for eligibility those segments meeting 

the criteria for inclusion in the many river segments and some additional segments 

identified by Forest Service personnel and the public during the inventory process, 

and found eligible only those that met the statewide criteria. 

Much of the Logan River is receiving interim protection of its free flowing 

character and identified values as a recreational river. The standards in Appendix 

VIII of the revised Forest Plan itemize what that protection entails. The Logan 

River must go through a suitability analysis to see if maintaining its values and freeflowing condition are the most appropriate use of the river. Designation as a Wild 

and Scenic River could come after an act of Congress, and is outside the authority 

of the Forest Service. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 259 

1102. The Wasatch-Cache National Forest should not designate additional Wild 

and Scenic Rivers like Little Bear Creek. 

 Response: The Forest Service does not designate Wild and Scenic Rivers, but as 

part of the inventory process, can find rivers eligible and afford them interim 

protection until suitability is determined or Congress acts to designate the river. The 

Wasatch-Cache has field checked Little Bear Creek, and agrees with a comment 

which provided information contending that 1) the stream should neither have been 

classified as “wild” because of the presence of a motorized trail nor 2) were 

Bonneville cutthroat trout metapopulations present in the stream more than a mile 

above its confluence with the Logan River. For these reasons Little Bear Creek’s 

classification has changed to Scenic, and the length of the eligible segment length 

has changed from 4.5 miles to about 1 mile. 

1103. The Wasatch-Cache National Forest should ensure that operational patterns 

for Trial, Lost, and Washington Lakes are consistent with a “Recreational” 

designation. 

 Response: The concern suggests that a Recreational classification of a river below 

a dam may not be appropriate, as water flow regulation by a dam above the river 

segment (in this case the Upper Provo River) could affect the stream’s eligibility. 

The commenter had good insight in suggesting that flow regulation below a dam 

might affect eligibility, but the characteristic of the river in relation to the question 

is not its classification (i.e. Recreational, Scenic, or Wild), but whether its freeflowing character, and hence its eligibility, below the dam is precluded by the 

dam’s potential to modify free-flow. 

Congress and the Secretary of the Interior have designated many river segments that 

are above or below dams. Section 16 of the Wild and Scenic Rivers Act defines a 

“river” as “a body of water . . . or portion, section, or tributary thereof. . . “. “Freeflowing” is defined as “existing or flowing in natural condition without 

impoundment. . . “ Therefore, any section of river with flowing water meets the 

technical definition of free-flowing, even if impounded upstream. 

Topic 9: Oil and Gas Leasing 

Oil and Gas Leasing General 

1104. The Wasatch-Cache National Forest should indicate where oil and gas 

exploration and development are to be allowed. 

 Response: Management prescription 8 was mapped only for existing oil and gas 

areas of development (fields not single wells), not for areas of future exploration. 

Chapter 1 of the EIS discusses the fact that only the area of high potential for which 

there is no leasing decision is being addressed in the Forest plan revision. In 

Chapter 3, Topic 9 in the EIS further defined the leasing analysis completed and the 

area to be analyzed at this time. Leasing opportunities for each alternative are best 

represented in the set of 11 X 19 inch maps that was included in the map package. 

These maps showed the leasing stipulations to be applied. Management direction 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 260 

for future leasing exploration and development has been clarified in the Final 

Revised Plan. One part of the plan’s management direction are maps associated 

with the Western and Eastern Management Areas that show where future leasing is 

allowed and under what conditions. 

1105. The Forest Service should develop detailed standards for managing minerals, 

oil, and gas exploration/extraction to protect wildlife, water quality, and other 

surface resources. 

 Response: Oil and gas exploration and development is a staged decision making 

process. Determining availability and lease stipulations is the first step. The next 

step is when a specific application to drill is submitted for a specific location on the 

ground. It is at this step that specific conditions of approval and resource protection 

mitigation and monitoring requirements are applied. 

1106. The Wasatch-Cache National Forest should immediately begin to inspect oil 

and gas development sites to determine potential effects on surface and ground 

water. 

 Response: Annual inspection by Forest and Bureau of Land Management 

personnel is required. In addition the minerals administrator on the Mountain View 

Ranger District inspects sites frequently to assure compliance with requirements 

and regulations. 

1107. The Wasatch-Cache National Forest should ensure that oil and gas 

exploration sites are restored by making restoration a condition of the lease.

 Response: As explained in Chapter 3, Topic 9 and in Appendix G in the FEIS, oil 

and gas development is a staged decision process. As such, restoration of the site is 

addressed at the Application for Permit to Drill stage in the Surface Use Plan. 

Bonds are a requirement of development and are not released until oil companies 

have complied with all the requirements of reclamation. Not all sites are required to 

be restored to pre-development condition. Sometimes the decision is made to leave 

the roads in place for recreation access and use the well pads as trailheads sites. 

Adequacy of Analysis 

1108. The Wasatch-Cache National Forest should address oil and gas potential. 

1108. By providing analyses and maps showing oil/gas potential 

1108. By providing maps and text references on the Appeal Settlement Zone 

1108. By using more recent data on oil and gas resource potential 

 Response: We have expanded the discussion on oil and gas potential to include 

more recent information including the 1995 USGS National Assessment of Oil and 

Gas Resources. References to maps and information in this assessment can be 

retrieved from the USGS website and is referenced in the FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 261 

1109. The Draft EIS should provide further rationale for identification of a field in 

the area of North Flank Fault. 

 Response: Directional drilling has been completed by Union Pacific on their land 

in Summit County and has proven successful for them. There are many factors 

contributing to whether or not directional drilling can be used successfully on 

national forest terrain within the appeal settlement zone. However, because each 

situation is unique and must be evaluated and judged on its own merits, we think 

it’s reasonable to assume that no surface occupancy makes oil exploration and 

development more difficult for industry. 

 

After an exploratory well is drilled and successful, confirmation wells are needed to 

confirm the discovery and identify a field. Development of a field would then be 

proposed and analyzed. Each stage requires new analysis with public involvement. 

Each analysis would address consistency with the revised forest plan management 

direction including stipulations. 

The scope of the decision to be addressed in the revised forest plan was the area of 

high potential for which there is no leasing decision, referred to as the Appeal 

Settlement Zone. As explained in the cumulative effects section in the EIS, 

additional development in the Uinta Mountains outside the Appeal Settlement Zone 

is predicted and documented in the 1994 North Slope Oil and Gas Leasing Final 

Environmental Impact Statement. 

1110. The Wasatch-Cache National Forest should analyze the impacts of allocating 

land to oil and gas development to comply with the National Environmental 

Policy Act. 

 Response: We agree that by determining the availability of an area to leasing is 

an allocation decision and that there is potential to change an area from its current 

condition. However, while that does not mean every acre of every lease is going to 

be developed, there is still the potential. Because of the many variables involved 

with the petroleum industry’s decision to move forward, we have to portray effects 

based on some prediction of what seems to be a reasonably foreseeable 

development picture. That is why the leasing decision was a critical aspect of each 

alternative. The range of alternatives analyzes different levels of development. 

1111. The Wasatch-Cache National Forest should reexamine the financial risk of 

additional leasing in the Draft EIS to determine if the oil and gas industry will 

be at risk if leasing is not allowed. 

 Response: You are correct. The statement in the EIS reflected the situation with 

the current block of leases known at the Table Top unit. No, the entire oil and gas 

industry is not at risk if leasing is allowed. We have edited Topic 9 to be clearer on 

this point. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 262 

Allow Leasing 

1112. The Wasatch-Cache National Forest should allow oil and gas leasing in the 

Table Top Unit. 

 Response: Leasing is allowed in Alternatives 2, 3, 5, 6, and 7. In all alternatives 

existing leases are honored and their development is recognized in the effects 

disclosure. The range of alternatives addressed leasing scenarios that were very 

restrictive to the petroleum industry to those that allowed great opportunity for 

development. Alternative 7 tries to strike a balance in protecting some areas for 

future wilderness designation while allowing oil and gas development. Our 

reasoning to not issue leases after current ones expire is to not encumber future 

wilderness with outstanding rights. 

Do Not Allow/Restrict Leasing 

1113. The Wasatch-Cache National Forest should allow no oil and gas leasing in 

roadless areas. 

1113.1 To protect unique and vital habitat 

1113.2 To preserve roadless characteristics and values 

1113.3 In the Uintas 

1113.4 In the Appeal Settlement Zone 

1113.5 On the North Flank Fault 

1113.6 On the North Slope 

 Response: Alternative 1 which does not allow leasing within the Appeal 

Settlement Zone is most responsive to your concern. In Alternative 1 the ecosystem 

remains intact and unique habitat and roadless values are preserved. All the 

alternatives incorporate the 1994 Leasing decision for the North Slope of the Uinta 

Mountains, which does allow leasing on about 148,000 acres. 

Topic 10: Fire Management 

Fire Management General 

1114. The Wasatch-Cache National Forest should include the importance of fire in 

its new fire management plans 

 Response: Thank you for your comment. 

1115. The Wasatch-Cache National Forest should evaluate the feasibility of fire 

management in non-motorized, roadless, and wilderness areas 

1115.1 To protect habitat

 Response: We recognize that there may be increased costs to suppress fires in 

roadless or wilderness areas. We believe these costs will be far off set as some fires 

are allowed to burn in these backcountry areas with minimal staffing. It is 

important to realize that wildland fires that are allowed to burn are still managed 

within identified prescriptions or conditions to prevent major impacts to fish, birds, 

animal, soil and watershed resources. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 263 

See also the Fire Management direction in the Forest Service Manual and the 

Desired Future Condition, Forest-wide goals, subgoals, standards and guidelines of 

the Forest Plan. Fire management direction is also found in the Wasatch-Cache and 

Uinta Forests’ Fire Management Plan. 

1115.2 To manage small roadless areas 

 Response: Prescribed and wildland fires can be smaller than 5,000 acres in size 

and prescriptions can be set up for these smaller areas. If fire burn outside of their 

prescription the fire is reclassified as a wild fire and is suppressed. In areas where 

wild fires are not allowed and no thinning or timber harvest can take place there are 

a number of other treatments that can be used to change vegetation into an earlier 

successional stage and may include some type of mechanical treatment. We also 

recognize the fact that not all areas can or should be treated at once. In some cases 

areas may never be treated. Vegetation succession then continues on to a later stage 

of succession until a natural event alters this condition be it fire or a bug infestation 

for example. The vegetation is then changed to an earlier stage of succession. 

1115.3 To meet desired landscape goals 

 Response: Thank you for your comment. See response to 1115.1 

1115.4 To protect watersheds 

 Response: We recognize the need to be careful the municipal watersheds on the 

forest. Mechanical treatments can include the use of animals, equipment and/or 

people with hand tools. See also response to 1115.1 

1116. The Wasatch-Cache National Forest should develop a new fire plan for 

remote roadless and wilderness areas. 

 Response: Thank you for your comment. We are trying to make significant 

changes in this area with wildland fire use plans. You will notice in the FEIS that 

most prescriptions allow for wildland fire use. Additional direction for this area is 

in the Wasatch-Cache and Uinta National Forests’ Fire Management Plan. 

1117. The Wasatch-Cache National Forest should coordinate vegetation 

information with prescribed fire objectives to evaluate how threatened and 

endangered plant species respond to fire. 

 Response: See the Fire Management direction in the Implementation direction of 

the Forest Plan. A person trained in botany or plant ecology is part of the expertise 

required for biological evaluations. 

1118. The Wasatch-Cache National Forest should replace the word “historic” with 

“natural” in the desired condition for fire management because of historic fire 

suppression efforts. 

 Response: Thank you for your comment. Historical refers to the last 500 years. 

This has been added to the sentence. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 264 

1119. The Wasatch-Cache National Forest should be forthright in stating its 

objectives in priority treatments. 

 Response: Thank you for your comment. The intent is to restore aspen 

communities. Timber harvest may be one tool to accomplish this in an economical 

manner. 

Adequacy of Analysis 

1120. The Wasatch-Cache National Forest should explain what it means to “take 

timely actions to restore proper functioning of ecosystem after wildfire.” 

Response: This refers to the process of assigning an interdisciplinary team (soil 

scientist, hydrologist, ecologist) to evaluate the situation immediately and make 

recommendations on actions such as erosion control and seeding to prevent loss of 

soil productivity, sedimentation of streams, and invasions of noxious weeds. 

 

1121. The Wasatch-Cache National Forest should correct contradictory statements 

regarding fire suppression and insect activity levels 

Response: The first statement refers to the potential for extensive insect caused 

mortality, while the second statement refers to the current state of mountain pine 

beetle activity. The existing forests are comprised primarily of older age classes of 

trees growing at high densities, conditions that predispose them to widespread 

insect caused mortality. Currently mountain pine beetle activity is at endemic 

levels, with pockets of insect mortality occurring in several locations, but not 

covering extensive areas of the landscape. However, the stand conditions that 

facilitate the spread of the insects and favor increasing insect populations still exist. 

If insect populations were to increase rapidly in response to environmental factors 

such as drought, the existing stand conditions increase the potential for the outbreak 

to reach epidemic levels, similar to what occurred on the North Slope in the early 

1980s. 

Legal Considerations 

1122. The Wasatch-Cache National Forest should support exceptions to the Clean 

Air Act to restore forests to healthy conditions 

 Response: Thank you for your comment. We recognize that this will be a 

challenge and some exceptions are made, within the Act, to carry out these types of 

activities. 

Education 

1123. The Wasatch-Cache National Forest should educate the public and property 

owners about what they can do to protect their property from fire in order to 

accomplish fuel reduction. 

 Response: Thank you for your comment. This is currently being started. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 265 

Fuels Management 

Fuel Treatments 

1124. The Wasatch-Cache National Forest should create a long-term strategy for 

prescribed fires, wildland fire use, and mechanical treatments to alleviate 

threatened and endangered species concerns. 

 Response: See the objectives for vegetation management and urban interface fuels 

management. This would be part of the plan to be developed. 

1125. The Wasatch-Cache National Forest should carefully plan the prescribed 

sagebrush treatments to benefit sage grouse. 

 Response: This will be taken into consideration when treatments are done in 

sagebrush. We have a copy of the document and will be incorporation the 

appropriate information in site-specific NEPA documents for the treatments. 

1126. The Wasatch-Cache National Forest should more fully utilize timber harvest 

and grazing in conjunction with prescribed burns 

1126.1 To avoid wasting resources

 Response: Thanks for your comment. 

1126.2 To maintain a healthy forest 

 Response: We recognize that wild fires need to be suppressed. This is addressed 

in the Wasatch-Cache and Uinta National Forests’ Fire Management Plan. We also 

recognize the role fire plays in the ecosystems and that we will be unable to either 

harvest or graze sufficient areas of land large enough to maintain healthy 

ecosystems through the use of these two tools alone. 

1126.3 To avert fire risk 

 Response: Thanks for your comment. See response to response 1126.2. See also 

the Forest Wild Activities and Project Outputs for timber and range livestock 

outputs. We also believe that prescribe fire is a valuable tool to be used in restoring 

healthy ecosystems. 

1126.4 To bring the forest back into historic range of variability 

 Response: Thank you for your comment. We recognize the need for public 

information and maintaining prescribed fires, especially in urban interface zones, 

within prescription. See the objective for urban interface fuels management in the 

Plan. 

1126.5 To maintain the viability of local economies 

 Response: We recognize the opportunity that exists to provide forest products and 

the benefits that comes to local communities. However, our primary responsibility 

is to provide for the sustainability of the land. A greater discussion can be found in 

the plan under ecosystem management framework and the forest plan model and the 

Forest Service Natural Resouce Agenda for the 21st Century. It’s important to 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 266 

recognize that not all National Forest lands on the Wasatch-Cache National Forest 

are available for timber harvest. Based on information presented in Table 3, under 

land classification, of the Forest Plan, only 2.5% is identified as totally suitable 

forest lands for timber harvest. This is not to say that timber harvest cannot occur 

in other prescriptions than those identified as Management Prescriptions 5.2/6.2. It 

is recognized that timber harvest may occur on lands not mapped with prescription 

categories 5-2/6-2. The objectives in these other prescriptions are not timber 

production See FEIS Table TM-2. This increased the acres available for timber 

harvest is 202,000 acres or 16% of the forest. Harvest from this area is identified 

and accounted for in the plan. Also see the discussion for response to Issue 4 in the 

Forest Plan. 

1127. The Wasatch-Cache National Forest should utilize prescribed burns or 

selected removal of fuels instead of full harvesting to better mimic natural 

processes. 

 Response: Thank you for your comment. See Revision Topic 7 suitable 

timberlands. 

1128. The Wasatch-Cache National Forest should reevaluate timber harvesting 

and mechanical treatments as means to meet forest goals 

1128.1 Because of their inability to restore fire-adapted ecosystems 

Response: The Revised Forest Plan developed from the selected FEIS Alternative 

7 provides for a combination of approaches to restore fire-adapted ecosystems. 

These include timber harvest, mechanical treatments, prescribed fire and wildland 

fire use. The treatment applied to a particular stand will depend upon a site-specific 

analysis that incorporates management objectives, potential outputs and 

consideration of other resources. The majority of acres to be treated are with 

prescribed fire except in the wildland urban interface where human safety and needs 

for protecting structures such as homes require a mechanical treatment approach. 

1128.2 Because of the role of standing dead timber in forest wild fires 

Response: The Revised Forest Plan provides direction in the form of standards and 

guidelines to ensure that the functions of standing dead timber continue to be 

provided for after any kind of timber harvest or mechanical treatment. 

1128.3 Because mature trees are needed for wildlife habitat 

Response: The Revised Forest Plan provides direction in the form of standards and 

guidelines to ensure that the functions of mature trees for wildlife continue to be 

provided for after any kind of timber harvest or mechanical treatment. 

1128.4 Because young trees have high fuel load values 

Response: See response 1128.1. 

1128.5 Because timber harvesting cannot replace the role of fire in the forest 

Response: See response 1128.1. 
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Wasatch-Cache National Forest A - 267 

1128.6 Because harvested areas show a strong association with increased rate 

of spread and flame length

Response: See response 1128.1. 

Prescribed Burns 

1129. The Wasatch-Cache National Forest should not rely on prescribed burns for 

fire management 

1129.1 Because they do not prevent high-severity fires

 Response: Thanks for your comment. 

1129.2 Because they are not adequate to meet forest goals 

 Response: After reevaluating these projects the number of acres identified over a 

10 year period have been dropped to 37,000 or 3,700 per year. See table 2-2 in the 

FEIS. prescribed fire 

1130. The Wasatch-Cache National Forest should utilize prescribed burns to 

maintain bio-integrity 

 Response: Thank you for your comment. 

Fire Suppression 

1131. The Wasatch-Cache National Forest should view burned areas as a natural 

process and allow fires to burn within Historic Range of Variability. 

 Response: Fire and its affects are recognized as a natural process although the 

casual visitor may not see it as an esthetic or scenic character on the landscape. 

Wildland fire use is managed within prescriptions as identified by a fire 

management plan. These site specific plans identify when and where such use is 

appropriate. To define it in the Plan is premature.See the discussion in the analysis 

in the FEIS on the effects on scenic resources from fire, insects and disease. 

1132. The Wasatch-Cache National Forest should not make fire suppression the 

default course of action for areas not having a fire management plan. 

 Response: Wildland fire use requires pre-stated resource management objectives 

over predefined geographic areas. To allow a fire to burn without such objectives 

and a defined area would be inappropriate and not keeping with national direction. 

Heritage Resources 

1133. The Wasatch-Cache National Forest should modify current land management 

practices to protect western culture and heritage. 

 Response: The Revised Forest Plan includes goals and standards and guidelines 

that address protection of heritage resources. 
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Wasatch-Cache National Forest A - 268 

Locatable and Salable Minerals 

Locatable and Salable Minerals General 

1134. The Wasatch-Cache National Forest should include discussions on 

recreational fossil collecting in the Forest Plan. 

 Response: Recreational fossil collecting is briefly discussed in the Paleontology 

portion of the Locatable and Salable Minerals section of the EIS. While there are 

occurrences of some kinds of fossils in some areas that may attract recreational 

collecting interest, compared with other recreational activities, this use is rather 

limited and it has not by itself specifically been identified as a revision topic. 

Recreational fossil collecting is one of many recreational pursuits which are 

addressed through the management direction for recreation and access. As noted in 

the EIS, casual collecting of invertebrate fossils does not require any special 

authorization. 

1135. The Wasatch-Cache National Forest should add objectives for mineral and 

energy exploration and development to create better geologic maps, make 

inventories of the paleontological or mineral and energy resources, and 

regularly reassess the existing information on these geologic resources. 

 Response: Our objectives focus our efforts on areas where the need to correct 

resource conditions or meet user demands are greatest. 

The TERRA component of the NRIS database (the Forest Service’s National 

Resource Information System) is gathering basic geologic data and will eventually 

be integrated into GIS layers amenable to display with other GIS layers. That will 

be updated, as geologic data are available. 

The Wasatch-Cache experiences limited demand from mining claimants and few 

locatable mineral proposals. Commercial sources of salable material are available 

off-forest and sources on the forest are not in demand. Because of these factors we 

do not see a need for inventories of mineral resources. Where the petroleum 

industry has expressed interest in leasable minerals (primarily oil and gas), we have 

addressed that in Topic 9. 

1136. The Wasatch-Cache National Forest should add a discussion of the 

management direction for geologic, paleontologic, and mineral resources to the 

Forest Plan including a discussion of where energy and mineral development 

activites are, and are not, allowed under the proposed plan. 

 Response: We have included management direction for these resources where we 

view a there is a need. In many cases current policy and existing law provides 

adequate direction. In the case of locatable minerals, management will be consistent 

with the 1872 Mining law, as amended which governs the disposal of those 

minerals. We also believe no additional direction is required because of the existing 

law and regulation for salable minerals under the Materials Act of 1947, as 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 269 

amended. Management direction for paleontologic resources is found in Forest 

Service Manual 2680.3, which we believe is appropriate level needed. 

In the absence of broad public interest or interest from the scientific community, we 

have generally chosen not to provide management direction regarding management 

of geologic resources. We have added specific direction for cave management in the 

forestwide standards and guidelines. In the future if a significant need is expressed 

relative to a particular resource, we will address that through Forest Plan 

amendments. 

We have included management direction for oil and gas resources. For the areas of 

high potential for petroleum reserves on the Forest, we have added direction about 

leasing compatibility. 

1137. The Wasatch-Cache National Forest should combine the discussions on 

geological, mineral, and paleontological resources into a single topic in the 

Final EIS. 

 Response: While there is no right or wrong way to organize subject areas, we 

chose to organize our EIS by Planning Topic. 

1138. The Wasatch-Cache National Forest should include maps depicting all 

currently active quarries/sand and gravel pits in the Final EIS. 

 Response: All of the quarries sand and gravel pits on the Forest are used for 

internal Forest Service purposes only. There are no commercial operations. As 

such, we do not believe a map such as you one you request is necessary. Since 

commercial sources of salable material are available off-forest, there has not been a 

demand expressed by private operators. Should this situation change significantly, 

we’ll address the need at that time. 

Adequacy of Analysis 

1139. The Final EIS should include a discussion of the effects of oil pits on wildlife 

mortality. 

 Response: See Response 362. 

1140. The Wasatch-Cache National Forest should clarify whether acreage figures 

cited in the effects of oil and gas leasing on wildlife section are due to direct or 

indirect effects. 

 Response: They are direct effects. This has been clarified in the text. 

Mineral Extraction 

1141. The Wasatch-Cache National Forest should restore areas with mining 

damage. 

141.1 To protect watershed health 

141.2 To restore the scenic value of Little Cottonwood Canyon 
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Wasatch-Cache National Forest A - 270 

 Response: Since the mid-1980’s, the Forest has been an active partner with the 

Utah Division of Oil Gas and Mining in inventorying and closing mine openings 

deemed to present an immediate hazard to the public. An ancillary effect of that is 

to restore a measure of scenic value in the canyons. It is important to note 

restoration of mines located on private lands is outside of Forest Service authority. 

We agree that there are some harmful remaining effects to water quality from the 

mining in the 1800’s. Since 1998, the Forest has been a participant in the Little 

Cottonwood Group. This group is assessing the effect of mining on Little 

Cottonwood Creek by collecting field data on water quality, stream morphology 

and aquatic health. An assessment is being reviewed by the Environmental 

Protection Agency. 

1142. The Wasatch-Cache National Forest should continue to allow recreational 

mining because it is not harmful. 

 Response: As explained in the EIS, there are three stream segments open to 

recreational dredging, sluicing and panning under a cooperative USFS/BLNM/State 

permit. This use will continue in the revised forest plan. Other mining related 

activity is allowed on lands open to operations under the 1872 Mining Law, 

whether it be ‘recreational’ or not. We will manage those activities under Forest 

Service mining regulations when disturbance is significant. 

Social and Economic Analysis 

Social and Economic Analysis General 

1143. The Wasatch-Cache National Forest should prepare an adequate 

socioeconomic analysis. 

1143.1 By including costs associated with different management activities in 

the social economic assessment. 

Response: The economic analysis of alternatives was completed according to 

federal regulations and Forest Service requirements. The FEIS includes economic 

analyses from both a regional and a national accounting stance. The regional 

accounting stance is used for social and economic impact analysis to local 

communities and counties. This includes changes to employment and labor income. 

The national accounting stance is used for the consideration of benefits and coats to 

all of society. The economic PNV analysis includes market prices for timber, 

range, and mineral outputs and non-market price estimates for outdoor recreation. 

This analysis is explained in the social and economic analysis in chapter 4 of the 

FEIS and in further detail in Appendix B. 

Aside from the economic analysis, regional and national issues, values, and 

concerns were considered throughout the planning process. Comments from all 

interested people were used to develop alternatives and issues. Economic modeling 

considers impacts to local communities, but use of forest resources includes use 

from locals and visitors. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 271 

1143.2 By including an analysis of the receipts and expenditures of the Fee 

Demo program in the social economic assessment. 

Response: The Fee Demo program, while enjoying some success both locally and 

nationally is not a decision that is made in the forest plan, and consequently not a 

required or appropriate disclosure in forest planning. Periodic reports on Fee Demo 

receipts are developed internally, and these and programs are available from the 

Wasatch-Cache if requested. 

1143.3 By analyzing the social and economic impacts on all forest users, not 

just local communities. 

Response: See response 1143.1. 

 

1143.4 By including the results of the Utah State University study “An 

Economic and Social Assessment of Snowmobiling in Utah” 

Response: Thank you for your comment, while the draft report had been used in 

the DEIS analysis, and the final report has been used in FEIS economic analysis. 

Social Values 

Population Growth 

1144. The Wasatch-Cache National Forest should factor projected population 

growth into management plans. 

1144.1 By identifying the combined impacts of all users instead of viewing 

them separately. 

1144.2 By acknowledging that population growth will result in restrictions on 

traditional experiences. 

Responses: The Forest Service alone cannot control growth. The Forest Service, 

state and local governments, non-profits organizations, businesses, and individuals 

all share the burden of planning for the future together. Even then, market forces, 

international events, and demographic pressures in and outside of the analysis area 

are beyond the control of any and all parties. 

Growth of the Wasatch Front was identified and considered within the social and 

economic section of the FEIS, recreational growth and trends in use on the forest 

are presented in the recreation section of the FEIS. Cumulative effects of 

alternatives are presented in all resource sections and consider larger use trends 

surrounding the Forest. 

Development 

1145. The Wasatch-Cache National Forest should not have a goal to “encourage 

private enterprise to develop recreational facilities on and off the forest”, 

because this land belongs to the public.

 Response: Given increasingly higher demands for outdoor recreation, and the 

associated high cost of responding to these demands, federal funding alone is not 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 272 

sufficient to sustain resource values while continuing to meet a good part of that 

demand in a responsible manner. Reducing costs to the American taxpayer and 

stimulating responsible local governments and the private sector has been, and will 

continue to be a national strategy for dealing with the issues of high recreation user 

demand, high costs, and concern for the continuity of forest settings. 

 

1146. The Wasatch-Cache National Forest should allow extensive commercial 

development on the Park City side of the range, and little or no additional 

commercial development of the Wasatch Front and its canyons. 

 Response: In Alternative 3 some additional area for expansion of ski areas is 

provided on the east slopes of the Salt Lake District. This alternative also allows 

for some expansion of ski areas in canyons on the Wasatch Front side. Other 

alternatives do not allow for additional ski area expansions. 

 

1147. The Wasatch-Cache National Forest should prohibit development for 

environmental reasons. 

1147.1 To protect wildlife habitat and winter range 

1147.2 To protect watersheds 

Responses: In all alternatives wildlife habitat, winter range, and watershed 

protection are protected to varying degrees. The acreage available for development 

is minor in any alternative compared to what is protected, and certainly proposals 

for development would only apply to a very small percentage of lands. Any project 

planning would consider a range of mitigation treatments in alternatives where 

proposals for development are possible. 

 

1148. The Wasatch-Cache National Forest should prohibit development for social 

reasons. 

1148.1 To preserve wilderness characteristics that provide an escape from an 

urban environment 

1148.2 To preserve natural environments for the future 

1148.3 To avoid bringing more users into the forests 

1148.4 Until a carrying capacity study has been conducted 

Responses: A broad range of on-forest social settings are arrayed across the forest 

through the alternatives presented in the FEIS. Wasatch-Cache forest leadership 

recognizes the concerns of many in our population who feel that additional 

recreation use and impacts cannot be sustained. 

1149. The Wasatch-Cache National Forest should prohibit development in certain 

areas. 

1149.1 In roadless areas 

1149.2 In the canyons 

1149.3 In the Tri-Canyon area 

1149.4 In Taylor Canyon and Wheeler Creek 

1149.5 On the west side of Mount Ogden

Responses: The range of alternatives presented in the FEIS provide management 

prescriptions which either allow or do not allow a range of recreation development, 
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Wasatch-Cache National Forest A - 273 

vegetation treatments, and trail and road building on the forest. A range of possible 

development or protection prescriptions are applied to each of these areas. 

 

1150. The Wasatch-Cache National Forest should prohibit commercial or 

amusement type development in the canyons because these services can be 

provided by cities within close proximity. 

 Response: The Forest Service recognizes that some activities and developments 

are more appropriately and traditionally provided for on private lands than on 

National Forests. National, community, and individual values obviously vary on 

where to draw the line on these questions. Management prescriptions, scenery 

management, and recreation opportunity spectrum guidelines help frame what is 

allowable. Specific proposals will be compared to forest plan direction when they 

are presented, as well as to local site conditions, community needs, potential 

mitigation, and other manual and handbook direction. 

1151. The Wasatch-Cache National Forest should discourage unsightly 

development. 

 Response: Scenery Management System (SMS) guidelines presented in Chapter 4 

of the revised Forest Plan give direction for project proposals so that desirable 

developed and natural scenic settings are provided. 

Economic Values 

Economic Values General 

 

1152. The Wasatch-Cache National Forest should give economic considerations the 

lowest possible priority. 

 Response: Economics is one of the many criteria considered in the decision 

making process. The level of importance economic values plays will depend upon 

issues and concerns of the public and the information desired by the decision 

maker. 

1153. The Wasatch-Cache National Forest should not preserve wild country for the 

short-term desires of a few. 

 Response: Forest Plans are a balance between the many competing uses of 

national resources. The alternative selected will be a mix of preservation and 

resource uses with both short term and long term goals for resource conditions. 

Adequacy of Analysis 

1154. The Wasatch-Cache National Forest should strengthen its economic analysis. 

1154.1 By separating different industries and communities 

1154.2 By using more recent data 

1154.3 By disclosing the real socio-economic impacts of the various alternatives 

1154.4 By including information about the economic benefits of healthy forests 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 274 

1154.5 By analyzing the economic benefits to local communities from 

motorized recreation 

1154.6 By providing documentation to support its claim that backcountry 

areas are less expensive and more economically efficient to manage than 

designated wilderness 

1154.7 By using the travel cost method and contingent valuation method to 

show a similarity of possible economic and social valuations associated with 

preserving the Wasatch-Cache mountain ecosystem 

1154.8 By including information about externalized costs passed on to 

communities, businesses, and individuals when national forests are developed 

Response: Improvements have been made to the social and economic analysis in 

the FEIS to show individual industries and update to the most recent data available. 

It is difficult to always portray the economic data desired due to limited data 

sources and non-disclosure laws. There is generally a two-year lag with economic 

data between when it was collected and released for use. In terms of recreation use 

and expenditure data, it is often non-existent, available only at large scales (statewide), or based on assumptions that do not match with Forest Service management 

or priorities. 

Often an individual feels the greatest impact of an alternative or change in Forest 

Service management and such impacts are difficult to summarize at the large scale 

of a Forest Plan. The FEIS has been edited to show greater sensitivity between 

alternatives, but in many cases, there may be little difference. It is important to 

review the resource sections of the FEIS for more resource specific information 

concerning each area and alternative as well as the social and economic analysis. 

The value of healthy forests can be found in summary tables of anticipated, 

measurable outcomes and activities by alternative in Chapter 2. Detailed 

discussions of each outcome can be found in the corresponding sections of Chapter 

3 and 4. A balancing of all economic and non-economic outputs is best found in the 

Record of Decision. In that document, the Regional Forester discloses his 

consideration of outputs and outcomes that are monetarily valued (in the economic 

efficiency analysis) with others that do not have or cannot be monetarily valued. 

With regard to 1154.6, the commenter inferred that the Forest Service had 

suggested that Wilderness management was more expensive than backcountry 

management for the Lakes roadless area, and that the Forest Service has an 

unfounded bias against Wilderness, that can in part be shown through unfounded 

perceptions that Wilderness management is comparatively expensive. We have 

reread of this section of the Need section of Appendix C (DEIS) or C-1 (FEIS) for 

Lakes. The statement does not unequivocally state that managing backcountry is 

cheaper than managing Wilderness. What the sentence states is, “This type of 

management” (meaning backcountry, not Wilderness) “could allow for more cost 

effective mitigation of human impacts...” The intent of the statement was not to 

assert a hard fact derived from an analysis of the cost differences of wilderness vs 

backcountry management, rather a simple suggestion that this might be the case. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 275 

Cost of management is not a compelling factor choosing between alternatives in 

this forest plan revision. The economic analysis of alternatives does keep constant 

budgets as an assumption across all alternatives. 

The travel-cost method is one method to gather recreation expenditure data; the 

economic analysis used information readily available through Forest Service 

research to estimate recreation and tourism impacts to local communities. This 

analysis included motorized use, both OHV and snowmachines. For more 

information, see appendix B-11. 

Externalities are not required to be included in the economic analysis: 36 CFR 

219.12(g)3(i) directs that costs “of the agency and all other public and private costs 

required to manage the forest up to the point where the outputs are valued and the 

environmental consequences are realized” be included in the estimated effects of 

alternatives (emphasis added). Agency costs have been include in the FEIS 

Financial and Economic Efficiency analysis. Where there are significant private 

costs necessary to provide the valued outputs, they have been estimated and 

explicitly included in the efficiency analysis. 

1155. The Wasatch-Cache National Forest should strengthen its cost/benefits 

analysis. 

1155.1 By providing a full accounting of benefits and costs, including “nonuse” 

benefits 

1155.2 By comparing the management of roadless areas as wilderness versus 

the proposed management 

 Response: The Implementing regulations of NEPA expressly avoids a cost-benefit 

analysis as being a necessary basis for decisions: ‘For purposes of complying with 

the Act, the weighing of the merits and drawbacks of the various alternatives need 

not be displayed in a monetary cost-benefit analysis and should not be when there 

are important qualitative considerations.’ (40 CFR 1502.23) A cost-benefit 

analysis, however, may be conducted if desired or required by other laws, 

regulations, or directives. Economic impacts, however, are a concern of NEPA, but 

only where such issues have been identified during scoping. The economic section 

of the FEIS includes PNV and distribution analyses as required. 

Non-use benefits: Summary tables of anticipated, measurable outcomes and 

activities by alternative can be found in Chapter 2. Detailed discussions of each 

outcome can be found in the corresponding sections of Chapter 3 and 4. A 

balancing of all economic and non-economic outputs is best found in the Record of 

Decision. In that document, the Regional Forester discloses his consideration of 

outputs and outcomes that are monetarily valued (in the economic efficiency 

analysis) with others that do not have or cannot be monetarily valued. 

Even Wilderness areas require budget for management, and none of the alternatives 

designate the entire Forest or all roadless areas as Wilderness so a budget will still 

be needed outside of Wilderness for management and forest stewardship projects. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 276 

1156. The Wasatch-Cache National Forest should provide an accounting of costs 

associated with various activities. 

1156.1 Timber harvest 

1156.2 Grazing

 Response: The costs and benefits of resource uses of the national forest are 

highlighted in the FEIS in resource sections as well as within the social and 

economic section. 

1157. The Wasatch-Cache National Forest should revise or eliminate the net public 

benefits discussion. 

1157.1 Because the 50-year time frame is meaningless 

1157.2 Because it is based on faulty assumptions

 Response: A PNV analysis is required by the National Forest Management Act 

(36 CFR 219) the FEIS analysis has been clarified. 

1158. The Wasatch-Cache National Forest should establish accurate benchmarks 

for the net public benefits analysis. 

 Response: Benchmarks required by 39 CFR 219.12 (e) (1) were determined 

during the development of the 1985 Forest Plan, and were specified in the Chapter 

II, sections D, E, and F in the FEIS of November 2, 1984, and are summarized in 

the Preliminary Analysis of the Management Situation (April 1999). Our analysis 

in this forest plan revision has not recalculated those original benchmarks in 

revising the forest plan. Benchmarks, being minimum level of forest management 

to maintain the Forest and maximum production potential of significant goods and 

services (including associated monetary estimates of values) within which 

alternatives must be constructed are extremes. These extreme output levels are not 

approached or exceeded in the alternatives analyzed in the FEIS. 

1159. The Wasatch-Cache National Forest should establish an analytical process to

demonstrate that the final Forest Plan will maximize net public benefits.

 Response: RPA/NFMA and implementing regulations outline the economic 

analysis and criterion requirement for forest planning, the commenters 

misunderstand the ‘net public benefits’ analytical framework prescribed by 36 CFR 

219. ‘Net public benefits’ is not a benefit-cost analysis given a comprehensive 

economic efficiency framework – one that incorporates a monetary expression of all 

known market and non-market benefits and costs. Such an analysis is generally 

used when economic efficiency is the sole or primary criterion upon which a 

decision is made. The Forest Service does not endorse or expect this use of 

economic efficiency analysis in projects, programs, or other analyses. The agency 

recognizes that many of the values associated with natural resource management are 

best handled apart from, but in conjunction with, a more limited benefit-cost 

framework. This concept is expressed in NFMA regulations [36 CFR 219] and is 

referred as ‘cost-efficiency.’ When discussing the evaluation of Forest Plan 

alternatives, the regulations state that the evaluation ‘shall compare present net 

value, social and economic impacts, outputs of goods and services, and overall 

protection and enhancement of environmental resources’ [36 CFR 219.12(h)]. It is 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 277 

this process that results in a Forest Plan that ‘maximizes long term net public 

benefits in a environmentally sound manner’ [36 CFR 219.1]. 

The NFMA regulations define net public benefits as: ‘An expression used to signify 

the overall long-term value to the nation of all outputs and positive effects (benefits) 

less all associated inputs and negative effects (costs) whether they can be 

quantitatively valued or not. Net public benefits are measured by both quantitative 

and qualitative criteria rather than a single measure or index [36 CFR 219.3].’ 

Such an approach is reasonable given the vast array of environmental, social, and 

economic considerations in establishing or revising a Forest Plan. It is also 

consistent with the definition of multiple use as given in the MUSY Act. 

The Forest Service Manual and Handbook system agrees with this approach. FSH 

1909.17, section 10 calls for economic efficiency analysis for all projects. Section 

11 clarifies the analysis required. A pure economic efficiency analysis includes all 

benefits and cots in monetary, and therefore, maximizing present net value yields 

the same results as maximizing net public benefits. However, in most planning 

conditions all benefits and costs cannot be monetarily valued. Under this 

circumstance, maximizing present net value is not the same as maximizing net 

public benefits, and the handbook recommends the use of ‘cost-efficiency’ to 

satisfy these requirements. FSM 2430 and FSH2409.18 also focus on the concept 

of ‘cost-efficiency’ rather than pure economic efficiency. 

1160. The Wasatch-Cache National Forest should quantify ecosystem service 

values and externalized costs of commodity production in the net public 

benefits analysis.

 Response: Externalities are not required to be included in the economic analysis: 

36 CFR 219.12(g)3(i) directs that costs “of the agency and all other public and 

private costs required to manage the forest up to the point where the outputs are 

valued and the environmental consequences are realized” be included in the 

estimated effects of alternatives (emphasis added). Agency costs have been include 

in the FEIS Financial and Economic Efficiency analysis. Where there are 

significant private costs necessary to provide the valued outputs, they have been 

estimated and explicitly included in the efficiency analysis. 

There are many values associated with National Forests that cannot be expressed in 

monetary terms. Many values are highly personal and subjective in nature. These 

values include connections of people, circumstances, time and place that occur on 

the National Forests. An example may be an annual family trip to a certain scenic 

vista using their off-highway vehicle on a favorite designated route. Monetary 

expressions are poor measures for the moment and the reflection of such multifaceted values. These, however, may be the greatest value of National Forests to 

the nation. 
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Wasatch-Cache National Forest A - 278 

Other values can and have been expressed in monetary terms in the economics 

literature. Existence, option, and bequest values are among the kinds of values that 

have been expressed in monetary terms. Typically, a study is focused on a 

particular kind of value for a particular geographic location and a specific 

population. The results are valid for that specific location and population, but may 

not be transferable to all situations. Thus, a study in the southern Rockies or the 

Pacific Northwest may not be applicable to the Wasatch-Cache National Forest. 

The economics literature clearly shows that people hold passive use values for a 

variety of conditions on the National Forests. These values are relevant to the 

management situation on the Wasatch-Cache, but the spectrum of values in the 

literature is not easily transferred to the programmatic analyses and decisions being 

made for the Wasatch-Cache. Although the Forest Service recognizes the validity 

and importance of these values, the existing literature is not sufficient to serve as a 

basis for monetary estimates of the management actions proposed by the WasatchCache plan. Therefore, passive use values for such things as biological diversity 

and wildlife habitat must be taken into consideration in a qualitative sense. 

Comments on the DEIS have suggested that the full value of the Wasatch-Cache 

National Forest should be included in any benefit-cost analysis. This value might 

include such things as ecosystem services, its place in our national heritage, and all 

capital improvements. This kind of analysis would be appropriate if the decision in 

a forest plan revision was to retain or eliminate the entire National Forest. The 

decisions made in a forest plan revision, however, are incremental. The decisions 

are not whether to keep or sell the Wasatch-Cache National Forest, but rather to 

make step-wise changes in the way it is managed. Consequently, it is the difference 

between the ‘no action’ alternative and the other alternatives that offers insight into 

the benefits and costs of each course of action. 

The values mentioned above are often discussed in the biological, physical, 

recreational, or cultural sections of the FEIS. Their consideration is also 

documented in the Record of Decision. Because such values are not expressed in 

monetary terms and therefore not included in the economic efficiency analysis does 

not mean that they have been excluded from the calculus of ‘net public benefits’. 

Present net value is determined in part from benefits that can be expressed 

monetarily, but this is only a portion of all the values associated with the WasatchCache National Forest. 

1160.1 Incorporate information from The Economic Case against National Forest 

Logging 

 Response: Any policy regarding the subsidization of industries is not within the 

scope of the forest plan revision. While the Wasatch-Cache National Forest is 

concerned with effects on jobs in communities as it relates to Forest management, it 

has no policy to protect jobs in selected industries. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 279 

The timber industry is often singled out as receiving favored treatment by the Forest 

Service. Throughout the last decade, numerous mills in the Intermountain Region 

have closed while others have reconfigured to process smaller loges. International 

and national market forces now affect mills in the country more directly than ever 

before. There is a continuing demand for timber products in this country, and 

National Forests play an important role in supplying timber to meet the demand. 

The Wasatch-Cache National Forest historically has not been a large supplier of 

timber, but provides modest volumes of logs and wood fiber that are processed at 

local and regional mills in Utah, Idaho and Wyoming. 

Timber from the Wasatch-Cache National Forest is sold at market rates. Timber 

prices fluctuate from year to year, as influenced by market forces. Depending upon 

conditions, some firms purchase National Forest timber at prices above their 

production costs while others purchase timber below their production costs. Timber 

analysis in this FEIS used historic market prices, adjusted annually for projected 

real price increases. 

While the Forest Service in general and this Forest Plan in particular does not 

subsidize the timber industry with below-market prices, it has a keen interest in 

maintaining industry viability within the region. A local timber industry provides 

land managers and taxpayers with cost-effective options for treating vegetation to 

achieve 1) reduced risk of wildfires and insects and 2) improved forest health. 

1161. The Wasatch-Cache National Forest planning documents should incorporate 

ecosystem service values and externalized costs. 

1161.1 In order to comply with the Multiple Use and Sustained Yield (MUSY) 

Act 

1161.2 In order to comply with the National Environmental Policy Act 

1161.3 In order to comply with the Forest and Rangeland Renewable 

Resources Planning Act and the National Forest Management Act (NFMA) 

1161.4 In order to comply with the Administrative Procedures Act 

1161.5 In order to comply with the Economic and Social Analysis Handbook 

1161.6 In order to comply with the Timber Sale Preparation Handbook 

1161.7 In order to comply with the Forest Service Manual 

Response: MUSY calls for management of the National Forests ‘with 

consideration being given to the relative values of the various resources.’ There is 

no requirement for such values to be monetarily expressed. 

RPA/NFMA and implementing regulations outline the economic analysis and 

criterion requirement for forest planning, the commentors misunderstand the ‘net 

public benefits’ analytical framework prescribed by 36 CFR 219. ‘Net public 

benefits’ is not a benefit-cost analysis given a comprehensive economic efficiency 

framework – one that incorporates a monetary expression of all known market and 

non-market benefits and costs. Such an analysis is generally used when economic 

efficiency is the sole or primary criterion upon which a decision is made. The 

Forest Service does not endorse or expect this use of economic efficiency analysis 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 280 

in projects, programs, or other analyses. The agency recognizes that many of the 

values associated with natural resource management are best handled apart from, 

but in conjunction with, a more limited benefit-cost framework. This concept is 

expressed in NFMA regulations [36 CFR 219] and is referred as ‘cost-efficiency.’ 

When discussing the evaluation of Forest Plan alternatives, the regulations state that 

the evaluation ‘shall compare present net value, social and economic impacts, 

outputs of goods and services, and overall protection and enhancement of 

environmental resources’ [36 CFR 219.12(h)]. It is this process that results in a 

Forest Plan that ‘maximizes long term net public benefits in a environmentally 

sound manner’ [36 CFR 219.1]. 

The NFMA regulations define net public benefits as: ‘An expression used to 

signify the overall long-term value to the nation of all outputs and positive effects 

(benefits) less all associated inputs and negative effects (costs) whether they can be 

quantitatively valued or not. Net public benefits are measured by both quantitative 

and qualitative criteria rather than a single measure or index [36 CFR 219.3].’ 

Such an approach is reasonable given the vast array of environmental, social, and 

economic considerations in establishing or revising a Forest Plan. It is also 

consistent with the definition of multiple use as given in the MUSY Act. 

The FS Manual and Handbook system agrees with this approach. FSH 1909.17, 

section 10 calls for economic efficiency analysis for all projects. Section 11 

clarifies the analysis required. A pure economic efficiency analysis includes all 

benefits and cots in monetary, and therefore, maximizing present net value yields 

the same results as maximizing net public benefits. However, in most planning 

conditions all benefits and costs cannot be monetarily valued. Under this 

circumstance, maximizing present net value is not the same as maximizing net 

public benefits, and the handbook recommends the use of ‘cost-efficiency’ to 

satisfy these requirements. FSM 2430 and FSH2409.18 also focus on the concept 

of ‘cost-efficiency’ rather than pure economic efficiency. 

The Implementing regulations of NEPA expressly avoid a cost-benefit analysis as 

being a necessary basis for decisions: ‘For purposes of complying with the Act, the 

weighing of the merits and drawbacks of the various alternatives need not be 

displayed in a monetary cost-benefit analysis and should not be when there are 

important qualitative considerations.’ (40 CFR 1502.23) A cost-benefit analysis, 

however, may be conducted if desired or required by other laws, regulations, or 

directives. Economic impacts, however, are a concern of NEPA, but only where 

such issues have been identified during scoping. 

With regard to the Administrative Procedures Act, there have been no violations of 

law, regulation or procedure, as noted above, and thus the process for this Forest 

Plan is not arbitrary, capricious, or unreasonable. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 281 

1162. The Wasatch-Cache National Forest should resolve the discrepancy in 

timber employment numbers presented in the Draft EIS.

 Response: Thank you for you comment, the FEIS has been edited to ensure 

employment numbers between sections are consistent, or if reporting different types 

of employment, that the text clarifies the differences between the sections. 

Economic Impacts 

1163. The Wasatch-Cache National Forest should address the important economic 

contribution of various activities. 

1163.1 Grazing 

1163.2 Recreation and tourism 

1163.3 Motorized use 

 Response: The social and economic section in the FEIS highlights the 

contribution and potential impacts of each forest resource program. Specific output 

and resource information is available in specific resource sections of the FEIS. 

1164. The Wasatch-Cache National Forest should acknowledge that national 

forests do not contribute significantly to the agricultural economy.

 Response: The social and economic section of the FEIS highlights the 

contribution and potential impact of the agricultural sector to the analysis area 

economy. 

1165. The Wasatch-Cache National Forest should acknowledge that the value of 

one particular job is of no greater relative import than another job and that 

local economies are generally very elastic.

 Response: While the Wasatch-Cache National Forest is concerned with effects on 

jobs in communities as it relates to Forest management, it has no policy to protect 

jobs in selected industry. The social and economic section of the FEIS highlights 

the importance of Forest outputs local economies to communities within the 

analysis area. 

Funding 

1166. The Wasatch-Cache National Forest should formulate its budget to reflect 

the fact that recreation is the number one use of the forest.

 Response: The recreation section of the FEIS highlights the trends and use on the 

Wasatch-Cache for recreation and tourism activities. The social and economic 

section highlights the contribution and potential impacts of this activity on the 

analysis area economy. 
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Wasatch-Cache National Forest A - 282 

Subsidies 

1167. The Wasatch-Cache National Forest should not subsidize commercial 

industries or development. 

 Response: “Below-cost” management is not uncommon for national forests (with 

respect to timber sales, grazing and recreation management) as cost is not the only 

driver in determining what is appropriate management for an area. Most often, 

commercial ventures and proposals for the national forest are made because they 

are profitable for the operators. The Forest Service often makes operators bear the 

costs of environmental analyses associated with proposals. Commercial activities 

on national forests are carefully scrutinized in terms of their environmental, social 

and economic or business consequences. 

 

1168. The Wasatch-Cache National Forest should require user groups to restore 

the forest to properly functioning condition by requiring industries to pay a 

bond before issuing any extractive permits.

 Response: Permittees and contractors on national forest lands have to meet permit 

and contract requirements which include a performance bond, and in permits and 

contracts there are specific clauses for protection from and mitigation of effects to 

vegetation, soils, chemical use, litter and garbage, etc, associated with their 

activities. Requiring these groups to recover properly functioning condition (PFC) 

across broad areas of the forest is not something that has been done. The attainment 

of PFC (a relatively new concept in land management) is something that will likely 

take considerable time and integrated management and endeavors of both private 

user groups (commercial and non-commercial) and federal, state, and local 

governments. 

1169. The Wasatch-Cache National Forest should require lost or injured 

recreationists to pay for rescue efforts. 

 Response: While this question is outside the scope of forest plan revision, injured 

or lost recreationists can be billed if a medical helicopter is used in their rescue. 

Most often rescue is done by a County or State crew using the equipment necessary 

to complete the search and evacuation and the Counties bear this expense. The 

Forest Service does not pay for these rescues, but individual employees can 

participate in the rescue efforts. 

Lands, Real Estate, and Property Boundary Management 

Lands, Real Estate, and Property Boundary Management General 

 

1170. The Wasatch-Cache National Forest should modify the Federal land 

conveyances in the Forest Plan (p. 5–10) by not disposing of parcels with 

inefficient configurations.

 Response: Parcels of federal land with inefficient configurations are often the 

subject of degradation, trespass, or otherwise negatively affected, as they cannot be 

managed consistent with the land management goals of a larger block of federal 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 283 

land. These irregular parcels can be surrounded or influenced by lands under other 

ownership that are managed for very different intentions. 

1171. The Wasatch-Cache National Forest should wage a defense against interest 

claims it believes to be without merit. 

 Response: While this comment is generally outside the scope of forest plan 

decisions, the Forest Service does carefully scrutinize claims that are made 

regarding agency land so that the public lands are protected against unfounded 

assertions. 

 

Land Purchases and Exchanges 

 

1172. The Wasatch-Cache National Forest should add the Cache Valley foothills to 

its acquisition list to prevent further development

 Response: Landownership adjustment direction at the forest plan level is usually 

best stated in general terms across the forest without specifically mentioning 

individual tracts or areas. While such a disclosure might be desirable disclosure to 

those interested in knowing how the forest is approaching these ownership 

problems, detailed specificity often can alarm local landowners, escalate 

prices/values of lands and create unnecessary problems. 

1173. The Wasatch-Cache National Forest should acquire additional private lands. 

1173.1 To protect multiple resources 

1173.2 To protect moose habitat 

1173.3 To preserve watersheds 

 Response: These three types of settings are generally included in the priority land 

acquisitions presented in the revised Forest Plan. The ability of the Forest Service 

to acquire these lands is based on funding, the gravity of the need for acquisition, 

and other emphases that can affect the completion of a transaction. 

1174. The Wasatch-Cache National Forest should eliminate all private inholdings in 

roadless areas. 

 Response: Isolated private parcels within roadless areas can create some 

management difficulty or controversy if landowners need to develop a road into the 

parcels or otherwise develop the area they own. The Forest Service recognizes the 

desirability of blocking up ownership. This can often work to the advantage of both 

the private landowners and the government. 

1175. The Wasatch-Cache National Forest should consider additional land 

exchanges with public input. 

 Response: The Forest Service is considering more land exchanges and does 

involve the public through NEPA scoping and process for land exchanges and by 

complying with the Federal Land Exchange Facilitation Act (1988). 

1176. The Wasatch-Cache National Forest should not exchange lands within the 

Tri-Canyons. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 284 

1176.1 That would compromise watershed health and wildlife 

1176.2 That would create developable private property 

 Response: The forest recognizes the sensitivity of public sentiment concerning 

land development and land values in the Tri-Canyons. The revised Forest Plan 

identifies priority acquisitions and conveyances in its management direction. 

Riparian areas, areas valuable to wildlife and for watershed protection are identified 

as high value for acquisition. Conversely, they would not be easily traded out of 

public ownership. 

 

1177. The Wasatch-Cache National Forest should acquire private lands within TriCanyons wilderness additions that would prevent mining and development. 

 Response: A wide range of alternatives are presented with respect to 

recommendations for Wilderness in the Tri-Canyons. Part of the evaluation of 

potential for Wilderness is based on an area’s availability, that is, what liens are on 

the parcel which might make it less desirable as Wilderness. Clearly, active mineral 

claims and rights in a roadless area would make it less suitable as Wilderness. If a 

decision is made that recommends Wilderness that has private lands with private 

minerals, it could be in the interest of the Forest Service (and the American people) 

to pursue this ownership. 

 

1178. The Wasatch-Cache National Forest should not add land acquisitions on the 

North Slope of the Uintas to the existing wilderness area. 

 Response: Management direction and/or wilderness recommendations for lands 

outside federal ownership are not part of this forest plan decision and are outside its 

scope of considerations. 

 

Access 

Access to Forest Lands 

 

1179. The Wasatch-Cache National Forest should acquire more access rights-ofway across private lands. Motorized access is also important. 

 Response: Acquiring or providing for access and rights-or-way are identified as 

Priority 1 acquisitions in the revised Forest Plan. While the plan is silent on 

motorized or non-motorized use, both would be needed. 

1180. The Wasatch-Cache National Forest should institute boundary closures for 

private property owners who block access to public lands. 

 Response: The revised Forest Plan has a standard on Roads, Trails and Access 

Management that addresses this question. 

 

1181. The Wasatch-Cache National Forest should establish a motorized access rightof-way across Thousand Peaks Ranch. 

 Response: Identification of site-specific rights-of-way that could be acquired is 

not part of this forest plan decision. General direction on the priorities for 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 285 

acquisition and conveyance are identified, and access to the forest is considered a 

Priority 1 need. 

1182. The Wasatch-Cache National Forest should establish a public access right-ofway in the northern Wellsvilles. 

 Response: See response 1181. 

1183. The Wasatch-Cache National Forest should build an access road through the 

private property to the north point of Sardine Mountains to allow access to the 

Sardine Mountains 

 Response: See response 1181. 

1184. The Wasatch-Cache National Forest should acquire a public foot trail access 

right-of-way to the Mollen’s Hollow Research Natural Area to allow botanists 

access for plant community research. 

 Response: Part of the reason that the Mollen’s Hollow RNA has intact vegetation 

is because access into the area has been limited. Private lands along the western 

boundary of the area do not permit easy access from that side, and the Forest 

Service has not acquired public rights of way or easements from there. The area is 

accessible from the east off Forest Roads 059 to 221, but this access is not easy. 

Research scientists can come into the area from this direction to do research. 

1185. The Wasatch-Cache National Forest should secure a permanent access 

easement for non-motorized users south of Hardware Ranch. 

 Response: See response 1181. 

Access to Private Inholdings 

1186. The Wasatch-Cache National Forest should process easement applications in 

a timely fashion for inholders. 

 Response: The administration and processing of easement applications is not a 

forest plan decision. However, we recognize the validity of your statement and 

have passed it on to our lands people and forest management. 

Other 

1187. The Wasatch-Cache National Forest should replace “add specifics” in the 

proposed Forest Plan with the intended language. 

 Response: This section of the Response to Issue 4 has been rewritten in the FEIS. 
Final Environmental Impact Statement - Appendices 

Wasatch-Cache National Forest A - 286 

Letters from Other Government Agencies 

Copies of letters and oral comments from other federal, state, and local agencies are 

reproduced in this section. No letters were received from American Indian tribes. 

Letters and comments reproduced here were from: 

Federal Government 

Congressman James V. Hansen, U.S. House of Representatives, Committee on Resources 

USDI, Office of Environmental Policy and Compliance, Denver 

USDI, Bureau of Reclamation, Upper Colorado Region, Provo Area Office 

US Environmental Protection Agency, Denver 

USDA, Natural Resources Conservation Service, Snow Survey Office, Salt Lake City 

State Government 

State of Wyoming, Office of Federal Land Policy 

State of Wyoming, Department of Agriculture, Ron Micheli (transcription of oral 

comment) 

State of Utah, Governors Office of Planning and Budget 

Local Government 

Cache County, Utah 

Summit County, Utah 

Salt Lake County, Utah, Parks and Recreation 

Uinta County, Wyoming, County Commission, Bob Stoddard (transcription of oral 

comment) 

Ogden, Utah, City Council 

Ogden, Utah, Community and Economic Development Department 

Salt Lake City Corporation, Department of Public Utilities