Pemigewasset Wilderness, New Hampshire by Reid Gilman

Introduction

Since its founding in 1989, Wilderness Watch has pursued its mission as the citizen voice for Wilderness stewardship, giving a voice to the wilderness and wild rivers of our national preservation systems. We seek to preserve our unique natural heritage as articulated by the Wilderness Act and Wild and Scenic Rivers Act.

We wrote this guide to help you respond to wilderness and wild river management issues and to provide a basis for consistent management. It will not provide all the answers, but it will provide you with a foundation on which to base positions on critical issues that are consistent with wilderness and wild river legislation.

Management Methods

Wilderness Watch strongly favors management methods which provide the visitor with an opportunity for spontaneity and discovery. Education must constitute a major element of a comprehensive visitor management program and should be directed at the general public, specific wilderness visitor groups, and agency personnel. Education programs should explore wilderness concepts and promote the “leave no trace” concept. Education alone will not protect wilderness. It must be supported by regulations and a vigorous enforcement effort. Wilderness users and administrators must be held accountable for preserving wilderness character.

Federal and State agencies must abide by congressional mandates to manage wilderness to achieve a specific long range national objective. It is essential that personnel be educated about the meaning and value of wilderness.

Stewardship Parameters

All management decisions and actions must be firmly rooted in:

  • The Wilderness Act (P.L. 88-577);
  • The Wild and Scenic Rivers Act (P.L. 90-542);
  • Specific legislation which adds units to the Wilderness or Wild and Scenic Rivers Systems; and
  • Federal regulations implementing these Acts.

Some individual Wilderness bills have contained special provisions worth noting:

  • The so-called “Eastern Wilderness Act” (P.L. 93-622) granted the Secretary of Agriculture authority to use condemnation to acquire private land in wildernesses in the eastern states;
  • Alaska National Interest Lands Conservation Act (P.L. 96-487) included special provisions for motorized access and subsistence use on the 56 million acres in Alaska designated by ANILCA;
  • The “Colorado Wilderness Act” (P.L. 96-560) contains explicit language for managing livestock grazing in Wilderness; and
  • The Federal Land Policy and Management Act (P.L. 94-579), passed in 1976, expanded the list of federal lands that could be part of the Wilderness System to include lands managed by the Bureau of Land Management (BLM).

Stewardship Issues

Administrative Activities and Facilities

Administrative exceptions to the general prohibitions found in Section 4(c) of the Wilderness Act must be used only when it is not feasible to accomplish a necessary administrative task with other methods. Modern equipment use must be based on the minimum tool concept. Administrative personnel should set examples in how to travel, work and “live” in the wilderness. If there are standards the general public is expected to meet (e.g. portable tents rather than permanent structures), then managers­as well as agency cooperators, partners and permittees­should also meet or exceed those standards.

Trails

The Wilderness Act prohibits structures and installations in wilderness except where they are “…necessary to meet minimum requirements for the administration of the area…” as wilderness. Trails, bridges, signs, and related facilities are structures or installations that are permitted by the exception provided for in the Act, but only to the extent that the structures are the minimum necessary for administering the Wilderness.

No new trails or bridges should be constructed until a management plan demonstrates that the trails or bridges are necessary to achieve a wilderness stewardship objective. The plan must determine how trails contribute to the desired future condition without impairing wilderness character. No authority exists to build trails or other structures to higher standards than necessary for wilderness purposes. Existing trails, bridges and related structures should be periodically reviewed to determine whether they should be removed or relocated.

User-created trails should be closed and/or obliterated whenever possible. Users should be educated about the damage to soil, vegetation and other resources from creating new trails, and to the need to limit evidence of human activity in Wilderness. Projects that remove user-created trails make excellent service projects for Wilderness Watch chapters, members, and other volunteers.

Managers must keep trails and their use from causing unacceptable wilderness degradation. There is no authority to build or reconstruct trails to make them easy or more comfortable. The cutting of each tree, the blasting of each rock and the moving of each cubic foot of soil must be justified as the minimum necessary to meet a wilderness stewardship objective.

Wilderness trails should lie lightly on the land. They should “fit” the landscape as a game trail does, respecting landforms and natural hazards. Trails that intrude on the natural setting have no place in Wilderness.

Signs

Like other evidence of modern life, signs detract from the wilderness experience. Map reading, compass, and orienteering skills promote a closer relationship to the land. There should be no mileage markers, interpretive signs or place name signs within wilderness. Signs may be a management necessity at some trail junctions, and some temporary signs may be necessary to change damaging use patterns. Necessary signs should be constructed to blend with the landscape.

Fish Stocking

Stocking fish into naturally fishless waters has been shown to adversely impact the natural aquatic ecosystem including invertebrates, insect larvae, amphibians and other dependent wildlife species. Fish stocking has also been shown to significantly affect indigenous fish populations through competition, predation, and hybridization.

When supported by appropriate NEPA documentation and public involvement, fish stocking may be considered acceptable when it is essential to recover an indigenous species adversely affected by human influence and with methods appropriate within wilderness. Fish stocking that is intended to modify wilderness for recreational purposes, stocking with non-indigenous species, or fish stocking in lakes or streams historically and naturally devoid of fish is unacceptable.

Wildlife

Natural processes should prevail and should determine the relative abundance and diversity of fish and wildlife species in wilderness. Management decisions and activities should minimize the level of human influence in the wilderness system. Where human actions have eliminated an indigenous species, where habitat conditions are suitable, and where the population will be self-sustaining Wilderness Watch supports reintroduction of extirpated species. Natural recolonization is preferred to overt reintroduction. Manipulating habitat is unacceptable unless it is necessary to protect threatened or endangered species.

Wildlife management is the most manipulative management activity in most wildernesses. Population control, skewing male/female and age demographics, and introducing non-indigenous fish and terrestrial wildlife species are common manipulations. Managers and citizens must move wildlife management programs in a direction that leaves wilderness as an area “untrammeled by man…retaining its primeval character and influence…protected and managed so as to preserve its natural conditions…”

Recreation Livestock

The use of pack and saddle stock is part of the wilderness heritage. Continued use of livestock for recreation and administrative travel must be accommodated without degrading the Wilderness resource. Stock users should use and promote low impact equipment and techniques. If feed is carried into the wilderness it must be certified as “weed-free”.

It generally isn’t possible to use livestock without “leaving a trace”. However, impacts from livestock should recover from year to year, rather than persist over longer periods. Some areas are so fragile that livestock use must be severely restricted or prohibited. Management methods that promote minimum impact techniques and limit use are preferred to installing stock handling facilities.

Commercial Outfitting and Guiding

Section 4(c) of the Wilderness Act states “…there shall be no commercial enterprise…” within any wilderness area. Commercializing wilderness tends to interject economic considerations into wilderness management decisions, something Congress clearly wanted to avoid. At the same time, Congress recognized outfitting as a traditional use of wilderness and that some people needed the services of outfitters in order to experience the benefits of wilderness. Thus, Section 4(d)(5) of the Act provides that “Commercial services may be performed…to the extent necessary for activities which are proper for realizing the recreational or other wilderness purposes of the areas” (emphasis added). Whether to allow commercial outfitting and guiding is a discretionary decision for wilderness managers. The Act requires that managers preserve wilderness character and that commercial services be allowed only to the extent necessary.

There isn’t a hard and fast rule for determining how much or what kind of commercial services are necessary. Outfitters and guides play an important role by making it possible for people who don’t have the equipment, skill, or physical ability to enjoy wilderness on their own. Demand, however, expressed as a function of the industry’s ability to market wilderness, is not a valid indicator of what is necessary. Each wilderness management plan should include a “needs analysis” that defines the level and type of commercial services necessary to achieve the purposes of wilderness within the constraints of preserving wilderness character. Every effort should be made to prevent commercial activities from leading to expanded use of non-conforming equipment such as motorboats, aircraft, chainsaws or administrative structures.

Commercial outfitters, guides and their clients must abide by the same rules that apply to other wilderness users. For example, they should be governed by the same party-size and length of stay limits, they should compete fairly for campsites, they must “pack out” what they “pack in” (i.e. no caches or permanent structures) and they must strive to leave no trace of their visit.

When it is necessary to limit use, the allocation between outfitted and non-outfitted users should be equitable. All workable options should be explored to ensure that all citizens share equal opportunities to visit wilderness and wild rivers where use is limited by permits. The current system allows those who can afford and choose to hire an outfitter far greater opportunities to visit some wilderness and float some rivers than the general public enjoys.

Aircraft and Airstrips

Section 4(d) of the Wilderness Act allows administrators to permit use of aircraft and wilderness airstrips where those uses were established prior to wilderness designation. Because aircraft are a non-conforming use, their use should not be allowed to exceed the level of use that existed when the wilderness was designated.

Wilderness overflights degrade the experience of wilderness users, and cause stress to wildlife. Aircraft should fly at least 2,000 feet above terrain except when there is a bona fide emergency, such as search and rescue, or for fire control. Game-spotting and low-level sight-seeing flights are unacceptable.

Wilderness airstrips should not be enlarged or improved. Their only purpose should be to provide access for wilderness dependent activities. Helicopter landings should be prohibited except for emergencies involving the life of persons within the area and when primitive transport is not feasible.

Military training flights over wilderness must be justified through an EIS. The EIS should clearly demonstrate that such flights are necessary, in the national interest, and that use of alternate airspace over non-wilderness lands would create a greater impact on the environment.

Livestock Grazing

Section 4(d)(4)(2) of the Wilderness Act allows domestic livestock grazing to continue where established prior to wilderness designation. Congress has directed managers to not reduce grazing simply because an area is designated Wilderness. However, where there are impacts to soil, vegetation, wildlife, recreation, riparian areas, etc., grazing can be reduced.

While allowing for grazing, the Wilderness Act also charges managers with preserving “wilderness character” (i.e. “…retaining its primeval character and influence…managed so as to preserve its natural conditions…affected primarily by the forces of nature….”). Grazing should not inhibit natural succession (i.e. plant communities should reflect those that would exist with the absence of human impactreferred to as “potential natural vegetation”), increase the percentage of bare soil area, or measurably impair water quality.
Ranchers carved ranches out of the wilderness without motorized equipment and mechanical transport, and we believe that heritage can be kept alive by operating traditionally in Wilderness. Non-motorized transport and equipment should be used whenever feasible. House of Representatives Report No. 96-1126 provides additional congressional guidance for grazing management.

Predator Control

As Aldo Leopold succinctly stated in A Sand County Almanac ,”One of the most insidious invasions of wilderness is via predator control..” Predation is integral to a natural functioning ecosystem and should be allowed without management interference. Non-lethal methods should be used to protect livestock from predators.

Fire Management

Most wilderness ecosystems evolved with fire as a major influencing force. Fire must be allowed to return to wilderness as a natural process. Fire Management Plans should prescribe conditions that allow naturally ignited fires to burn under natural conditions.

Years of fire suppression have allowed unnatural fuel levels to accumulate in some situations. Planned ignitions may be necessary to reduce fuel levels to a point where natural fires can again define wilderness conditions. Planned ignitions, however, will not create the same biological effects as natural fires unless they are applied under the same conditions and time of year in which naturally ignited fires generally occur. Planned ignitions must be supported by an EIS.

Fire control should utilize natural features (rivers, vegetation changes) and hand tools. Motorized equipment such as chainsaws or aircraft should be approved only after the request has been subject to a rigorous “minimum tool” test.

Research

Wilderness Watch supports non-manipulative research within wilderness. The public purposes to which the Wilderness Act devotes wilderness include scientific and education use. Research is often necessary to determine wilderness management standards, and the health of wilderness ecosystems. Wilderness can also serve as a baseline to measure the health of non-wilderness ecosystems.

The general prohibitions of Section 4(c) of the Wilderness Act apply to research methods. Tagging or collaring wildlife or marking other wilderness features should be discouraged. Where alternatives exist, research should be conducted in non-wilderness settings. Motorized equipment and structures can be considered only if the research is the minimum necessary for administration of the area.

Devices used for measuring snowpack, flood control and other similar purposes that were established prior to wilderness designation should be removed as soon as adequate correlation can be established with sites outside the wilderness.

Historic Structures

Significant historic structures, such as those eligible for the National Register, should be identified and protected, but attempts to restore or stabilize structures should be discouraged. The natural deterioration of historic structures is part of wilderness; it is evidence of untrammeled and timeless natural processes reclaiming the wilderness from temporary human occupation. Insignificant historic structures or those causing resource damage should be removed if their removal can be done in a manner consistent with wilderness principles and the impact from reclaiming the site or removing the structure is less than the impact from leaving the structure in place.

Dams

Many water storage facilities were built in areas that were later designated by Congress as wilderness. Most are stock watering facilities. Others are used to store water for irrigation or other “beneficial uses” recognized by state water laws. A few small dams were built to provide fishing or other recreational opportunities, but it is difficult to justify their continued existence. They were built precisely to modify and trammel the wilderness.

We recognize that if a dam is to remain, it must be maintained in a safe condition as defined by federal and state dam safety laws. However, work on structures must meet the same minimum tool analysis as any other wilderness project, and some dams may not be needed. Most dams in Wilderness were built without motorized equipment, and except in exceptional circumstances which must be justified on a case by case basis, all work must be completed without motorized equipment.

Access to Private Land

The Act guarantees adequate access to private inholdings “…or privately owned land shall be exchanged for federally owned land in the same state…” Access to recreation retreats will be by primitive travel over existing trails. Where current or planned development is inconsistent with wilderness values a land exchange or purchase must ensue.

Personal Safety

Wilderness is a place where visitors should expect opportunities for risk and challenge. People must accept responsibility for their own health and safety. The manager’s principle safety responsibility is to eliminate man-made hazards. Administrative structures should not create a safety hazard, and assigned campsites must avoid hazard trees, areas susceptible to flash flooding, and other avoidable risks.

Naming Of Geographic Features

Giving names to geographic features (rivers, peaks) is one way that humans “occupy” or leave their mark on the land. With each new name the wilderness loses a bit of its character as terra incognita, as a blank spot on the map. Where unnamed geographic features still exist they should remain unnamed.

Photo: Pemigewasset Wilderness, New Hampshire by Reid Gilman via Flickr