Wilderness Watch and Standing Trees are urging the Forest Service (FS) to reconsider its proposal to amend its Forest Plan in regards to Wilderness trail management in the White Mountain National Forest (WMNF) in New Hampshire and Maine. The agency is trying to do the right thing by addressing trail issues in Wilderness, but a better approach would be to consider Wilderness trail relocations on an individual basis so as to allow for better analysis of impacts to Wilderness.

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

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

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

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

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

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

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

• Read our joint comment letter to the Forest Service

Photo: ScenicNH Photography