by Kevin Proescholdt
At the end of October, Wilderness Watch filed a formal objection to the new Final Land Management Plan for the Chugach National Forest in response to the Forest Service’s seemingly intentional disregard for protecting the 2 million-acre Nellie Juan-College Fiord Wilderness Study Area (WSA) that is part of the Chugach. In January, Wilderness Watch participated in an objection resolution meeting with the Forest Service, though the agency has not yet ruled on any of the objections we raised.
The Congressionally-designated Nellie Juan-College Fiord WSA in Alaska’s western Prince William Sound is an ecological and scenic treasure of roughly 2 million acres of ancient rainforest, stunning mountains, sprawling glaciers, and meandering fiords laced with hundreds of remote islands. The Nellie Juan-College Fiord WSA is also the nation’s largest Wilderness Study Area.
Not a single acre of Wilderness has been designated on the 5.4 million-acre Chugach National Forest, further elevating the importance of protecting the Nellie Juan-College Fiord WSA. Unfortunately, the agency’s Final Land Management Plan for the Chugach fails abysmally to protect the wilderness character of the Nellie Juan-College Fiord WSA.
Wilderness Watch filed the formal objection with Alaska Wilderness League, Eyak Preservation Council, WildEarth Guardians, and the Wilderness Society, highlighting the following concerns:
- The Final Plan downgrades protection for the WSA. The past two Chugach management plans have directed the Forest Service to protect “presently existing wilderness character” of the WSA, but the new plan downgrades that management to the undefined and meaningless standard of “presently existing character,” which would allow never-ending degradation over time.
- The Final Plan eliminates use of the Minimum Requirements Analysis (MRA), a tool for protecting wilderness. The 1964 Wilderness Act generally prohibits the use of motor vehicles, motorized equipment, structures and installations, allowing their use only if it is “necessary to meet minimum requirements for the administration of the area” to preserve its wilderness character. Congress included this clause in the Wilderness Act to minimize the use of nonconforming activities that agencies often want to do when stewarding Wilderness. Though terribly weak and are often abused by the agencies, the MRA process is still better than nothing. The Forest Service completely eliminated the use of MRA in the Final Chugach Plan, suggesting the agency has little or no intention to analyze the impacts of its management activities on the WSA’s wilderness character.
- The Final Plan eliminates WSA protection for 100,000 acres of wilderness-quality lands. The federal government acquired lands from other ownerships within the boundaries of the Nellie Juan-College Fiord WSA as part of the settlement following the Exxon Valdez Oil Spill (EVOS) in 1989. Past Chugach National Forest plans haven’t differentiated between WSA lands and EVOS-acquired lands within the WSA, but the new Final Plan does, and creates a new management area classification for the EVOS lands that could well lead to degradation and development over time. The Forest Service should instead equally protect the EVOS-acquired lands by managing them as WSA lands, and the agency should also recommend the EVOS-acquired lands within the WSA for wilderness designation.
- The Final Plan needs a larger Wilderness recommendation. As part of any Forest Plan, the Forest Service recommends to Congress areas that the agency believes should be formally designated as Wilderness. The agency recommended only 1.4 million acres of the 2 million-acre WSA for Wilderness designation. But this is Alaska, after all, home to some of the wildest, largest, and most magnificent wilderness lands in the nation, including the Nellie Juan-College Fiord WSA. The agency should instead recommend all of the qualifying lands in and adjacent to the WSA for Wilderness designation.
- The Final Plan fails to protect Chugach National Forest roadless areas. The Final Plan fails to incorporate Roadless Rule protection for all Inventoried Roadless Areas on the Chugach. The Inventoried Roadless Areas are National Forest lands on the Chugach outside of the WSA that retain wild and roadless characteristics. Particularly with the Forest Service proposing in a separate action (the Alaska Specific Roadless Rule) that the protection for any Alaska roadless area could be eliminated after a 45-day comment period, the need to protect the Inventoried Roadless Areas on the Chugach is greater than ever. The Final Plan should incorporate Roadless Rule protections for these roadless areas on the Chugach so they retain some protection even if the Alaska Specific Roadless Rule is adopted.
The formal administrative objection process continues, as Wilderness Watch and our allies urge the Forest Service to protect the wilderness lands on the Chugach and in the Nellie Juan-College Fiord WSA. We will continue to fight to protect the wild character of the magnificent Nellie Juan-College Fiord Wilderness Study Area so that future generations may also know the awe-inspiring beauty and magnificent wilderness qualities of these nationally important lands.
Read our Objection
Kevin Proescholdt is the conservation director for Wilderness Watch, a national wilderness conservation organization headquartered in Missoula and focused on the protection of the National Wilderness Preservation System.