Wilderness Working Papera123.g.akamai.net/7/123/11558/abc123/forestservic... · 2010. 8. 3. ·...

Wilderness Working Paper

Introduction The following section is provided as an introduction to the laws, regulations, and policies which guide the Forest Service management of Congressionally designated wilderness areas. In this introduction, we highlight the key portions of the laws, regulations, and policies that set the sideboards for wilderness management. We have used these laws, regulations, and policies to focus our analysis. The Wilderness Act and the Illinois Wilderness Act The Wilderness Act of 1964 is the enabling legislation for the management of the National Wilderness Preservation System (NWPS). In 1990, the Illinois Wilderness Act designated seven areas of the Forest as units of the NWPS. Three of these areas, Garden of the God’s, Lusk Creek and Bay Creek Wildernesses, are located in the project area. There are about 13,500 acres of wilderness within the project area. Acreage for each wilderness is presented in Table 33. To ensure consistent wilderness management, 254 acres of the Bay Creek Wilderness in the Lower South Fork Saline Creek watershed is included in this analysis.

Table 33. Acreage for each wilderness in the project area.

Garden of the God’s

Lusk Creek

Bay Creek

Total Acreage

Acres 3,997 6,718 2,769 13,484 Within the Wilderness Act, there is language which both defines wilderness and describes how wilderness is to be managed. Section 2 (c) states, “A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which:

(1) Generally appears to have been affected primarily by the forces of nature, with the imprint of man’s work being substantially unnoticeable; (2) Has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) Has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and

(4) May also contain ecological, geological, or other features of scientific, educational, scenic or historical value” (The Wilderness Act of 1964).

Section 4(b), which addresses use of wilderness, states that “each agency administering any area designated as wilderness shall be responsible for preserving the wilderness character of the area for such other purposes for which it may have been established as also to preserve its wilderness character” (The Wilderness Act of 1964). Section 2(a) of the Act specifically states that such areas, “shall be administered for the use and enjoyment of the American people in such a manner as will leave them unimpaired for future use and enjoyment as wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness character” (The Wilderness Act of 1964).

Wilderness Act Prohibitions Section 4c of the 1964 Act also defines uses considered to be prohibited within wilderness:

“Except as specifically provided for in this chapter, and subject to existing private rights, there shall be no commercial enterprise and no permanent road within any wilderness area designated by this chapter and, except as necessary to meet minimum requirements for the administration of the area for the purpose of this chapter (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area” (The Wilderness Act of 1964).

Finally, although Section 4(c) of the Act states that no structure, installation or commercial use enterprise is allowed within wilderness, Forest Service policy further clarifies this language. Trails, for example, are considered an acceptable improvement even though a trail is considered a permanent improvement and is clear evidence of man’s work. Other temporary and permanent structures and installations considered to be appropriate include bridges, signs, outfitter and guide operations and recreation stock structures –, when they are designed to minimize the impact on wilderness, and when they are deemed to be necessary for managing the wilderness resource (FSM 2323.13f, 13g, 2324.33). Outfitter and guide services are also considered appropriate when they existed prior to wilderness designation or when they provide services that are deemed necessary to meeting the purpose of the act. Forest Service Wilderness Regulations Wilderness is to be made available for human use to the optimum extent consistent with the maintenance of primitive conditions (36 CFR 293.2). A key section of the Forest Service wilderness regulations (36 CFR 293.6.c) concerning use of wilderness is tied to the language used in Section 4(c) of the Wilderness Act:

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Shawnee National Forest, Trails Designation Project Wilderness Working Paper, Appendix A. Minimum Requirement Analysis

Except as provided in the Wilderness Act, there shall be in National Forest wilderness no . . . structures or installations . . . .

The Chief of the Forest Service may authorize use of National Forest land to carry out the purposes of the Act and will prescribe conditions under which motorized equipment, installations, and structures may be used. Such uses must meet the minimum requirements for authorized activities in the administration of wilderness (36 CFR 293.6.c). Forest Service regulations (36 CFR 293.8) also provide direction with regard to permanent structures in wilderness:

Motels, summer homes, stores, resorts, organization camps, hunting and fishing lodges, electronic installations, and similar structures are prohibited in National Forest Wilderness. The Chief, Forest Service, may permit temporary structures . . . within National Forest Wilderness to the extent necessary for realizing the recreational or other wilderness purposes, which may include, but not limited to, the public services offered by packers, outfitters, and guides.

Forest Service Policy Forest Service policy (Forest Service Manual 2320.1 – 2323.26b and Forest Service Handbook 2709.11, 2309.18) and the 1992 Forest Plan provide direction for the management of the three wildernesses within the project area. The intent of the Wilderness Act of 1964 and the Illinois Wilderness Act of 1990 are incorporated into both Forest Service policy and the 1992 Forest Plan. The overall goal of wilderness management is to maintain or improve wilderness character from its state at the time of wilderness designation. Policy directs the agency to consider the wilderness resource as the overriding value when a choice must be made between wilderness values and visitor or any other activity, in order to preserve wilderness. Because uses and values on each area will vary, management and administration should be tailored to meet the need of each area (FSM 2320.6). The Forest Service may authorize the use of motorized equipment and mechanical transport to meet minimum needs for administration of wilderness where “[a]n essential activity is impossible to accomplish by nonmotorized means because of such factors as time or season limitations, safety, or other material restrictions” (FSM 2326.1). Additionally, Section 4(d) of the 1964 Act allows for certain activities that would normally be prohibited within wilderness - when the uses were already in place prior to wilderness designation. For example, a road (considered a permanent structure) which is used for motorized access, is a prohibited or non-conforming use within wilderness. This type of use is permitted to occur within the Lusk Creek Wilderness to access private property because the access to private property was a valid existing right at the time of wilderness designation in 1990 (FSM 2320.5,16).

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The Minimum Necessary for Administering Wilderness The concept of minimum requirements for the administration of wilderness is derived from Section 4(c) of the Wilderness Act of 1964 (please refer to the preceding page). The Act has multiple references to the concept of determining what (if anything) constitutes the minimum necessary action. Although not required by law, regulation or policy, a minimum requirements analysis process is recommended to determine if there is a need for action and to determine what method, tool, structure or installation is necessary in order to protect wilderness values (Forest Service, Arthur Carhart National Wilderness Training Center, 2005). In response to comments on the DEIS, we have completed a minimum requirements rationale following the guidance provided in the Forest Service Minimum Requirements Decision Guide (Arthur Carhart National Wilderness Training Center, 2005). We have summarized the minimum requirements rationale in the FEIS and provided a complete analysis in the Wilderness Working Paper. We prepared this rationale to ensure that the alternatives considered, including the Selected Action, were consistent with the intent of the Wilderness Act. We include this summary in the FEIS to clarify and better communicate the rationale for the findings of the interdisciplinary team during formulation of the DEIS. We found that all of the components of the minimum requirements analysis were considered during formulation of the DEIS, and reflected in the alternatives developed for the DEIS. We have added this summary to address public concerns that the Forest has not considered “minimum requirements” consistent with Wilderness Act Section 4( c ) and agency policy. The summary documents the Forest’s analysis and findings with regard to minimum requirements and its compliance with the Wilderness Act. Summary of the Minimum Requirements Rationale The public comments on the DEIS focused on several questions relative to compliance with The Wilderness Act. Graveled trails, stock confinement areas, and commercial equestrian outfitter/guide services offered in wilderness were the primary concerns raised relative to the proposed alternatives in the DEIS. 1) Graveled Trails In the comments on the DEIS, the importation of relatively large amounts of gravel to harden trails and provide a firm tread was questioned. The appearance of the gravel, whether it would be a prohibited structure, and the impact of the gravel on the natural condition and undeveloped nature of wilderness character were the primary concerns raised. The interdisciplinary team considered the color of the gravel, the time it would be visible, and the appropriateness of using gravel in the wilderness in the development of the alternatives presented in the DEIS. The conclusions that were reached were:

A. the use of gravel is integral to a properly designed trail in our fine soils so that the trail is does not become muddy, braided, or excessively wide,

B. hardening the trails with gravel is the simplest method to provide a trail system that can be maintained under moderate to heavy equestrian use,

C. that the dark colored gravel would not be obtrusive,

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D. natural condition would be improved over time because the dark gravel would be worked into the soil and would not be highly visible,

E. the 49 miles of wilderness trail in about 13,500 acres of wilderness would not appreciably impact the level of development, and

F. the use of gravel would improve wilderness character by lessening the visual impact of the trail system.

We also considered limiting use, rather than constructing and maintaining a trail system (with gravel) that can withstand moderate to heavy equestrian use. The team concluded that building a reasonable trail system that could be maintained was a logical first step in solving the issues related to wilderness character. In addition, the team considered using seasonal and wet-weather closures to manage impacts to the trail system. These type of closures would impact many users experience because of the unpredictability of the weather. Many users plan their trips month in advance and would be denied the use of the wilderness during wet conditions. Additionally, trail conditions vary greatly depending on the terrain where the trail is located. Many areas would remain in poor condition for extended periods without the use of gravel to stabilize the trail tread. The interdisciplinary team concluded that graveled trails were the minimum tool necessary to meet the recreation purposes of the Wilderness Act. As a result of public concern (expressed in comments on the DEIS) about the density of trails, the level of development, and the opportunity for solitude, the Selected Alternative reflects a decrease in the number of miles of trails in the Lusk Creek Wilderness Area. This Area, above all others on the Forest, has been the subject of much study, public debate and litigation. The effect of the lower trail mileage in Lusk Creek Wilderness Area is within the environmental effects disclosed in the DEIS, and the issue of trail mileage in the area was a focal point of the DEIS. Some public comment on the DEIS supported more access to the area, while others strongly opposed the 34 miles of trail proposed in Preferred Alternative. After re-consideration of the interdisciplinary teams’ analysis of wilderness character, Alternative 2, the Selected Alternative, was modified. The level of access to Lusk Creek Wilderness Area is still reasonable, but provides, out of an abundance of caution, additional protection of wilderness values. This change is consistent with the regulatory direction to allow wilderness values to dominate (to the extent not limited by the Wilderness Act) resolution of conflicts in resource use (36 CFR 293.2(c)). 2) Stock Confinement Areas The appropriateness of stock confinement areas in wilderness was also a concern raised during the comment period. In the development of the DEIS, the interdisciplinary team considered eliminating stock confinement areas and concluded that the resource damage that would result from their elimination would outweigh the environmental impacts likely to occur in their absence. Without the stock confinement areas, people would probably tie their animals in many places and spread out the level of impact. Since these permanent improvements can be allowed and they reduce the overall level of impact the team thought their use was appropriate.

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The interdisciplinary team determined that the nine existing confinement areas (about 1.25 acres) could be reduced to four confinement areas (about 0.8 acres). The impacts were minimized by eliminating four areas (River-to-River East, River-to-River West, Coyote Club, and Bear Branch), relocating four areas (Saltpeter Cave, Natural Bridge, Owl Point, and Indian Kitchen) and reducing the impact onsite in one case (Secret Canyon). The interdisciplinary team concluded that the stock confinement areas were appropriate and necessary to fulfill the recreation purpose of the Wilderness Act. 3) Commercial Equestrian Outfitter/Guide Services In the public comments on the DEIS there was some concern over the appropriateness of offering commercial equestrian outfitter/guide services in the wilderness. The wilderness prohibits commercial enterprises in the wilderness but it does allow for commercial services to be provided to the extent necessary to meet the recreational purpose of the Act. The interdisciplinary team considered several factors in assessing the need for commercial services in the wildernesses. Between April 2003 and March 2005, about 6,000 equestrian wilderness visitors stayed at the commercial campgrounds around Lusk Creek Wilderness (Chilman 2005). While this is only one year of data, it does provide some insight into the level of use at the campgrounds. These equestrians make up the majority of our wilderness users in the Lusk Creek Wilderness. Without the commercial equestrian campgrounds, most of these users would not have a place to stay that could accommodate them and their stock. These users are seeking a recreational experience that meets an important purpose for the designation of the wilderness. The Lusk Creek Wilderness visitor survey (Chilman et al. 2005) found that 81% of users rated their wilderness experience above an eight on a scale of one to ten. With the high satisfaction rate indicated by this, the interdisciplinary team concluded that use should not be limited at this time. As mentioned above, the team concluded that building a reasonable trail system that could be maintained was a logical first step in solving the issues related to wilderness character. Another important aspect in allowing for commercial services to be provided in wilderness is the extent to which these services are necessary. The campgrounds serve as hosts for most of the equestrian users that visit the project area; without these services many equestrian tourists would not be able to enjoy our wilderness resource. Working together to educate people to the proper use of the trail system is potentially the biggest benefit that we can provide for resource management. If, in the future, a limit on the total number of users is determined to be needed, then the equestrian outfitter/guide permits will provide a mechanism for limiting commercial use. Until use limits would be necessary, the current permitting process should be adequate to enhance and protect wilderness character. The interdisciplinary team concluded that commercial equestrian outfitter/guide services were necessary to meet the recreation purpose of the Wilderness Act. Summary

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The need for action within the Garden of the God’s, Lusk Creek and Bay Creek Wilderness is displayed in the Purpose of and Need for Action in Chapter 1. In addition, the existing condition of key wilderness resources is displayed in Chapter 3. Those resources included soil and water resources, aquatic resources, botanical resources, wildlife resources, recreation resources and trail facilities, heritage resources, and visual resources. The existing resource condition and the resource analysis, presented in Chapter 3, demonstrate a need for action to improve wilderness character. Congress clearly intended that wilderness areas were to be administered to protect wilderness character. However, Congress unquestionably also directed that these same lands be administered to ensure future use and enjoyment by the American public, and that such use and enjoyment includes recreational activity. The Wilderness Act does not mandate federal agencies to pursue a limited or single purpose regarding wilderness. Instead, the Act requires agencies to administer wilderness areas to serve many public purposes and facilitate “recreational, scenic, scientific, educational, conservation, and historical use.” 16 U.S.C. 1133(b). The Forest’s wilderness management decisions must encompass and consider all of these purposes, and as one court said, “must undertake a minimum of administration, in order to make the Wilderness accessible to those Americans who wish to use it.” Forest Service policy states that “[t]rails are an acceptable improvement.” Compliance with the Wilderness Act must be viewed in terms of the purposes and intents of the Act as a whole. Both the Wilderness Act and the Forest Service regulations express a preference against permanent structures in wilderness, but do not prohibit such structures. The Wilderness Act does not contain a blanket prohibition of permanent structures at all times, under all circumstances. Instead, Congress recognized that some minor structures, including permanent ones, may be “necessary to meet the minimum requirements for administration of [a wilderness] area” (The Wilderness Act of 1964). This could reasonably be interpreted to include those minimum requirements for administration of wilderness that advance the purposes of the Act, one of which is to provide recreation opportunities. The Act directs federal agencies to both conserve wilderness and ensure recreational use and enjoyment of the land by the American people. Likewise, Forest Service wilderness regulations do not preclude all permanent structures. Both statute and regulations allow for permanent structures necessary for minimum administration of a wilderness area. In order to administer wilderness for recreation and where deemed necessary for management of wilderness, minimal structures such as a hitching posts and similar livestock constraints are allowable, as they leave wilderness unimpaired for future generations and provide for its use and enjoyment by the public as Congress intended. Indeed, permanent structures such as hitching racks and spring boxes placed by outfitters in wilderness for the purpose of administration of the wilderness consistent with recreational purposes have been upheld in court. Wilderness Watch v. Forest Service, 1998 U.S. Lexis Dist.14457 (D. D.C. Aug.

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31, 1998). These permanent structures, placed in wilderness to facilitate recreational access, were necessary for administration of wilderness. The Forest Service has discretion under the Wilderness Act to determine what structures are necessary for the administration of wilderness. Equestrian recreation on the Shawnee National Forest has been recognized as a long-standing, traditional use of the Forest, including wilderness areas encompassed by the project area. In general, this use is compatible with the Wilderness Act goals of conservation of wilderness values and access for recreation in the Forest Plan. Some recreation trails in these wildernesses pre-date the creation of wilderness in 1990, as well as establishment of the Forest in 1933. Trail use by a wide variety of visitors is an integral part of the sustainable, multiple use context of the Forest. Moreover, commercial operations in support of this recreational use of the lands in the project area have been part of the Forest’s operation for over 4 decades. The purposes set forth in the Wilderness Act - protection and conservation of wilderness, as well as recreation use and enjoyment - are germane to the Forest’s proposal to administer the wilderness as set forth in the Selected Alternative. Defining and Monitoring Wilderness Character The Wilderness Act identifies four qualities of wilderness character: “untrammeled,” “natural,” “undeveloped” and offering “outstanding opportunities for solitude or a primitive and unconfined recreation (United States Congress, 1964). Although there is no definition of wilderness character provided in the Act and the meaning is not discussed in the legislative history, it may be described as a combination of biophysical, experiential and symbolic ideals that distinguish wilderness from all other land. In addition to the range of biophysical conditions found within wilderness, each wilderness has its own unique character due to the relationships people have with the area. The values visitors have, and the experiences visitors associate with an individual wilderness, has been considered for determining the Garden of the God’s, Lusk Creek and Bay Creek wilderness character. (Landres, et al., 2005) In 2005, the USDA General Technical Report (RMRS-GTR-151) Monitoring Selected Conditions Related to Wilderness Character: A National Framework (Landres et al. 2005) was published to provide managers a way to select indicators which could be used to more effectively monitor changes to wilderness character. This monitoring framework, which is consistent with Forest Service policy, is expected to be implemented on all National Forest System Wilderness in 2006 and 2007. The guidelines provided in this framework have been used to choose the appropriate indicators for wilderness character. For this analysis, the four qualities of wilderness (untrammeled, natural, undeveloped and outstanding opportunities for solitude or a primitive and unconfined recreation) are used as indicators to determine baseline (time of designation) conditions, establish existing conditions and compare the effects of the proposed alternatives. Regarding wilderness character, many of the wilderness areas in the eastern United States bear the imprint of substantial past human influence. However, this does not preclude

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their management as wilderness. It is not imperative that all such areas possess wilderness qualities in equal measure. What is important is that management of a given area serves to improve its wilderness character (FSM 2320.2). The presence of fallow fields or old roadbeds within the project area may detract from the undeveloped or untrammeled quality of wilderness. However, the primary stewardship challenge is to manage both the natural systems and the opportunity for primitive recreational experience - to ensure that these attributes improve over time. The ideal baseline for determining changes to wilderness character would be the conditions that existed at the time of the 1990 wilderness designation. However, the conditions at the time of wilderness designation are not readily or reliably identifiable for the Garden of the God’s, Lusk Creek and Bay Creek Wildernesses. Baseline conditions have been inferred from analyses completed prior to designation, from historical travel route maps and from discussion included in the 1992 Forest Plan. Where no prior data exists, information gathered post-designation has served as the baseline for this analysis. In accordance with the Forest Plan, wilderness areas on the forest are managed under the Recreation Opportunity Spectrum (ROS) class Semi-Primitive Non-Motorized. This class is made up of lands characterized by a “predominantly natural or natural appearing environment of moderate to large size”, where “interaction between users is low but there is often evidence of other users”. The area is managed in such a way that minimum onsite controls and restrictions may be present but is subtle. As mentioned previously, motorized use is not permitted (Forest Service ROS Guide 1982). The visual resources section of the FEIS provides additional information on the visual and ROS aspect of wilderness. The wilderness character indicators are described below. Additional wilderness-specific character information follows this discussion.

A. Wilderness Indicators 1. Untrammeled Condition

“A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain.” The Wilderness Act of 1964, Section 2c

“Untrammeled” is defined as unconfined or unhindered, and is a measure of the control or manipulation that modern human activities exert over the components or processes of ecological systems inside wilderness. The object of managing for an untrammeled condition is neither to stop ecological change nor to return an area to some historical condition, but rather to let change progress to whatever outcome might occur if unhindered by human influence (Landres et al. 2005). Some examples of management-related manipulation within wilderness includes actions such as igniting fire,

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mechanically reducing fuels, introducing plants or animals or applying herbicides and pesticides. An example of human manipulation that is not management-related would be the creation of multiple trails that negatively affect ecological processes. It is recognized that in the short term, all actions diminish the untrammeled quality of wilderness - even though they are intended to restore natural conditions and support the concept of natural quality of wilderness. However, in the long term, these actions may eventually lead to reduced trammeling. The intent of monitoring is to track significant manipulations such as reducing fire-accumulated fuels over a large area and not track small-scale manipulations (Landres et.al, 2005). Many past land uses have contributed to the untrammeled condition of wilderness within the analysis area. Surveys conducted pre-designation indicate that an average of 35 percent of the areas were fallow crop or pasture lands planted to pine during the first decades of Forest Service management. The buildings and other improvements that were once common throughout these areas are gone, but many wire fences, stone walls, roadbeds, cisterns and piles of fieldstones remain. Road-building and logging developed openings, as did the management of numerous small clearings for wildlife. Autumn olive, Japanese honeysuckle and other non-native species are common. At the time of wilderness designation, there was an average of 2.6 miles of old road per square mile in the Forest wilderness areas. In all three wilderness areas, there has been no road-building, timber-cutting or management of wildlife openings since designation in 1990. The portions of the old road network not being used as trails are naturalizing. Direct management actions have been concentrated on discouraging motorized use, protecting known populations of listed plant species and maintaining the designated trail system. Fire management policies in wilderness have the potential to limit natural processes. As no fire management plans have yet been completed for these areas, any wildfire would be suppressed. In the time since designation, few fires have occurred with little effect on the conditions within project area wildernesses. 2. Natural Condition The natural condition of wilderness is a measure of the effect that human activity has on the individual components of the natural community (Landres et al. 2005). This indicator examines the impairment of soil and water, wildlife, aquatic organisms and native and non-native plants. It is recognized that when natural conditions are manipulated for the purpose of restoring ecological systems, both anticipated and unforeseen impacts can occur (Landres et.al. 2005). By monitoring natural condition, managers can assess the physical effects of recreational use in wilderness. Past and present land use and management uses have affected the natural condition of the project area wildernesses, which were in private ownership prior to acquisition by the forest. Land use prior to acquisition included primarily small homesteads with networks

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of roads and plowed and grazed fields. These activities resulted in erosion, sedimentation into streams, disruptions in the distribution of native plant species and the introduction of non-native invasive species. When acquired by the Forest Service, road construction and maintenance continued, timber harvesting occurred on some acres, wildfires were suppressed, and non-native pine was planted to reduce erosion. All of these activities had effects upon the natural conditions in the areas that would become wilderness. In addition to the old roads, there were 24 miles of designated trails and some unknown amount of non-system trails. The old road system, the non-system trails and the designated trails combined to develop an extensive network where equestrians could ride in the wilderness. Equestrian use was relatively low when compared to current use. Since designation in 1990, the greatest changes to natural conditions within the Garden of the God’s, Lusk Creek and Bay Creek Wildernesses have come from recreational use. Recreational uses in wilderness include horseback riding, hiking, hunting and fishing and occasional camping. Perceptions of the impacts to natural condition vary among visitors. In the landmark work Wilderness Management it is reported that often what land managers perceive as degradation, soil loss or the introduction of non-native plants, is often less important to wilderness users who most often cite littering and noise as their chief concerns (Hendee, et al. 1990). For example, a visitor survey was conducted in 2000 that included visitors in all seven wildernesses on the forest. Overall, wilderness users were satisfied (good to very good ratings) with: scenery (100 percent satisfied), condition of the natural environment (92 percent) and condition of the trails (74 percent) (USDA Forest Service, 2000). Wilderness-wide, the following activities and/or conditions are currently affecting, or have the potential to affect, natural processes:

• Soil and water resources are affected. Major sources of sediment on forest lands in the project area are likely the facilities associated with transportation systems, mainly unimproved roads and trails (Soil and Water Resources, Chapter 3).

• Equestrian and hiker use of unimproved roads and trails exposes bare soil which

can lead to accelerated erosion (Soil and Water Resources, Chapter 3).

• Existing trails with a steeper gradient have a greater erosion potential than trails with a lower gradient and steep trails have higher potential for erosion (Soil and Water Resources, Chapter 3).

• Many of the trails and roads cross ephemeral, intermittent and perennial streams.

These crossings are direct points of sediment delivery. Localized disturbance to banks and channel substrate can occur. Trail crossings at larger stream channels

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can cut the banks causing them to become unstable and erode (Soil and Water Resources, Chapter 3).

• As trails conditions have deteriorated, users move to a parallel alignment –

increasing area exposed to erosion and results in multiple scars and un-necessary erosion. Given past experience with user created trails, there is no indication that non-system trails would not continue to proliferate (Soil and Water Resources, Chapter 3).

• Under wet soil conditions trails are more vulnerable to rutting, compaction and

erosions. Water is less likely to infiltrate the trail tread causing excess water to run off (Soil and Water Resources, Chapter 3).

• Trails in the wilderness areas are rutted, braided and have wide sections that

demonstrate accelerated erosion. These existing un-maintained trails do not have adequate drainage and erode providing more sediment to streams than maintained trails would in the long term (Soil and Water Resources, Chapter 3).

• Some existing heavy-used stock confinement areas are located within sensitive

riparian areas which could impair their filtering function (Soil and Water Resources, Chapter 3).

• Non-native Invasive species are found along travel corridors. Cross country travel

would result in the greatest spread of NNIS and extirpation of botanical individuals, populations and habitat of one or more of sensitive and forest listed botanical species may occur from the continuation of this use (Botanical Resources, Chapter 3).

• Disturbance to wildlife from human use associated with trails and cross country

travel may occur. In addition, reduction in available habitat from human disturbances associated with cross country travel may occur (Wildlife Resources, Chapter 3).

• Unauthorized motorized use (mostly ATV use) into wilderness is occurring.

The environmental consequences displayed throughout the resources that comprise the natural condition (soil, water, botany, aquatic and wildlife) indicate that management action is necessary to protect wilderness resources by eliminating, reducing or mitigating these impacts. 3. Undeveloped Condition “…an area of undeveloped Federal Land retaining its primeval character and

influence, without permanent improvements or human habitation…where man himself is a visitor who does not remain…with the imprint of man’s work substantially unnoticeable…” The Wilderness Act of 1964, Section 2c

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The undeveloped quality of wilderness monitors the presence and development level of trails, campsites and other structures that were built before wilderness designation - as well as those built since designation. A concern with this type of physical evidence is the impact on the opportunity visitors have to experience a primitive environment since wilderness is a place where the evidence of man is substantially unnoticeable (Landres et al., 2005, pp. iii, 15). At the time of wilderness designation, development included a network of old roads, designated trails and non-system trails. In addition to 2.6 miles per square mile of old roads, there were about 24 miles of designated trails and an unknown amount of non-system trails. The old road system, the non-system trails and the designated trails combined to develop a large network of areas where equestrians could ride. Because equestrian use was not restricted to trails, cross-country riding led to the creation of additional non-system trails. The use of the roads and non-system trails for recreational purposes within wilderness was consistent with the 1992 Forest Plan which stated, “Roads, some very good, some impassable, criss-cross the designated Wilderness on the Shawnee (averaging about 2.6 miles per square mile). Upon designation, all roads under Forest jurisdiction were closed to use by motorized and mechanical (e.g. bicycles) vehicles. Some of these roadways or road segments will be used for hiking or equestrian trails. Roads that are not converted to trails will be allowed to grow over. Some of these old roadways have stretches with significant soil erosion. These areas will be rehabilitated using tools and equipment having the least effect on the area’s Wilderness character. Wilderness trails will be managed to provide some challenge to the user but also provide for user safety” (USDA Forest Service, 1992, Shawnee National Forest Supplemental FEIS, C-21)”. Currently, management-related developments within wilderness considered to be necessary for the administration of wilderness are experience level 2 and 3 trails, old road beds being used as trails, directional signs, regulatory (trail or area closures) signs, stock-confinement areas with high lines and natural area boundary signs. Other evidences of man, not related to the management of wilderness include multiple user-created trails, deer stands and spray-painted rocks and live trees and graffiti (which have been used for directional purposes). In addition, unauthorized motorized use is occurring. Monitoring the size and extent of these recreational improvements indicate how the undeveloped aspect of wilderness character may be changing. For determining the environmental consequences to the “undeveloped” indicator, the size, extent and developed nature of the trail system, including stock-confinement areas is used. While Forest Service policy considers trails to be an acceptable improvement in wilderness, the standard of trail development and the extent of the system throughout an area can have an effect on visitors’ perceptions of development (Landres et al. 2005). There are currently about 90 miles of inventoried travel routes in the project area wildernesses (Table 35) that are primarily low-standard, minimally developed trails and former roads.

Table 35. Existing acreage and trail miles for each wilderness in the area.

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Wilderness Acres System Trail Miles

Non-System Trail Miles

System and Non-System Trail Miles

Garden of the God’s 3,997 14* 6 20

Lusk Creek 6,718 10 50 60

Bay Creek 2,769 0 10 10 Total 13,484 24 66 90

Garden of the God’s Wilderness The Garden of the God’s Wilderness is steep and rocky, and most of the trail system has been in place for a long time. New trail development has been fairly low, with only six miles of non-system trail. The forest has performed trail maintenance and several trails have been designated in the Garden of the God’s area since wilderness designation. There are no developed or engineered bridges in any of the wilderness areas. Overall, given the minimal amount of signing, maintained trails, user-created trails and the absence of stock confinement areas, the evidence of man’s work is minimal. Bay Creek Wilderness The Bay Creek Wilderness has ten miles of mostly old road that is used as trail. Given that directional signing is minimal, user-created trails have not proliferated, and there are no stock confinement areas, this wilderness displays the least evidence of man’s work. Lusk Creek Wilderness Of the three wildernesses, the Lusk Creek Wilderness displays the most evidence of man’s work. There are 60 miles of inventoried routes which include a combination of old roads and trails. There are stock confinement areas, natural area boundary signs, regulatory signs and some directional signs. The Lusk Creek Wilderness has the most miles of user-created trails. In addition, this wilderness has the most evidence of user-created signing which, as previously mentioned, is in the form of spray painted rocks and painted or graffiti-laden live trees. Regarding stock confinement areas, the forest has installed, or allowed the installation of, these areas of concentrated use to limit the effect of many users to relatively small areas. They also facilitate equestrian use by providing riders with a place to tether stock. Structures typically include a high line rope which is left in place for an extended period of time. There are currently nine stock-confinement areas that cover about 1.3 acres. Some of the structures, because of their location adjacent to trails, live water or scenic features, are considered to be substantially noticeable. These areas affect the undeveloped condition of the Lusk Creek Wilderness. This wilderness tends to receive the most use because of the presence of equestrian campgrounds located in close proximity to the wilderness boundary. The relationship between wilderness use and the opportunity for solitude is addressed in detail later in this document. Regarding trail development, the 1992 Forest Plan directs that trails within wilderness be managed at experience level 2 or 3. Such trails would characteristically be narrow, native surface paths and, at times difficult to follow, steep and rough. Such standards offer a measure of challenge to the wilderness recreational experience. Since the time that the

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1992 Forest Plan was written, research into trails in the eastern United States, on fine-textured soils similar to those on the Shawnee, shows that these routes often show signs of braiding, muddiness and erosion even at low to moderate levels of equestrian use (Marion 1994, Marion 2004,Aust et al. 2005). To provide an opportunity for anything above the lowest use levels, outside of the driest months of the year, soil properties in some places in the analysis area would benefit from trail surfacing. This may increase the trail experience level from the current 2’s and 3’s to an experience level 1. The addition of gravel to trail surfaces can increase the resilience of the trail to use by stock, eliminate muddiness and braiding and decrease trail width along muddy segments (Aust et al. 2005). 4. Solitude or Primitive and Unconfined Recreation The wilderness conditions, untrammeled, natural and undeveloped, all relate to the ecological condition of wilderness. The opportunity for solitude or a primitive and unconfined type of recreation is the condition related to the human experience of wilderness. While all wilderness visitors do not seek solitude or primitive and unconfined recreation, it is implicit in the law that managers should provide and protect these opportunities. Lusk Creek, Bay Creek and Garden of the God’s are all small compared to many western wilderness areas. The fact that they can’t offer the days of solitary travel and vastness of scale found in more remote country is not material to this analysis. Instead, it is the change since designation in the opportunity to find solitude or primitive and unconfined recreation and the effects of the alternatives upon these opportunities that our analysis focuses. Solitude is defined as the “state of being alone or remote from society.” The monitoring framework (Landres et al. 2005) elaborates: “Given the content of early wilderness writings, it is likely that solitude was viewed holistically, encompassing attributes such as separation from people and civilization, inspiration (an awakening of the senses, connection with the beauty of nature and the larger community of life) and a sense of timelessness (allowing one to let go of day-to-day obligations, go at one’s own pace and spend time reflecting).” Primitive recreation is both reliance on non-motorized and non-mechanized means of transport and reliance on personal skills to travel and camp in an area rather than relying on facilities or outside help. Primitive recreation in wilderness has largely been interpreted as travel by horse, foot and canoe which reinforces the connection to our ancestors and our heritage (Landres et. al. 2005 ). The term “unconfined” is freedom from societal or managerial constraints. It is the opportunity for physical and mental challenge associated with adventure and the opportunity to make mistakes, face and overcome obstacles (Landres et.al. 2005). There is a management dilemma when the objective is to have unrestricted and unconfined recreation while providing outstanding opportunities for solitude – when the demand for access to wilderness is high and supply is limited (Cole and Hammit 2000). Of the three wildernesses within the project area, the Lusk Creek Wilderness best fits this description.

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In terms of recreational use within wilderness, the direction in both Forest Service policy (FSM 2323.12, 1.3) and the 1992 Forest Plan is to maximize visitor freedom within wilderness and minimize direct controls and restrictions (USDA Forest Service, Shawnee Forest Plan, 1992, IV-113). Controls are to be applied only when they are essential for the protection of the resource and when indirect measures (such as educational programs) have failed. However, a minimum of adaptations should be employed in order to accommodate recreation within wilderness (FSM 2323.12, 3.). There is a management dilemma when the objective is to have unrestricted and unconfined recreation while providing outstanding opportunities for solitude – when the demand for access to wilderness is high and supply is limited. (Cole and Hammit, 2000) Of the three wildernesses within the project area, the Lusk Creek Wilderness best fits this description. Considerable research has examined the impact of large groups upon visitor wilderness experiences. Wilderness visitors generally say that encountering large groups reduces the feeling of wilderness. Numerous studies have been completed on group size limits as it relates to the wilderness experience. However, there are few studies on the influence group size has on the areas extent or intensity of ecological impact” – other than firewood use. Monz et al (2000) found that regarding management controls, limiting party size is an established and accepted visitor management technique used in wilderness. Reasons for limits are typically environmental impact, conflict between groups, conflict within groups, facility or site constraints, overall high use of the area, public complaints or pressure and consistency with neighboring wilderness areas. Monz et al (2000) also found that if the goal was to emphasize resource and experience protection, wilderness managers often impose group size limitations which emphasize smaller group size numbers. If the goal is to maximize access to wilderness, group size limitations would favor moderate to higher numbers. Finding the middle ground between the two, protection of resources while providing for opportunities, is the overall objective of this analysis. Current trends suggest that more managers are adopting party size restrictions and that the maximum allowable group size is getting smaller. In 1981, research indicated 46% of Forest Service and 43% of National Park Service wilderness had a maximum group size. Research in 1993 indicated that the percent had increased to 62%. In 2000, research by Monz et al. found that given the perception that larger parties have disproportionately high impacts, managers throughout the NWPS have moved towards more stringent group size restrictions As of 2,000 about 52% of wilderness areas had established some type of group size limit. Numbers of people vary from 6 to 60 with 10 being the most common limit. Horse and packstock limits range from 5 to 35 with a median of 15. Heartbeat limits range from 8 to 25 with a median of 15.

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For this analysis, comments received from scoping on the subject of group size and wilderness experience were mixed. While some visitors (primarily equestrians) did not see the need for group size restrictions, many visitors did respond that having group size restrictions would maintain or improve their wilderness experience. Conflict between groups from having to share trails that were muddy and often laden with manure appeared to be more of an issue than group size. This conflict has resulted in numerous public complaints and pressure for action. In accordance with the 1992 Forest Plan, less restrictive methods should be tried prior to the resorting to the type of system that limits all use. A more restrictive type of system is commonly referred to as a permit or quota system. This management strategy issues a set number of permits to control the number of visitors entering or utilizing wilderness on any given day. The forest believes a group size limitation is the better option for maintaining and improving the opportunity for solitude or primitive and unconfined recreation. For purposes of this analysis, the amount of the Congressionally designated wilderness area that is at least 1/8 or 1/4 of a mile from a trail or road, the total number of users, group size limits and encounter rates would affect the opportunity for solitude. The criteria of 1/8 and 1/4 of a mile were used to display the area that would likely provide the most solitude, even during high use periods. These criteria are not meant to define solitude, but to offer some measurable insight into areas that allow visitors to experience different levels of isolation, closeness to nature, tranquility and challenge. Generally, in Southern Illinois with our rolling hills, bluffs and hollows, if a person is 1/8 of a mile from a trail (660 feet) they would be out of the sightline of other users. At the 1/4 mile a user would probably be out of sight and sound of the trail. These measures were designed to show differences among the alternatives in the opportunity for solitude away from the developed trail system. However, it is important to note, that throughout much of the year, ample opportunity for solitude also exists on the trail system. The opportunity for primitive recreation could likewise be affected by the level of trail experience and the presence of structures or amenities designed to accommodate recreation. Unconfined recreation could be affected by the level of management restriction placed upon users.

B. Wilderness Existing Condition

1. Garden of the God’s Wilderness The Garden of the God’s Wilderness is about seven miles southeast of Harrisburg, Illinois. The wilderness is very scenic, with unique rock formations and a mature hardwood (oak-hickory) forest. Regarding the untrammeled nature of this wilderness, the landscape has been affected by past land uses. Fire, logging and farming occurred prior

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to the 1930’s. Many old homesites and scars from miles of un-surfaced primitive roads remain. About 14 percent of the area was planted in non-native pine plantations that are now maturing. The Garden of the God’s area was used for camping, picnicking, hiking and riding from the days prior to Forest proclamation. A camp offering facilities for equestrians has been in operation near the area since the 1960s. The Garden of the God’s Wilderness contains about 4,000 acres split between the Big Grand Pierre and Eagle Creek watersheds. It wraps around three sides of the Garden of the God’s Recreation Area. With a campground, picnic facilities, two trailheads, an interpretive trail and a large paved parking lot, this Recreation Area is the most heavily used on the forest. Over 150,000 people annually visit the Garden of the God’s Recreation Area and the nearby wilderness trails are sometimes heavily used by hikers. Most of the wilderness can be viewed from several overlooks on the popular interpretive trail in the Garden of the God’s Recreation Area. The River-to-River Trail transects the wilderness east and west and is popular with both equestrians and hikers Presently there is little development of the trail system and no structures exist in the wilderness to support recreation. There are fourteen miles of designated trail in this wilderness, including about two miles of hiker-only routes (please refer Table 35). In addition, about six miles of non-system trail are present in the wilderness. A long loop is available for equestrians and hikers in the eastern portion of the wilderness. Shorter loops are also available for hikers. Trails are generally single tracked although at times wider than the 24 inch width standard for wilderness. Sections of braided trail do exist along with areas of muddiness excessive steepness. More detailed information on the untrammeled, natural condition and undeveloped qualities of this wilderness, please refer to Section A. Wilderness Indicators. Currently, there are few management restrictions and there is ample opportunity for primitive and unconfined recreation. Few directional signs exist, there are trails with steeper grades and water crossings are un-developed which enhances the opportunity for challenge. Opportunities for solitude are most abundant as one gets away from the recreation area. For those visitors who may be concerned with shared use trails, hiker only trails currently exist which may increase the perception of solitude for some visitors.

2. Lusk Creek Wilderness The Lusk Creek Wilderness is about 12 miles south of Harrisburg, Illinois. The scenic nature of the area is due, in part, to the bluffs and clear waters of Lusk Creek that extend north to south for about six miles within wilderness. Regarding the untrammeled nature of this wilderness, the landscape has been affected by past land uses. Fire, logging and farming occurred on much of the area prior to the 1930’s. Many old homesites remain discernable as do miles of old, un-surfaced roads. Cisterns, wells, fences and burial plots are also located in proximity to these old homesites. Non-native plants and trees exist that are left over from the area’s agricultural past.

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When acquired by the Forest Service, road construction and maintenance continued, timber harvesting occurred on some acres and about 23 percent of the area was planted in non-native pine to reduce erosion. Many small wildlife openings were managed in the forested area to provide food and cover for wildlife. Ponds were built and maintained for habitat improvement. Erosion was evident on many miles of old roads. At the time of designation, the Lusk Creek Wilderness had visible past land use. Since wilderness designation, there has been no additional road building, timber cutting or management of wildlife openings. However, there are several non-federal land in-holdings in the Lusk Creek Wilderness. Roads (considered to be non-conforming uses within wilderness) are utilized to access private property. Overall, the area was, and continues to be, a popular destination for equestrian users. There are many geologic, biological and ecological values within this wilderness. Indian Kitchen is a state nature preserve and popular destination because of the scenic beauty of the bluffs and Lusk Creek. Lusk Creek Canyon (including state and federal property) is a national natural landmark. Several natural areas are located within the wilderness. Lusk Creek (from bank to bank) is the only one with a system trail: the River-to-River Trail crosses east-west through the wilderness. Lusk Creek is most likely the forest’s second most-visited wilderness due to its scenic beauty, relatively large size (6,700 acres) and its proximity to several commercial equestrian campgrounds. At the time of wilderness designation there was an average of 2.6 miles per square mile of old road in wilderness areas on the forest. Much of the old road system is now being used as part of the trail system. The portions of the old road network not being used as trails are naturalizing. Direct management actions have concentrated on discouraging motorized use, protecting known populations of listed plant species (through the signing and management of natural areas) and maintaining the designated trail system. Of the three wildernesses, the Lusk Creek Wilderness displays the most evidence of man’s work. There are ten miles of system trails and fifty miles of non-system trails (please refer Table 35). Many of the trails display the effects of moderate to heavy use on poorly designed and located facilities. Trail widening, braiding, erosion, compaction and muddy conditions, which affect the natural condition of this wilderness, exist in many areas. Equestrian use is allowed on system and existing non-system trails and cross-country. This type of use has affected the undeveloped aspect of wilderness as user-created trails have proliferated. For detailed information on the natural condition of this wilderness, please refer to the previous section. In addition, there are two old roads leading to private lands in Lusk Creek Wilderness. Fore more detailed information on the untrammeled, natural and undeveloped nature of the Lusk Creek Wilderness, please refer to Section A. Wilderness Indicators. Regarding the opportunity for solitude, a recent study conducted in Lusk Creek Wilderness indicated about 8,800 visitors (7,600 equestrian visitors and 1,200 pedestrians) visited this area from March of 2003 through February 2004 (Chilman,

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2005). The primary use seasons were fall and spring, followed by summer. Only 15 percent of the total equestrian use occurred during the winter months (Table 34). Table 34 displays that weekend use is high from March through October. However, use throughout the week is much less during the winter months of November through February. Although use is highest in this wilderness, opportunities for solitude both on and off the designated trail system are readily available. One threat to the opportunity for solitude that currently exists is both the authorized and unauthorized vehicle, ATV and bicycle use that is known to occur on roads or trails within the Lusk Creek Wilderness.

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Table 34. Distribution of 7,613 horseback riders in Lusk Creek.

Months Est. Horseback Riders

Weekends

Horseback Ave/weekend

day

Est. Horseback Riders week

days

Horseback Ave/week day

March 280 35 120 6 April 308 39 600 30 May 392 49 418 21 June 432 54 648 32 July 192 24 0 0

August 112 14 221 11 September 512 64 475 24

October 364 46 1932 97 November 437 55 0 0 December 80 10 0 0

January 0 0 0 0 February 90 11 0 0

Total 3199 4414 Regarding the opportunity for unconfined and primitive recreation, there are some management restrictions – primarily related to the management of the natural areas for the protection of key ecological resources. No group size limitations or restrictions on use currently exist. Few directional signs exist, there are trails with steeper grades and water crossings are un-developed which enhances the opportunity for challenge. Cross country use, which has resulted in the proliferation of non-system trails, currently offers both equestrian and hikers the most freedom possible for pursuing challenge and for reliance on personal skills.

3. Bay Creek Wilderness Bay Creek Wilderness is about eight miles south of Harrisburg. It is most likely the least visited of the three. It is characterized by Bay Creek and its headwater tributaries and is primarily hardwood forest (oak-hickory). Regarding the untrammeled nature of this wilderness, the landscape has been affected by past land uses, including fire, logging and farming prior to the 1930’s. There are about 570 acres (21 percent) of non-native, planted pine trees. Within the wilderness are cisterns, old fencerows, old homesites and the remnants of unsurfaced roads. Near the time of designation, visitor use of the Bay Creek Wilderness was surveyed (McCurdy et al. 1994). At that time it was found that most of the use in the area was foot-travel associated with hunting. Because of the low visitor use in the wilderness, opportunities for solitude were most likely readily available and not dependent upon the timing of use. Solitude was most likely readily available both on and off the trail system for both equestrians and hikers. Although it was possible to meet others off-trail, it was very unlikely. The effects of recreational use are less apparent in the Bay Creek Wilderness when -compared to the other project area wildernesses. There may be less use because this area does not contain the scenic bluffs and water sites that are known to attract visitors to

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specific locations. During trail surveys conducted in 2003-2004 it was noted that equestrian use appears most prevalent in the southeast portion of the area. During the surveys, no recreationists were encountered in any portion of the wilderness. Fewer miles of trail were found during the 2003-2004 surveys than were reported in the McCurdy study from 1994. Some evidence of unauthorized use by ATVs was also found in this area. Outside of the autumn deer-hunting seasons, this wilderness appears to receive much less use than either the Garden of the God’s or Lusk Creek Wilderness. The Bay Creek Wilderness, due to its minimal amount of use, offers ample opportunities for solitude both on and off the existing trail routes. Within the Bay Creek Wilderness, there is little development of the trail system and a minimal amount of trail maintenance has been performed. There are no miles of designated trail in this wilderness and ten miles of non-system trail (please refer Table 35). No other structures, such as directional signs and no stock confinement areas, exist in the wilderness to support recreation. Regarding opportunities for primitive and unconfined recreation, trails with steeper grades are present and water crossings are un-developed which enhances the opportunity for challenge. Trails are mostly on old roadbeds but in other ways exhibit characteristics of a more primitive single-track, being difficult to follow in some areas. Use of the area requires some ability to navigate, and it can be a challenge to locate and stay on trails. Currently, cross-country riding is minimal and appears to be a minor component of recreational use in this wilderness. This use has not resulted in the development of new trails. There are no natural areas included in this wilderness; therefore, there are no restrictions to access or movement by foot or with stock. Primitive and unconfined recreation is readily available. Additional information on the untrammeled, natural condition and undeveloped qualities of this wilderness, please refer to Section A. Wilderness Indicators.

Direct and Indirect Effects on Wilderness Character 1. Untrammeled Condition All Alternatives For each wilderness within the project area, the signs of past land-use would continue to fade into obscurity. The fallow fields and wildlife openings would be allowed to progress without management intervention to whatever vegetative characteristics they will assume. Roads would be allowed to continue to naturalize through the growth of vegetation and leaf-fall. Those that have been used as trails, but are not designated, would be closed and rehabilitated in all alternatives. The proposed actions which include trail management (designation, maintenance and construction) and designation of stock-confinement areas would have an effect on the untrammeled character of wilderness. There would be effects in the short term (up to five

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years) from construction and maintenance activities; however, in the longer term (up to 15 years), these actions should improve the untrammeled nature of wilderness by reducing the effect of equestrian use on the overall ecological processes. Of the 9 existing user-developed stock confinement areas in Lusk Creek Wilderness Area, 1 will be reduced in size, 2 relocated and consolidated into 1 area, 2 more relocated, and 4 eliminated (see Table 5). Map 2-C in Appendix A shows where in Lusk Creek Wilderness Area the 4 confinement areas proposed for Alternative 2 will be located. The confinement area at Saltpeter Cave and Natural Bridge will be consolidated and relocated into a nearby pine plantation. The Indian Kitchen and Owl Bluff areas will also be relocated into pine plantations. The confinement areas will have highlines that are less intrusive than hitching racks in keeping with the wilderness (see also FEIS, Soil and Water Resources, and Recreation and Trail, Chapter 3). The elimination, consolidation, and relocation of stock confinement areas will have a positive effect on the untrammeled condition of Lusk Creek Wilderness Area. The Illinois Department of Natural Resources (comment letter, November 2005) acknowledged that “stock confinement areas are necessary as part of the infrastructure supporting equestrian trails” and supported the action proposed for stock confinement areas, especially the relocation of the Indian Kitchen confinement area. Compared with the No Action alternative or elimination of stock confinement in wilderness areas, the relocation and redesign of existing areas will provide more benefit to the untrammeled condition of the Wilderness. Fewer acres will be affected, and the effects will be mitigated and controlled, rather than randomly spread throughout the wilderness. Left unmanaged (personal tethers, for example), ecological processes of wilderness are more likely to be impacted as riders naturally tend to re-use sites, or may inadvertently use sites that are poorly located from a wilderness resource protection point of view. The notion of eliminating existing confinement areas, only to allow users to create new areas, defies common sense. Eliminating confinements from wilderness entirely would be tantamount to elimination of equestrian access to wilderness. Thus, we agree with the Illinois Department of Natural Resources that confinements are necessary. Considerably more risk to the environment (e.g. ecological processes) is presented by allowing riders to continually find and populate their own rest sites, compared to allowing less than one acre of Wilderness to be managed for this purpose. Confinement areas are a necessary and essential part of managing recreation use to protect wilderness values. The 1.24 acres of user-developed stock confinement areas presently in Lusk Creek Wilderness Area will be reduced to 0.8 acres of the 6,718 acre wilderness, so less area is affected (0.0001 percent of the Lusk Creek Wilderness Area). Redesign and relocation of these areas will have short term effects, but over time would diminish soil, water, and visual effects. Ecological processes will continue unhindered by human activity in more of the wilderness as a result of Alternative 2. The consolidation and relocation of the Saltpeter and Natural Bridge confinement areas into a pine plantation allows restoration of 0.3 acres of floodplain and native vegetation. The Secret Canyon confinement area

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will be reduced from 0.3 to 0.1 acres. Indian Kitchen and Owl Bluff confinement areas will be relocated to benefit the environment and wilderness values. These 4 areas, effecting less than one acre of wilderness, are necessary to protect the untrammeled condition of the Wilderness. The small fraction of area and resources are affected by this proposal is consistent with the Wilderness Act Section 4(c) (Wilderness Working Paper). There are no stock confinement areas proposed in Alternative 2 for the Bay Creek or Garden of the God Wilderness Areas. The remaining stock confinement areas will be located outside of wilderness, and therefore will have no effect on the untrammeled condition of wilderness in the project area. In addition to the proposed trail-management activities, non-native invasive species adjacent to the trail would be controlled manually or by some other means compatible with wilderness. The effects of removing non-native plants would likely be restricted to local areas of infestation. Overall, this would be considered a small-scale manipulation when the actual area treated (trail corridors) is considered in context to the wilderness-wide acreage. The effect to the untrammeled character of wilderness would be minimal and would maintain or improve the natural condition of wilderness. All action alternatives should provide some benefit to the untrammeled condition of wilderness relative to the time of designation. Sedimentation of streams should be reduced compared to 1990 levels because of the drainage and maintenance work that will be accomplished. In addition, the reduction in travelways should lessen the human disturbances of wildlife in wilderness. This should reduce the level of impact on the ecological processes in wilderness relative to the time of designation. Alternative 1 Alternative 1 would continue to perpetuate human manipulation within wilderness. While direct management actions such as fire ignitions or fuels reduction are not in the reasonably foreseeable future, the continuation of cross country travel on non-system trails would continue to affect and diminish the untrammeled nature of each wilderness. This effect would be higher in the Lusk Creek Wilderness which currently has 50 miles of non-system trails and a history for user-created trails to proliferate. Within 13,484 acres of wilderness, 90 miles of trail would be authorized. However, with no means to control the creation of new trails, additional wilderness acreage, which is currently un-disturbed, would likely be impacted - until the decision has been made that excessive resource damage is occurring. Only upon reaching this threshold would the trails be closed. Alternative 2 Alternative 2 would reduce the impact to the untrammeled nature of wilderness by reducing trail mileage and restoring un-necessary trails. This also benefits other wilderness qualities such as natural condition. Within 13,484 acres of wilderness, about 49 miles of trail would exist. Because cross-country equestrian use would be eliminated, the potential for user-created trails to become established on undisturbed areas would be reduced. Overall, the untrammeled quality of the Bay Creek and Garden of the God’s

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wilderness would be maintained or improved while in the Lusk Creek Wilderness this indicator would be improved. Alternative 3 Even though Alternative 3 increases the miles of trail that becomes part of the designated system (from 22 miles to about 73 miles), the impact to the untrammeled nature of wilderness would benefit most from the elimination of cross country equestrian use – particularly in the Lusk Creek Wilderness where user-created trails have proliferated. About 73 miles of trail would be distributed within 13,484 acres of wilderness. In the long term, the closing and restoration of 24 miles of trail throughout each wilderness would further reduce the impact to the untrammeled nature by restoring natural processes. Alternative 4 Alternative 4 benefits the untrammeled nature of wilderness most by significantly reducing trail mileage and restoring non-system trails. This benefits other wilderness qualities such as natural condition. About 25 miles of trail would exist within 13,484 acres of wilderness. Similar to Alternatives 2 and 3, this alternative eliminates cross-country equestrian use and reduces the potential for user-created trails to impact undisturbed areas. Overall, the untrammeled quality of the Bay Creek and Garden of the God’s wilderness would be maintained or improved. In the Lusk Creek Wilderness this would be, in the long term, significantly improved. 2. Natural Condition All Alternatives In all alternatives, visible remnants of past land use and management, such as recovering farmlands, roadbeds and pine plantations, have an adverse effect on the natural condition of wilderness. Erosion is evident on many miles of old roads. Non-native plants and trees are present in old homesteads. Over time, many of these effects would fade into the landscape as trees mature and vegetation becomes re-established within the old roadways. In all alternatives, authorized motorized access to private land in-holdings would continue in Lusk Creek. Those access roads in poor condition would continue to have an adverse effect on wilderness natural condition through erosion and sedimentation. These roads also break up the natural appearance of the area and are obvious signs of human manipulation of the landscape. Authorized motorized access would continue to have an adverse effect on the natural condition in all alternatives. Likewise, any future occurrences of unauthorized motorized use within wilderness is likely to adversely affect natural processes because the trail system would not be designed to facilitate and minimize the impacts of such use. All action alternatives should provide some benefit to the natural condition of wilderness relative to the time of designation. Visible erosion and the current obtrusive stock

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confinement areas should be lessened. Sedimentation of streams should be reduced compared to 1990 levels because of the drainage and maintenance work that will be accomplished. In addition, the reduction in travelways should lessen the human disturbances of wildlife in wilderness. This should reduce the visible level of impact on the wilderness natural condition relative to the time of designation.

0

20

40

60

80

100

120

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Mile

s of

Tra

ilNon-system Trails

Proposed System Trails

Figure 26. Comparison of total system and non-system trails in wildernesses in the project area in each alternative.

Alternative 1 In Alternative 1, guided commercial recreation use from campgrounds would be restricted to system trails and roads. All other equestrian use would be allowed on non-system trails and cross-country. Soil, water, aquatics, botanical and wildlife resources are the components that make up the natural condition of wilderness. Overall, the use on non-system (unmaintained) trails and cross-country equestrian use pose the greatest threat to then natural condition of wilderness within the project area. Although the Lusk Creek Wilderness shows the most evidence of cross-country use, the potential for negative effects also applies to Bay Creek and Garden of the God’s. Implementation of Alternative 1 would result in the continued use of many non-system trails that could not be maintained and would continue to erode and deliver sediment to streams. Over time, it is likely that many non-system trails would be closed and rehabilitated. However, the threshold at which they become closed is when resource degradation becomes evident. By the time the closures are put in place, the natural condition would be negatively impacted. There is considerable evidence within the project area that as trails conditions deteriorate, users move to a parallel alignment. This would increase the area exposed to erosion and results in additional multiple scars and unnecessary erosion (DEIS, p. 64) In terms of soil and water resources, the environmental consequences displayed for this resource show that Alternative 1 would result in the most adverse effects. Any decline in erosion and sedimentation from closed trails would likely be counterbalanced by an increase in erosion and sedimentation from new trails that are likely to appear (DEIS, p.

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71). Stock confinement areas would continue to be compacted and would continue to reduce the infiltration capacity of the soil which increases runoff and erosion. The riparian component of the natural condition of wilderness would continue to be impacted by the location of some stock confinement areas (USDA Forest Service, 2005, DEIS, p. 67-69). For aquatic resources, the deterioration of non-system trails would lead to increased sedimentation downstream of the project area. Several Forest-listed aquatic species would be negatively affected (DEIS, pp. 87, 90-91). For botanical resources, the extirpation of individuals, populations and habitat of one or more of sensitive and forest listed botanical species from continuation of cross country travel may occur (Botanical Resources, Chapter 3). With regards to non native invasive species, Alternative 1 would result in the greatest spread of NNIS since cross country equestrian use could continue to facilitate their spread via non-system trails and off-trail use (DEIS, p. 103). Alternative 1 would not reduce the potential for disturbance to wildlife from human use associated with trails and cross country travel.. In addition, reduction in available habitat from human disturbances associated with cross country travel may occur (DEIS, p. 115-116). Alternative 1 would implement a wet-weather closure for 24 hours after one-inch of rain for guided commercial equestrian use. Under wet soil conditions trails are more vulnerable to rutting, compaction and erosions. Water is less likely to infiltrate the trail tread causing excess water to run off (DEIS, p. 62). The wet-weather closure for guided commercial equestrian use would reduce adverse effects of equestrian use on trails – a benefit to the natural condition. However, since this only applies to guided uses, impacts from general equestrian use is likely to continue. Overall, implementation of Alternative 1 would result in an adverse effect on the natural condition of wildernesses in the project area. When compared to the other alternatives, it would have the most significant adverse effect. Alternatives 2, 3 and 4 In all action alternatives, both general public and guided equestrian use would be restricted to using designated trails. This would eliminate cross country use as well as use of non-system (un-maintained) trails. These uses pose the greatest threat to the soil and water, aquatic and botanical resources that make up the natural condition of wilderness. In terms of soil and water resources, the environmental consequences displayed for this resource show that Alternatives 2-4 would have fewer adverse effects because the trails chosen for designation would be mitigated and maintained. This would reduce erosion rates (DEIS, p. 71).

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Trail maintenance and construction and the designation of stock confinement-areas would have a short-term adverse effect on the natural condition. Bare-soil exposure may be evident on newly constructed or reconstructed trails or in confinement areas, leaving soils vulnerable to erosion (Cole 1987). However, soil and water impacts from stock confinement areas would be mitigated by reducing the size and relocating some sites out of riparian filter strips. This would reduce the erosion and sedimentation potential of the site and protect riparian health – an overall net benefit to the natural condition of wilderness (USDA Forest Service, DEIS, 2005, p. 69) Trails would be graveled to reduce trail widening and lessen erosion, thereby improving wilderness resource condition. Selected trees could be cut for trail improvements or to clear confinement areas, exposing freshly cut stumps. The bare-soil exposure, graveled trails and cut vegetation associated with construction and reconstruction could cause direct adverse effects in the short term. In addition, trail maintenance would cause some soil disturbance and slight increase in soil erosion (DEIS, p. 64). However, in the long term, these effects would be expected to be negligible. For aquatic resources, trail drainage and maintenance would greatly reduce the trail area and sediment draining directly into stream channels by re-directing runoff into a vegetated buffer. Further armoring of the crossings with gravel or cobble would reduce substrate erosion (DEIS, p. 69). However, a more extensive trail system would also cross from ephemeral, intermittent and perennial stream channels in the watershed. Additional un-maintained crossings supply more sediment directly to the stream system. More miles of trail expose a larger area to erosion and compaction (DEIS, p. 62). Alternative 4 would have the most beneficial effect to this component of wilderness natural condition. While Alternative 2 would also result in beneficial effects, Alternative 3 would have the least benefit as tributary areas outside of wilderness would be unprotected. Regarding forest-listed aquatic species, Alternatives 4 and 2 provide the most beneficial effects due to less trail miles, fewer crossings, the elimination of many non-system trails and maintenance of the remaining trails. Alternative 3, which increases trail mileage, would adversely affect some aquatic individuals (2005, DEIS, pp. 87-93). For botanical resources, the extirpation of individuals, populations and habitat of one or more of sensitive and forest listed botanical species from continuation of cross country travel may occur (DEIS, p. 100). With regards to non native invasive species, Alternative 1 would result in the greatest spread of NNIS since cross country equestrian use could continue to facilitate their spread via non-system trails and off-trail use (DEIS, p. 103). In the long term, Alternative 2 and 4 benefit wildlife most by reducing the area affected by forest visitors in terms of disturbance and acres of habitat affected (DEIS, p. 116). Seasonal and wet-weather closures are features of Alternatives 2 and 4 for the Lusk Creek Wilderness. These closures are intended to mitigate impacts to soils. They are to be temporary, lasting until completion of the work necessary to establish and harden the

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primary trail system with gravel. It is estimated that this work would be completed in two or three years, dependent upon levels of funding and staffing. In Alternative 2 the Lusk Creek Wilderness would be closed to stock use from December 1 through March 31, in contrast with Alternative 4, which imposes a closure from November 1 through May 15 (the period when soils are most susceptible to wet season-related effects). Both Alternative 2 and 4 also contain a wet-weather closure for 24 hours following a precipitation event of 1 inch or more during April and May, October and November. Under wet soil conditions trails are more vulnerable to rutting, compaction and erosion. Water is less likely to infiltrate the trail tread causing excess water to run off (DEIS, p. 62). Alternative 2 contains a shorter seasonal closure, accepting a degree of effect in favor of including additional opportunities for early and late season riding. In the short term, the wet-weather closure for would reduce adverse effects of equestrian use on trails. In the long term, there should be minimal effects from this use since the trails would be designed to withstand wet weather. However, Alternative 3 does not include a seasonal or wet-weather closure for the Lusk Creek Wilderness. The potential for equestrian use to degrade sub-standard trails when they are in a wet condition is likely to result in additional soil degradation if use occurs during these periods – until they are brought up to standard. All three action alternatives locate (close, reduce or relocate) stock confinement areas to minimize soil erosion and limit the area affected by compaction. Each action alternative would benefit the natural condition of wilderness by reducing the potential for erosion and sedimentation (from compaction) and protect riparian health ((Soil and Water Resources, Chapter 3). Overall, when the environmental consequences to soil and water, aquatic, botanical and wildlife resources are reviewed, those alternatives that propose the least number of trail miles, the least number of stream crossings and the elimination of equestrian cross country (and non-system trail use) benefit the natural condition of wilderness most. While Alternative 1 has the most adverse effects to natural processes, Alternative 4 provides the most benefit – due to the minimal number of trails which results in fewer water crossings. Alternative 2 provides more benefit than Alternative 3 primarily because of the substantial difference in the miles of trail and stream crossings. 3. Undeveloped Condition All Action Alternatives The action alternatives propose to close and rehabilitate about 48 miles of trails in Alternative 2, about 22 miles in Alternative 3 and about 54 miles in Alternative 4. Initially, the focus on closing non-system trails would concentrate on their junctions with the designated trail system. In the first year or two these trail connections would be obscured with brush to hide their existence and discourage their use. At the same time, rehabilitation would focus on stabilizing any actively eroding trail sections. Remaining trail sections would be abandoned and allowed to revegetate naturally. The closure

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process in all action alternatives should be completed in three to four years. There would be direct (up to five years) effects from trail closure activities, including brush-cutting for screening and ground-disturbance for erosion control. However, indirectly these actions in the long term (up to 15 years) should improve the undeveloped nature of wilderness, reduce the effect of recreational use (over a large portion of wilderness) and be substantially un-noticeable. Each action alternative varies in the miles of designated trail. Although trails are an appropriate structure or improvement in wilderness, more trail miles would be further evidence of man’s work and would affect undeveloped character. However, when considered in the larger context of each wilderness (its total acreage), the trail systems, in each alternative, would have a relatively minimal effect on the undeveloped condition of the wilderness (FSM 2309.18.2). Trails maintenance would incorporate some features of experience level 1. However, they would appear to visitors to be experience level 2 or 3 and meet wilderness character objectives. The trail corridors would be relatively small (4-8 feet), with vegetation growing back along the edges after initial clearing. The trail-tread width (area of bare soil or gravel) would be small (12-24 inches). Initially the gravel would be evident; but, over time, most would become packed into the dirt and the trail tread would appear to be a small ribbon of exposed soil. In the short term, gravelling would also be expected to increase the perception of development or be a deviation from the natural appearance expected within wilderness. This effect would be mitigated by choosing naturally occurring, dark colored gravel. After one or two seasons of use the gravel would work into the trail surface and appear, to most users, to be a native surface. Muddy and braided sections of trail would be narrowed to a firm walking surface, decreasing the perception of development. In the long term, the use of gravel material to fortify tread should be substantially un-noticeable. All action alternatives remove the ability camp with stock in wilderness. This would preclude the potential for currently undisturbed areas from being impacted and becoming substantially noticeable. However, the potential for new areas of disturbance to occur from backpacking use would remain. All action alternatives should provide some benefit to the undeveloped condition of wilderness relative to the time of designation. Impacts from visible erosion on the old travelways and the obtrusive stock confinement areas should be lessened. Sedimentation of streams should be reduced compared to 1990 levels because of the drainage and maintenance work that will be accomplished. The reduction in travelways, relative to the time of designation, would have the greatest impact on the undeveloped condition. Based on information in the 1992 Forest Plan FEIS and the 1979 Fralish and Sudalnik wilderness evaluation project, the project area wildernesses contained about 50 miles of old roads and about 25 miles of designated trail, at the time of designation. Additionally there were probably close to 30 miles of non-system trail in the project area wildernesses in 1990. All told there were nearly 100 miles of old travelways in the project area at the time of designation. The action alternatives propose a varying level of developed trail:

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Alternative Two proposes a 49 miles of trail

(about a 50% decrease from the time of designation), Alternative Three proposes a 73 miles of trail

(about a 27% decrease from the time of designation), Alternative Four proposes a 25 miles of trail

(about a 75% decrease from the time of designation).

This reduction in travelways should provide a visible decrease in the amount of development within the wildernesses relative to the time of designation. Since the time of designation, the level of equestrian use and concurrently the level impacts from the travel network has undoubtedly increased. With the action alternatives all restrict equestrian use to a designated trail system that would represent less development that existed in 1990. There would be a substantial improvement in the undeveloped condition of project area wildernesses. Alternative 1 Alternative 1 designates no new trails. Other than undesignated trails in natural areas, riding would be available on most wilderness acres. Because they cannot be maintained, many trails would likely deteriorate, triggering closure. However, when this decision is made, excessive resource damage would likely have occurred. Only upon reaching this threshold would the trails be closed. The perpetuation of eroded and degraded trails would be negative evidence of man’s impact and would continue to adversely affect the undeveloped aspect of wilderness. Given past experience with the proliferation of user created trails, particularly within the Lusk Creek Wilderness, this evidence of man (or impact) is likely to increase. An unending management loop of closure and trail formation is likely, unless the area is closed to the use. Emphasis for management in such areas would shift from the trail system to compliance and law enforcement. In this alternative, trails would only be maintained to experience level 2 or 3, which would not provide a sustainable trail system. The lack of stabilization could cause sections of accelerated erosion which negatively affects the undeveloped character of wilderness. Trails would be closed or use would be greatly restricted to prevent resource damage. This alternative would be the least expensive to build and maintain, but the most expensive to regulate. In Alternative 1, no changes are proposed to the current stock-confinement areas in the Lusk Creek Wilderness. They would continue to be sources of erosion that adversely affect the undeveloped condition because some confinement areas would continue to be highly visible (substantially noticeable). Alternative 1 would not address the lack of directional signage which has resulted in significant (although un-authorized) evidence of man – spray painted rocks and live trees and graffiti. Although actions would likely be taken (through routine wilderness management) to remove these intrusions, it is unlikely to solve the need for some level of signing.

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Overall, it is expected that this alternative would result in adverse effects on the undeveloped character of wildernesses in the project area. Alternative 2 Alternative 2, the preferred alternative, proposes 49 total miles of designated trail in project area wildernesses (Table 36). It also limits equestrians to designated trails. The designation, maintenance and construction would lead to a sustainable trail system that could support the current and expected amount of equestrian use without evident resource effects. It would be less intrusive than the current network of trails. In addition, trail system maintenance would be accomplished to ensure that the trail system would not be a dominant feature of the wilderness landscape. The designation and maintenance of a sustainable trail system would reduce the impact (visible excessive erosion, muddiness, etc) that currently exists to the undeveloped character of wilderness.

Table 36. Wilderness trail miles in the project area by alternative.

Alternative Wilderness

1* 2 3 4 Garden of the God’s 20 15 15 8 Lusk Creek 60 25 48 12 Bay Creek 10 9 10 5

Total 90 49 73 25 * Trail miles for Alternative 1 include system and non-system trails.

Stock-confinement areas would be relocated, reduced in size or eliminated in order to reduce their effects on wilderness resources such as soils, water and riparian areas. A total of four confinement areas would remain after reducing and consolidating existing areas – a decrease from the nine that currently exist. Stock-confinement areas would be less visually intrusive because many would be reduced in size and several would be removed from proximity to scenic features. Stock-confinement areas in wilderness would be reduced by about 40 percent, from the current 1.3 acres to about 0.8 acres. This action would reduce the level of development in wilderness and make the confinement areas less noticeable. As noted above, stock confinements are a necessary element to managing livestock use in wilderness. Alternatives, including elimination of confinement areas in wilderness, were considered. In the absence of the four confinement areas proposed, the effects on wilderness resources (vegetation, visuals, soil, water) from random user-created rest sites (using personal tethers or temporary hitches) throughout wilderness would be greater than for the 0.8 acre of confinement areas.. Some method of providing rest stops must be provided in conjunction with equestrian access to wilderness areas. Although other methods were analyzed, a small number of discretely located and small in size confinement areas was found to be both necessary and the minimal requirement for

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managing recreation use in these three wildernesses. To protect the undeveloped character of wilderness, the 4 proposed confinements will be kept at the minimum size and capacity necessary to accomplish their intended purpose. Trail-density standards would be eliminated in Alternative 2. Overall trail density in Alternative 2 would be about 2.8 miles per square mile in the project area wildernesses (Table 37). There would be about 2.4 miles per square mile in Garden of the God’s, about 2.4 miles per square mile in Lusk Creek, and about 2.1 miles per square mile in Bay Creek. While these trail densities are higher than the current standard of one mile of designated trail per square mile, they substantially lessen the overall travelways available for equestrian use in wilderness. The designated trail system in this alternative would be properly constructed and maintained to lessen the visual effect of the trails on the undeveloped condition of the wildernesses. Relative to the time of wilderness designation, there would be a reduction in the amount of travel routes available, which would improve wilderness character. The trail density standards of the 1992 Forest Plan are eliminated by Plan amendment in Alternative 2. (Likewise, trail density standards were proposed to be dropped from the revised plan, due to be finalized in 2006.) When the 1992 Plan was developed, trail density was thought to be a surrogate for protecting undeveloped condition and solitude in wilderness management. Protection of the undeveloped character of wilderness is a complex and evolving area of science. We are aware of the competing methodologies available to evaluate various means of protecting wilderness. Clearly, in the project area, the trail density limit failed, as the miles of user-created trails increased dramatically in the project area despite the trail density limit, which applied only to designated trails. Considering user-created trails, the “real” or on-the-ground existing trail density is 4.3 miles per square mile as opposed to the proposed 2.4 miles per square mile under Alternative 2. Ending cross-country riding and creation of user-developed trails under Alternative 2 will have an on-the-ground or practical effect of reducing trail density, even though the Forest Plan limit is eliminated. Although we have sought diligently, we have no evidence to show that retaining trail density will provide a greater degree of wilderness protection compared to proper trail design and location. Although some comments opposed the Plan amendment eliminating trail density, we could find no logical or credible reason in the comments for modifying this aspect of Alternatives 2 and 3. Plan amendment is designed to allow reasonable access while protecting the undeveloped character of the wilderness. The current density standards are too restrictive and would confine equestrian use onto too few trails, undermining the environmental benefit this project is intended to achieve. With more than a decade of hindsight, we see that the trail density standards adopted so long ago were not firmly rooted in science or logic. Like other aspects of the 1992 Forest Plan currently under revision, trail density standards, recognized now as impotent to protect the undeveloped condition of wilderness, have become archaic.

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Table 37. Wilderness trail miles and trail density by alternative.

Trail Miles* and (Trail Density) by Alternative Wilderness Acres Square

Miles 1 2 3 4

Garden of the God’s 3,997 6.25 20 (3.2)

15 (2.4)

15 (2.4)

8 (1.3)

Lusk Creek 6,718 10.5 60

(5.7) 25

(2.4) 48

(4.6) 12

(1.2)

Bay Creek 2,769 4.33 10 (2.3)

9 (2.1)

10 (2.3)

5 (1.2)

Totals 13,484 21.08 90 (4.3)

49 (2.3)

73 (3.5)

25 (1.2)

* For Alternative 1, system and non-system trail miles are included. **Density is calculated by dividing the trail miles by the square miles Physical factors of trail layout such as isolating trails by geography and using vegetation to isolate trails have been employed in the design of the trail system. Trail signing would be minimized in wilderness to reduce signs of human development. Some natural area signing would be done with natural materials, but the bright yellow carsonite posts would be removed. Existing informal signing, including spray-painted trees and rocks, would be removed or cleaned. While the number of structures such as signs would increase, they would reduce the existing impact that currently exists on the undeveloped quality of wilderness. In addition, the reduction in trail miles results in fewer trail junctions which further reduces the volume of signing needed. Overall, it is expected that this alternative would result in beneficial effects on the undeveloped character of wildernesses in the project area. Alternative 3 Alternative 3 contains the greatest number of miles of designated trails in wilderness and would be less effective at mitigating impacts to the undeveloped condition than Alternatives 2 or 4. With 50 percent more trail miles, the trail maintenance and trail construction effects of this alternative would be somewhat larger than Alternative 2. Trail-density standards would be eliminated in this alternative, and the proposed wilderness density would be about 3.5 miles per square miles. This alternative accepts more of the existing trail system than any other alternative, so the isolation of trails is not as great as in Alternatives 2 and 4. The designated trail system in this alternative would be properly constructed and maintained to lessen the visual effect (of the remaining trails) on the undeveloped condition of the wildernesses. Six stock-confinement areas in Alternative 3 would cover about one acre. The stock-confinement areas in the riparian areas would be reduced in size to meet Plan standards and guidelines for bare area in filter strips. These areas have more effect and would be more visually evident in this alternative than in either Alternatives 2 or 4. They would

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have a greater effect on the undeveloped condition of the wildernesses than in Alternatives 2 and 4 but less of an effect than Alternative 1. Trail signing would be minimized in wilderness to reduce the signs of human development. Some natural area signing would be done with natural materials, but the bright yellow carsonite posts would be removed. Existing informal signing, including spray-painted trees and rocks, would be removed or cleaned. While the number of structures such as signs would increase, they would reduce the existing impact that currently exists on the undeveloped quality of wilderness. However, the miles of trails (which are higher than in Alternatives 2 and 3) would require a larger volume of signage since more trail junctions would become part of the designated system. Overall, it is expected that this alternative would result in minimally adverse effects on the undeveloped character of wildernesses in the project area. Alternative 4 Alternative 4 would provide about 25 miles of system trail in the project area wildernesses. This alternative would preclude cross-country riding and decrease the existing trail mileage in both wilderness and natural areas. Trail maintenance and trail construction effects would be similar to Alternative 2, except that there would be about 57 percent fewer trail miles. A trail-density standard of about one mile per square miles would be applied to each wilderness in this alternative, and the proposed wilderness density would be about 1.2 miles per square miles. This alternative accepts the least amount of the existing trail network of the alternatives, so the isolation of trails is greater than in Alternatives 2 and 3. The designated trail system in this alternative would be properly constructed and maintained to lessen the visual effect of the trails on the undeveloped condition of the wildernesses. Relative to the time of wilderness designation, there would be a large reduction in the amount of travel routes available. Four stock-confinement areas in Alternative 4 would occupy about 0.9 acres. The stock-confinement areas in the riparian filter strips would be reduced in size to meet Plan standards and guidelines for bare area in filter strips. The four areas would be moved away from scenic features and moved to less visible places. These confinement areas would have less effect on soil, water and riparian resources and would not be as visually evident (substantially noticeable) in this alternative when compared to Alternative 3. Alternative 4 would have a beneficial or positive effect on the undeveloped condition of the wildernesses from reduced trail miles and structures, when compared to the other action alternatives. Physical factors of trail layout such as isolating trails by geography and using vegetation to isolate trails have been employed in the design of the trail system. Trail signing would be minimized in wilderness to reduce the signs of human development. Some natural area signing would be done with natural materials, but the bright yellow carsonite posts would be removed. Existing informal signing, including spray-painted trees and rocks, would be removed or cleaned. While the number of structures such as signs would slightly increase, they would reduce the existing impact that currently exists on the

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undeveloped quality of wilderness. In addition, the significant reduction in trail miles results in few trail junctions which reduces the volume of signing needed. Overall, it is expected that this alternative would result in the greatest beneficial effect on the undeveloped character of wildernesses in the project area. D. Solitude or Primitive and Unconfined Recreation All Action Alternatives In all action alternatives, group size restrictions would apply. While this restriction increases management control and reduces the unconfined nature of wilderness (free from restrictions), the size restrictions should improve the feeling of solitude for those visitors who believe that large groups diminish their experience. The group size limitations combined with improved trail conditions should indirectly improve experiences by reducing environmental impact and conflicts between groups – particularly in the Lusk Creek Wilderness. The range of group sizes proposed throughout the alternatives is well within the group sizes that have been typically documented within wilderness (Chilton, 2005). Minimal adverse effects to the opportunity for primitive and unconfined recreation are expected. In all action alternatives, the threat to solitude and the wilderness experience from the un-authorized use of ATV’s within wilderness may decrease from increased Forest Service presence (which provides both education and law enforcement) during project implementation and monitoring. In addition, trail reconstruction techniques would be used, where feasible, to make it more difficult for ATV’s to travel on designated trails. All action alternatives should provide some benefit to the opportunities for solitude or primitive and unconfined recreation condition of wilderness relative to the time of designation. With the decrease in travelways (50% in Alternative 2, 27% in Alternative 3, and 75% in Alternative 4) the opportunity for solitude or primitive and unconfined recreation will be increased away from the trail system. However, the concentration of users on the trail system will have an adverse effect on those users who use the trail system. There will still be ample opportunity for solitude or primitive and unconfined recreation on the trail system for much of the year. However, when use is the highest (April and October) encounter of other groups on the trail system would increase. 1. Garden of the God’s Wilderness Alternative 1 Alternative 1 proposes no changes for the Garden of the God’s Wilderness. For those visitors who associate interactions with other groups as affecting their opportunity for

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solitude, Alternative 1 has the least opportunity for hikers traveling off trail as it is possible that equestrians may be encountered. Solitude for all equestrians (both guided and general public) is available off-trail only in this alternative. Ample opportunities for solitude or primitive and unconfined recreation is expected to remain, particularly as visitors travel away from the developed recreation site because overall use is lighter in these outlying areas Opportunities for primitive and unconfined recreation would remain. No directional signs would exist, there would be trails with steeper grades and water crossings would be un-developed - which enhances the opportunity for challenge. Management control would continue to be minimal. However, if user created trails degrade to the point of closure (from cross country use) it is expected that trails would be closed. The opportunity for unconfined recreation would be reduced in order to protect other aspects of wilderness character. In the context of the entire 3,997-acre wilderness and assuming that no trails become closed, no effects are expected from Alternative. Alternative 2 Many of the trails in this wilderness are located near the developed recreational site, so the acreage and percentage of the area that is remote, trail-less wilderness is a good indication of the area where the opportunity for solitude is greatest.

Table 38. Remote area without trails in the Garden of the God’s wilderness.

Remote/Trail-less Wilderness Garden of the God’s Wilderness

Acres and (Percent of Area) Alternative

Distance from nearest trail or

Road 1 2 3 4

⅛ mile 1626 (41%)

2023 (51%)

2023 (51%)

2619 (66%)

¼ mile 535 (13%)

789 (20%)

789 (20%)

1264 (32%)

Alternatives 2 and 3 have the same acreage and percentage of area that is remote and trail-less and, therefore, the same opportunity for solitude. About 51 percent of the area is removed further than an eighth of a mile from a trail or road and 20 percent further than a quarter of a mile. Alternative 2 would restrict equestrian use to a 15-mile system of designated trails. It places a group-size restriction of ten persons on all wilderness users and precludes camping in wilderness with stock. This alternative would remove the opportunity for a remote, trail-less experience for equestrians. While many people find adequate solitude and challenge without leaving the trail, the lack of choice for equestrians may diminish the experience for some. Hikers willing to get away from the developed recreational site are still likely to find outstanding opportunities for solitude along designated trails,

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although those willing to hike cross-country would have even greater opportunities (because they would be much less likely to encounter other visitors). Opportunities for primitive recreation would remain. While additional directional signs would exist and extreme trail grades would be reduced, water crossings would remain primitive (no engineered structures across the water) - which would retain the opportunity for challenge for all visitors. There would still be ample opportunity for hikers to test their personal skills by traveling cross-country. Management control would increase. While group size restrictions would apply to all visitors, no camping with stock and the elimination of cross country use for equestrians is likely to diminish (more-so than hikers) the ability to seek unconfined recreation. Overall, in the context of the entire 3,997-acre wilderness, minimal adverse effects are expected for both equestrians and hikers from Alternative 2. Alternative 3 Alternatives 2 and 3 have the same acreage and percentage of area that is remote and trail-less and, therefore, the same opportunity for solitude. About 51 percent of the area is removed further than an eighth of a mile from a trail or road and 20 percent further than a quarter of a mile. The effects of Alternative 3 are similar to Alternative 2, as the trail system proposed is the same. Alternative 4 Alternative 4 restricts equestrian use to eight miles of designated trail in the wilderness. Alternative 4 offers the greatest opportunities for solitude for cross country hikers, because about 66 percent of the area would be more than an eighth of a mile from a trail or road and 32 percent would be further than a quarter of a mile from any road or trail. However, the diminished availability of trails in this alternative would increase the likelihood that hikers and equestrians encounter one another while using the trail system. Restriction of group size to eight persons may be perceived by some as a reduction in the sense of crowding while others would see it as an unnecessary confinement. Alternative 4 likely would constrain the equestrian experience to a greater degree than the other three alternatives and, thereby, reduce the opportunity for primitive and unconfined recreation. Hikers would have the beneficial effect of the greatest area available for primitive and unconfined recreation in this alternative when compared to all other alternatives. 2. Lusk Creek Wilderness Alternative 1 There are no changes proposed to the trail system in Alternative 1. The opportunity for solitude in Lusk Creek Wilderness is currently affected by the 60 miles of trail that provide access to most areas of the wilderness. About seven percent of the wilderness is further than a one-quarter of a mile from any road or trail and about 25 percent of the wilderness is further than one-eighth of a mile (Table 39) from any road or trail. The opportunity for solitude is enhanced on and off trails from a variety of physiographic factors, with the presence of bluffs, hills, ravines and dense vegetation. Factors that may

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decrease the feeling of solitude include the presence of roads within and adjacent to the wilderness boundary, vehicle access on authorized interior roads and unauthorized use by ATV’s or mountain bicycles. Guided equestrian use from commercial camps would be restricted to system trails and roads, reducing the opportunity for primitive recreation for these users. All other (non-guided) horseback riders and hikers would continue to have ample opportunity for primitive and unconfined recreation off of the trail network. Management control would remain minimal and focused on protecting natural areas. However, if user created trails degrade to the point of closure (from cross country use) it is expected that trails would be closed which would reduce the opportunity for unconfined recreation in order to protect other aspects of wilderness character. In Alternative 1 a minimal amount of directional signs would exist, there would be trails with steeper grades and water crossings would be undeveloped - which enhances the opportunity for challenge. In the context of the entire 6,718-acre wilderness, minimal effects to both equestrians and hikers are expected from Alternative 1.

Table 39. Remote area without trails in Lusk Creek Wilderness.

Remote/Trail-less Wilderness Lusk Creek Wilderness Acres and (Percent of Area)

Alternative Distance from nearest Trail or

Road

1 2 3 4

⅛ mile 1,702 (25%)

3,358 (50%)

1,943 (29%)

4,671 (70%)

¼ mile 459 (7%)

1424 (21%)

630 (9%)

3,049 (45%)

Alternative 2 Alternative 2 would provide in Lusk Creek Wilderness 25 miles of system trail (Table 37), including about 1.25 miles of hiker-only trail. Equestrian use would be restricted to system trails. Under this alternative, a group-size restriction of ten persons would be placed on all wilderness users and camping in wilderness with stock would not be allowed. Under Alternative 2, hikers willing to get away from the trail system are likely to find outstanding opportunities for solitude. The trail system proposed under this alternative would increase the amount of remote, trail-less wilderness. About 35 non-system trail miles would be closed and rehabilitated. There would be about 21 percent of the wilderness that is further than one-quarter of a mile from a road or trail and about 50 percent of the wilderness that is further than one-eighth of a mile (Table 39). In addition, during the temporary seasonal trail closure (December 1 – March 31), hikers would have reduced encounters in wilderness and are likely to experience better trail conditions. This may improve a sense of solitude or improve the wilderness experience. This alternative would remove the opportunity for a remote, trail-less experience for equestrians. While many people find adequate solitude and challenge without leaving the

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trail, the lack of choice for equestrians could diminish the experience for some. However, solitude would be available at many times along the trail system for equestrian users particularly during the week days and during the winter months (table 34) after the lifting of seasonal closures. Under all action alternatives, monitoring use and numbers of encounters on system trails would document long-term changes and visitor perceptions. In Alternative 2, the potential numbers of trail encounters are expected to be more than in Alternatives 1 and 3, and less than in Alternative 4, based on the miles of trail available to disperse use. Management control would increase and the opportunity for unconfined recreation would decrease in order to protect wilderness character. Although the group size limitation as well as the seasonal restriction to stream crossings in least brook lamprey habitat would apply to all users, the restriction of equestrians to designated trails, the temporary seasonal restrictions, the requirement to utilize stock confinement areas and the elimination of the opportunity to camp with stock would increase the perception of management control for some equestrian users. Alternative 2 is expected to result in the adverse effect of diminished opportunities for primitive and unconfined recreation for equestrians. In terms of retaining skills and challenge, additional directional signs would exist and extreme trail grades would be reduced. Water crossings would be primitive (no engineered structures across the water) - which would retain the opportunity for challenge for all visitors. There would still be ample opportunity for hikers to test their personal skills by traveling cross-country. Overall, the opportunity for primitive and unconfined recreation for hikers would be minimally affected or enhanced. Alternative 3 In Alternative 3, all equestrian use would be restricted to system trails in wilderness, with no cross-country use. A total of 48 miles of system trail would be improved and maintained in the Lusk Creek Wilderness (Table 38). Under this alternative, a group-size restriction of twenty persons would be placed on all wilderness users, and camping in wilderness with stock would not be allowed. The trail system proposed under this alternative would slightly increase the amount of remote, trail-less wilderness when compared to Alternative 1. About 22 non-system trail miles would be closed and rehabilitated. About nine percent of the wilderness is further than one-quarter of a mile from a road or trail and about 29 percent of the wilderness is further than one-eighth of a mile (Table 39). Solitude also would be available at many times along the trail system. The extent of the trail system has the potential to disperse use over more miles. However use is expected to continue to concentrate at popular, scenic areas. Monitoring use and numbers of encounters on system trails would be conducted to document or respond to long-term changes in use and visitor perceptions. In Alternative 3, the potential numbers of trail encounters is expected to be more than in Alternative 1, and less than in Alternatives 2

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and 4 (based on miles of trail available). Environmental consequences as they relate to management control, the opportunity for solitude and unconfined recreation are the same as displayed in Alternative 2. Alternative 4 The trail system proposed under this alternative would greatly increase the amount of remote, trail-less wilderness. About 50 non-system trail miles would be closed and rehabilitated. About 45 percent of the wilderness would be further than one-quarter of a mile from a road or trail and about 70 percent of the wilderness would be further than one- eighth of a mile (Table 39). Alternative 4 restricts equestrian use to about 12 miles of designated trail in the wilderness. The diminished availability of trails in this alternative would increase the likelihood that hikers and equestrians encounter one another while using the trail system. The group size limit of 8 persons could constrain some users, even while it may reduce perceptions of crowding for others. Environmental consequences as they relate to management control, the opportunity for solitude and unconfined recreation are the same as displayed in Alternative 2 and 3. However, Alternative 4 is expected to constrain the equestrian experience to a greater degree than the other three alternatives and, thereby, reduce the opportunity for primitive and unconfined recreation, an adverse effect for equestrians as well as hikers who prefer trails. Cross-country hikers would have the greatest area available for primitive and unconfined recreation in this alternative as compared to all other alternatives, a beneficial effect for them. 3. Bay Creek Wilderness Alternative 1 Alternative 1 proposes no changes for the Bay Creek Wilderness. Some visitors associate interactions with other groups as affecting their opportunity for solitude. For these visitors, Alternative 1 has the least opportunity for hikers traveling off trail because equestrians may be encountered. Solitude for all equestrians (both guided and general public) is available off-trail only in this alternative. Ample opportunities for solitude or primitive and unconfined recreation is expected barring a sharp increase in the amount of use. Opportunities for primitive and unconfined recreation would remain. No directional signs exist, there would be trails with steeper grades and water crossings would be un-developed - which enhances the opportunity for challenge. Management control would continue to be minimal. However, if user created trails degrade to the point of closure

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(from cross country use) it is expected that trails would be closed. The opportunity for unconfined recreation would be reduced in order to protect wilderness character. In the context of the entire 2,769-acre wilderness, minimal effects are expected from Alternative 1. . Alternative 2 Alternative 2 would restrict equestrian use to a nine-mile system of designated trails. It places a group-size restriction of ten persons on all wilderness users and precludes camping in wilderness with stock. This alternative would remove the opportunity for a remote, trail-less experience for equestrians. While many people find adequate solitude and challenge without leaving the trail, the lack of choice for equestrians could diminish the experience for some. Hikers would still be likely to find outstanding opportunities for solitude along designated trails; although those willing to hike cross-country would have even greater opportunities because they would be less likely to encounter other visitors. In addition, during the temporary wilderness-wide seasonal trail closure (December 1 – March 31), hikers would have reduced encounters in wilderness and are likely to experience improved trail conditions. Monitoring use and numbers of encounters on system trails would document long-term changes and visitor perceptions. Because the miles of trail and the current levels of use are minimal, the potential numbers of trail encounters may be indistinguishable between Alternatives 1 through 3 and the most in Alternative 4, based on the minimal (five) miles of trail available to disperse use. See table 36.

Table 36. Wilderness trail miles in the project area by alternative.

Alternative Wilderness

1* 2 3 4 Garden of the God’s 20 15 15 8 Lusk Creek 60 25 48 12 Bay Creek 10 9 10 5

Total 90 49 73 25 * Trail miles for Alternative 1 include system and non-system trails.

Management control would increase and the opportunity for unconfined recreation would decrease in order to protect other attributes of wilderness character. Although the group size limitation as well as the 1 location where a seasonal restriction to stream crossings ( in least brook lamprey habitat) would apply to all users, the restriction of equestrians to designated trails and the temporary wilderness-wide seasonal restrictions would increase the perception of management control for some equestrian users. Although there is little evidence that camping with stock occurs, the fact that it has been eliminated may increase this perception.

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In terms of retaining skills and challenge, directional signs would be installed and extreme trail grades would be reduced. Water crossings would be primitive (no engineered structures across the water) - which would retain the opportunity for challenge for all visitors. There would still be ample opportunity for hikers to test their personal skills by traveling cross-country. In terms of solitude, Alternative 2 is expected to provide outstanding opportunities for hikers on both designated trails and more remote and trail-less acreage. For equestrians, Alternative 2 diminishes the opportunity for solitude because the trail-less experience is eliminated. However, given the low amounts of use that occur in this wilderness, ample opportunities should still exist. Overall, Alternative 2 is expected to result in the adverse effect of diminished opportunities for primitive and unconfined recreation for equestrians. For hikers, the opportunity for primitive and unconfined recreation for hikers would be minimally affected or enhanced. Alternative 3 Alternative 3 adds one mile of trail, offering another loop opportunity in the wilderness. The effects of this alternative are similar to Alternative 2, although the additional trail would offer slightly more freedom for equestrians and slightly less remote, trail-less wilderness for hikers (Table 40). Remote, trail-less wilderness area that is further than a quarter of a mile or an eighth of a mile away from a trail or road is 13 percent and 44 percent, respectively.

Table 40. Remote area without trails in Bay Creek Wilderness.

Remote/Trail-less Wilderness Bay Creek Wilderness Acres and (Percent of Area)

Alternative Distance from Nearest

Trail or Road

1 2 3 4

⅛ mile 1192 (43%)

1320 (48%)

1219 (44%)

1925 (70%)

¼ mile 295 (11%)

428 (15%)

369 (13%)

1371 (50%)

Alternative 4 Alternative 4 would restrict equestrian use to the five miles of designated trail in the southeast portion of the wilderness that appeared to be receiving the greatest amount of equestrian use in 2004. The diminished availability of trails in this alternative would increase the likelihood that hikers and equestrians encounter one another while using the trail system. The group size limit of 8 persons could constrain some users, even while it may reduce perceptions of crowding for others. The likelihood that a hiker would encounter another visitor off-trail would be diminished, as 40 percent of the area would be farther than one quarter of a mile and 70 percent would be farther than one eighth of a mile from a road or trail. Alternative 4 is expected

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to decrease the opportunity for solitude on designated trails for all visitors, increase solitude off-trail for hikers, and constrain the equestrian experience to a greater degree than the other three alternatives. Overall, with regards to solitude, there would be an adverse effect for both hikers and equestrians on the designated trail system due to the minimal miles of trail. While a beneficial effect would be expected off-trail for hikers, the inability to travel cross country would be an adverse effect for equestrians – particularly since the available trails miles is minimal. Management control would increase and the opportunity for unconfined recreation would decrease in order to protect other attributes of wilderness character. Although the group size limitation as well as the one location where a seasonal restriction to stream crossings ( in least brook lamprey habitat) would apply to all users, the restriction of equestrians to designated trails and the temporary wilderness-wide seasonal restrictions would increase the perception of management control for some equestrian users. Although there is little evidence that camping with stock occurs, the fact that it has been eliminated may increase this perception. In terms of retaining skills and challenge, directional signs would be installed and extreme trail grades would be reduced. However, given the low trail miles, signs would be minimal. Water crossings would be primitive (no engineered structures across the water) - which would retain the opportunity for challenge for all visitors. There would still be ample opportunity for hikers to test their personal skills by traveling cross-country. However, Alternative 4 is expected to constrain the equestrian experience to a greatest degree than the other three alternatives and, thereby, reduce the opportunity for primitive and unconfined recreation - an adverse effect for equestrians as well as hikers who prefer trails. Cross-country hikers would have the greatest area available for primitive and unconfined recreation in this alternative as compared to all other alternatives, a beneficial effect for them.

Cumulative Effects on Wilderness The analysis of cumulative effects investigates the effects of the proposal in concert with all pertinent public and private sector actions, past and present, as well as those reasonably foreseeable. A list of past, present and reasonably foreseeable future actions within the project area can be found at the beginning of this chapter. The cumulative effects analysis for wilderness character focuses on the subset of these actions that have affected or could potentially affect wilderness. The legacy of homesteading, farming and the accompanying transportation infrastructure shaped the character of each of the three wilderness areas. After acquisition by the federal government further modification ensued by the creation of artificial ponds and open spaces for wildlife, the widespread planting of non-native pines, the construction of developed recreational facilities, fire suppression, some timber harvest and additional

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road building. All of these activities played a role in determining the base-line untrammeled, natural, and undeveloped character of the lands that were designated as wilderness in 1990 as well as the opportunities for solitude and primitive recreation to be found there. Concurrently on private land, actions were being taken that influenced the adjacent Forest. The development of private camping facilities, either through the construction of new camps or the addition of capacity to existing operations, has facilitated recreational use by those from outside the local area. The conversion of farms to residential properties has brought more people to live in close proximity to the Forest boundary and an incremental increase in the number of access trails leading from private lands. The widespread appeal of all terrain vehicles (ATVs) has led to incursions into wilderness. The inclusion of private lands within the boundaries of the Lusk Creek wilderness has allowed non-conforming uses such as landowner access. A list of past (within the last 5 years) and present actions is presented in Table 14. While agriculture and road maintenance have had a small level of sedimentation impact to wilderness (Soils and Water Resources, Chapter 3), the areas have been most heavily influenced by recreation-related actions by Forest managers and commercial operations on private land. These actions include the uses of system and non-system trails, cross-country riding, increases in use, trail closures, the creation of Stock-confinement areas, the issuance of recreation special use permits for recreational events and outfitter and guiding, and commercial operations on private lands. Summary of Cumulative Effects on Wilderness Resources Alternative 1 - Cumulative Effects on Wilderness In the long term, no action would have the most substantial effect on wilderness character. With minimal actions that would address resource degradation (from the continuation of cross country use and the use of trails in poor condition), visitor use would continue to impinge upon and degrade the physical, biological and social aspects of wilderness. Untrammeled Under Alternative 1 the historical factors, past agricultural, wildlife management, plantings of non-native species, and such, would continue to fade as natural processes dilute their effects. Much of the influence of the recreation activities from the last ten years would continue unabated. Although commercial users would not be able to ride cross-country they would continue to use a system ill-sited and designed for the purpose. Meanwhile, their non-commercial counterparts would continue cross-country use. Recreation would be expected to continue to influence the untrammeled characteristic of wilderness. The Bay Creek Wilderness would likely be least affected as it is the least used and is currently beyond the reach of much of the commercial traffic. In Garden of the Gods the location of the busiest developed recreation area on the forest next to the wilderness will continue to impact the condition of the trail system; however, most trails

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in the area are already designated and can be fixed. In Lusk Creek Wilderness the popularity of the area coupled with the level of commercial use will continue to produce impacts. The untrammeled nature of this area will also be influenced by the continuation of non-conforming uses such as the authorized access to private lands as well as the unauthorized use of all-terrain vehicles. Any natural fire ignitions in these wilderness areas would be suppressed as currently no plans are in place to allow such fires to occur naturally. The direct and indirect effects of Alternative 1 would combine with other past and present impacts to yield a c cumulative effect on the untrammeled character of area wilderness. Natural The natural condition of area wilderness areas are affected to a limited degree by influences that drain down from upstream. The effects of sedimentation from upstream roads and agricultural activities on private land have been discussed in the Soil and Water section of this chapter. The greatest influence to natural conditions stems from the continuing recreation use of the areas. Natural conditions in the Bay Creek Wilderness are being altered by the combination of authorized recreational use of the trail system by hikers and equestrians and the unauthorized use of all-terrain. Because the trail system here receives no maintenance, all uses have the potential to cause trail widening, to lead to trail erosion and to provide a vector for the spread of non-native invasive species. This area receives less scrutiny as it is farther from the majority of commercial equestrian camps and is relatively little used. While cross-country riding is available here, there is little evidence that it occurs frequently. The threats to its natural conditions have been generally less urgent. Because many of the trails in this wilderness are on fairly flat ridge tops an increase in the use of this area, from any combination of factors, could quickly lead to muddy, overly wide trails and the associated impacts to plants, soils and watershed. Most of the watershed upstream of the wilderness is private and some recreational use does occur on these lands. This proposal will not mitigate any impacts that may be occurring from this use. Alternative 1 contains no mechanism to address impacts to natural conditions in the Bay Creek Wilderness. The Garden of the Gods Wilderness sits at the top of the Eagle Creek and Big Grand Pierre Watersheds and is not effected by up stream uses on private lands. Impacts to the natural condition here are a product of the interaction of the historical uses described above, which occurred mostly before wilderness designation, coupled with the recreational uses occurring there today. Some cross-country riding does occur, along with some unauthorized ATV use. The area is within a half day’s ride of two commercial equestrian camps. Its proximity to a popular developed recreation makes the area popular with hikers and backpackers. Many of the shelter bluffs in the area, as well as some of the overlooks reveal the impacts associated with overnight camping. Management opportunities for maintenance are currently available along the designated trail system which comprises most of the trail in this wilderness. Alternative 1 proposes no mitigation for the approximately six miles of non-designated trail in this area. The

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cumulative effects to the natural conditions in Alternative 1 will largely be a function of the direct and indirect effects of recreational use. Natural conditions in the Lusk Creek Wilderness displays the effects from historical agricultural and wildlife management practices coupled with current recreational use. Additionally, non-conforming motorized access to private lands is impacting soils and plants in the east side of the wilderness. Most of the recreational impacts to natural conditions in this area are associated with current and past levels of recreational use. Alternative 1 does not address impacts to plants, water and soils and will, therefore, lead to a cumulative impact to natural conditions in this wilderness. Undeveloped Past management activities, both public and private have left a legacy of old road beds, artificial ponds, fence lines, foundations, cisterns and stone walls in all three wilderness areas. Some measure of development has been perpetuated by non-conforming motorized use in the Lusk Creek Wilderness and by unauthorized motorized uses in all three areas. Since designation additions to the developed character of wilderness have come largely from the signs (constructed and contrived with spray paint), confinement areas, highlines, campsites and overly wide and at times, overly abundant trails. The proximity to public or private trailheads generally exacerbates recreation influences with the Bay Creek Wilderness being less impacted than Garden of the Gods near the observation site, or Lusk Creek on its west side. Alternative 1 does not develop mitigations to deal with the recreation use that exists in these areas and so it is anticipated that while historical development abates with the passage of time the mechanism for increased recreational development will remain. Without the designation of trails, designed and located for their intended user group, additional trail proliferation is likely to occur. Alternative 1 will combine with past and present uses yield cumulative effects to the undeveloped character of all three wilderness areas. Opportunities for Solitude or a Primitive and Unconfined Recreation The opportunity for solitude within area wildernesses is influenced by a combination of sounds from within and out of the area and from encounters with other recreationists. All three areas are bordered partially by roads. Lusk Creek and the Garden of the Gods wildernesses have trailheads and campgrounds in the vicinity adding to the potential for disturbance. Authorized (although non-conforming) and unauthorized motorized use from motor vehicles causes both visual and noise intrusion. This analysis makes no proposal for sounds generated from outside of the wilderness. Neither does it address non-conforming means of access to private lands. Alternative 1 proposes no action to deal with encounter rates or group sizes of visitors within wilderness. While opportunity for solitude still exists in all wilderness areas, especially for those willing to time their use, Alternative 1 takes no action to preserve or enhance these opportunities. It leaves stock confinement facilities within sight and sound of popular scenic attractions, and in the case of the Lusk Creek Wilderness leaves trails in almost every part of the wilderness. Alternative 1 is expected to combine with other, non-recreational uses to create cumulative impacts to wilderness solitude.

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Unconfined recreation is currently available in all three area wildernesses for those equestrians who are non-commercial. With the exception of natural areas, non-commercial equestrians are welcome to ride just about anywhere they can get to. Those riding from commercial camps (the majority of use in the Lusk Creek Wilderness) must stay to the permitted trail system although there are enough miles of trail available that the confinement of experience is small. Those customers who ride with a guide and must stay on system trails will find their opportunities diminished. For hikers, all areas are available. As popular non-designated trails deteriorate past acceptable standards over time it is anticipated that some segments would be closed, increasing management control in wilderness and confining recreation. Impacts to unconfined recreation are direct and indirect effects of implementation and are not cumulative. Alternatives 2, 3 and 4 - Cumulative Effects on Wilderness Untrammeled The action alternatives each include measures that will decrease the effects of recreational use in wilderness. The elimination of cross-country riding and the management of a system of designated trails will mitigate the recreation effects, especially in the Lusk Creek Wilderness. While the trails will be an improvement, they are allowed by Forest Service policy (FSM 2320) as being necessary to achieve the recreational purposes of wilderness. Trammeling of wilderness from past actions and uses will continue to abate. Therefore, the implementation of an action alternative will not cause cumulative effects to trammeling in the wilderness. Natural The most pervasive impacts to the natural function of the wilderness areas are associated with current recreational use. Impacts have been recorded to plants, soils, water quality and the introduction of non-native invasive species. Alternatives 3, 2 and 4 restrict use a respectively decreasing system of trails that will be maintained to mitigate impacts. Although impacts will be greatly reduced there will be remain a measure of effect to these resources that when combined with the effects of unauthorized uses or effects from activities on private lands higher in the watersheds will produce a small measure of cumulative effect. Alternatives 2 and 4 have seasonal closures which may produce the added result of displacing use into the Burden Falls Wilderness during those times when project area wilderness is closed. Because trails in Burden Falls are not maintained this action could produce additional effects to natural conditions in that area. Monitoring conditions in Burden Falls is included in the Monitoring Plan. Undeveloped All action alternatives contain some level of development in wilderness from trails and from Stock-confinement areas. Levels are highest in Alternative 3 and lowest in Alternative 4. The Bay Creek Wilderness would go from no managed trail to having 9 miles, although little change will be noticeable. The Garden of the Gods Wilderness will remain much the same while the Lusk Creek Wilderness will have a nearly 50 percent

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decrease in overall trail mileage. The level of development in all wilderness areas will decrease as direct effect of implementation of any action alternative and will not combine with other past, present or reasonably foreseeable future actions to produce cumulative effects. Opportunities for Solitude or a Primitive and Unconfined Recreation Opportunities for solitude would increase for hikers in all action alternatives as the cross-country spaces between trails will not be available for riding. For equestrians and hikers who do not leave the trail system the opportunity for solitude is retained although on fewer miles of trail in Alternatives 3, 2 and 4, respectively. On most days of the year solitude would be available in wilderness; overwhelmingly in the Bay Creek wilderness while in Lusk Creek and the Garden of the Gods timing of use could be an important factor for solitude especially in April and October (See Table 36). Even in Alternative 3, with the least reduction in available trail mileage, users are more likely to encounter one another at scenic attractions during these popular use periods. Implementation of an action alternative is expected to produce a minimal impact to solitude for equestrians as they will be restricted to designated trails. This effect is most notable in Alternative 4 and least notable in Alternative 3. The opportunities for solitude for hikers who wish to get off the trail are somewhat the opposite, with Alternative 4 having more opportunities than 3. Alternative 2 provides trails to scenic destinations while still providing loops away from popular areas for those who wish to get away from others. Additionally, Alternative 2 retains large tracts of wilderness without trails for hikers to enjoy off-trail (see Tables 39, 40 and 41). All action alternatives impose group size restrictions to limit encounters with large groups. Opportunities for solitude will continue to be affected by influences outside the scope of this document. Non conforming motor vehicle access to private lands in the Lusk Creek Wilderness and motor vehicle, recreation area and other noises from outside all wilderness areas will continue. The continued issuance of special use permits for equestrian camping facilities near wilderness will make the areas available for more people. Additional monitoring will be required to determine if increases in use lead to unacceptable degradation of solitude. Implementation of Alternatives 3 and 4 would have slight effects to hikers or equestrians. Implementation of Alternative 2 would balance the effects between the two groups. All action alternatives would combine with the effects of actions outside of wilderness to produce minimal cumulative effect. Primitive and unconfined recreation for equestrians is effected most by the restriction to designated trails. This management action is deemed necessary to protect other facets of wilderness character and is most pronounced in Alternative 4 and least in Alternative 3. In all action alternatives challenge is retained as streams are crossed with fords and trail standards and signs are kept to the minimum necessary to protect wilderness values. Connecting trails together in a loop is more difficult in Alternatives 2 and 4 and will provide more challenge to those wishing to see the less-visited portions of wilderness. Management control of wilderness through signing, and access will also increase in all action alternatives. Effects to primitive and unconfined recreation are described further under Direct and Indirect Effects above. These effects will are not expected to produce

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cumulative effects when added to other past, present and reasonably foreseeable actions in the analysis area.

Appendix A Shawnee National Forest

Trails Designation Project, Phase 1

Minimum Requirement Rationale Garden of the God’s Wilderness Area

Lusk Creek Wilderness Area Bay Creek Wilderness Area

Introduction The Shawnee National Forest published a Draft Environmental Impact Statement for the Trails Designation Project, Phase 1 in September of 2005. In response to public comments on the DEIS, we have documented this minimum requirements rationale following the guidance provided in the Forest Service Minimum Requirements Decision Guide – U.S. Forest Service Guidelines (Arthur Carhart National Wilderness Training Center, 2005). Although not required by law, regulation or policy, a minimum requirements analysis process is recommended to determine if there is a need for action and to determine what method, tool, structure or installation is necessary in order to protect wilderness values (Forest Service, Arthur Carhart National Wilderness Training Center, 2005). While this process of formally documenting minimum requirements is not required by the Wilderness Act, regulations, or policy, we have taken this extra step to comprehensively document our consideration of minimum requirements to ensure that the alternatives in the EIS were consistent with the Wilderness Act. As noted on the first page of the Minimum Requirements Decision Guide – U.S. Forest Service Guidelines, the analytical outline suggested, as its name suggests, merely a guide to decision making. There is no legal requirement that the minimum requirements analysis be documented or described in any particular fashion. Neither law, nor policy or the Guide requires formal documentation of the minimum requirements inquiry. In response to public comments on the DEIS, this Appendix clarifies and better communicates the underlying rationale for the findings and determinations made by the interdisciplinary team during formulation of the DEIS. During the comment period, the public questioned the EIS’s minimum requirements analysis. Specifically, the public questioned whether the preferred alternative clearly set forth the rationale for actions taken in wilderness areas. Although the analytical components set forth in Minimum Requirements Decision Guide were more or less considered during the formulation of the DEIS, as noted in the public comments, compliance with the minimum requirements provision of the Wilderness Act was not well documented. The DEIS alternatives, however, mirror the Decision Guide. Based upon interdisciplinary team discussions and

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deliberations during DEIS development, this Appendix more formally documents the rationale with regard to minimum requirements for administration of the wilderness areas in the project area.

This Appendix does not introduce new issues, alternatives, data, or analysis. It simply distills, in one place in the record, the thought processes of the interdisciplinary team in the development of the DEIS. As such, the appendix is a logical outgrowth of the request by the public for better information on the rationale underlying the preferred alternative’s compliance with the Wilderness Act. We have improved documentation of this information for the convenience of the reader, and to better communicate the tradeoffs between alternatives and underlying rationale for the Selected Alternative. The purpose of this document is to better describe the underpinnings of the alternatives presented in the DEIS. The non-binding Decision Guide was used as the means to improve our communication of compliance with the Wilderness Act. The Selected Alternative reduces the environmental effects of recreation relative to the No Action Alternative, and this Appendix likewise serves that purpose. In this respect, the Appendix improves the analysis set forth in the DEIS, see 40 CFR 1503.4(a)(3), in response to public comments. Although insightful to the public, this appendix does not presently a serious different picture of the environmental consequences or analysis of the minimum requirements for administering wilderness set forth in the DEIS. The Appendix was prepared for clarification purposes and does not contain significant new information, 40 CFR 1502.9(c). This Appendix demonstrates to the public that the decision maker was fully informed of the tradeoffs involved in the various alternatives. The Wilderness Act has multiple references to the concept of determining what (if anything) constitutes the minimum necessary action. The concept of minimum requirements for the administration of wilderness is derived from Section 4(c) of the Wilderness Act of 1964:

“Except as specifically provided for in this Act, and subject to existing private rights, there shall be no commercial enterprise and no permanent road within any wilderness area designated by this Act and except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area.” (emphasis added)

From a detailed review of the proposed actions and public comment on the DEIS, we identified specific actions at both the programmatic and project level to ensure that all appropriate actions were reviewed. Identified actions included recreational improvements (trails, stock confinement areas, stream crossings, and signage), commercial equestrian outfitter/guide services, and existing non-conforming uses (road access to properties that existed prior to designation).

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This Minimum Requirement Rationale for the Shawnee National Forest Trails Designation Project is based upon the guidelines provided in the 2005, USDA Forest Service, Arthur Carhart National Wilderness Training Center, Minimum Requirements Decision Guide. The Minimum Requirements Decision Guide basically involves two sequential steps. We have broken step one into two sub-steps as explained below.

Step One - Determine whether action is necessary.

Step One (A) - Background This step involves answering a series of questions designed to provide an understanding of the wilderness resource. The first questions are designed to set the side-boards for the decision by looking at existing rights, laws, regulations and policies. The next few questions focus on the features that make the wilderness area unique such as the ecological, biological, geological, and historic significance of these areas. Another question examines the existing or foreseen threats to wilderness character. And the last looks at the users’ relationship to the wilderness area. Step One (B) - Wilderness Character Indicators This step would typically examine in depth each action proposed to determine whether that specific action would be necessary. However, since the action were proposed in the DEIS, we have taken a broad approach to this step. We have provided an in depth look into existing condition for each wilderness character indicator to display the current condition and the effects of the proposed actions. In the tabular review of each action found under Step Two, we provide further rationale for why each individual action was deemed necessary. Actions determine to be necessary are presented in tabular form along with the components of Step Two.

Step Two - Determine the minimum activity. Step two consists of an in depth review of the each proposed activity, including:

1) summary of step one determination of necessary 2) guiding laws, regulations, and policy 3) alternative actions considered, and 4) the interdisciplinary team’s rationale for proposing the activity.

(1) Step One (A) - Background 1. What are the valid existing rights that allows for consideration of actions involving Section 4c uses?

Lusk Creek Wilderness

Garden of the God’s Wilderness Bay Creek Wilderness

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All three wilderness areas are used by customers of the Commercial Outfitter/Guides. Current permits were issued under court order. Motorized access to private property within the Lusk Creek Wilderness. 2. Applicable laws and regulations.



The following are applicable to all three Wildernesses: Wilderness Act of 1964 Illinois Wilderness Act of 1990 Endangered Species Act Clean Water Act Clean Air Act National Forest Management Act National Environmental Policy Act 36 CFR, Part 219, 228, and 261 3. Applicable Standards and Guidelines and direction continued in agency policy, unit and wilderness management plans, etc.



The following are applicable to all three Wildernesses: Forest Service Manual 2323 Forest Service Handbook 2700 1992 Shawnee National Forest Plan

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4. What are the ecological, geological or other features of scientific, scenic or historical values?



Saltpeter Cave Camel Rock Bay Creek Lusk Creek Canyon Little Eagle Creek Mature Hardwood Forest Natural Bridge Scenic rocks and bluffs Lusk Creek Mature Hardwood Forest

5. What are the ecological and biological features?



Excellent water quality and excellent aquatic and riparian habitat

Sandstone glades and outstanding examples of erosion of the Caseyville escarpment

Streams in the project area have good water quality, aquatic and riparian habitat

Least brook lamprey habitat Standstone cliff and overhang communities

Least brook lamprey habitat

Sensitive botanical species Sensitive botanical species Rare plant species near wilderness boundary

Outstanding examples of streams of the Shawnee Hills and Ozark Plateau

Streams in project area have good water quality

Category VII perennial streams and Category VII springs

Garden of the God’s Ecological Area, Little Eagle Creek

Lusk Creek Canyon and Lusk Creek North Martha’s Woods

Sensitive species that are specific to this Wilderness

6. What are the historical values (the following may reflect social values more so than those with historical significance)?



The following are applicable to all three Wildernesses: Remnant homesites and associated infrastructure: cisterns, wells, fences and burial plots Evidence of past logging, fire, and farming Remnants of past agricultural practices (non-native plants and trees) Equestrian use has been a favorite mode of travel which predates the wilderness designation in 1990

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7. What are existing or potential threats to wilderness?



The following are applicable to all three Wildernesses: Soil and water resources are being affected. Major sources of sediment in the project area are likely from unimproved roads and trails. Excessive number of miles of non-system trail in wilderness. Improper location, lack of design for non-system stock confinement areas. Equestrian and hiker use of unimproved roads and trails exposes bare soil which can lead to accelerated erosion. Existing trails with a steeper gradient have a greater erosion potential than trails with a lower gradient and steep trails have higher potential for erosion. There are many trails that have excessive steep grades. Many of the trails and roads cross ephemeral, intermittent and perennial streams. These crossings are direct points of sediment delivery. Disturbance to banks and channel substrate can occur. Trail crossings at larger stream channels can cut the banks causing them to become unstable and erode. As trails conditions have deteriorated, users move to a parallel alignment – increasing area exposed to erosion and results in multiple scars and un-necessary erosion. There is no indication that non-system trails would not continue to proliferate. Under wet soil conditions trails are more vulnerable to rutting, compaction and erosions. Water is less likely to infiltrate the trail tread causing excess water to run off. Trails in the wilderness areas are rutted, braided and have wide sections that have caused accelerated erosion. These existing un-maintained trails do not have adequate natural drainage and would erode and provide more sediment the streams than maintained trails in the long term. Non Native Invasive species are found along travel corridors. Cross country travel would result in the greatest spread of NNIS and extirpation of botanical individuals, populations and habitat of one or more of sensitive and forest listed botanical species may occur from the continuation of this use. Disturbance to wildlife from human use associated with trails and cross country travel may occur. In addition, reduction in available habitat from human disturbances associated with cross country travel may occur. Unauthorized motorized use (ATV and motorcycle) into wilderness is occurring

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8. What appear to be the associations visitors have with the Lusk Creek Wilderness? What is unique? What do they expect?



The following are applicable to all three Wildernesses: Visitors expect unrestricted access to travel within and outside of wilderness on both designated trails and via cross country. Visitors expect unrestricted ability to enjoy scenic and iconic features. Visitors are drawn to wilderness by the free flowing water and the landscapes. Experiencing wilderness on horses is a key association visitors have to wilderness. Visitors expect to be able to access wilderness from nearby private campgrounds. Wilderness primarily serves day use visitors. Wilderness offers four-season use for both hikers and equestrians. Many access points exist which offer numerous ways to enter and exist the wilderness. Most camping occurs at private campgrounds. Visitor association to the wilderness is not a result of it being designated wilderness. A visitor survey conducted by Chilman indicated most people were not aware the area was wilderness. Wilderness is in close proximity to urban interfaces. (2) Step One (B) - Wilderness Character Indicators A. Untrammeled Condition - Wilderness Character 1. What is the existing condition in terms of un-trammeled?

There has been no road-building, timber-cutting or management of wildlife openings since designation in 1990.

The portions of the old road network not being used as trails are naturalizing.

Management has been protecting known populations of listed plant species.

Management has been maintaining the designated trail system.

Stock confinement areas exist which affect the untrammeled nature of the Lusk Creek

Wilderness.

Cross country travel and the use of many miles of non-system (un-maintained) trails occurs and has resulted in numerous heavily eroded trails, affecting the untrammeled character.

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2. Is action needed to support (Wilderness Act Section 4(b)) the public purposes of wilderness of recreation, scenic, scientific, education, conservation and historical use? ) IDT Recommendation The need for action is displayed in the existing resource conditions noted in the previous discussion on existing and potential threats to wilderness. There are numerous opportunities to reduce the impact of both management and visitor use on the untrammeled nature of wilderness. No action would allow for degradation of the untrammeled nature of wilderness to an unacceptable level. Action would most benefit the conservation aspect of wilderness. 3. What is the purpose of our actions - to restore natural condition, to restore or maintain or improve the opportunity for quiet? There are several objectives for action. It is to maintain, improve or restore those resources that comprise the natural condition (soil, water, aquatics, botany and wildlife). It is to maintain the opportunity for solitude or a primitive and unconfined recreation. However, in order to maintain and improve wilderness character, some management control is needed. This may reduce the opportunity for solitude for some visitors and reduce the ability of some to have primitive and unconfined recreation. 4. How do our actions affect both short and long term of the untrammeled condition in both the short and long term? There would be effects in the short term (up to five years) from construction and maintenance activities; however, in the longer term (up to 15 years), these actions should improve the untrammeled nature of wilderness by reducing the effect of equestrian use on the overall ecological processes. Alternatives -Untrammeled Condition

Alternative 1 – No Action has the highest impact on the untrammeled condition No Action would continue to perpetuate human manipulation within wilderness, more so from visitor

use impacts than management.

The continuation of cross country travel and the use and creation of non-system trails would continue to affect and diminish the untrammeled nature of wilderness.

Additional un-disturbed wilderness acreage would likely be impacted - until the decision has been

made that excessive resource damage is occurring. Only upon reaching this threshold would the trails be closed. This would increase the impact on the untrammeled aspect of wilderness.

Alternative 2 – reduces the impact from human manipulation to wilderness and maintains or improves the untrammeled condition

Reduces trail mileage from the existing 90 miles to 49 miles.

This alternative closes 48 miles of un-necessary trails.

Cross-country equestrian use would be eliminated. Therefore, the potential for user-created trails to become established on undisturbed areas would be greatly reduced.

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Alternative 3 – benefits the untrammeled condition by eliminating cross-country use. However, it retains the highest number of designated trails. In comparison to other alternatives, is less beneficial that 2 or 4 for the untrammeled condition.

Eliminates cross country equestrian use which reduces the chance of additional undisturbed acreage from being impacted

This alternative has the highest number of designated trails (73 miles) in wilderness.

Closes and restoration of 22 miles of trail in wilderness.

Alternative 4 – in the long term, substantially improves the untrammeled condition of wilderness. Best of the alternatives for the untrammeled condition,

Benefits the untrammeled nature of wilderness most by substantially reducing trail mileage and restoring non-system trails.

Reduces miles of trail to about 12 miles of trail within 13,484 acres of wilderness.

Eliminates cross-country equestrian use and reduces the potential for user-created trails to impact

undisturbed areas. Overall, the untrammeled quality of the Bay Creek and Garden of the Gods wilderness would be maintained or improved. In the long term, the Lusk Creek Wilderness would be substantially improved.

B. Natural Condition - Wilderness Character

1. What is the existing Natural Condition? How do our actions affect both short and long term the natural condition in both the short and long term?

Wilderness-wide, the following activities and/or conditions are currently affecting, or have the potential to affect processes that comprise natural condition:

Soil and water resources are affected. Major sources of sediment on forest lands in the project area are likely the facilities associated with transportation systems, mainly unimproved roads and trails.

Equestrian and hiker use of unimproved roads and trails exposes bare soil which can lead to

accelerated erosion.

Existing trails with a steeper gradient have a greater erosion potential than trails with a lower gradient and steep trails have higher potential for erosion.

Many of the trails and roads cross ephemeral, intermittent and perennial streams. These crossings are

direct points of sediment delivery. Localized disturbance to banks and channel substrate can occur. Trail crossings at larger stream channels can cut the banks causing them to become unstable and erode.

As trails conditions have deteriorated, users move to a parallel alignment – increasing area exposed to

erosion and results in multiple scars and un-necessary erosion. Given past experience with user created trails, there is no indication that non-system trails would not continue to proliferate.


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Under wet soil conditions trails are more vulnerable to rutting, compaction and erosions. Water is less likely to infiltrate the trail tread causing excess water to run off.

Trails in the wilderness areas are rutted, braided and have wide sections that demonstrate accelerated

erosion. These existing un-maintained trails do not have adequate natural drainage and would erode and provide more sediment the streams than maintained trails in the long term.

Some heavily-used existing stock confinement areas, are located within sensitive riparian filter areas

which could impair riparian function.

Non-Native Invasive species are found along travel corridors. Cross country travel would result in the greatest spread of NNIS and extirpation of botanical individuals, populations and habitat of one or more of sensitive and forest listed botanical species may occur from the continuation of this use.

Disturbance to wildlife from human use associated with trails and cross country travel may occur. In

addition, reduction in available habitat from human disturbances associated with cross country travel may occur.

Unauthorized motorized use (ATV and motorcycle) into wilderness is occurring.

Authorized motorized use to access private property is occurring on 2 roads.

2. Is some action is needed to support the conservation and scenic public purpose of wilderness (select either recreation, scenic, scientific, education or conservation)?

IDT Recommendation The need for action is displayed in the existing resource conditions noted in the previous discussion on threats to wilderness. No action would continue to degrade natural processes within wilderness to an unacceptable level. Action would most benefit the conservation aspect of wilderness.

3. What are the short and long term effects from Action? In all alternatives, the visible remnants of past land use and management, such as recovering

farmlands, roadbeds and pine plantations would continue to fade into the landscape as trees mature and vegetation becomes re-established within the old roadways. In the long term the adverse effect on the natural condition would be reduced.

Non-native invasive species adjacent to the trail may be controlled manually or by some other means

compatible with wilderness. Overall, this would be considered a small-scale manipulation. The effect to the wilderness would be minimal and would maintain or improve the natural condition of wilderness.

In all alternatives, authorized motorized access to private land in-holdings would continue in Lusk

Creek. Authorized motorized access would continue to have an adverse effect on the natural condition in all alternatives.

Future occurrences of unauthorized motorized use are likely to adversely affect natural condition.

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Alternatives - Natural Condition

Alternative 1 – No Action would result in an adverse effect on the natural condition of wildernesses in the project area. When compared to the other alternatives, it would have the most substantial adverse effect.

General public equestrian use would continue. Overall, the use on non-system (un-maintained) trails and cross-country equestrian use pose the greatest threat to the natural condition of wilderness within the project area.

There would be continued use of many non-system trails that would not be maintained and would

continue to erode and deliver sediment to streams. Over time, it is likely that many non-system trails would be closed and rehabilitated. However, the threshold at which they become closed is when resource degradation becomes evident. By the time the closures are put in place, the natural condition would be negatively impacted. This would adversely affect natural condition.

As trails conditions deteriorate, users would likely move to a parallel alignment. This would increase

the area exposed to erosion and results in additional multiple scars and un-necessary erosion. This would adversely affect natural condition.

No Action would result in the most adverse effects to soil and water. Any decline in erosion and

sedimentation from closed trails would likely be counterbalanced by an increase in erosion and sedimentation from new trails that are likely to appear.

Stock confinement areas would continue to be compacted and would continue to reduce the

infiltration capacity of the soil which increases runoff and erosion.

The riparian component of the natural condition of wilderness would continue to be impacted by the location of some stock confinement areas.

For aquatic resources, the deterioration of non-system trails would lead to increased sedimentation

downstream of the project area. Several Forest-listed aquatic species would be negatively affected.

For botanical resources, the extirpation of individuals, populations and habitat of one or more of sensitive and forest listed botanical species from continuation of cross country travel may occur.

Alternative 1 would result in the greatest spread of NNIS since cross country equestrian use could

continue to facilitate their spread via non-system trails and off-trail use.

Alternative 1 would not reduce the potential for disturbance to wildlife from human use associated with trails and cross country travel may occur. In addition, reduction in available habitat from human disturbances associated with cross country travel may occur.

Alternative 1 would implement a wet-weather closure for 24 hours after one-inch of rain for guided

commercial equestrian use. Under wet soil conditions trails are more vulnerable to rutting, compaction and erosions. Water is less likely to infiltrate the trail tread causing excess water to run off. The wet-weather closure for guided commercial equestrian use would reduce adverse effects of equestrian use on trails – a benefit to the natural condition. However, since this only applies to guided uses, impacts from general equestrian use is likely to continue.


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Alternative 2 - Alternative 2 provides more benefit than No Action because it reduces the miles of trail from 60 miles to 25 miles, reduces the number of needed stream crossings and eliminates cross country equestrian use.

General public and guided equestrian use would be restricted to using designated trails. This would eliminate cross country and the use of non-system (un-maintained) trails which poses the greatest threat to the soil and water, aquatic and botanical resources that make up the natural condition of wilderness.

There would be fewer adverse effects because the trails chosen for designation would be mitigated

and maintained. This would reduce erosion rates.

Trail maintenance and construction and the construction of stock confinement-areas would have a short-term adverse effect on the natural condition. Bare-soil exposure may be evident on newly constructed or reconstructed trails or in confinement areas, leaving soils vulnerable to erosion (Cole 1987). However, soil and water impacts from stock confinement areas would be mitigated by reducing the size and relocating some sites out of riparian areas. This would reduce the erosion and sedimentation potential of the site and protect riparian health – an overall net benefit to the natural condition.

Trails would be graveled to reduce trail widening and lessen erosion, thereby improving wilderness

resource condition. The bare-soil exposure, graveled trails and cut vegetation associated with construction and reconstruction could cause direct adverse effects in the short term.

Trail maintenance would cause some soil disturbance and slight increase in soil erosion. However, in

the long term, they would be expected to be negligible.

For aquatic resources, trail drainage and maintenance would greatly reduce the trail area and sediment draining directly into stream channels by re-directing runoff into a vegetated buffer. Further armoring the crossing with gravel or cobble would also reduce substrate erosion.

Forty-nine miles of trail would cross ephemeral, intermittent and perennial stream channels in the

watersheds. More miles of trail expose a larger area to erosion and compaction. Because trail mileage would be reduced from 90 to 49, and the trails will have proper drainage, there would be beneficial effects relative to current conditions.

Alternative 2 provides beneficial effects to forest-listed aquatic species due to less trail miles,

improved drainage, fewer crossings, and the elimination of many non-system trails and trail maintenance.

For botanical resources, the potential for extirpation of individuals, populations and habitat of one or

more of sensitive and forest listed botanical species from continuation of cross country travel would be reduced.

The alternative would reduce the spread of NNIS since cross country equestrian use is eliminated and

trail mileage is reduced.

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In the long term, Alternative 2 benefit wildlife by reducing the area affected by forest visitors in terms of disturbance and acres of habitat affected.

The seasonal and wet-weather closures in Alternatives 2 would mitigate impacts to soils during the

period when soils are most susceptible to wet season-related effects.

The alternative relocates, closes or maintains stock confinement areas to minimize soil erosion and limit the area affected by compaction. This management would benefit the natural condition of wilderness by reducing the potential for erosion and sedimentation (from compaction) and protect riparian health.

Alternative 3– benefits the natural condition by eliminating cross-country use. However, it retains the highest number of designated trails. In comparison to other alternatives, is less beneficial that 2 or 4 for the natural condition.

Equestrian use would be restricted to using designated trails. This would eliminate cross country and the use of non-system (un-maintained) trails which poses the greatest threat to the soil and water, aquatic and botanical resources that make up the natural condition of wilderness.








For aquatic resources, trail drainage and maintenance would greatly reduce the trail area and sediment draining directly into stream channels by re-directing runoff into a vegetated buffer. Further armoring the crossing with gravel or cobble would reduce substrate erosion.

Seventy-three miles of trail would cross from ephemeral, intermittent and perennial stream channels in

the watershed. More miles of trail expose a larger area to erosion and compaction. Because trail mileage would not be significantly reduced from sixty miles to forty-eight miles, there would be an adverse effect and little improvement from the current condition.

Alternative 3 would adversely affect some forest-listed aquatic individuals due to seventy-three trail

miles and more stream crossings.


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For botanical resources, the potential for the extirpation of individuals, populations and habitat of one or more of sensitive and forest listed botanical species from continuation of cross country travel would be reduced.

The alternative would reduce the spread of NNIS since cross country equestrian use is eliminated.

In the long term, Alternative 3 benefit wildlife by reducing the area affected by forest visitors in terms

of disturbance and acres of habitat affected.

Alternative 3 does not include a seasonal or wet-weather closure for the Lusk Creek Wilderness. The potential for equestrian use to degrade sub-standard trails when they are in a wet condition is likely to result in additional soil degradation if use occurs during these periods – until they are brought up to standard.

The alternative relocates, closes or maintains stock confinement areas to minimize soil erosion and

limit compaction. This management would benefit the natural condition of wilderness by reducing the potential for erosion and sedimentation (from compaction) and protect riparian health.

In the long term, Alternative 3 would benefit wildlife by reducing the area affected by forest visitors

in terms of disturbance and acres of habitat affected but not as much as Alternatives 2 and 4.

Alternative 4 - provides the most benefit – due to the minimal number of trails, fewer water crossings and less acres of disturbance.

General public and guided equestrian use would be restricted to using designated trails. This would eliminate cross country and the use of non-system (un-maintained) trails which poses the greatest threat to the soil and water, aquatic and botanical resources that make up the natural condition of wilderness.








For aquatic resources, trail drainage and maintenance would greatly reduce the trail area and sediment draining directly into stream channels by re-directing runoff into a vegetated buffer. Further armoring the crossing with gravel or cobble would reduce substrate erosion.

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Twenty-five miles of trail system would cross from ephemeral, intermittent and perennial stream

channels in the watershed. More miles of trail expose a larger area to erosion and compaction. Because trail mileage would be reduced from ninety to twenty-five, Alternative 4 would have the most beneficial effect to this component of wilderness natural condition.

Alternative 4 provides the most beneficial effects to forest-listed aquatic species due to less trail miles,

fewer crossings, and the elimination of many non-system trails and maintenance of trails.

For botanical resources, the potential for extirpation of individuals, populations and habitat of one or more of sensitive and forest listed botanical species from continuation of cross country travel would be reduced.

The alternative would reduce the spread of NNIS since cross country equestrian use is eliminated.

In the long term, Alternative 4 benefits wildlife most by reducing the area affected by forest visitors in

terms of disturbance and acres of habitat affected.

The Seasonal and wet-weather closures are features of Alternatives 4 would mitigate impacts to soils during the period when soils are most susceptible to wet season-related effects).

The alternative relocates, closes or maintains stock confinement areas to minimize soil erosion and

limit compaction. This management would benefit the natural condition of wilderness by reducing the potential for erosion and sedimentation (from compaction) and protect riparian health.

C. Undeveloped Condition - Wilderness Character

1. What is the existing condition in terms of un-developed? Management-related developments within wilderness are experience level 2 and 3 trails and old road

beds being used as trails. Such trails would characteristically be narrow, native surface paths and, at times difficult to follow, steep and rough.

Other evidences of man, not related to the management of wilderness include multiple user-created

trails, deer stands and spray pained rocks and live trees and graffiti (which have been used for directional purposes).

Unauthorized motorized use is occurring.

There are 90 miles of inventoried routes which includes a combination of old roads and trails. There

are stock confinement areas, natural area boundary signs, regulatory signs and some directional signs.

The Lusk Creek Wilderness has the most miles of user-created trails, of sixty miles of trail, only ten miles are designated.

There is evidence of user-created signing in the form of spray painted rocks and painted or graffiti-

laden live trees.


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Regarding stock confinement areas, the forest has installed, or allowed the installation of, these areas of concentrated use to limit the effect of many users to relatively small areas. They also facilitate equestrian use by providing riders with a place to tether stock. Structures typically include a high line rope which is left in place for an extended period of time. There are currently nine stock-confinement areas that cover about 1.3 acres. Some of the structures, because of their location adjacent to trails, live water or scenic features, are considered to be substantially noticeable. These areas affect the undeveloped condition of the Lusk Creek Wilderness.

This wilderness tends to receive the most use because of the equestrian campgrounds located in close

proximity to wilderness.

2. Is some action needed to support the conservation, scenic and recreation public purpose of wilderness (select either recreation, scenic, scientific, education or conservation)? IDT Recommendation There is a need for action because there are many opportunities to improve the undeveloped character of wilderness. No action would result in further degradation of this quality of wilderness. Action would most benefit the conservation aspect of wilderness.

3. How would our actions affect the objective of evidence of man being “substantially unnoticeable?

The action alternatives propose to close and rehabilitate about 48 miles of trails in Alternative 2, about 22 miles in Alternative 3 and about 54 miles in Alternative 4. Initially, the focus on closing non-system trails would concentrate on their junctions with the designated trail system. In the first year or two these trail connections would be brushed to obscure their existence and discourage their use. At the same time, rehabilitation would focus on stabilizing any actively eroding trail sections. Remaining trail sections would be abandoned and allowed to revegetate naturally. The closure process in all action alternatives should be completed in three to four years. There would be direct (up to five years) effects from trail closure activities, including brush-cutting for screening and ground-disturbance for erosion control. However, indirectly these actions in the long term (up to 15 years) should improve the undeveloped nature of wilderness, reduce the effect of recreational use (over a large portion of wilderness) and be substantially un-noticeable.

Each action alternative varies in the miles of designated trail. Although trails are an appropriate

improvement in wilderness, more trail miles would be further evidence of man’s work and would affect its undeveloped character. However, when considered in the larger context of each wilderness (its total acreage), the trail systems, in each alternative, would have a relatively minimal effect on the undeveloped condition of the wilderness (FSM 2309.18.2).

Trails would be maintained to experience level 1. However, they would to appear to visitors to be

level 2 or 3 and meet wilderness character objectives. The trail corridors would be relatively small (4-8 feet), with vegetation growing back in along the bench after initial clearing. The trail-tread width (area of bare soil or gravel) would be small (12-24 inches). Initially the gravel would be evident; but, over time, most would become packed into the dirt and the trail tread would appear to be a small ribbon of exposed soil. In the short term, gravelling would also be expected to increase the perception of development or be a deviation from the natural appearance expected within wilderness. This effect would be mitigated by choosing naturally occurring, dark colored gravel. After one or two seasons of use the gravel would work into the trail surface and appear, to most users, to be a native surface.

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Muddy and braided sections of trail would be narrowed to a firm walking surface, decreasing the perception of development. In the long term, the use of gravel material to fortify tread should be substantially un-noticeable.

All action alternatives remove the ability to camp with stock. This would preclude the potential for

currently undisturbed areas from being impacted and becoming substantially noticeable. However, the potential for new areas of disturbance to occur from backpacking use would remain.

Alternatives - Undeveloped Condition

Alternative 1 - Overall, No Action would result in adverse effects on the undeveloped character of wildernesses in the project area.

Alternative 1 designates no new trails. Other than undesignated trails in natural areas, riding would be available on most wilderness acres. Because they cannot be maintained, many trails would likely deteriorate, triggering closure. However, when this decision is made, excessive resource damage would likely have occurred. Only upon reaching this threshold would the trails be closed. The perpetuation of eroded and degraded trails would be negative evidence of man’s impact and would continue to adversely affect the undeveloped aspect of wilderness. Given past experience with the proliferation of user created trails, particularly within the Lusk Creek Wilderness, this evidence of man (or impact) is likely to increase.

In this alternative, trails would only be maintained to experience level 2 or 3, which would not provide

a sustainable trail system. The lack of stabilization could cause sections of accelerated erosion which negatively affects the undeveloped character of wilderness. Trails would be closed or use would be greatly restricted to prevent resource damage.

Stock confinement areas would continue to be erosion sources and adversely affect the undeveloped

condition because some confinement areas would continue to be highly visible (substantially noticeable).

Alternative 1 would not address the lack of directional signage which has resulted in significant

(although un-authorized) evidence of man – spray pained rocks and live trees and graffiti. Although actions would likely be taken (through routine wilderness management) to remove these intrusions, it is unlikely to solve the need for some level of signing. Alternative 2 – Overall there would be a beneficial improvement on the undeveloped condition.

There would be a significant reduction in the miles of trail, from ninety miles to forty-nine miles.

The designation, maintenance and construction would lead to a sustainable trail system that could support the current and expected amount of equestrian use without evident resource effects.

A reconstructed trail system would be less intrusive then the current network of trails. Trail system

maintenance would be accomplished to ensure that the trail system would not be a dominant feature of the wilderness landscape. The designation and maintenance of a sustainable trail system would reduce the impact (visible excessive erosion, muddiness, etc) that currently exists to the undeveloped character of wilderness.

A total of four confinement areas would remain after reducing and consolidating existing areas – a

decrease from the nine that currently exist. Stock-confinement areas would be less visually intrusive


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because many would be reduced in size and several would be removed from proximity to scenic features into pine stands. Stock-confinement areas in wilderness would be reduced by about 40 percent, from the current 1.3 acres to about 0.8 acres. This action would reduce the level of development in wilderness and make the confinement areas less noticeable.

Overall trail density in Alternative 2 would be about 2.3 miles per square mile. While this trail density

is higher than the current standard of one mile of designated trail per square mile, it substantially lessens the overall travel ways available for equestrian use in wilderness.

Relative to the time of wilderness designation, there would be a reduction in the amount of travel

routes available, which would improve wilderness character.

Physical factors of trail layout such as isolating trails by geography and using vegetation to isolate trails have been employed in the design of the trail system. Trail signing would be minimized in wilderness to reduce signs of human development. Natural area signing would be done with natural materials and the bright yellow carsonite posts would be removed. Existing informal signing, including spray-painted trees and rocks, would be removed or cleaned. While the number of structures such as signs would increase, they would reduce the existing impact that currently exists on the undeveloped quality of wilderness. In addition, the reduction in trail miles results in fewer trail junctions which further reduces the volume of signing needed. Overall, it is expected that this alternative would result in beneficial effects on the undeveloped character of wildernesses in the project area.

Alternative 3 - Overall, it is expected that this alternative would result in minimally adverse effects on the undeveloped character of wilderness.

Alternative 3 contains the greatest number of miles of designated trails in wilderness with seventy-three miles and would be less effective at mitigating impacts to the undeveloped condition.

The designation, maintenance and construction would lead to a sustainable trail system that could

support the current and expected amount of equestrian use without evident resource effects.

A reconstructed trail system would be less intrusive then the current network of trails. Trail system maintenance would be accomplished to ensure that the trail system would not be a dominant feature of the wilderness landscape. The designation and maintenance of a sustainable trail system would reduce the impact (visible excessive erosion, muddiness, etc) that currently exists to the undeveloped character of wilderness.

Trail density would be about 3.5 miles per square miles. This alternative accepts more of the existing

trail system than any other alternative, so the isolation of trails is not as great as in Alternatives 2 and 4.

The designated trail system in this alternative would be properly constructed and maintained to lessen

the visual effect (of the remaining trails) on the undeveloped condition of the wildernesses.

There would be six stock-confinement areas that would cover about one acre. The stock-confinement areas in the riparian areas would be reduced in size to meet Plan standards and guidelines for bare area in filter strips. These areas have more effect and would be more visually evident in this alternative than in either Alternatives 2 or 4. They would have a greater effect on the undeveloped condition of the wildernesses than in Alternatives 2 and 4 but less of an effect than Alternative 1.

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Physical factors of trail layout such as isolating trails by geography and using vegetation to isolate

trails have been employed in the design of the trail system. Trail signing would be minimized in wilderness to reduce the signs of human development. Some natural area signing would be done with natural materials, but the bright yellow carsonite posts would be removed. Existing informal signing, including spray-painted trees and rocks, would be removed or cleaned. While the number of structures such as signs would increase, they would reduce the existing impact that currently exists on the undeveloped quality of wilderness. However, the miles of trails (which are higher than in Alternatives 2 and 3) would require a larger volume of signage since more trail junctions would become part of the designated system.

Alternative 4 – Overall, it is expected that this alternative would result in the greatest beneficial effect on the undeveloped character of wilderness.

Alternative 4 would significantly reduce trail miles from ninety miles to twenty-five miles.

The designation, maintenance and construction would lead to a sustainable trail system that could support the current and expected amount of equestrian use without evident resource effects.

A reconstructed trail system would be less intrusive then the current network of trails. Trail system

maintenance would be accomplished to ensure that the trail system would not be a dominant feature of the wilderness landscape. The designation and maintenance of a sustainable trail system would reduce the impact (visible excessive erosion, muddiness, etc) that currently exists to the undeveloped character of wilderness.

This alternative would preclude cross-country riding and decrease the existing trail mileage in both

wilderness and natural areas.

Trail maintenance and trail construction effects would be similar to Alternative 2, except that there would be about 51 percent fewer trail miles.

Wilderness density would be about 1.2 miles per square miles.

This alternative accepts the least amount of the existing trail network of the alternatives, so the

isolation of trails is greater than Alternatives 2 and 3.

Relative to the time of wilderness designation, there would be a large reduction in the amount of travel routes available.

Four stock-confinement areas in Alternative 4 would occupy about 0.8 acres. The stock-confinement

areas in the riparian areas would be reduced in size to meet Plan standards and guidelines for bare area in filter strips. The four areas would be moved away from scenic features and moved to less visible places. These confinement areas would have less effect on soil, water and riparian resources and would not be as visually evident (substantially noticeable) in this alternative when compared to Alternative 3.

Physical factors of trail layout such as isolating trails by geography and using vegetation to isolate

trails have been employed in the design of the trail system. Trail signing would be minimized in wilderness to reduce the signs of human development. Some natural area signing would be done with natural materials, but the bright yellow carsonite posts would be removed. Existing informal signing, including spray-painted trees and rocks, would be removed or cleaned. While the number of structures


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such as signs would slightly increase, they would reduce the existing impact that currently exists on the undeveloped quality of wilderness. In addition, the significant reduction in trail miles results in few trail junctions which reduces the volume of signing needed.

C. - Outstanding Opportunities for Solitude or a Primitive and Unconfined Type of Recreation - Wilderness Character

1. What is the existing condition in terms of outstanding opportunities for solitude or a primitive and unconfined type of recreation?

Based on data gathered in Lusk Creek (Chilman et. al. 2005), weekend use is high from March through October. However, use is much less during the winter months of November through February. Overall of the wilderness areas, opportunities for solitude both on and off the designated trail system should be readily available most of the year.

A threat to the opportunity for solitude that currently exists is both the unauthorized vehicle, ATV and

bicycle use that is known to occur on roads or trails.

There are some management restrictions, primarily related to the management of the natural areas, for the protection of key ecological resources. No group size limitations or restrictions on use currently exist.

Few directional signs exist, there are trails with steeper grades and water crossings are un-developed which enhances the opportunity for challenge.

Cross country use, which has resulted in the proliferation of non-system trails, currently offers both

equestrian and hikers the most freedom possible for pursuing challenge and for reliance on personal skills.

2. Is some action is needed to support the conservation, scenic and recreation public purpose of wilderness (select either recreation, scenic, scientific, education or conservation)? IDT Recommendation Action would support both the conservation and recreation purpose of wilderness. Some type of management control is needed to maintain and preserve the untrammeled, natural condition and undeveloped aspects of wilderness. Increased levels of management control may reduce the opportunity for solitude or a primitive and unconfined recreation for some visitors. However, action would be consistent with Section 2(a) of the Wilderness Act that specifically states that such areas:

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“shall be administered for the use and enjoyment of the American people in such a manner as will leave them unimpaired for future use and enjoyment as wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness character” (The Wilderness Act of 1964). In addition, action would be consistent with agency policy that directs the Forest to consider the wilderness resource as the overriding value when a choice must be made between wilderness values and visitor or any other activity, in order to preserve wilderness. 3. What are the short and long term effects of our action?

In all action alternatives, group size restrictions would apply. While this restriction increases management control and reduces the unconfined nature of wilderness (free from restrictions), the size restrictions should improve the feeling of solitude for those visitors who believe that large groups diminish their experience.

Group size limitations combined with improved trail conditions should indirectly improve experiences

by reducing environmental impact and conflicts between groups.

The range of group sizes proposed throughout the alternatives is well within the group sizes that have been typically documented within wilderness (Chilman, 2005). Minimal adverse effects to the opportunity for primitive and unconfined recreation are expected.

In all action alternatives, the threat to solitude and the wilderness experience from the un-authorized

use of ATV’s within wilderness may decrease from increased Forest Service presence (which provides both education and law enforcement) during project implementation and monitoring. In addition, trail reconstruction techniques would be used, where feasible, to make it more difficult for ATV’s to travel on designated trails.

4. How would the actions affect the available opportunity for solitude, for physical and mental challenge?

Do actions minimize the number of people heard or seen? Yes, in action alternatives trails are designed to be as isolated as possible from one another and not visually apparent. Group size limitations minimize the number of people heard and seen at one time. Camping with stock would be eliminated in the wilderness, backpacking use would continue. Off trail use and the opportunity to encounter other people would be reduced because equestrian use would be eliminated off of designated trails. However, overall limitations to use are not proposed.

Minimize sounds and sights of motorized and mechanized transport? There are 2 authorized

roads within the Lusk Creek Wilderness. There are minimal opportunities to minimize the sounds and sight of this use. Regarding unauthorized ATV use, all action alternatives would, where feasible, reconstruct trails to discourage ATV use.

Promote primitive means of traveling, camping and accomplishing stewardship work? Travel

would be primitive and by traditional modes - foot and horse. Camping opportunities would be eliminated for stock users but it would still exist for backpackers. Implementation of the project would


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use traditional modes of travel. Currently, no authorization has been requested for use of mechanized or motorized equipment.

Minimize regulatory controls and maximize the opportunity for visitors to make their own

choices and discover things for themselves? In order to protect wilderness character, a range of regulatory controls are needed: (1) regulatory signs at natural area boundaries; (2) elimination of un-designated stock confinement areas; (3) elimination of camping with stock; (4) equestrian use of designated trails only and the elimination of cross country equestrian travel, and (5) group size limitations. The opportunity for equestrians to make their own choices and discover things for themselves is reduced; however, it is still available if they choose to tie up their animals and hike.

Allow some degree of challenge such as streams that must be forded, rough trails? Yes, all

stream crossings are natural and do not have engineered structures through the water. Stream banks would be armored to protect sensitive soils and aquatic habitat. A “rough” trail for this analysis is considered to be those trails that are currently on excessive grades (greater than 12%). Trail grades would be reduced to protect wilderness resources given the volume of use Lusk Creek Wilderness. A small portion of trails would have grades greater than 12%.

Maximize that natural sounds and sights dominate? Yes, in action alternatives trails are designed

to be as isolated as possible from one another and not visually apparent. Group size limitations minimize the number of people heard and seen at one time. Camping with stock would be eliminated in wilderness, backpacking use would continue. Off trail use and the opportunity to encounter other people would be reduced because equestrian use would be eliminated off of designated trails. However, overall limitations to use, which would be a means to maximize natural sounds and sights, are not proposed.

Promote immersion in nature? All action alternatives would bring trail conditions up to standard

and eliminate muddy trails and areas that have visible signs of excessive erosion. Natural areas would continue to be protected. Stock confinement areas would be relocated, closed, or maintained to minimize their visual and soil impacts. An overall reduction in resource impacts should improve the opportunity for visitors to focus on nature and not resource degradation. In addition, hikers, who would continue to be able to travel cross-country, should have optimum opportunities for immersion in nature.

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Alternatives - Outstanding Opportunities for Solitude or a Primitive and Unconfined Type of Recreation

Alternative 1 - Overall, No Action would result in adverse effects on the opportunity for solitude or a primitive and unconfined type of recreation of wildernesses in the project area.

There are no changes proposed to the trail system in Alternative 1. The opportunity for solitude in wilderness is currently affected by the 90 miles of system and non-system trail that provide access to most areas of wilderness. About ten percent of the wilderness is further than a one-quarter of a mile from any road or trail and about 34 percent of the wilderness is further than one-eighth of a mile (FEIS, Table 12) from any road or trail. The opportunity for solitude is enhanced on and off trails from a variety of physiographic factors, with the presence of bluffs, hills, ravines and dense vegetation. Factors that may decrease the feeling of solitude include the presence of roads within and adjacent to the wilderness boundary, vehicle access on authorized interior roads and unauthorized use by ATV’s or mountain bicycles.

All equestrians and hikers would continue to have ample opportunity for primitive and unconfined

recreation off of the trail network. Management control would remain minimal and focused on protecting natural areas. However, if user created trails degrade to the point of closure it is expected that trails would be closed, which would reduce the opportunity for unconfined recreation. In Alternative 1 a minimal amount of directional signs would exist, there would be trails with steeper grades and water crossings would be un-developed, which enhances the opportunity for challenge. In the context of the entire 13,484-acres of wilderness, adverse effects would be expected to continue for both equestrians and hikers from Alternative 1.

Alternative 2 – Overall there would be a beneficial improvement in the opportunity for solitude or a primitive and unconfined type of recreation of wildernesses in the project area.

Alternative 2 would provide 49 miles of system trail (FEIS, Table 37), including about two miles of hiker-only trail in wilderness. Equestrian use would be restricted to system trails. Under this alternative, a group-size restriction of ten persons would be placed on all wilderness users and camping in wilderness with stock would not be allowed.

Under Alternative 2, hikers willing to get away from the trail system are likely to find outstanding

opportunities for solitude. The trail system proposed under this alternative would increase the amount of remote, trail-less wilderness. About 48 trail miles would be closed and rehabilitated. There would be about 22 percent of the wilderness that is further than one-quarter of a mile from a road or trail and about 51 percent of the wilderness that is further than one-eighth of a mile (FEIS, Table 12). In addition, during the temporary seasonal trail closure (December 1 – March 31), hikers would have reduced encounters in wilderness and are likely to experience better trail conditions. This may improve a sense of solitude or improve the wilderness experience.

This alternative would remove the opportunity for a remote, trail-less experience for equestrians.

While many people find adequate solitude and challenge without leaving the trail, the lack of choice for equestrians could diminish the experience for some. However, solitude would be available at many times along the trail system for equestrian users particularly during the week days and during the winter months (FEIS, Table 34).

Under all action alternatives, monitoring use and numbers of encounters on system trails would

document long-term changes and visitor perceptions. In Alternative 2, the potential numbers of trail


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encounters are expected to be more than in Alternatives 1 and 3, and less than in Alternative 4, based on the miles of trail available to disperse use.

Management control would increase and the opportunity for unconfined recreation would decrease in

order to protect wilderness character. Although the group size limitation as well as the seasonal restriction to stream crossings in least brook lamprey habitat would apply to all users, the restriction of equestrians to designated trails, the temporary wet weather seasonal restrictions, the requirement to utilize stock confinement areas and the elimination of the opportunity to camp with stock would increase the perception of management control for some equestrian users. Alternative 2 is expected to result in the adverse effect of diminished opportunities for primitive and unconfined recreation for equestrians.

In terms of retaining skills and challenge, additional directional signs would exist and extreme trail

grades would be reduced. Water crossings would be primitive (no engineered structures across the water) - which would retain the opportunity for challenge for all visitors. There would still be ample opportunity for hikers to test their personal skills by traveling cross-country. Overall, the opportunity for primitive and unconfined recreation for hikers would be minimally affected or enhanced.

Alternative 3 - Overall, it is expected that this alternative would result in minimally adverse effects in the opportunity for solitude or a primitive and unconfined type of recreation of wildernesses in the project area.

In Alternative 3, all equestrian use would be restricted to system trails in wilderness, with no cross-country use. A total of 73 miles of system trail would be improved and maintained in the wilderness (FEIS, Table 12). Under this alternative, a group-size restriction of twenty persons would be placed on all wilderness users, and camping in wilderness with stock would not be allowed.

The trail system proposed under this alternative would slightly increase the amount of remote, trail-

less wilderness when compared to Alternative 1. About 22 non-system trail miles would be closed and rehabilitated. About 13 percent of the wilderness is further than one-quarter of a mile from a road or trail and about 38 percent of the wilderness is further than one-eighth of a mile (Table 39).

Solitude also would be available at many times along the trail system. The extent of the trail system

has the potential to disperse use over more miles. However use is expected to continue to concentrate at popular, scenic areas. Monitoring use and numbers of encounters on system trails would be conducted to document or respond to long-term changes and visitor perceptions. In Alternative 3, the potential numbers of trail encounters is expected to be more than in Alternative 1, and less than in Alternatives 2 and 4 (based on miles of trail available).

Environmental consequences as they relate to management control, the opportunity for solitude and

unconfined recreation are the same as displayed in Alternative 2.

Alternative 4 – Overall, it is expected that this alternative would result in the greatest beneficial effect in the opportunity for solitude or a primitive and unconfined type of recreation of wildernesses in the project area.

The trail system proposed under this alternative would greatly increase the amount of remote, trail-less wilderness. About 54 non-system trail miles would be closed and rehabilitated. About 42 percent of the wilderness would be further than one-quarter of a mile from a road or trail and about 68 percent of the wilderness would be further than one- eighth of a mile (Table 39).

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Alternative 4 restricts equestrian use to about 25 miles of designated trail in the wilderness. The diminished availability of trails in this alternative would increase the likelihood that hikers and equestrians encounter one another while using the trail system. The group size limit of 8 persons could constrain some users, even while it may reduce perceptions of crowding for others.

Environmental consequences as they relate to management control, the opportunity for solitude and

unconfined recreation are the same as displayed in Alternative 2 and 3.

Alternative 4 is expected to constrain the equestrian experience to a greater degree than the other three alternatives and, thereby, reduce the opportunity for primitive and unconfined recreation, an adverse effect for equestrians as well as hikers who prefer trails. Cross-country hikers would have the greatest area available for primitive and unconfined recreation in this alternative as compared to all other alternatives, a beneficial effect for them.

Reducing trail gradient, reducing mile of steep trail and maintaining trails to standard would reduce

the rate of accelerated erosion and sedimentation relative to existing conditions. A small portion of trail would exceed 12% which would provide for challenge and risk.

In order to reduce encounters between hikers and equestrians in two popular areas in the Lusk Creek

Wilderness, additional hiker-only trails would be provided. The current trail from the existing trailhead to the Indian Kitchen area would be designated as hiker only (about 1.5 miles). A new trail (about 0.5 mile) would be provided from a new parking area along County Road 1628 on the north side of the wilderness to the Saltpeter Cave area.


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STEP TWO – Evaluations of Individual Actions

Designated Trail

Step One – Determine whether action is necessary. The purpose and need clearly displays why we believe that additional designated trails are necessary. In order to stop the creation of non-system trails, we have chosen to designate a system of trails and then maintain and construct that system to reduce overall impacts from the trail system. The lack of designated trails makes this action necessary. Step Two – Determine the minimum activity.

Miles of Designated Trail Wilderness Alt 1 Alt 2 Alt 3 Alt 4

Garden of the God’s 14 15 15 8 Lusk Creek 10 25 48 12 Bay Creek 0 9 10 5 Total Trail Miles 24 49 73 25 Forest Service Policy

• FSM 2323.13f – Trails are an acceptable improvement in wilderness. Construct and maintain to standards described in FSH 2309.18.

Forest Plan Direction: • The average density for improved system trails will be about 1 mile per square mile. This

guidance is applied across all wilderness areas on the Forest and not to individual areas. Trails will be designated closed to motorized or mechanized use. (SFP, IV-114)

Options Considered: • No change • No change but with the reduction in non-system trail miles over time, essentially leaving

only currently designated trails • Increase miles of designated trails (Forest Plan amendment needed) • Decrease miles of designated trails

IDT Discussion No Action would allow for trails that are in poor condition and not adequately located to remain. Retaining 60 miles of trail because they are currently in existence would not be a minimum activity. Alternative 4 would best improve the natural and untrammeled condition of wilderness. However, it would focus only on the physical and biological qualities of wilderness and not be the minimum necessary for the recreational purpose of the Lusk Creek Wilderness. The recreation component of wilderness is a valid quality to consider. Policy directs the agency to consider the wilderness resource as the overriding value when a choice must be made between wilderness values and visitor or any other activity, in order to preserve wilderness. Because uses and values on each area will vary, management and administration should be tailored to meet the need of each area (FSM 2320.6). With mitigation (group size limits) and monitoring of wilderness character, the wilderness untrammeled, natural and undeveloped qualities should be improved while providing for recreational uses and values. Alternative 3 could be considered the minimum necessary when only looking at the recreational purpose of wilderness. Alternative 2, because it also improves the physical and biological component of wilderness, may create more of a balance between the untrammeled, natural and undeveloped objectives of wilderness and the recreational purpose of wilderness.

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Non-System Trail Closure

Step One – Determine whether action is necessary. The purpose and need clearly displays why many non-system trails need to be closed. In order to prevent unnecessary erosion and to reduce overall impacts from the trail system non-system trails not designated into the system need to be closed. Closing non-system trails is necessary to properly manage wilderness character. Step Two – Determine the minimum activity.

Miles of Non-System Trail to be closed Wilderness Alt 1* Alt 2 Alt 3 Alt 4

Garden of the God’s 0 6 5 12 Lusk Creek 0 35 22 50 Bay Creek 0 1 1 6 Total Non-system Trail Miles (Closed) 0 42 28 68

* Non-system trails would be closed over time for resource degradation. Forest Plan Direction

Construction or reconstruction of user created trails for hiking or equestrian use requires Forest Service approval of location and design in full compliance with NEPA (SFP IV-22).

LAC will be used for monitoring effects of management on the wilderness resource and the range of options will be considered when unacceptable environmental damage or significant user dissatisfaction occurs. The emphasis for correcting problems is: (1) Educational approaches such as signing and brochures (2) Natural resource modification such as closing trails, restoration and tent pads (3) Use of regulatory approaches such as law enforcement (4) Permit systems will be used only when other methods fail (SFP, IV-113)

Options Considered: Incorporate into the designated system Close and rehabilitate

IDT Discussion: The minimum necessary is to close user created trails that are not both not needed and are currently or have the potential to compromise both the physical, biological and social wilderness resource. The minimum tool would be the use of methods that use native materials and complete activities with primitive tools – no use of mechanized or motorized equipment.


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Trail Experience Level (Graveled Trails)

Step One – Determine whether action is necessary. The purpose and need clearly displays why many non-system trails need to be closed. In order to prevent unnecessary erosion and to reduce overall impacts from the trail system. Closing non-system trails is necessary to properly manage wilderness character. Step Two – Determine the minimum activity.

Miles of Non-System Trail Alternative 1 2 3 4

Trail Experience Level* 2-3 1 – short term 2-3 – long term

1 – short term 2-3 – long term

1 – short term 2-3 – long term

* Short-term = 2-5 years and Long Term = beyond 5 years Forest Plan Direction

Wilderness trails will generally be constructed and maintained for experience level 2 and 3 (Forest Plan, IV-114).

Level 1 – Easiest – accommodates moderate to heavy traffic on a safe and well marked trail (Forest Plan, IV-22).

Level 2 – More Difficult – accommodates low volume of use on a trail which is safe for those users with backcountry experience and good physical ability (SFP, IV-22)

Level 3 – Most difficult – accommodates low volume of users seeking to test their skills in rugged terrain. Route should appear challenging and require good physical conditioning ((Forest Plan, IV-22)

LAC will be used for monitoring effects of management on the wilderness resource and the range of options will be considered when unacceptable environmental damage or significant user dissatisfaction occurs. The emphasis for correcting problems is:

o Educational approaches such as signing and brochures, o Natural resource modification such as closing trails and tent pads, o Use of regulatory approaches such as law enforcement, and o Permit systems will be used only when other methods fail,

(Forest Plan IV-113). Options Considered:

• Trails remain a mix of Level 2 and 3 • Trails are upgraded to Level 1 experience • color of the gravel and the time it would be visible • Wet segments reconstructed using imported gravel.

IDT Discussion: Trails that remain technically at a Level 2 and 3 would not be a sustainable system because moderate to heavy stock use in fine soils causes muddiness, braiding and unnecessary erosion. In the comments on the DEIS, the importation of relatively large amounts of gravel to harden trails and provide a firm tread was questioned. The appearance of the gravel, whether it would be a prohibited structure, and the impact of the gravel on the natural condition and undeveloped nature of wilderness character were the primary concerns raised. The interdisciplinary team considered the color of the gravel, the time it would be visible, and the appropriateness of using gravel in the wilderness in the development of the alternatives presented in the DEIS. The conclusions that were reached were:

G. the use of gravel is integral to a properly designed trail in our fine soils so that the trail is does not become muddy, braided, or excessively wide,

H. hardening the trails with gravel is the simplest method to provide a trail system that can be

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maintained under moderate to heavy equestrian use, I. that the dark colored gravel would not be obtrusive, J. natural condition would be improved over time because the dark gravel would be worked into

the soil and would not be highly visible, K. the 49 miles of wilderness trail in about 13,500 acres of wilderness would not appreciably

impact the level of development, and L. the use of gravel would improve wilderness character by lessening the visual impact of the trail

system. We also considered limiting use, rather than constructing and maintaining a trail system (with gravel) that can withstand moderate to heavy equestrian use. The team concluded that building a reasonable trail system that could be maintained was a logical first step in solving the issues related to wilderness character. In addition, the team considered using seasonal and wet-weather closures to manage impacts to the trail system. These type of closures would impact many users experience because of the unpredictability of the weather. Many users plan their trips month in advance and would be denied the use of the wilderness during wet conditions. Additionally, trail conditions vary greatly depending on the terrain where the trail is located. Many areas would remain in poor condition for extended periods without the use of gravel to stabilize the trail tread. The interdisciplinary team concluded that graveled trails were the minimum tool necessary to meet the recreation purposes of the Wilderness Act. As a result of public concern (expressed in comments on the DEIS) about the density of trails, the level of development, and the opportunity for solitude, the Selected Alternative reflects a decrease in the number of miles of trails in the Lusk Creek Wilderness Area. This Area, above all others on the Forest, has been the subject of much study, public debate and litigation. The effect of the lower trail mileage in Lusk Creek Wilderness Area is within the environmental effects disclosed in the DEIS, and the issue of trail mileage in the area was a focal point of the DEIS. Some public comment on the DEIS supported more access to the area, while others strongly opposed the 34 miles of trail proposed in Preferred Alternative. After re-consideration of the interdisciplinary teams’ analysis of wilderness character, Alternative 2, the Selected Alternative, was modified. The level of access to Lusk Creek Wilderness Area is still reasonable, but provides, out of an abundance of caution, additional protection of wilderness values. This change is consistent with the regulatory direction to allow wilderness values to dominate (to the extent not limited by the Wilderness Act) resolution of conflicts in resource use (36 CFR 293.2(c)).


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Constructed a New Trail System

Trail Miles* and (Trail Density) by Alternative Wilderness Acres Square

Miles 1 2 3 4

Garden of the Gods 3,997 6.25 20 15 15 8 (3.2) (2.4) (2.4) (1.3)

Lusk Creek 6,718 10.5 60 25 48 12

(5.7) (2.4) (4.6) (1.2)

Bay Creek 2,769 4.33 10 9 10 5 (2.3) (2.1) (2.3) (1.2)

Totals 13,484 21.08 90 49 73 25 (4.3) (2.3) (3.5) (1.2)

* For Alternative 1, system and non-system trail miles are included. **Density is calculated by dividing the trail miles by the square miles

Step One – Determine whether action is necessary. Totally replacing the existing network of non-system and system trails with new trails that would be properly sited and constructed to standard was considered as an option to working with the existing trail system and the miles of non-system trail. The interdisciplinary team decided that the reconstruction and designation of existing trails would have the least impact. The construction of all new trails was not considered to be necessary; therefore, Step Two was not completed.

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Trail Density

Step One – Determine whether action is necessary. The current density standards are too restrictive and would confine equestrian use onto too few trails, undermining the environmental benefit this project is intended to achieve. With more than a decade of hindsight, we see that the trail density standards adopted so long ago were not firmly rooted in science or logic. Action to reduce the “on-the-ground” trail density to restore, enhance and protect wilderness character was deemed necessary. Step Two – Determine the minimum activity.

Miles of Non-System Trail Forest Plan Direction:

• The Forest Plan states that the average density for improved system trails will be about 1 mile per square mille. Trails will be designated closed to motorized or mechanized use. (Forest Plan, IV-114)

Options Considered: • Trail density remains the same • Trail density increases or decrease • Trail density as an indicator is eliminated

IDT Discussion: The trail density standards of the 1992 Forest Plan are eliminated by Plan amendment in Alternative 2. (Likewise, trail density standards were proposed to be dropped from the revised plan, due to be finalized in 2006.) When the 1992 Plan was developed, trail density was thought to be a surrogate for protecting undeveloped condition and solitude in wilderness management. Protection of the undeveloped character of wilderness is a complex and evolving area of science. We are aware of the competing methodologies available to evaluate various means of protecting wilderness. Clearly, in the project area, the trail density limit failed, as the miles of user-created trails increased dramatically in the project area despite the trail density limit, which applied only to designated trails. Considering user-created trails, the “real” or on-the-ground existing trail density is 4.3 miles per square mile as opposed to the proposed 2.4 miles per square mile under Alternative 2. Ending cross-country riding and creation of user-developed trails under Alternative 2 will have an on-the-ground or practical effect of reducing trail density, even though the Forest Plan limit is eliminated. Although we have sought diligently, we have no evidence to show that retaining trail density will provide a greater degree of wilderness protection compared to proper trail design and location. Although some comments opposed the Plan amendment eliminating trail density, we could find no logical or credible reason in the comments for modifying this aspect of Alternatives 2 and 3. Plan amendment is designed to allow reasonable access while protecting the undeveloped character of the wilderness. The current density standards are too restrictive and would confine equestrian use onto too few trails, undermining the environmental benefit this project is intended to achieve. With more than a decade of hindsight, we see that the trail density standards adopted so long ago were not firmly rooted in science or logic. Like other aspects of the 1992 Forest Plan currently under revision, trail density standards, recognized now as impotent to protect the undeveloped condition of wilderness, have become archaic.


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Cross Country Travel

Step One – Determine whether action is necessary. The purpose and need clearly displays that cross-country travel leads to a proliferation of non-system trails. Eliminating cross-country travel was determined to be necessary in wilderness to protect, restore, and enhance wilderness character. Step Two – Determine the minimum activity. Cross Country Travel Yes No No No

Forest Plan Direction: Equestrian use is permitted off designated trails (cross country or user-created trails that existed prior

to this Plan Amendment) with the following exceptions: • Within 8.2 management areas or inclusions (natural areas) equestrian use is prohibited except on

designated equestrian trails. • Where area or trails are closed or restricted to prevent or stop resource damage (SFP IV 26-27).

Forest Service Policy FSM 2323.12 – maximize visitor freedom within wilderness. Minimize direct controls and

restrictions. Apply controls only when they are essential for protection of the wilderness resource and after indirect measures have failed.

Options Considered: Allow for a continuation of cross country travel for all visitors IDT Discussion: The minimum necessary is to close or upgrade trails that have exceeded the threshold in terms of resource degradation. The minimum is also to restrict or remove the uses that are likely to perpetuate negative evidence of man’s impact and are likely to continue adversely affect the undeveloped, untrammeled and natural aspect of wilderness. The tool is a higher degree of management control or restrictions and monitoring.

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Signage Step One – Determine whether action is necessary. Current signage in the wilderness does not conform to Forest Service guidance and policy. Action to restore, enhance and protect wilderness character by bringing signage up to standards is necessary to improve wilderness character. Step Two – Determine the minimum activity. Signs – Directional, Regulatory, Boundary

Not in

compliance

Yes

Yes

Yes

Forest Plan Direction: All signs will conform to Wilderness standards (SFP, IV-119) Signing will be kept to a minimum and primarily used for direction and safety (SFP, IV-119) Axe blazing will generally be used where reassurance markers are needed. There should be no

painted or plastic blazes (SFP, IV-114) Options within wilderness considered:

Axe blaze on trees as reassurance (directional) markers, Boundary signs (wilderness and natural area) only, Mix of unpainted, branded wooden directional signs and branded (unpainted) boundary signs No additional blazing or signing

IDT Discussion: The use of axe blazing would be the most minimum evidence of man’s work within wilderness. However, it is not likely to be enough of a reassurance marker to eliminate spray painted rocks and live trees or graffiti on live trees that visitors are currently using as directional signage. The boundary signing found around natural areas is not the minimum tool. A more minimal tool would be to replace the highly visible yellow markings with materials that blend with the wilderness landscape.


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Stock Confinement Areas

Step One – Determine whether action is necessary. Equestrian users need to have the opportunity to tether their horses and hike to scenic features where equestrian use is not allowed. Using areas to confine these impacts to a smaller footprint would benefit wilderness character. Stock Confinement areas were deemed to be necessary. Step Two – Determine the minimum activity. Signs – Directional, Regulatory, Boundary

Not in

compliance

Yes

Yes

Yes

Number/Size of confinement areas

9/1.3 acres

4/0.8 acres

4/0.8 acres

4/0.8 acres

Forest Service Policy FSM 2323.12 – maximize visitor freedom within wilderness. Minimize direct controls and

restrictions. Apply controls only when they are essential for protection of the wilderness resource and after indirect measures have failed.

Options Considered: Eliminating stock confinement areas Retain existing number and size of areas Expand number and size of areas Reduce number and size of areas Relocation of areas

IDT Discussion: Equestrian use is a valid and traditional means to travel within wilderness. Visitors with stock need a place to tie up horses. The minimum activity is to offer stock confinement areas that are located where they are not substantially noticeable and where they have the least impact on soil, water, botanical and riparian resources. Stock confinements areas need to be of a size that precludes more undisturbed vegetation from being impacted due to the designated areas being insufficient in size. The number of areas needs to reflect, from established use patterns, where these areas are needed and would be readily utilized in order to prevent additional undisturbed vegetation from being impacted due to there being an insufficient number of areas.

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Improvements within Stock Confinement Areas

Step One – Determine whether action is necessary. Equestrian users need to have the opportunity to tether their horses and hike to scenic features where equestrian use is not allowed. Using areas to confine these impacts to a smaller footprint would benefit wilderness character. Improvements within Stock Confinement areas were deemed to be necessary to further confine impacts. Step Two – Determine the minimum activity. Improvements within Stock Confinement areas

Highlines and Remnant

Hitchracks

Highlines

Highlines

Highlines

Forest Plan Direction: The Forest Plan states that new facilities incompatible with wilderness will not be constructed.

Hitching racks and fire rings will not be constructed. (Forest Plan, IV-113).

Forest Service Manual • FSM 2320.5.5. – Permanent improvements... a structural or non-structural improvement that is to

remain at a particular location for more than one field season - include trails…fences… • FSM 2320.5.7. - Temporary structure is any structure that is easy to dismantle, that could be

removed completely from a site between periods of actual use. • FSM 2323.13e – Construct hitch-racks and drift fences to control recreation stock only where

they are essential to protect the wilderness resource. Build them with materials and locate them in places that harmonize with the environment.

Options Considered: • Equestrians carry and use their own portable electric fences. • Equestrians carry and use pickets and hobbles. • Equestrians carry and use their own highlines. • Corrals/pens/fences are constructed on-site. • Hitching racks are constructed on site.

IDT Discussion: Relying on visitors to bring their own equipment such as electric fences, picket and hobbles and highlines is not likely to meet the objective of restricting the amount of acreage impacted for stock confinement purposes. The use of electric fences and pickets and hobbles would require more sites or sites that are much larger. For those that choose to use a highline, more trees that are currently undamaged may be routinely used with root damage and cribbing resulting. In this situation, where a high volume of equestrian use occurs, the ability for individuals to select and choose their tie-up location as well as restraint method is not the minimum necessary for administering wilderness. While hitching racks and corrals/fences may meet the objective of confining impacts, the structures would be substantially noticeable when compared to other options. In addition, a Forest Plan amendment would be needed. The use of a highline is, in these circumstances, would be a minimum tool when other options are considered. Eliminating horses from wilderness is not a viable option and would be contrary to the enabling legislation, Forest Plan goals, Forest Service policy and the Wilderness Act which does recognize traditional modes of travel to access wilderness.


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Regulatory Controls Step One – Determine whether action is necessary. The interdisciplinary team determined that certain actions were necessary to restore, enhance and protect wilderness character. Specifically, we considered group size limits, seasonal and wet-weather closures and hiker-only trails. Step Two – Determine the minimum activity.

Restrictions Alternative 1 Alternative 2 Alternative 3 Alternative 4

Group Size Limits No Yes/10 people per group

Yes/20 people per group Yes/8 people per group

Seasonal Closures No Yes 12/1 - 3/31 No Yes

11/1 – 5/15 Hiker Only Trails No Yes Yes Yes

Forest Plan Direction: The Forest plan (IV-113) states that LAC will be used for monitoring effects of management on the

wilderness resource and the range of options will be considered when unacceptable environmental damage or significant user dissatisfaction occurs. The emphasis for correcting problems is:

1) Educational approaches such as signing and brochures 2) Natural resource modification such as closing trails, restoration and tent pads 3) Use of regulatory approaches such as law enforcement 4) Permit systems will be used only when other methods fail

Forest Service Policy FSM 2323.12 – maximize visitor freedom within wilderness. Minimize direct controls and restrictions. Apply controls only when they are essential for protection of the wilderness resource and after indirect measures have failed Options Considered:

Voluntary group size recommendations Group size restrictions (regulations) Use (quota) limitations by issuance of voluntary permits Use (quota) limitations by issue of mandatory permits Group size restrictions for equestrians

IDT discussion: Relying on voluntary group size recommendations and voluntary permits may not achieve the objective of maintaining or improving a visitor’s wilderness experience by managing encounters with groups. Intensive management would be required to gauge the results. Imposing wilderness-wide quotas (or overall use limitations) would not be the minimum necessary for the administration of wilderness at this time. The actual use levels by trail within the Lusk Creek Wilderness (and wilderness wide) are unknown - or are supported by very little use data. The Forest Plan is clear that a range of options should be tried before reverting to this type of permit system. Until a response is seen from the proposed trail upgrades, a group size regulation is viewed as the minimum necessary to maintain and improve wilderness character. Monitoring needs to occur to gauge the effects of trail upgrades, of all actions to wilderness biological and physical resources, and to changes in use or encounters in order to determine what the long term management need is to maintain and improve wilderness character.

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Seasonal Stream Crossing Closures Forest Service Policy

FSM 2323.38 Wilderness Act requires managers to search for a balance between preserving the wilderness resource by protecting natural ecological processes that can cause plant and animal populations to change, while at the same time making the resource available for visitor use and enjoyment. It may be necessary at times to limit visitor use to ensure that human influence does not impair natural wildlife or fish populations or their habitat.

IDT Discussion: One option would be to install a bridge to avoid the seasonal closures. In terms of the minimum necessary, seasonal stream crossing closures would be the minimum tool or the minimum necessary for the administration of wilderness as it relates to the least brook lamprey. The closure would be relatively short in duration (2 months), would achieve resource objectives and would still allow visitor’s the use and enjoyment of the area for the majority (10 of 12 months) of the year. A bridge would be substantially more noticeable as it could not be simple log stringer. It would have to be engineered and designed to accommodate horse use. Hiker-only trails IDT Discussion: The purpose of the hiking-only trails is to limit encounters between hikers and equestrians on routes that lead to high use iconic sites. The minimum activity would be to monitor the effect of this action to determine effectiveness given the minimal number of trails that would separate use. Upgrading the trail system to reduce or eliminate resource degradation would not reduce the potential for encounters but it should improve wilderness experience.

Stream Crossings Step One – Determine whether action is necessary. Bank structures at designated stream crossings were determined to be necessary to minimize erosion and protect the functioning of the streambanks. Step Two – Determine the minimum activity. Options Considered:

• Engineered and designed planked bridges • Horse fords – tread is built up through the stream channel with gravel and rocks • Reinforced streambanks and stream approach with no engineered crossing

IDT Discussion: The minimum necessary is to protect sensitive soil, water and aquatic habitat resources by reducing or eliminating the potential for trail systems (which cross water) to impact the resources from erosion and sedimentation. The minimum tool or activity is the option that protects resources while being as unobtrusive as possible. In this case, reinforced streambanks with no engineered crossings serves both objectives. This option also retains the opportunity for some risk and challenge to both hiker and equestrian visitors.


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Commercial Outfitter/Guide Services Step One – Determine whether action is necessary. Without the commercial equestrian campgrounds, most of our wilderness users would not have a place to stay that could accommodate them and their stock. These users are seeking a recreational experience that meets an important purpose for the designation of the wilderness. Since we already had court-ordered permits and if new permits were to be issued they needed the proper environmental review, the interdisciplinary team concluded that this action was necessary. Step Two – Determine the minimum activity. Forest Plan Direction:

Special uses in Wilderness will not be permitted, except where in accordance with private rights. Requests for new permits will be considered on a case by case basis and will include evaluation of the potential impact on the Wilderness Character (SFP IV-116).

Outfitter and other commercial permits may be issued if compatible with Wilderness objectives and if they provide for protection of Wilderness attributes (SFP, IV-117).

Forest Service Manual (FSM) 2323.13, 2320.3.3. (non-conforming uses) and FSM 2320.2.3 (minimize impacts of those kinds of uses and activities generally prohibited by the Wilderness Act)

Forest Service Manual (FSM) 2323.12 – Consistent with management as wilderness, permit outfitter/guide operations where they are necessary to help segments of the public use and enjoy wilderness areas for recreational or other wilderness purposes.

Options Considered: Elimination of existing equestrian outfitter and guide permits Re-issuance of outfitter and guide permits at existing levels

IDT Discussion: The interdisciplinary team considered several factors in assessing the need for commercial services in the wildernesses. Between April 2003 and March 2005, about 6,000 equestrian wilderness visitors stayed at the commercial campgrounds around Lusk Creek Wilderness (Chilman 2005). While this is only one year of data, it does provide some insight into the level of use at the campgrounds. These equestrians make up the majority of our wilderness users in the Lusk Creek Wilderness. Without the commercial equestrian campgrounds, most of these users would not have a place to stay that could accommodate them and their stock. These users are seeking a recreational experience that meets an important purpose for the designation of the wilderness. The Lusk Creek Wilderness visitor survey (Chilman et al. 2005) found that 81% of users rated their wilderness experience above an eight on a scale of one to ten. With the high satisfaction rate indicated by this, the interdisciplinary team concluded that use should not be limited at this time. As mentioned above, the team concluded that building a reasonable trail system that could be maintained was a logical first step in solving the issues related to wilderness character. Another important aspect in allowing for commercial services to be provided in wilderness is the extent to which these services are necessary. The campgrounds serve as hosts for most of the equestrian users that visit the project area; without these services many equestrian tourists would not be able to enjoy our wilderness resource. Working together to educate people to the proper use of the trail system is potentially the biggest benefit that we can provide for resource management. If, in the future, a limit on the total number of users is determined to be needed, then the equestrian outfitter/guide permits will provide a mechanism for limiting commercial use. Until use limits would be necessary, the current permitting process should be adequate to enhance and protect wilderness character.

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The interdisciplinary team concluded that Commercial Equestrian Outfitter/Guide Services were appropriate and necessary to fulfill the recreation purpose of the Wilderness Act. In addition, future monitoring of use levels and satisfaction will provide the information necessary to make future determinations on whether the use needs to be limited to further protect the social aspects of wilderness character.

Non-Conforming Uses Step One – Determine whether action is necessary. According to the Wilderness Act of 1964, existing (at the time of designation) valid non-conforming uses such as access to private property must be allowed. Step Two – Determine the minimum activity. Forest Plan Direction:

Special uses in Wilderness will not be permitted, except where in accordance with private rights. Requests for new permits will be considered on a case by case basis and will include evaluation of the potential impact on the Wilderness Character (SFP IV-116).

All roads will be eliminated except those necessary for access to private property (SFP, IV-119)

Forest Service Manual: (FSM) 2323.13, 2320.3.3. (non-conforming uses) and FSM 2320.2.3 (minimize impacts of those

kinds of uses and activities generally prohibited by the Wilderness Act) (FSM) 2320.5.16 – Valid Existing Rights – those property rights that were in existence on the date

of wilderness designation…that were created by a legally binding conveyance, lease, deed, contract, or other document; or as otherwise provided by Federal law.

IDT Discussion: Whether the action meets the minimum necessary has been determined by law, regulation, and policy.


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Wilderness Working Papera123.g.akamai.net/7/123/11558/abc123/forestservic... · 2010. 8. 3. ·...

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