SEKI - Comment Period - Wilderness Stewardship Plan -

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gdurkee
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by gdurkee »

Hmmm. You're right. It came in the mail and I had assumed they'd posted it on their web site. I'll try to scan and post it.

g.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by tomba »

Thank you George for bringing attention to destination quotas. I missed their significance when I first read these documents.

I am concerned that when SEKI perceives that there is too much human impact in some area, often close to trailheads, they may reduce trailhead quota or maintain current low quota. This in effect limits the total number of people entering the wilderness, even for people that disperse far from trailheads, or even far from trails (cross country).

Instead, they could add additional permits for entering wilderness and traveling the first day beyond popular areas close to the trailhead. I.e., the first night must be spent further than these popular destinations. Yosemite has few permits like this (Glen Aulin Pass Thru, Happy Isles Pass Thru, Mono Meadow). A candidate for such additional quota could be Lakes Trail. A portion of such permits should be reservable.

Additionally, they could add cross country "trailhead" permits were feasible. Yosemite has such permits - Budd Ck. and Nelson Lk. There may be no suitable places in SEKI for such "trailheads" in High Sierra though.

Before reducing quota for a given area, SEKI should present studies that show that human impact is too high in that area and seek feedback on how to address this issue.

They should consider removing quota for trailheads for which quotas rarely fill up. This would remove needless worry for visitors.

I am concerned that most alternatives call for reduced visitor access.

Tomorrow is the last day to submit comments.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by tomba »

Based on my comment ID it seems that only about 100 comments have been submitted about about one hour before deadline.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by gdurkee »

On re-re-re-reading, I'm less sure there's an emphasis on destination quotas, though they're holding that open as a possibility. There's definitely a proposed relationship between their zones and maximum party size. Currently there's only group size limits for on trail (15) and some off-trail locations (8).

It's good to have trailhead numbers but current and projected use levels just don't, to me, justify the sometimes draconian sounding numbers they propose nor the headers of the alternatives. The several other comments sent me from NPS friends seem to agree with this, so maybe there's hope they'll rethink this.

But ultimately, the zone approach just made this document a confusing mess without an obvious need for doing it.

I submitted mine separately as a full document, as did a few other friends of mine. Most organizations also submit that way (e.g. High Sierra Hikers) so that wouldn't be reflected in the numbers.

But anyway, this is only stage 1! Thanks, everyone, for getting involved in the process. Once you're on their email list, you'll get updates on the next stage of the process. Mike would know better, but I think it'll be commenting on the final Alternatives when they're published.

George
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by oldranger »

George wrote:
It's good to have trailhead numbers but current and projected use levels just don't, to me, justify the sometimes draconian sounding numbers they propose nor the headers of the alternatives. The several other comments sent me from NPS friends seem to agree with this, so maybe there's hope they'll rethink this.
Remember these are preliminary draft alternatives just used in scoping (getting feedback from public). The Draft EIS will include a Purpose and Need and Affected Environment. The need portion must clearly state the issues and the Affected Environment should provide the data to substantiate that the issues are real. Failure to do so would constitute a fatal flaw in the courts. The alternatives then will be tweaked (my guess is significantly from what we have seen) to address the Issues described under "Need." Finally the "Enviornmental Consequences" of the alternatives must be described and these include not only consequences on the "environment of the wilderness" but also on the "users." Because the mechanism for developing the plan is an EIS an alternative that has impacts that can be considered "bad" can be chosen if the decision maker considers the negative stuff necessary to achieve an overall best choice. For example a certain amount of impacts of overall use may be acceptable close to trailheads (for example lack of Solitude) in order to provide reasonable access to more distant destinations.

Anyhow I would not be surprised if we are 2 years away from a draft EIS (which will provide another comment period and 4 to 5 years from now for the Final (another opportunity to provide imput and a time at which imput must be made by individuals and organizations if they might be willing to go to court to change a decision). You can't enter the "game" or cause "overtime" unless you participate in the process to establish "status."

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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by gdurkee »

Mike: good overview!
Anyhow I would not be surprised if we are 2 years away from a draft EIS (which will provide another comment period and 4 to 5 years from now for the Final
That was my thinking when this whole thing started, but they're under Congressional mandate to finish by 2014. An interesting way to legislate (likely) bad planning.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by oldranger »

George wrote
That was my thinking when this whole thing started, but they're under Congressional mandate to finish by 2014. An interesting way to legislate (likely) bad planning.
Having experienced other congressional mandates for plans by a certain date I can tell you that the complexities of NEPA (National Envionmental Policy Act--an act of Congress) plus subsequent Court Rulings makes the mandated date irrelevant. Ultimately if NEPA were not followed it would be easy to get a Court Ruling to go back to the drawing board without even having to question the substance of the plan. Fortunately Congress does not control the Courts (as I understand the concept of separation of Powers). As much as the NPS might like to cite the 2014 date it really is not possible to meet that date--(I don't want to bore you with all the necessary steps that need to be taken--the most critical are to ensure that the Public has a chance to comment and that those comments are addressed).

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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by gdurkee »

I wondered about that in the original Act vs. court. Can Congress interfere with an active court case? I didn't think they could but never followed up with anyone at HSHA to explain what the court said.

And then ordering a complex process to take place in X time. Well, they do stuff like that all the time but, as you say, it probably is meaningless. I also wonder if what I think of as a moderate mess of a first draft of alternatives reflects the haste & pressure being applied.
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