SEKI - Comment Period - Wilderness Stewardship Plan -

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KathyW
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SEKI - Comment Period - Wilderness Stewardship Plan -

Post by KathyW »

Don't forget to comment:

http://parkplanning.nps.gov/document.cf ... ntID=49956" onclick="window.open(this.href);return false;
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by tomba »

Many of the proposed alternatives call for wilderness permit quota reduction (Table 1).
Many of them also call for pack-out waste kit bags for human waste (Table 3).
-- Found trash? Please pack it out. Thank you.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by gdurkee »

OK. It's taken me awhile, but I'm finally putting together my darned brilliant insights on the Sequoia Kings Wilderness Stewardship Plan. The draft alternatives they've presented are kind of a mess and hard to get through, but remember, the last one came out in 1986. This Plan will guide & regulate backcountry use for, likely, the next 30 years, so it's important to read it and comment.

I'm constantly revising this and posted it over on Whitney Zone, but these are my updated commennts. I'll post in three sections. The first will be a summary; the next on the zone system they're proposing; and the last on protecting Sierra meadows.

Everyone's thoughts and comments appreciated. The deadline for comments to NPS is November 19th! So get your thoughts in online soon!!

Thanks,

George

************************************************

In spite of several readings of the Draft Alternative Tables for the Sequoia Kings Wilderness Stewardship Plan, I’m not sure I fully understand many of the proposed alternatives. I’m hopeful the final Alternatives are more clearly presented. In addition, the current headers seem perhaps too provocative for Alternatives 4, 5 and 6. The phrase “decreasing visitor access and increasing restrictions” and the increasingly draconian sounding alternatives from there is dependent on actual numbers for future implementation – numbers that are not presented yet. The reality is, when compared to current use patterns, the actual effects may not be all that significant. To present the Alternatives as you now have them may skew people’s perceptions of their true impact and so affect their understanding and comments.

Summary
I have three major criticisms of the Draft Alternatives as written. I will summarize here and provide details further on.

1. Organizing and potentially limiting wilderness visitation and permitting by zones is both practically unworkable and violates the basic spirit of wilderness travel. It marks a major departure for both the practical side of managing wilderness use as well as a major change in how visitors might relate to wilderness. A person should, within reason, be able to travel wherever they want and stay as long as they like. This is the long-established Freedom of the Hills that is at the core of the wilderness experience. Nothing in current or projected future use patterns suggest any need to change this.

Zones are useful for visualizing use patterns and modeling dispersal from trailheads, but actual implementation of permit quotas and camping restrictions should continue to be based on controlling the daily number of people and stock allowed to leave a trailhead each day. There can, of course, be mitigations within an area—the number of nights at a lake, for instance, could be limited. The guiding philosophy, though, should be that once a person gets a permit, that person can go almost wherever they want as their spirit inspires them.

2. While establishing an elevation limit for grazing is an alternative worth considering, it does not guarantee full protection for iconic Sierra meadows should grazing be closed in elevations above those meadows. It is imperative that Alternatives 3, 4 and 5 contain wording that at least one or more meadows will be completely closed to grazing in each canyon ecosystem. Such permanent closure would be determined based on the meadow’s ecological, esthetic and social importance to that canyon ecosystem.

Merely limiting grazing of meadows is not sufficient. To allow visitors a full range of a true wilderness experience when travelling in wilderness, they absolutely must have the opportunity to experience large meadows absent ANY grazing by stock. In addition, the park service must carry out its mandate under the wilderness act to afford complete protection to at least some meadows, allowing them to reach their full ecological potential that has been denied by over a century of stock grazing.

3. The zones proposed are, apparently, created relative to their current use levels – a factor that is a result of their geography (close to a trailhead) and social variables of visitation (popular trail corridor). Tables 4 and 6 say that stock numbers and grazing will be managed to, among other reasons, protect resources – an ecological constraint. The Alternatives for those tables, though, seem to propose stock use levels based on the socially-defined zones rather than the ecological and aesthetic effects of grazing on specific areas – meadows and watersheds. The WSP cannot use a socially derived zonal plan to regulate what the document clearly says should be based on resource protection.

For instance, while several of the Alternatives propose a possible elevational limit to grazing, that is only a small part of the resource protection variables that must be considered as a direct result of the impacts of stock grazing. Such impacts and potential impacts are not reflected in a zone approach to management. Management must be based on ecological and aesthetic considerations – local and general – and not on these socially-derived zones.

Grazing, then, must be managed independent of these zones. That does not mean that stock users need be regulated much differently in their access and group size by zone – a social consideration – but that the animals supporting their trip cannot graze more or less based on those zones.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by gdurkee »

Part 2, for your reading enjoyment!

****************************************
Detailed Comments
Zones
I understand that this document is, necessarily, general in presentation. As such, there are no details on how a zonal system would be used to regulate use. Nonetheless, I don’t see how it can realistically be enforced or, philosophically, implemented within the spirit of the Wilderness Act and historical attitudes towards backcountry use.

Practical Considerations
If I’m reading this correctly, a person getting a permit would be limited as to where they could go based on where they want to go and what zone their destinations are in. In my 40+ years of experience, people getting permits might have only a general idea of their route and be able to name just a few of the specific places on that route. The permit issuer, then, would have to determine what zones of travel the person goes through and grant or deny a permit based on that. In addition, for permitting purposes, will the zones be as shown by the map, or more fine-tuned like the Travel Zones that currently exist for the parks. So would travel limits be based on the former (larger) zones or the latter? If, say, zone D has reached it maximum, does that mean that a person wanting to enter the Ionian basin – where maybe no one has gone – can’t go there because the overall zone is full?

Whether the alternatives are based on the broader zones as mapped by the Draft or the existing Travel Zones, implementation means that separate daily tallies have to be made of travel destinations and the permit issuer has to be aware of those tallies AND know the place names of the traveler. The permit issuer must locate those zones to be able to determine if the zone is full or not. This is totally unworkable. There is no way a USFS permit issuer in Lone Pine or Bishop, for instance, is going to know the location of Chasm Lake or Lake 10,212 then be able to tell a person it’s full, then take the time while the visitor tries to come up with alternative routes that are not full. In my experience, permit issuers now almost universally only list the first three or four nightly camp destinations. To do more requires greater knowledge and time. Both are almost impossible given the size of their area of responsibility and the length of lines on an August day.

Nor can I imagine how the zone system is going to be effectively enforced once the visitor is travelling in the backcountry. A ranger is going to have to be familiar with what locations are in what zones and carefully check the permit to see if the visitor is allowed at a particular place. The named place (or zone) on a permit may not at all match where that person is but enforcement will depend on matching their location to the zone allowed on the permit. Another level of especially intrusive enforcement is placed on both the visitor and the ranger to the benefit of no one but to the detriment of the spirit of wilderness. Finally, if a visitor is suddenly inspired to go somewhere not listed as part of their original plan, can they get permission to change if they find a ranger or are they locked into their original itinerary?

Philosophical Considerations
Wilderness is about freedom. Any management system that limits that freedom is inherently antithetical to the very spirit of wilderness. Absent obvious and quantifiable ecological or social impacts from overuse, there is no need to micro-manage wilderness travel as proposed by the zone plan introduced with these alternatives. I have been a backcountry ranger for over 40 years and can authoritatively say that impacts are not even close to those where such micro-management is necessary.

At the height of wilderness visitation in the late 60s and through the 70s, impacts were far greater than they are now or are even projected to be. Even then, those impacts were localized and did not require anything other than the daily trailhead maximums that were established by the mid-70s. Those maximums were, to a certain extent, based on dispersal patterns. If 50 hikers left the trailhead, 30 of them would go to, say, the closest lake, 10 would continue on a loop, and maybe 10 would disperse to more isolated cross-country areas. Use, then, could be regulated by the total numbers allowed per day. If impacts increased in, say, the close-in lake, the trailhead quota could be – and often was – reduced to reduce overall impacts. Or if it was clearly a localized problem, a camping nights limit could be placed on the specific lake and the daily quota remain the same.

In my direct and long-time experience, this management approach continues to work extremely well. A person leaving a trailhead has an infinite number of possibilities to choose from while travelling. A wilderness traveler can see a basin from the trail or on a map and suddenly choose to go there. Such unrestricted possibility is at the core of what wilderness – and Sequoia and Kings Canyon National Parks – must offer backcountry users. People’s daily lives are nothing but constraint on their movement: schedules must be met; specific roads must be followed in specific directions and at specific speeds; a myriad of rules govern every aspect of work and life. But when a person puts on a backpack and steps onto a trail, all that changes. There are a few rules, sure, but a person can go wherever they want at whatever pace they want. They’re not required to be at a certain place at a certain time. They can change where they’re going and even how long they’re staying if the spirit of wilderness so moves and inspires them.


This must not be tampered with in any way. Absent any compelling reason to change from trailhead quotas, that system should continue to be the primary management tool to regulate use levels. To no obvious advantage or reason, zone-level management would seem to increase regulation and discourage the realization of immanence, even enlightenment, when travelling in wilderness.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by gdurkee »

And, last, meadow protection, which I consider the most critical aspect of this plan.
Thanks for wading through this!

George

*************************************************
Protect Specific Iconic Meadows
Manage Grazing According to Ecological and Aesthetic Criteria, Not Zones

Meadows are the heart and soul of the Sierra. Along with granite peaks, the huge meadows that occur along rivers in canyon bottoms are iconic. Their unique riparian ecosystems are vital to both the ecology of watersheds and the aesthetic experience of wilderness travelers. With only one exception, in all of Sequoia and Kings Canyon National Parks, every major meadow on a popular trail corridor is subject to grazing. A person hiking the John Muir Trail has only one opportunity in over 100 miles of travel to experience a large meadow free of grazing impacts – Vidette Meadow. This is unacceptable and a glaring failure of the Park Service to truly provide for the enjoyment of visitors and leave park areas in as unimpaired condition as possible.

Managing meadows and watershed-level meadow ecologies cannot be done according to the zones proposed. Those zones are based almost entirely on social criteria – where use has, historically, been concentrated or not. They are not in any way based on the ecological relationships of the requirements and relationships of meadows or the watersheds they are a part of. The draft says that, if allowed, grazing will be “managed to protect ecological functions…”. It appears, though, that such management will be based on, among other criteria, the zones the grazing takes place in. That’s a contradiction. Grazing must be entirely managed on ecological and scenic criteria, regardless of the zone the grazing takes place in or the previous history of grazing in individual meadows or watersheds.

Although the USE of stock is, unquestionably, “a primitive type of recreation appropriate to fulfill the recreational purpose of wilderness…” the stock supporting the people has absolutely no intrinsic right to graze Sierra meadows. Stock and meadow management has morphed into recognizing the animals as a user group equal to people. Stock numbers are looked at independent of the number of people they carry into the wilderness and their associated grazing as a fundamental right of those animals. The essential question when stock is regulated – whether for grazing or party size – is: Is the ecological, aesthetic and social impact of stock justified by the number of people they support on any given trip?

In LeConte Canyon this year, I witnessed a meadow that was made aesthetically offensive for about three weeks following a stay of 6 animals for three nights. The grasses were trampled, soil churned up, two new 10’ X 3’ roll pits eroded through meadow sod, stream banks collapsed by hoofs and the entire area smelled strongly of horse urine and manure. Those 6 animals supported a multi-day trip of only two visitors. Two park visitors essentially wrecked the wilderness experience of anyone who wanted to camp at that site and meadow for at least the next three weeks. It was perfectly acceptable under current regulations and meadow management criteria. That is not in any way acceptable and the Draft Alternatives of the WSP must establish clear rules to both mitigate and prohibit such impacts.

Stock can be allowed only to the extent they further wilderness values by allowing human visitors to experience wilderness. This must be made clear in the Topic summary and the Alternatives so derived. The Alternatives must also clearly require carrying feed to mitigate and eliminate many of the unacceptable impacts of grazing. Stock use can and should continue to be allowed to further the wilderness experience of visitors choosing to travel with animals, however grazing must be severely limited to protect a meadow’s ecology and a visitor’s experience.

Aesthetic and Ecological Considerations : Protecting Meadows
These iconic Siearra meadows are endangered. Each one is slowly disappearing from encroachment of Lodgepole pine around their margins. Most of the major meadows in, for instance, Evolution Valley will lose 20% of their area over the next two decades. The reasons for the lodgepole encroachment are not completely clear. Climate change is certainly a factor, but it could well be accelerated or exacerbated as a result of grazing or other human activity. This threat makes total protection for at least some of these meadows imperative.

The draft alternatives suggest that the primary management tool to completely close meadows to grazing will be by a yet to be determined elevational limit. This is not sufficient to provide for the ecological integrity and aesthetic enjoyment of the meadows that might be below such limits. The grazing section of Table 6, Alternatives 2, 3, 4 and 5 must explicitly require that criteria will be established such that an increasing number of the large canyon-bottom meadow per drainage will be completely closed and protected from grazing to preserve and protect their ecological and aesthetic integrity. The long-term goal would be rehabilitating them to as pristine a state as possible.

Historically, meadow management has been focused almost entirely on establishing limits for use nights in specific meadows. Establishing those limits have been based on several criteria: long term ecological impacts, e.g. whether the meadow is likely to show changes in species composition over years; and short term ecological impacts, e.g. whether an unacceptable amount of biomass (aka grass) is being removed from the meadow such that it can’t recover to some arbitrary level that season. No serious consideration is given to either aesthetics or the effects of grazing on any part of meadow ecology other than removal of grass by grazing. No serious consideration is given to meadows as a vital riparian habitat, as nesting area to waterfowl and land-nesting birds; to the small mammals and insects that make up the fragile ecology of these meadows.

Aesthetics – the sights, sounds and smell of a meadow – are inseparable from the wilderness experience and enjoyment of a meadow. Yet aesthetics and the potential effects of grazing on visitor enjoyment of a meadow play absolutely no part in meadow management and little explicit part in the draft alternatives.

Stock routinely create “roll pits” in fragile meadows. While not optimal or encouraged, these pits are not a violation of any current regulations or policies. There is no Sierra meadow free of roll pits. Such pits take decades to recover to their vegetated condition, if they do at all. In addition, a party supported by even a small group of stock will leave the immediate area around their camp an incredibly unpleasant experience for weeks after their visit. Manure and urine in and around camps make them smell like a pasture; the grasses for hundreds of yards surrounding a camp is trampled, pawed and chewed up; stream banks near where stock go to water are sheared off; and stock often urinates and defecates directly into and near open water. Regulations are in place – and strictly enforced – stopping human visitors from causing even 1/100 of these types of impacts, yet it is perfectly within regulations for stock to do it.

The draft alternatives say that grazing and party size of stock will be managed to protect resources. Yet it allows a 1:1 exchange of people and stock to make up a maximum on total party size. Although a maximum of each (people and stock) is set and can’t be exceeded, the implication is that subtracting one person can be substituted by an animal, which is an absurd proposition. An animal has, at minimum, ten times the ecological impact of a human – and some experts put that impact at 50 times. Nowhere is there a hint on how these relative numbers are arrived at or a clear set of criteria for changing those numbers based on actual ecological and aesthetic benchmarks. While the proposed total party size and limits on total stock would seem to provide a reasonable standard for total group size, stock must not be allowed to be part of that exchange. They are not equivalent and there must be no management policy that makes them so or implies that they are the same.

Standards
Two standards, then, must be explicitly stated throughout the final alternatives:
1. Independent of where a possible elevational limit is set for grazing, specific iconic meadows will be chosen for their ecological and aesthetic values and closed permanently to grazing. For Alternative 2, this could be one meadow per canyon; for Alternative 3 this could be 2 meadows; and 3 meadows for Alternative 4 and all meadows for Alternative 5. In Alternative 2 and,3, camping in closed meadows with stock would still be allowed in designated stock camps (to preserve the aesthetic integrity of both camps and meadow) but they’d have to bring their own feed.

2. It is not enough to merely list “scenic” as a quality to determine a management criteria. Aesthetic considerations must be clearly defined and integral – fully equal to biomass removal – to how meadows are evaluated for stock use nights. Such an evaluation will establish criteria to look at the meadow, the stream and surrounding campsites. Criteria will include how an area looks – how close does it resemble a meadow undisturbed by stock or human use; how it smells; and how it sounds – are the grasses tall enough such that one can hear the susurration as they are moved by the breeze? The latter won’t happen if the grasses are trampled or eaten by stock.

Additional ecological considerations beyond mere biomass removal must be established and made in both the alternatives and, eventually, accompanying supporting narrative. Short term impairment should be fundamental to a true evaluation of a meadow. It is not enough if, after several stock parties have grazed a meadow that recovery the following season is sufficient to find no impairment to the ecology of a meadow. A meadow’s total ecological integrity much be considered – what is the effect of grazing for small mammals such as marmots and belding’s ground squirrel; what are the potential effects on nesting habitat of birds, both aquatic and those on dry ground; what are the effects of manure on meadows and the potential runoff of pathogens, nitrates, phosphorous etc. into streams? Not a single one of these criteria currently guides stock use numbers.

We are not the Bureau of Land Management or US Forest Service. Preservation should be the primary goal of all management, not what is effectively a “sustained yield” policy of current meadow management practices. If meadow management is truly to be about meadows, then in actual practice it has to be more than rangeland management, which is all it currently is.

Finally, both of these criteria would be independent of what zone the camping or grazing is in. They would be established entirely according to the ecological and aesthetic needs and criteria of the individual meadows and watersheds they are in.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by Shawn »

George,

Hope you don't mind too much; I just used some of your words when submitting my feedback (mostly the wilderness travel aspects). Thanks for the in depth review.

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

Post by gdurkee »

Shawn & anyone else -- happy to be quoted.
Thanks for getting involved in this!

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

Post by Wandering Daisy »

I thought that the Inyo Forest and Yosemite already has a zone system - not that the zones are used specifically for limiting access, but rather so they can code where people are. I half recall that when I got a permit the ranger had to look up zones, but I may be wrong. I do know that Happy Isles had two TH quotas - those who stay at Little Yosemite Valley and another quota for going beyond the first night.

A zone system may be a good "guideline" to keep everyone from clogging a few areas - help spread things out, but, would be nearly impossible to strictly enforce. It seems that if you had some "pass through" permits to get beyond the popular close attractions, you could actually give out more permits.

Thanks for your summary. I will have to re-read what you wrote and think about it.
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Re: SEKI - Comment Period - Wilderness Stewardship Plan -

Post by LMBSGV »

SEKI also puts down which zone you are staying in each night. The current zones are different than the ones in the Wilderness Stewardship Plan. They correspond to an area on the map and don't pay attention to how popular the area is. One time when I was picking up my permit, a ranger told me that I wasn't required to actually spend each night in the zone indicated on the permit; it just would be helpful for their record keeping and future planning as well as help narrow down where I might be if a SAR was needed. This year when I was picking up my permit for Kaweah Basin, I had to show the ranger where it was on the map and the correct zone to put down.
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SEKI - Comment Period - Wilderness Stewardship Plan -

Post by ironmike »

Does anyone have any insight as to which Alternative Plans have more current favor with the NPS or DOI? I'm guessing that Alternative 3 is the unwritten PC choice (whereas my preferences lean more towards Alternatives 2 or 6). Alternatives 4 and 5 seem extremely radical and unlikely to get much public support.
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