Open Letter to Gallatin Forest Partnership supporters

INTRODUCTION

The Gallatin Range lies between Bozeman and the northwest corner of Yellowstone National Park.  Whether to advocate for Wilderness designation for as much of the range that qualifies or supports less restrictive, and consequently less protective designations is an on-going discussion.

Wilderness is the “Gold Standard” for land protection, and I contend that if any public lands possess the minimum attributes to qualify for wilderness designation under the 1964 Wilderness Act, conservationists should always advocate for that classification. We may not get such a designation; however, we should always begin any campaign seeking such classification.

The Gallatin Range is the most significant unprotected wildlands in the northern Greater Yellowstone Ecosystem. Approximately 250,000 acres are still roadless and could qualify as Wilderness under the 1964 Wilderness Act.

The Gallatin Forest Partnership (GFP) is composed of various interest groups including mountain bike advocates, conservation groups like the Greater Yellowstone Coalition, The Wilderness Society, Montana Wilderness Association, guest ranches, and other affiliated organizations.  An agreement was signed in January of 2018 among these various groups on how to divvy up recreational uses in the Gallatin Range and presumably at the same time protect the wildlands values.

The GFP proposes that approximately 102,000 acres out of 250,000 roadless acres be classified as Wilderness, with separate lesser protections such as “Wildlife Management Area” or “Watershed and Recreation Area” designations for other lands in the range.

Proponents argue the GFP proposal is the best landscape protection legislation we can get given opposition to wilderness protection, primarily from mountain bikers and some ORV users. You can learn more about the proposal here https://gallatinpartners.org/wp-content/uploads/2018/01/Final-unified-agreement.pdf

Most of my critique is directed toward the future management of the Gallatin Range.

Within this context, the following is my letter to supporters.

 

Dear GFP supporters

The following is both a critique of the Gallatin Forest Partnerships short-comings as I see them, as well as an attempt to convince you that advocating for as much Wilderness as can be realized in the Gallatin Range is the only ecological and ethical position for any conservation groups to hold.

Wilderness is the rarest “resource” in America. There are plenty of places to ride bikes or do any other outdoor recreation, but there are only a limited number of areas that qualify and can be protected as Wilderness under the 1964 Wilderness Act. And the Gallatin Range is one of those places.

The Wilderness Act is the Gold Standard for landscape protection. With an outstanding wild landscape as exists in the Gallatin Range, let us seek the maximum acreage as Wilderness as possible.

We need to appeal to society’s higher angels. Protecting wildlands by Wilderness designation is an act of self-restraint, an act of humility, and a rejection of the idea that wildlands are primarily an outdoor gymnasium.

EMPHASIZE ECOLOGICAL VALUES

I think the way to succeed in protecting the entire range is to emphasize the ecological values. There is no other part of the northern GYE that is as ecologically valuable as the Gallatin Range, particularly the Buffalo Horn Porcupine drainages (BHP), though I also believe some areas like West Pine in the northern part of the range should also be designated as wilderness as well.

The lower elevation valleys like the Buffalo Horn Porcupine is among the best wildlife habitat in the Gallatin Range and entire northern Greater Yellowstone Ecosystem.  The BHP is documented as some of the best grizzly habitats outside of Yellowstone Park.  It is also an essential elk winter habitat and an elk migration corridor and also supports moose, bighorn sheep, wolverine, mountain goat, wolves, and black bear. According to the Montana Heritage Program, 18 birds, eight mammals, three fish, three amphibians, and one reptile as “at risk” or declining in numbers, demonstrating the need to provide the most durable protection possible for this area. Given the high wildlife values of this area, any proposal that seeks to maintain recreational uses like mountain biking, ORVs, or snowmobiles should be opposed.

I have not seen much attention given to the ecological values in the GFP materials. Though there is “lip service”provided for protecting the outstanding ecological and wildlands values of the range, much of the GFP recommendations would maintain current recreational uses which are not necessarily benign. Worse, in some part of the range, the document calls for an increase in recreational uses that will likely have adverse impacts on the precious wildlands and wildlife attributes that we all strive to preserve.

I think if all of us in the conservation community emphasized the ecological values, opponents would have a difficult time defending their position. I.e., my “right” to ride my bike is more important than protecting the ecological values of the best wildlife habitat in the entire GYE! Can you imagine how selfish and self-centered that sounds?

The scientific literature demonstrates that mountain biking harms wildlife more than other recreational users like hikers or bird watchers. More recreation can harm wildlife, so we must always defer to the land management policies that can do the least harm and bring about the best protection.

ICE AND ROCKS

The 102,000 acres proposed wilderness designation for the crest of the Gallatin Range in the GFP proposal is a good start. It contains a lot of great scenic alpine country. However, it’s the same old Ice and Rocks approach that has been discredited.

In times past, wilderness advocates frequently left out the lower elevation areas of their wilderness proposals to permit logging, roading, or other resource development.  We now recognize how this approach effectively impoverished the ecological value of protected landscapes.

Yet the GFP proposal, by leaving out the lower elevation valleys which have the highest wildlife values, is making the same mistake. And we are excluding the best protection so people can ride their bikes?

The BHP is one of the most critical areas in the entire ecosystem and even in the country. I just can’t believe we can’t make a credible argument that Wilderness is the best designation for these lands.

ECONOMIC VS RECREATION OPPOSITION

In my view, there is a big difference between opposition to wilderness from some recreationists and opposition from the resource extraction industry. When someone thinks they are losing their job that is a far more significant loss than telling someone you can’t ride your bike on this or that trail. I just find it so tragic that we in the conservation community can’t say to mountain bikers that protecting the ecological integrity of these areas is more important than riding a bike.

I have some sympathy for those people who might suffer some economic hardship because of new protective designation; though, of course, I still believe protecting wildlands is more valuable than anyone’s job. But I do understand how that can cause strife and anxiety to someone who might lose their means of putting food on the table.  I feel no certain sympathy for someone who might lose a few mountain biking trail opportunities.

PAST CONSERVATION SUCCESSES

I could give you so many examples where wilderness activists (when united) were able to overcome economic interests. The closest case occurred in the Absaroka Beartooth Wilderness I was around for that effort and participated first hand. I had my very first article published in Wilderness Magazine on the AB proposal. At the time, there were many sawmills in all the communities near the AB wilderness including in Columbus, Big Timber, Livingston, Bozeman, and Cooke City. There were miners with many more small operations scattered around. Oil and gas advocates opposed wilderness around Red Lodge. And there were large herds of sheep in the alpine country in summer.

Imagine how much more difficult it is to overcome such economic interests—all of whom were united in their opposition to the AB Wilderness designation.

And even the motorized recreation lobby was stronger than today. Many snowmobiles, jeep, and dirt bike enthusiasts were regularly traveling from the Boulder River to Cooke City through what became known as the Slough Creek Corridor, and of course, they opposed a unified wilderness as it would close down their existing use of this corridor.

Some members of the MWA wanted to shrink the AB proposal in half to avoid controversy and opposition, especially from the motorized recreationists. But the Wilderness Society, among others, said no way and went for the whole proposal.

To one degree or another, we faced the same strong resource extraction opponents to the Great Bear Wilderness and Lincoln Scapegoat Wilderness. People were active in promoting those wildernesses were run out of town.  Cecil Garland, one of the most vocal supporters of the Lincoln Scapegoat Wilderness was forced to sell his store in Lincoln and move to rural Utah.

SELF-DEFEATING

The GFP is an example of the self-defeating attitude I find is common today among many conservation organizations. It is based on what some believe is “politically possible.”

However, politics is not a straight line, and you cannot predict what will or will not pass Congress. I can give you many examples from the past where seemingly hopeless conservation campaigns ultimately ended up victorious despite all the nay-sayers.

A good example is the Sierra Club’s effort under David Brower’s leadership to preclude dams in the Grand Canyon. Imagine the situation. You had the Bureau of Reclamation, Corps of Engineers, the Congressional delegations in multiple states including powerful Senator Barry Goldwater, Ag interests, city interests, and recreational interests all supportive of building dams in the canyon. Most people thought the dams were unstoppable — most people that is except David Brower.

David Brower was unwilling to accept the idea that dams were inevitable. He fought the dam proposals including countering the argument that creation of reservoirs would “improve” recreational opportunities since people could use motorboats to access the canyon. In a New York Times ad, Brower asked rhetorically “Should we also flood the Sistine Chapel so tourists can get nearer the ceiling?”

I ask the same question of GFP. Should we promote mountain biking and other recreational uses that will inevitably compromise the wildness and the high-quality wildlife attributes of the Gallatin Range? Is this the role of “conservation” advocates?

PROBLEMS WITH ALTERNATIVE DESIGNATIONS

The GFP calls for designating much of the Gallatin Range with alternative classifications including Wildlife Management Area (WMA) and Watershed and Recreation Area (WRA).

None of these classifications are part of an “organic act,” and their implementation will be entirely dependent on how well the Forest Service manages them, and how well the restrictions and other management sidebars are implemented.

In the GFP, the proponents have recommendations like the Forest Service “should” monitor recreational uses, should monitor wildlife movements, and should hire more enforcement personnel to patrol and enforce restrictions. There is no legally defined level in their document that tells me or anyone else when there is “too much” impact. Do they really believe that you can trust the FS to do such monitoring and enforcement? As far as I can determine, there are no legal or other steps that will assure me and others that the policies contained in the GFP document will be implemented and followed.

There is nothing in the document that addresses the advances of technology. The mountain bike of today is vastly more efficient than those that existed just ten years ago, and we can predict that ten years from now, technology will likely step up efficiency further including electric mountain bikes. Yet there’s nothing that I have seen in the GFP document that recognizes this issue of escalating technology.

The GFP calls for expansion of mountain biking trails in both the BHP drainages as well as West Pine area of the HPBH Wilderness Study Area, as well as greater winter recreation and development in the Hyalite Canyon Watershed and Recreation Area. All of this will accelerate recreational impacts, even though the GFP suggests they are going to maintain the status quo. It’s quite possible the status quo is already unacceptable from an ecological integrity perspective.

With Wilderness designation, we know what we are getting. With WMA and other designations, we are left with uncertain futures.

ALTERNATIVES NOT AS GOOD AS WILDERNESS PROTECITON

However, another reason I’m skeptical about alternative designations is due to the situation that I’ve seen in other places. In every instance, the supporters of alternative measures have assured folks that whatever was used (NRA, Conservation Area, National Monument, etc.) would be as good as wilderness. But many of the places I know personally have not lived up that promise. In part, because the proposals could not anticipate new threats or technology. Because all of these alternatives often depend on specific language for each area, so there is no consistency in policies to these alternative designations. As a result, there is much more room for disagreement on the meaning of this or that rule or regulation.

And in many cases, one must rely on the local agency to interpret the management regulations, and we all know how difficult it is for local FS, BLM, etc. to resist local pressure. We see that problem with the Gallatin Range WSA under the Gallatin Forest interpretation. Even though the language in 1977 Senate Bill 393 that created the Hyalite Porcupine Buffalo Horn Wilderness Study Area told the FS to manage the area for its wilderness qualities and to limit any non-conforming uses like ORVs, the Forest Service did little to restrict ORVS in the Gallatin WSA.

ILLEGAL MOUNTAIN BIKING LEGITIMIZED

The fact that mountain biking has been on-going in the WSA for years is a perfect example of the problem. At least as I read the S. 393 WSA language, mountain bikes should never have been allowed in the HPBH Wilderness Study Area.  The FS was directed to manage the WSA to protect wilderness values and only allow recreational uses that existed in 1977. There were no mountain bikes back in 1977; therefore, it is reasonable to question whether any of the existing mountain bike use in the WSA is legal.

It is ironic that both the MWA and TWS are supporting the Bitterroot National Forest in their restriction of mountain biking in the Blue Joint WSA and Sapphire WSA which were also created under the same S.393 legislation as the HPBH WSA in the Gallatin Range. But instead of arguing that on-going mountain biking in places like the BHP and West Pine drainages is illegal, the GFP is essentially making these illegal mountain biking encroachments legal by advocating for on-going mountain biking use, and even expansion of trails and use in these areas.

https://www.wbur.org/onlyagame/2019/02/01/pirate-trails-vermont-outside-in

RELIANCE ON AGENCY ENFORCEMENT OF MOUNTAIN BIKERS IS UNCERTAIN

Mountain bikers have built numerous illegal trails throughout the public lands, often without any oversight from federal land management agencies. You can have all the regulations you want about limiting bikes to existing trails, but there is an outlaw element in the mountain biking community, and I guarantee there will be many more miles of new trails in the BHP and elsewhere in the Gallatin Range if the area is designated a “wildlife management area.” With wilderness, any bike would be illegal. It’s a lot easier to enforce that kind of restriction than limiting use to specific trails.

CAN’T ANTICIPATE NEW THREATS

So what new threats will be out there in twenty years that we cannot imagine? What new excuse will arise for logging once the justification of “forest health and wildfire prevention is discredited? Because we can’t imagine them, we can’t anticipate them and preclude them with “wildlife management area” even with specific restrictions as the GFP have outlined.

Now in many of the above cases that I mentioned, the alternative designation was the “political” result after many groups lobbied for wilderness protection.  In other words, often we must accept compromises. But I want to start with advocacy for wilderness if the lands meet the minimum criteria for such designation under the law.

WILDERNESS IS THE RAREST NATURAL RESOURCE

The GFP proposal divvies up the range into different recreational opportunity spectrum. But this neglects to consider that the wilderness is the rarest of all “commodities.” There is no shortage of places to ride a bike or even ski, hike or camp on public lands. But what is rare throughout the country and world are wild places where the land is self-willed, and where humans if they visit at all, do so with respect for the wildness.

The highest “use” of the Gallatin Range is to protect as much of it as Wilderness under the Wilderness Act.