Here's my draft comments on their draft... . I'll have more detail later. This is just the Summary/Abstract of what I'm putting together.
************************
In spite of several readings of the Draft Alternative Tables on 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. Limits based on daily limits of visitors leaving from the trailheads and how they disperse through wilderness has worked quite well.
The models may need to be redone, but it is the only system that is both workable where permits are issued and where later enforced by rangers. 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 Sierran meadow should grazing be closed in elevations above these 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 meadow 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 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 direct result of stock grazing. They are not directly a function of how the zones are derived, but of much more local ecological considerations.
Grazing, then, must be managed independent of these zones. That does not mean that stock users need be regulated much differently in their access by zone, only that the animals supporting their trip cannot graze more or less based on those zones.
*********************
Specifics to come.
Thanks,
George
