As to the Wilderness Act, this thread has a great number of photos of toilets within designated Wilderness, so that argument doesn't match reality throughout the Sierras. They were used for decades in the Whitney Zone. The bigger question is why is this special zone with enormous popularity and difficult management challenges considered "Wilderness" in the first place? It makes more sense to set the boundary at Trail Crest, in my opinion.
In any case, toilets were considered compatible with Wilderness ethics under these unique circumstances for decades. This concern about Wilderness values was mentioned in the EA but it was not a deal breaker because of the history and the reality that toilets provide the best environmental protection. Apparently a trail littered with plastic bags full of human waste is the new definition of Wilderness.
True, but I wonder how many were installed in the last, say, 10 years before EAs and environmental compliance became much stricter? For instance, Sequoia Kings put a bridge on the South Fork crossing. The EA was about 25 pages and took two months to write. It was quickly approved. A couple of years later, I was the lead writer for an EA to replace 3 existing ranger stations. That took several years to write, went to 150 pages and wasn't approved for almost 10 years. Those aren't necessarily equivalent to putting in a toilet, but the point is there's major scrutiny of anything being built in designated wilderness. Something we could easily do 10+ years ago is now difficult to impossible.
Regarding Wilderness boundaries: a reasonable point in some ways but now impossible to change. Ostrander Ski Hut is an enclave within the Yosemite Wilderness. The boundary is something like 10 feet from the walls of the hut and the guy who drew the boundary admits that was a major mistake. The old septic tank (at 25') is outside that boundary so when we needed to create a better toilet system, we couldn't because we couldn't repair the old septic tank. (Toilets, it's always about toilets...). It would literally take an act of Congress to change any wilderness boundary.
Also true that the toilet itself is not a deal breaker within the WA. But you still have to show it's the best environmental choice (not an absolute, there's wiggle room, but it's got to be pretty solid compared to the other Alternatives). If the USFS EA was shoddy or dishonest -- and I'll take your word for it (and am not surprised) -- getting it overturned still wouldn't help all that much. You'd have to go back to square one, show the need (unacceptable impacts of status quo) then justify the toilets compared to other alternatives.
As a side note, there might have been a chance before the old ones were destroyed. You might have been able to argue a Categorical Exclusion (Cat X) and put the new one on the existing site without an EA. But I think once those were gone, that chance passed. We very possibly could have gotten a Cat X for putting new ranger stations on the existing footprint of the old one, but SEKI opted for the safest course with a full EA.
An interesting point about not using the wag bags. I don't know. Sequoia Kings has what's called the Superintendent's Compendium -- these are local park rules with the force of law. So there's one that says all rules shown on the wilderness permit must be obeyed and to not do so is a violation of the Compendium with a fine and CFR violation code. I don't know if USFS has a similar regulation through the CFR (Code of Federal Regulations). When you get a permit, does the permit say you have to use the wag bag in the Whitney corridor? Or do they just hand you the bags and say use them (please). If the latter, then it probably doesn't have the force of law. You could contact the USFS Law Enforcement Office and ask. I'd be interested in what they say.
Just checking the SEKI permit, there's nothing about a specific wag bag requirement for Guitar Lake and beyond. I absolutely don't want to advocate not using them there, but unless there's something else for the NPS side, it's voluntary (and there may well be something else...). I also want to point out that the ranger there reports much less problem with toilet paper and feces under rocks. I think there's also some evidence of lower levels of e coli in the lake, which is to say the bags have a net positive effect.
Well, anyway, I do want to give SN an attaboy. As a long-time advocate and organizer for various forlorn hopes, I'm impressed with the quality of the groundwork you've done. As noted, I don't agree with the need, but the basis of all change is educating the public in an honest and straightforward way and hoping others join in. So, on that front: solid work!
